PURPOSE

First Georgia Community Bank, (the “Company”), is committed to the highest possible standards of ethical, moral and legal business conduct.  In line with this commitment and First Georgia Community Bank’s commitment to open communication, this policy aims to provide an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith.

POLICY:

This whistleblowing policy is intended to cover serious concerns that could have a large or negative impact on First Georgia Community Bank, such as actions that:

• May lead to incorrect financial reporting;
• Are unlawful;
• Are not in line with company policy, including the Code of Conduct/Ethics; or
• Otherwise amount to serious improper conduct.

This policy does not apply to all grievances, such as those related to terms of employment or those concerns that are addressed by the Company’s policies on anti-discrimination or sexual harassment.

SAFEGUARDS:

HARASSMENT OR VICTIMIZATION:

This policy and the related procedures offer protection from retaliation to anyone who makes any disclosure with respect to matters that are, or could give rise to, harmful violations, provided the disclosure is made:

• In good faith, and
• In the reasonable belief of the individual making the disclosure that the conduct or matter covered by the disclosure could give rise to a harmful violation.

Confidentiality

The Company will treat all disclosures by whistleblowers as confidential and privileged to the fullest extent permitted by law.  The Company will exercise particular care to keep confidential the identity of the person making the disclosure under this procedure until a formal investigation is launched.  Thereafter, the identity of the one making the disclosure may be kept confidential, if requested, unless such confidentiality is incompatible with a fair investigation, unless there is an overriding reason for identifying or otherwise disclosing the identity of the whistleblower or unless the disclosure is required by law.  In this instance, the one making the disclosure will be so informed in advance of his or her being identified with the disclosure.  Where disciplinary proceedings are invoked any individual following a disclosure under this procedure, the Company will normally require the name of the person making the disclosure to be disclosed to the person subject to such proceedings.

Anonymous Allegations

The Company encourages employees to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified.  Concerns expressed anonymously will be investigated, but consideration will be given to:

• The seriousness of the issue raised;
• The credibility of the concern; and
• The prospects of conducting an effective investigation and discovery of evidence.

Investigations will be conducted as quickly as possible, taking into account the nature and complexity of the disclosure and the issues raised therein.

Malicious Allegations

If an employee makes a disclosure in good faith pursuant to this policy and any facts alleged are not confirmed by subsequent investigation, no action will be taken against the whistleblower.  In making a disclosure, all individuals should exercise due care to ensure the accuracy of the information disclosed.

If after an investigation a matter raised under this procedure is found to be without substance and to have been made for malicious or frivolous reasons, the person making the disclosure could be subject to disciplinary action.

PROCEDURE

Process for Raising a Concern-

Reporting

The whistleblowing procedure is intended to be used for serious and sensitive issues.  Serious concerns relating to financial reporting or unethical or illegal conduct should be reported in either of the following ways:

• Through the email address of the Bank’s President (elewis@firstga.com)
• Through the email address of the Chairman of the Board of Directors (gweaver@cgemc.com)
• Through the email address of the Bank’s legal council (thomas.powell@troutmansanders.com)

Employment-related concerns should continue to be reported through your normal channels such as your supervisor or to the Company’s Human Resources Manager.

Timing

The earlier a concern is expressed, the easier it is to take action.

Evidence

Although the employee is not expected to prove the truth of an allegation, the employee needs to demonstrate to the person contacted that there are sufficient grounds for concern.

How the Complaint will be Handled-

The action taken will depend on the nature of the concern. The Audit Committee of First Georgia Community Bank’s Board of Directors will receive a report on each complaint and a follow-up report on actions taken.

We want to ensure you’re aware of First Georgia's Privacy Policy, so we’re including this notice with many of the account statements you receive from First Georgia Community Bank.