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INTRODUCTION
The business of Timberland Bancorp, Inc. ("Timberland") is built on trust. Our stockholders, customers and employees depend upon our honesty and integrity. Accordingly, the Board of Directors of Timberland has adopted a Code of Ethics ("Code") to express a code of conduct applicable to our Chief Executive Officer, President, Chief Financial Officer, and Treasurer (collectively, the "Senior Financial Officers"). The Code does not constitute a new set of requirements to which the Senior Financial Officers must adhere, but simply reduces to writing the behavior that has always been required of our Senior Financial Officers.
The Code sets forth certain standards for the guidance of the Senior Financial Officers. The Code should be considered as illustrative, but not regarded as all-inclusive. The Senior Financial Officers are also subject to Timberland's Code of Ethics applicable to all officers and employees.
HONEST AND ETHICAL CONDUCT
Each Senior Financial Officer must act honestly and ethically. Senior Financial Officers should also promote honest and ethical behavior within Timberland.
Acting honestly and ethically includes the duty to avoid actual or apparent conflicts of interest, as well as situations which could result in an actual or apparent conflict of interest. A conflict of interest may arise when personal or financial interest is adverse to, or appears adverse to, the interest of Timberland. Each Senior Financial Officer should report to the Audit Committee of the Board of Directors any material transaction or relationship that reasonably could be expected to result in a conflict of interest.
In addition to the duty to avoid conflicts of interest, Senior Financial Officers must treat confidential information properly. All information obtained by virtue of employment with Timberland should be held in strictest confidence. Confidential information must not be disclosed to anyone except as required for business transactions or as required by law. When confidential information is disclosed, it must be done in a manner that does not risk violating confidentiality.
PREPARATION OF PUBLIC DOCUMENTS
Each Senior Financial Officer must ensure that all public documents filed with the Securities and Exchange Commission which he or she is involved in preparing or reviewing contain full, fair, accurate, timely and understandable disclosure.
In order to ensure this, the Senior Financial Officers must maintain the skills relevant to Timberland's needs. The Senior Financial Officers are also responsible for establishing and maintaining appropriate disclosure controls and procedures and internal controls.
COMPLIANCE WITH LAW, RULES and REGULATIONS
Each Senior Financial Officer must comply with all local, state and federals laws, rules and regulations. Any Senior Financial Officer engaged in activities found to be in conflict with and against these laws, rules and regulations will be subject to termination of employment. The Senior Financial Officers should also cause other officers and employees to comply with all local, state and federal laws, rules and regulations.
ADMINISTRATION OF THE CODE
Any violation or suspected violation of this Code of Ethics must be promptly reported to the Audit Committee of the Board of Directors. Violations of the Code may be subject to disciplinary action, up to and including termination of employment. Questions regarding the Code and requests for a waiver from the Code should be brought to the Audit Committee. The Audit Committee will administer the Code and will make periodic reports to the Board of Directors, as necessary.
This Code of Ethics shall be publicly available. Changes to, and waivers from the Code shall also be disclosed to the public.
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