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Wheelhouse Credit Union Ethics Policy

Wheelhouse Credit Union holds employees and volunteers accountable for performing their duties and responsibilities on behalf of the credit union with integrity and in a manner that excludes considerations of personal advantage or gain. All employees and volunteers are responsible for maintaining the highest ethical standards in complying with all applicable laws, regulations, and credit union policies and procedures.

The following is a summary of the credit union's policy with respect to:
  1. Gifts, favors, consideration and payments given or received by employees.
  2. Potential conflicts of interest.
  3. Certain other matters.

Gifts, Favors & Payments Given by Employees

Gifts, favors, and payments may be given to others at the credit union's expense, if they meet the following criteria:

  • They are consistent with accepted credit union business practices.
  • They are of limited value and in a form that will not be construed as a bribe or payoff.
  • They are not in violation of applicable laws, regulations, and credit union policy.
  • Public disclosure of the facts will not place the credit union's reputation at risk.
  • They are within the employees approved signing authority.

Gifts, Favors and Payments Received by Employees and Volunteers

Credit union employees and volunteers shall not seek or accept for themselves or others any gifts, favors, and/or payments without a legitimate business purpose from any persons or business organizations that do or seek to do business with the credit union.

Credit union employees and volunteers may accept for themselves, and/or their department, common courtesies normally associated with generally accepted business practices. Adherence to applicable laws, regulations, and credit union policies and procedures is expected with respect to accepting gifts, favors or considerations of any kind.

Conflicts of Interest

The credit union's Personnel Policy governs conflicts of interest. In short, credit union employees must avoid any situation where an employee, or other credit union representative has a substantial personal interest in a transaction that might have the appearance of influencing the judgment he/she exercises on behalf of the credit union. The personal interest may arise through the expectation of future personal gain or through the existence of a personal obligation previously created.

Confidential Information

The revelation or use of any confidential information, data on decisions, plans, or any other information that might be contrary to the interest of the credit union or its members without prior authorization, is prohibited. The misuse, unauthorized access to, or mishandling of confidential information, particularly member and personnel information, is strictly prohibited and will subject the employee to disciplinary action up to and including immediate termination.

Whistleblower Reporting

Any member who suspects or has knowledge of illegal or unethical business or workplace conduct, including violation of a state or federal statute, or regulation is obligated to report the situation to a member of senior management or the Supervisory Committee Chair. A thorough, objective, and discreet investigation of all reports will be undertaken. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge. Members may file reports anonymously, however, in certain circumstances filing an anonymous report may restrict the scope of the investigation. If concerns or complaints require confidentiality, then this confidentiality will be protected to the extent feasible, subject to applicable law. The member will have the opportunity to obtain follow-up information concerning his/her report.

To report illegal or unethical business or workplace conduct, members may contact the following:

Supervisory Committee Chair

C/O Wheelhouse Credit Union
P.O. Box 719099
San Diego, CA 92171-9099

Or any member of the Senior Management Team:

Lisa Paul-Hill, President / CEO
John Stabler, Vice President / Chief Financial Officer
John Frazza, Vice President, Lending
Rebecca Ramos-Arzola, Vice President, Human Resources
Bret Johnson, Vice President Operations
Gay Peterson, Assistant Vice President, Operations
Bret Johnson, Vice President of Operations
Alex Hosch, Senior Vice President Enterprise Risk
Kathryn Busch, Vice President of Marketing

C/O Wheelhouse Credit Union
P.O. Box 719099
San Diego, CA 92171-9099

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