Adams Bank & Trust Policies

Notice of Your Financial Privacy Rights

We, our, and us when used in this notice, mean Adams Bank & Trust.

This is our privacy notice for our customers. When we use the words "you" and "your" we mean the following types of customers:

Our consumer customers who have a continuing relationship by purchasing or holding financial products or services such as a(n):

—Deposit Account

—Loan Account

—Safe Deposit Box

—Automobile leases we service

—Financial, investment, or economic advisory services

—Mortgage brokerage services

—All IRA accounts for which we act as a custodian

—Other leases we service

We will tell you the source of the information we collect about you. We will tell you what measures we take to secure that information.

We first define some terms.

Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records. Hereafter, we will use the term "information" to mean nonpublic personal information defined in this section.

An affiliate is a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.

A nonaffiliated third party is a person we do not employ or a company that is not an affiliate of ours. This is also known as nonaffiliated third party, or simply, an "other party".

The Information We Collect
We collect information about you from the following sources:

Information you give us on applications or other forms
Information about your transactions with us
Information about your transactions with our affiliates
Information about your transactions with other parties
Information from a consumer reporting agency
Information we receive as a result of verifying customer information

The Confidentiality, Security, and Integrity of Your Information
We restrict access to information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to protect this information.

Your Information and Our Affiliates
We may disclose information about you to our affiliates. Here are the kinds of information and the source of that information:

Transaction and experience information from our account records:

Information about your transactions and experience with us, such as:

—Name

—Address

—Types of Accounts

Federal Law allows us to disclose the information listed above to our affiliates. You do not have a right to opt out of the disclosure of this information.

Types of Affiliates
We may disclose information about you to the following types of affiliates:

Financial service providers, such as:

—Insurance Agents

Reasons for Disclosure
We may disclose information about you to our affiliates to provide you with information about additional products and services.

Your Information and Other Parties
We will not disclose information about you to anyone except as disclosed in this policy or as permitted by law. Examples of this might include disclosures necessary to service your account or prevent unauthorized transactions.

Information about Former Customers
We do not disclose information about former customers, except as permitted by law.

Children's Internet Privacy Policy

Our web site is directed to a general audience. We do not knowingly solicit or collect personal information from children on our site.

Patriot Act - Important Information about Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all banks to obtain, verify and record information that identifies each person who opens an account.

What this means to you: When you open an account, we will ask for your name, physical address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license and other identifying documents. If you are opening a new business account, we may also ask to see business authorization and verification documents.

Excessive or Luxury Expenditure Policy

It shall be the policy of Adams Bank & Trust that the following categories of expenditures are prohibited:

Entertainment or event expenses the total cost of which is over $50,000.00

Aviation or transportation services that have a one-time or per event cost of more than $50,000.00

Individual office renovations the total cost of which is over $50,000.00

Educational events where the individual cost per employee is over $50,000.00

The following types of categories or expenses require prior approval by the Board of Directors:

Office and facility renovations that cost of which is over $25,000.00

Aviation or transportation services or any other contracts the total cost of which is over $50,000.00

Entertainment or events, including golf tournaments or other similar events that total cost of which is over $25,000.00

The approval process for expenditures that are submitted to the Board of Directors for approval shall require a request to be submitted to the CEO of the organization for placement on the agenda of the next Board of Directors meeting. At that time sufficient information shall be presented to the Board for vote to be taken so that such expenditures can be approved or denied. On expenditures that are approved by the Board of Directors, the CEO and CFO will provide the required certification that the approval of such expenditure was properly obtained by the Board of Directors. Any violations of this policy will be reported to the CEO and the Board. The CEO shall be accountable for contents of this policy.

All employees of Adbanc, Inc., and any of its subsidiaries, including Adams Mortgage, LLC and Adams Bank & Trust, are subject to this Policy, and will be held accountable for compliance with this Policy.