Any claim of misconduct by the bank or any director, officer, or employee of the bank, relating to the bank’s accounting, internal accounting controls, or any bank auditing matter, should be directed to, and regardless of whether so directed, shall be forwarded when received by any employee of the bank to the bank’s General Counsel for review, analysis, treatment and reporting to the Audit Committee.

(a) Complaints will be accepted and treated under this process regardless of whether received from an employee, customer, vendor, or any other person with information about the bank’s accounting, internal accounting controls, or any bank auditing matter.

(b) Complaints may be submitted anonymously by mail in a postage prepaid envelope, addressed as follows:

General Counsel
First National Bank Alaska
P.O. Box 100720
Anchorage, AK 99510

(c) All complaints will be treated confidentially, and the identity of the complainant will not be disclosed by the bank’s General Counsel to anyone called upon to analyze or treat the matter raised in the complaint, except members of the Audit Committee.