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The Farmers National Bank of Emlenton - Social Media Policy


Purpose
Farmers National Bank (the “Bank”) is committed to projecting a positive corporate image and customer perception, while presenting product and service information in a manner intended to enhance interest from current and prospective customers utilizing the lawful, accurate, fair and timely disclosure of all information relative to its products and the representatives of the Bank. In order to facilitate the dissemination of information related to its products, services, community involvement and financial education, the Bank will be utilizing online social media platforms. In order to ensure the Bank’s compliance with all statutes and regulations applicable to social media outreach, Farmers National Bank is adopting this Social Media Policy, effective immediately. This policy documents the responsibilities of Bank representatives who engage in any aspect of social media on the Bank’s behalf and/or are involved in communication pertaining to the Bank; requires the training of such Bank representatives with respect to this Policy; establishes procedures and controls to ensure that all aspects of the Bank’s social media practices comply with all applicable laws and regulations; and provides for the ongoing evaluation of the effectiveness of social media procedures.

Copies of Policy
This policy is available on the Bank website at https://www.farmersnb.com/Legal-Disclosures.aspx.
The Bank will also send a copy of this Policy via U.S. Mail or electronic mail to any consumer who requests a copy. Requests should be made to the Bank’s Marketing Department by phone at 844.895.2698, by email at info@farmersnb.com, or in writing to Farmers National Bank, Attn: Marketing Department, 612 Main Street, Emlenton, Pa. 16373.

Scope
The policy document specifically refers to requirements for participating in such media that are Bank sponsored and in media that are non-Bank sponsored but where the employees affiliation with the Bank is known, identified, or reasonably presumed by either the Bank or the public at large.
For the purpose of this Policy, the term social media includes of any form of interactive online communication in which users can generate and share content through text, images, audio, and/or video, including but not limited to:

• Micro-blogging sites (e.g., Facebook, Google Plus, and Twitter);
• Forums, blogs, customer review websites, and bulletin boards (e.g., Yelp);
• Photo and video sites (e.g., Flickr, Instagram and YouTube);
• Sites that enable professional networking (e.g., LinkedIn);
• Social games (e.g., FarmVille and CityVille); and
• Any other format of electronic communication that gain sufficient popularity.

For purposes of this Policy, messages sent via email or text message, standing alone, do not constitute social media, although such communications may be subject to a number of laws and regulations. Social media can be distinguished from other online media in that the communication tends to be more interactive. Social media is a dynamic and constantly evolving technology. Thus, any definition for such technology is meant to be illustrative and not exhaustive. Similarly, other forms of social media may emerge in the future that the Bank should also consider.

General Provision
Farmers National Bank employees are expected to adhere to all rules that apply to other Bank communications when participating in social media, specifically: respecting co-workers privacy, respecting customer privacy, protecting confidentiality and security, safeguarding and proper uses of the Bank’s information and assets. All social media activities should be conducted in accordance with the following guidelines.
The Bank social media and web presences are maintained in the interest of establishing a community forum in which the Bank’s employees, customers, prospective customers, partners, the media, and the broader community may engage in relevant dialogue toward intelligent and productive conversations. The Bank presence is governed by the principles of community, constructive dialogue, transparency, and education. The Board of Directors recognizes the value-add of leveraging social media in communicating with its customers and non-customers. Being active in social media networking allows the Institution to be current and relevant while leveraging low-cost marketing tools. Social media is about building a community of supporters; it provides an opportunity to share and further the Institution’s objectives and mission to provide quality financial products and services and to promote customer education with respect to financial products and services.

Enforcement and Oversight
The primary responsibility for ensuring compliance with this Policy and its operating procedures rests with the Board of Directors and each employee. Any change to this Policy must be approved by Compliance Council. The Compliance Council shall review and approve this Policy each year for any changes that may be necessary to ensure the Institution’s compliance and for risk mitigation.
The Marketing Department and Senior Management are responsible for ensuring appropriate directives are implemented and administered in compliance with this approved policy.
Any violation of this Policy must be promptly reported to the Marketing Department and/or Human Resources. Due to the nature of social networking, it is essential that prompt reporting occurs to mitigate any risk to the Institution.

Audit and Monitoring
The fast-pace of social media requires frequent, relevant posts and quick responses. The Marketing Department and employees designated as social media administrators are responsible for monitoring the Bank’s social media sites at least dailyon a regular basis. Additionally, references to the Institution on non-Institution sites shall be monitored no less than monthly leveragingusing search tools such as Google Alerts and search features on common sites such as Facebook, Twitter, Google, LinkedIn, and such others as may be appropriate.
The Bank’s Compliance Officer shall audit the Institution’s compliance with this Policy and report the results of such audit to the Board of Directorsis responsible for the policy.

Record Retention
The Institution shall retain evidence of compliance with this Policy in accordance with the applicable laws, rules, and regulations, including but not limited to, the Truth in Lending Act and Regulation Z; the Truth in Savings Act and Regulation DD; unfair, deceptive, or abusive acts or practices (UDAAP and as may be proscribed by Section 5 of the FTC Act and UDAAP as may be proscribed by Sections 1031 and 1036 of the Dodd-Frank Act); membership requirements [FDIC]; the Equal Credit Opportunity Act and Regulation B; and the Fair Housing Act. Social media posts will be retained in accordance with the Bank’s Record Retention Schedule.

Rules of Social Media Engagement
By posting to social media, the participant becomes a de facto representative of Farmers National Bank. As such, the participant will be held to the following standards. Noncompliance with these standards or behavior that otherwise conflicts with the Bank’s mission and values, violates administrative policies and procedures, and/or compromise the privacy and security of the institution, employees, or customers, will be subject to corrective action, including but not limited to disciplinary action, revocation of official social media privileges, or termination. The following requirements apply to employees using social media while at work or away from work when the employee’s affiliation with the Bank is known, identified, or reasonably presumed by either the Bank or public at large.

Use of Social Media
Authorized employees may engage in social media activity during work time provided that such activity is directly related to their work and does not interfere with their or their co-workers’ work. It is the policy of the Bank to require the express written consent of the individual or entity, including customers, non-customers, or vendors, prior to making any reference to such individual or entity on the Bank’s social media sites.
In the event of comments posted by customers or non-customers regarding the Bank, all such comments must be addressed proactively and timely. Any complaints shall be addressed in accordance with the Bank’s Complaint Policy. The Marketing Department is responsible for ensuring appropriate and timely responses are provided.

Use of Social Media While Off-Duty
The Bank recognizes that its employees may engage in the personal use of social media. The Bank generally considers off-duty social media activities to be personal endeavors. Such activities may not conflict with the Bank’s guidelines, policies, or business, consistent with any applicable employment laws, including the National Labor Relations Act.
It is the policy of the Bank to prohibit any individual employee who utilizes social media from publishing content that contains any information about the Bank other than the fact that the person is an employee and the person’s position with the Bank or as otherwise permitted by law. It is the policy of the Bank to require any employees who utilize social media for their personal use and utilize social media for the business of the Bank to establish separate social media channels for their personal use and the use of the Bank’s business, the latter of which is subject to this Policy. If an employee has a question about whether a social media activity he or she is considering would violate this Policy, the employee is encouraged to contact the Chief Operating Officer, Marketing Department, or Human Resources, who will assist the employee in obtaining guidance or clarification.

Participant Code of Conduct
By participating in discourse herein, the participant implicitly agrees to adhere to the following rules:
• Participant must not disclose any information that is confidential or proprietary to the organization or to any customer or vendor that has disclosed such information to the Bank.
• Any communication occurring in a public forum such as those identified previously in this policy must be respectful to the Bank, fellow employees, our affiliates, and our business partners.
• The Bank may request at any time that the participant cease any communication concerning the company on social media sites or require the participant to block access to such communication if the Bank believes that such action is necessary to ensure compliance with government regulations or other laws.
• Do not use the Bank’s trademarks or any official marketing material on any personal communication or reproduce any company material.
• Do not use Social Media portals for communication with fellow employees or customers concerning business matters. Such communication must go through normal channels such as e-mail, to comply with archiving requirements.
• For protection of the participant and the Bank, do not post any copyrighted material unless the participant holds the copyright, has written permission from the copyright holder, or is sure the material is permitted by “fair use”.

Comment Management
While the Bank encourages posts and responses from a wide range of audience members with various perspectives, the Bank reserves the right to edit or delete any posts containing inappropriate language (including but not limited to insults, profanity, or obscenity), content that is off topic, could be construed as slanderous, discloses trade secrets or other confidential information, Spam, or other inappropriate postings. The Bank will make every effort to contact the contributor of an edited or deleted post to communicate the motivation behind the alteration.

Guiding Principles
In its social media participation, the Bank will strive to:
• Have an open and honest dialogue;
• Correct inaccurate or misleading content in a diligent or timely manner. The Bank will not delete posts unless the posts violate Bank policies or include verbiage outlined in the comment management section above. Any changes or additions will be marked clearly;
• Disclose any conflicts of interest;
• Provide relevant and original material and appropriate cite/attribute material made available via other social media presences and web sites;
• Use good judgment in posts and respond to comment in a respectful and timely manner;
• Trust the participant to be respectful and to be mindful of the information in this medium;
• Respect the participant’s privacy.

Quality Control
Right to manage content: Due to the live nature of social media, changes may be made immediately and followed up with participant notification. Such notification will be communicated via email and/or private message to the participant, explaining the reason for the change.

Damage Control
The Bank will respond to and maintain record of legitimate negative posts listed on social media, including but not limited to, service or product complaints, “flaming”, or attack on customer, institution, or employee character. These responses will come from an appropriate Bank Officer and/or Social Media Administrator and should include a public invitation to correspond by email or phone (as determined by the participant) to settle the issue outside of the forum.

Mandated Response
All external posts (those by customer, media, and the general public) should be dignified with at least one response in an effort to encourage participation and increase social involvement within two days of posting. 
Future Litigation
Social media content and record will be available, inevitably, so what is said can and may be used against the participant. Do not post anything that could be potentially harmful to reputations or disclose the bank practices, etc. The Bank will not be held liable for any damage and/or or legal fees associated with content published by employees through personal contribution.

Human Resource Monitoring – Personal Contribution
Although the Bank’s social media presence is a corporate representation, the participant assumes personal liability for anything posted by the participant. The Bank will assume no responsibility for the content published by the participant. The Bank’s presence as institution-sponsored media and the content therein remain under the governance of the policies of Farmers National Bank. Any editing or removal of a post will not be made with the intent of limiting free speech, and by participating, the participant agrees to not hold Farmers National Bank liable for any such post alterations, including but not limited to, infringement of free speech or discrimination. The Bank reserves the right to monitor any social media presence for violations of this or other Bank policies. The Bank reserve the right to review the conduct of any participant not adhering in good faith to this and other institution policies and take action in accordance with those policies.

Protocol
Inappropriate postings that may include discriminatory remarks, harassment, and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject you to disciplinary action up to and including termination.

Training
The Bank’s Marketing Department, Compliance Officer, and/or Training Department shall coordinate and facilitate appropriate training for all new and existing employees. The social media policy will be reviewed and acknowledged by all employees on an annual basis.