OCFC
Published on 05/11/2026 at 04:58 pm EDT
Code of Ethics and Standards of Personal Conduct
November 12
2025
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Purpose 3
Scope 3
Overall Policy 3
Specific Policies 3
ADMINISTRATION AND RESPONSIBILITY FOR COMPLIANCE 13
Roles and Responsibilities 13
Policy Exception Requirements & Escalation Protocols 13
Policy Approval History 14
CODE OF ETHICS AND
STANDARDS OF PERSONAL CONDUCT
Purpose
This Policy establishes the standards of ethical business behavior and personal conduct for the directors, officers, employees, attorneys and/or agents (together referred to as "Representatives") of OceanFirst Financial Corp. (the "Holding Company"), OceanFirst Bank,
N.A. (the "Bank") and their subsidiaries. The term "OceanFirst" means the Holding Company, the Bank and their subsidiaries.
Fundamental to OceanFirst's continued success is the exercise of integrity and the highest ethical standards among all of OceanFirst's Representatives. The intent of this policy is to safeguard OceanFirst's tradition of strong moral, ethical and social standards of conduct. This policy is not a replacement for policies and procedures that address the specifics of our business or which may impose stricter or more detailed requirements.
Scope
This policy applies to all Representatives of OceanFirst.
Overall Policy
A bank, as a business built upon public trust and confidence, depends upon a favorable perception by customers, shareholders, federal and state regulators and others in both the business community and the general community. It is imperative that OceanFirst Representatives conduct their business and personal actions honestly and ethically. Representatives must ensure that a person observing their actions would not have reason to believe that even the slightest irregularity or impropriety in their conduct exists or could be implied.
Since OceanFirst is a publicly traded company, it is particularly critical that OceanFirst Representatives learn about and comply with securities law requirements and restrictions concerning trading company stock while occupying insider positions, as well as the prohibition on disclosing material information relating to the Holding Company or the Bank, which is not generally available to the public.
Specific Policies
Representatives of OceanFirst are expected to conduct their private business and personal activities involving OceanFirst, its customers or third parties honestly,
ethically and in a manner that avoids conflicts of interest. A conflict of interest cannot be defined precisely, only illustrated. The basic factor that exists in all conflict situations is a division of loyalty between the company's best interests and the personal interests of the individual. The following examples illustrate types of situations that may cause conflicts:
A Representative has a personal financial interest in an outside business or venture that conducts business or has a financial relationship with OceanFirst so that one's judgment on behalf of OceanFirst might reasonably be influenced by that outside relationship.
A Representative may not advance his or her personal or business interests, or those of someone with whom he or she has a personal or business relationship at the expense of OceanFirst. On any matter coming before the Board of Directors in which a Representative has an interest, he or she shall disclose to the Board:
1) the nature and extent of the interest; 2) all material non-privileged information and facts as to the matter under consideration; and 3) the Representative shall refrain from participating in and, if a director, from voting following the Board's deliberations.
Representatives may not take personal advantage of corporate opportunities which are of present or practical advantage to OceanFirst and which are within the corporate powers of OceanFirst.
No lending officer or employee should loan, review a loan or make any decision regarding a loan to himself or herself, or any related person or interest, or to any customer, syndicate or corporation in which he or she has a present or prospective financial interest.
All OceanFirst Representatives shall be supplied with, acknowledge and honor the terms of the Privacy Policy and Information Security Policy adopted by the Board of Directors. In addition to possible penalties imposed by any state or federal regulation or statute, violation of the Policy, if proven, will subject the Representative to discharge or removal from his/her position of trust.
Except for information authorized for public disclosure by the Board of Directors, or as required or permitted by appropriate governmental agency or law, no financial or other information regarding OceanFirst or any of its activities is to be provided to any person not employed by OceanFirst.
No investment interest, direct or indirect, in the business of any of the Bank's customers or suppliers is permitted except as outlined below in paragraphs 2 and
Any exceptions must be reported to and approved in advance by the Board of Directors. This prohibition applies to the Vice Presidents in charge of the Information Technology and General Services Departments, and all Senior Vice Presidents, Executive Officers and Directors and their immediate families and to all forms of investment including, but not limited to, securities, investment in proprietorships, limited liability companies, joint ventures or similar business activities.
Investments are permitted in public companies which are customers or suppliers, if the securities of the company are listed on an organized exchange or are traded in the over-the-counter market or if it is otherwise evident that such investments are not being made on terms that are any more favorable than those terms available to the general public, subject, however, to the following restrictions:
Caution should be exercised by each Representative to ensure that the nature and amount of such permitted investments are in such amounts as are prudent for a person maintaining a financial condition entirely within conservative limits.
Acceptance of preferential treatment in the form of an allocation of "hot" issues that are, or may become, in such demand that the broker, investment banker, issuer or other seller of such securities could reasonably expect to receive or has already received favorable treatment by reason of making the allocation available is prohibited.
Investments in "limited partnership interests" will be permitted if it is evident that such investments are not being made on terms more favorable than those that are available to the general public. In the case of "limited partnership investments", it would be important that an individual's investment be only one of several such interests sold to the general public and in such amounts as are
Disclaimer
OceanFirst Financial Corporation published this content on May 11, 2026, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on May 11, 2026 at 20:50 UTC.