It is the policy of Sterling Bank to afford equal opportunity for employment to all individuals regardless of race, color, religion, sex, age, national origin, citizenship status, veteran status, disability, or genetic information and to prohibit harassment based on any of these factors. Sterling Bank also observes the fair employment laws in each respective jurisdiction in which we operate. We are strongly bound to this policy. Therefore, we will take affirmative action to ensure that we:

1. Recruit, hire, train, and promote persons in all job titles without regard to race, color, religion, sex, age, national origin, citizenship status, veteran status, disability, or genetic information;
2. Base decisions on employment so as to further the principle of Equal Employment Opportunity;
3. Ensure that promotion decisions are in accord with principles of Equal Employment Opportunity by imposing only valid requirements for promotional opportunities;
4. Ensure that all personnel actions such as compensation, benefits, transfers, layoffs, return from layoff, bank sponsored training, education, tuition assistance, and social and recreational programs will be administered without regard to race, color, religion, sex, age, national origin, citizenship status, veteran status, disability, or genetic information.

It is our belief that our continued success depends on our ability to attract, develop, and retain a highly competent workforce and on the creative, effective and productive use of all our human resources. We are convinced that talent exists across all population groups. We will conduct our business with due regard to the human dignity and innate worth of each individual.

The successful achievement of a nondiscriminatory employment program requires a highly cooperative effort. Management is obliged to lead the way in establishing and implementing affirmative procedures and practices which will ensure our objectives: namely, equitable employment opportunity for all.

This statement of policy on equal employment opportunity is consistent with the requirements and objectives stated in the long-standing policy adopted by Sterling Bank’s President and Chief Executive Officer and reaffirmed in 2004.

Sterling Bank’s President and Chief Executive Officer has designated Executive Vice President, Chief Human Resource Officer, to direct the establishment of and to monitor the implementation of personnel procedures to guide the bank’s Equal Employment Opportunity and Affirmative Action Program.

On a quarterly basis, the Executive Vice President, Chief Human Resource Officer is to audit and report to the President and Chief Executive Officer regarding the status of the bank’s Equal Employment Opportunity and Affirmative Action efforts.