General Responsibility
The Code of Ethics for the Senior Financial Officers (herein referred to as financial officers) of Security Capital Corporation, a one-bank holding company, and of its bank subsidiary, First Security Bank, (herein both corporations collectively referred as the Bank) require its chief or its primary financial officers to respect the basic principles of honesty, integrity, and dedication in the performance of their job responsibilities and in their representation as an agent for the Bank. In addition, the financial officers will be required to certify that the financial statements reflect accurately the true financial condition of the entity - void of misleading and fraudulent information and with full disclosure and in compliance with applicable governmental rules and regulations.

Conflicts of Interest; Fair Dealing; and Misuse of Corporate Opportunities
The Bank Officers who are responsible for the accuracy and completeness of the financial reports will be required to avoid all  arrangements and transactions that would be interpreted as a conflict of interest or a misuse of the corporate opportunities. The Bank has adopted policies to discourage illegal or unethical behavior. They are:

If the Bank is required to restate its financial statements due to financial reporting misconduct, the financial officers, not limited to the CEO and the CFO, will forfeit any compensation incentive in the year of the discovery of the misconduct.

Misconduct is defined as a willing intent of the officer to mislead stockholders, internal and external auditors, directors, other Company officers and other related parties with inaccurate financial statements.

Financial officers are prohibited from using nonpublic information for personal gain or benefit in the selling and buying of company stock.

The financial officers are required to cooperate with internal auditors and external auditors in a manner that exhibits integrity and to avoid situations in which the auditors would appear to be fraudulently influenced or coerced or mislead by financial information presented by the financial officers.

Preservation of the Confidentiality of Company Information
Company information that is nonpublic will be considered as confidential and will be protected and will not be shared with unauthorized persons. Company information that is considered public will be provided as required by law.

Protection and Proper Use of Company’s Assets
The financial management is responsible for the evaluation of internal controls. Internal controls are a necessary element in an organization to protect the assets and records from improper use. Procedures must be established by the financial officers in an ongoing basis to evaluate the adequacy of such controls and report significant deficiencies to the Audit Committee. Significant deficiencies would be any that would affect the Bank in an adverse manner.

Compliance with Laws and Regulations
The financial officers are to stay abreast of the details of the latest laws and regulations related to the financial statements so that the Bank can be examined and be found in compliance with the current laws and regulations. The laws and regulations will include those issued for compliance with the Securities Exchange Commission, the Federal Deposit Insurance Corporation and the Mississippi Department of Bank Supervision.

The financial officers will be responsible for the design of the financial statements, for evaluating and reviewing the documents and disclosing the required financial information to the proper individuals and to the governmental and regulatory agencies.

Responsibility of the Audit Committee
The Audit Committee of Security Capital Corporation and First Security Bank will continue to monitor the performance, the activities, the responsibilities and the integrity of the financial officers to determine satisfactory job performance and to update the Code of Ethics as needed.