Exhibit 14.1

February 2004              

The Conway National BankCode of Ethics Policy

The Bank Bribery Law (12 U.S.C. 215) prohibits anofficer, director, employee, agent, or attorneyof The Conway National Bank tocorruptly solicit or demand for the benefit of any person, or tocorruptlyaccept or agree to accept, anything of value from any person, with the intentof beinginfluenced or rewarded in connection with any business or transactionof the bank.  The lawalso prohibits any individual to corruptly give, offer,or promise anything of value to any person,with the intent of influencing orrewarding an officer, director, employee, agent, or attorney ofthe bank inconnection with any business or transaction with the bank.  If the value of thethingoffered or received exceeds $100.00, the offense is a felony punishableby up to five yearsimprisonment and a fine of $5,000.00 or three times thevalue of the bribe or gratuity.  If valuedoes not exceed $100.00, the offenseis a misdemeanor punishable by up to one year imprisonmentand maximum fine of$1,000.00.

The Conway National Bank understands that the intent of the law is to reachacts of corruption in thebanking industry and not the prosecution ofinsignificant gift giving or entertaining that does notinvolve a breach offiduciary duty or dishonesty.  Accordingly, the bank considers the following tobe within the guidelines of acceptable conduct:

(A)     the acceptance of gifts, gratuities,amenities, or favors based on obvious family or          personalrelationships where it is clear that it is those relationships rather than the          business of thebank concerned which are the motivating factor;

(B)     the acceptance of meals, refreshments, travelarrangements, accommodations, or          entertainment, allof reasonable value and in the course of a meeting or other          occasion thepurpose of which is to hold bona fide business discussions, provided          that the expenseswould be paid for by the bank as a reasonable business          expense, if notpaid for by another party;

(C)     the acceptance of loans from other financialinstitutions on customary terms to          finance proper andusual activities;

(D)     the acceptance of advertising or promotionalmaterial of reasonable value, such as          pens, pencils, notepads, calendars, and similar items;

(E)     the acceptance of discounts or rebates onmerchandise or services that do not          exceed thoseavailable to other customers;

(F)     the acceptance of gifts of reasonable valuethat are related to commonly          recognized eventsor occasions, such as promotion, new job, wedding, retirement,         Christmas or bar or batmitzvah; or

(G)     the acceptance of civic, charitable,educational, or religious organizational awards          for recognition ofservice and accomplishment.

The bank may also approve, on a case by case basis, other circumstances notidentified above inwhich a bank officer accepts something of value inconnection with bank business, providing theofficer involved provides a fullwritten disclosure of all relevant facts and senior bank managementapproves inwriting and determines that the act is consistent with the bank briberystatute.

While The Conway National Bank is reluctant to establish a fixed dollar amountas to what isconsidered "reasonable value" due to the nature ofvarious benefits that a bank officer mayreceive from those doing or seeking todo business with the bank during the normal course ofbusiness and within theguidelines of ethical conduct of the bank, the bank will normally consideranamount up to $100.00 to be of "reasonable value".  If an officer ofthe bank receives or isoffered something of value above $100.00, the bankofficer must disclose that fact in writing tosenior bank management. The bankwill keep contemporaneous written reports of such disclosuresand seniormanagement will review the disclosures and determine that what is accepted isreasonable and does not pose a threat to the integrity of the bank.  Thisreporting and reviewmechanism should serve to prevent situations that mightotherwise lead to implications of corruptintent or breach of trust and shouldenable the bank to better protect itself from self-dealing. 

The Conway National Bank also recognizes that a serious threat to the integrityof the bank mayoccur when a bank officer becomes involved in outside businessinterests or employment that givesrise to a conflict of interest.  Suchconflict of interest may evolve into corrupt transactions.Accordingly, TheConway National Bank prohibits officers from self-dealing or otherwise tradingon their positions with the bank or accepting from one doing or seeking to dobusiness with thebank a business opportunity not available to other persons orthat is made available because of theofficer's position with the bank.  Inthis regard, the bank will require all bank officers to disclose allpotentialconflicts of interest, including those in which they have been inadvertentlyplaced dueto either business or personal relationships with customers,suppliers, business associates, orcompetitors of the bank.

To comply with the above-stated policy, all bank officers are required to:

(1)     Sign and return a form which acknowledgesreceipt of the policy and indicates          agreement to complytherewith;

(2)     Disclose in writing any potential conflicts ofinterest; and

(3)     Disclose in writing the receipt or offer ofsomething of value above $100.00.

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The Conway National BankCode of EthicsAcknowledgement/Disclosure Form

     I acknowledge receiptof The Conway National Bank Code of Ethics Policy and agree to complytherewith.

___________________________            ___/___/___Signature                                                        Date

     I further disclose the following potentialconflicts of interest:

Note:       Please fully describe anypotential conflicts of interest.               Ifnone, so state.

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