Exhibit 14
 
 BANK OF BIRMINGHAM
CODE OF ETHICS
 I. Overview
    1.
    
    Requires the highest standards for honest and ethical conduct, including proper and
ethical procedures for dealing with actual or apparent conflicts of interest between
personal and professional relationships.2.
    
    Requires full, fair, accurate, timely and understandable disclosure in the periodic
reports required to be filed by Bank of Birmingham with governmental and regulatory
agencies.3.
    
    Requires compliance with applicable laws, rules and regulations.4.
    
    Addresses potential or apparent conflicts of interest and provides guidance for
employees, officers and directors to communicate those conflicts to Bank of Birmingham.5.
    
    Addresses misuse or misapplication of Bank of Birmingham property and corporate
opportunities.6.
    
    Requires the highest level of confidentiality and fair dealing within and outside the
Bank of Birmingham environment.7.
    
    Requires reporting of any illegal behavior.
 II. Conflicts of Interest
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1.
    
    Invest in a customers business unless the investment is made by the purchase of stock
that is actively traded and the Bank has no access to confidential information relating to
the business.2.
    
    Subscribe to new issues of stock in a customers business.3.
    
    Invest in a customers business or enable others to do so as a result of material
inside information.
 III. Confidentiality
   1.
    
    Trade secrets, which include any business or technical information, such as formula,
program, method, technique, compilation or information that is valuable because it is not
generally known.2.
    
    All rights to any invention or process developed by an employee using the Bank
facilities or trade secret information, resulting from any work for the Bank, or relating
to the Banks business, is considered to be work-for-hire under the United States
copyright laws and shall belong to the Bank.3.
    
    Proprietary information such as customer lists and customers confidential information.
  IV. Corporate Opportunities
   1.
    
    Taking for themselves personally opportunities that properly belong to the Bank or are
discovered through the use of corporate property, information or position.2.
    
    Using corporate property, information or position for personal gain.3.
    
    Competing with the Bank.
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4.
    
    Soliciting, demanding, accepting or agreeing to accept anything of value from any
person in conjunction with the performance of your employment or duties at the Bank.5.
    
    Acting on behalf of the Bank in any transaction in which you or your immediate family
has a significant direct or indirect financial interest.6.
    
    Offering something of value to someone with whom you transact business if the benefit
is not otherwise available to other similarly situated customers or suppliers of the Bank
under the same conditions.
  1.
    
    Solicit for himself, herself or for a third party anything of value from anyone in
return for any business, service or confidential information of the Bank.2.
    
    Accept anything of value (other than normal authorized compensation) from anyone in
connection with the business of the Bank, either before or after a transaction is discussed
or consummated.
  1.
    
    Accepting a gift in recognition of a commonly recognized event or occasion (such as a
promotion, new job, wedding, retirement or holiday) if the gift, together with all other
gifts received from any one individual or Bank, does not exceed $100 from any one
individual in any calendar year.2.
    
    Offering a gift in recognition of a commonly recognized event or occasion (such as a
promotion, new job, wedding, retirement or holiday) if the gift, together with all other
gifts given by the Bank and its officers and employees, does not exceed $100 to any one
individual in any calendar year.3.
    
    Accepting something of value if the benefit is available to the general public under
the same conditions on which it is available to you.4.
    
    Accepting meals, refreshments, travel arrangements and accommodations and entertainment
of reasonable value in the course of a meeting or other occasion to conduct business or
foster business relations if the expense would be reimbursed by the Bank as a business
expense if the other party did not pay for it.5.
    
    Paying for meals, refreshments, travel arrangements and accommodations and
entertainment of reasonable value in the course of a meeting or other occasion to conduct
business or foster business relations if the expense is reimbursed by the Bank under its
policy for reimbursement of business expenses.
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V. Insider Trading
   VI. Extensions of Credit
  VII. Outside Business Relationships
     VIII. Fair Dealing
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IX. Protection and Proper Use of Bank Property
  X. Compliance with Laws, Rules and Regulations
   XI. Reporting Illegal or Unethical Behavior
  XII. Non-Retaliation
  XIII. Public Bank Reporting
  XIV. Administration of Code of Ethics
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XV. Amendment, Modification and Waiver
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