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                                                                      EXHIBIT 14

                             ALPENA BANCSHARES, INC.
                  CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS

                                                          Adopted: 12 March 2004

PURPOSE

      The Chief Executive Officer, Chief Financial Officer and other senior
officers of Alpena Bancshares, Inc. (together with its subsidiaries and
affiliates, separately or collectively, as the context may require, the
"Company") performing financial management functions (the "Senior Financial
Officers") have an obligation to the public, the Company, and themselves to
maintain the highest standards of ethical conduct.

      The Code of Ethics for Senior Financial Officers (the "Ethical Code")
provides fundamental principles to which the Senior Financial Officers are
expected to adhere and advocate. These principles are designed to deter
wrongdoing and to promote:

      -     Honest and ethical conduct, including the ethical handling of actual
            or apparent conflicts of interest in personal and professional
            relationships;

      -     Full, fair, accurate, timely and understandable disclosures in
            reports and documents that the Company files with, or submits to,
            the Securities and Exchange Commission (the "SEC") and in other
            public communications made by the Company;

      -     Provision to the Company's other employees, consultants and advisors
            of information that is accurate, complete, objective, relevant,
            timely and understandable;

      -     Compliance with applicable governmental laws, rules and regulations;

      -     Respect for the confidentiality of information acquired in the
            course of work except where the Senior Financial Officer has Company
            approval or where disclosure is otherwise legally mandated, and
            assurance that confidential information acquired in the course of
            work will not be used for personal advantage;

      -     Maintenance of skills important and relevant to the Company's needs;

      -     Promotion of ethical behavior among peers in the work environment;

      -     Responsible use of and control over all assets and resources
            employed by and/or entrusted to Senior Financial Officers;

      -     The prompt internal reporting to an appropriate person or persons
            identified in the Ethical Code of violations of the Ethical Code;
            and

      -     Accountability for adherence to the Ethical Code

This Ethical Code supplements the Company's code of conduct (Rules for All of Us
to Live By) and other employee policies (as found in the First Federal of Alpena
Employee Handbook dated May 1999) and reflects our corporate values of ethics,
respect, teamwork and excellence. The Senior Financial Officers are expected to
abide by the Ethical Code as well as the Company's code of conduct and all other
applicable ABI policies and guidelines (or those of its subsidiaries or
affiliates) referred to in the Company's Code of Conduct.
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FINANCIAL REPORTING AND DISCLOSURE

      Senior Financial Officers will seek to promote fair, accurate, timely and
understandable disclosure in the reports and documents the Company files with or
submits to the SEC. The Company seeks to provide disclosure to the investment
community that is not only in conformity with applicable rules of the SEC, but
that also fairly presents to investor the financial condition and results of
operations of the Company. Senior Financial Officers shall seek to promote
ethical behavior by other Company officers and employees involved in financial
reporting.

CONSEQUENCES OF VIOLATIONS

      Any violation of this Ethical Code may result in disciplinary action
including, but not limited to, the following:

      -     Disciplinary action (up to and including suspension or termination
            of employment);

      -     Pursuit of any and all remedies available to the Company for any
            damages or harm resulting to the Company from a violation, including
            injunctive relief; and

      -     Referral of matters to appropriate legal or regulatory authorities
            for investigation and prosecution.

REPORTING OF VIOLATIONS

      Any employee of the Company who becomes aware of actual or potential
infractions of this Ethical Code or who has concerns regarding questionable
accounting or auditing matters involving the Company or a Senior Financial
Officer should submit a report, as is explained in the Company's Audit Committee
Complaints Procedure which can be found on the Company's website at
www.first-federal.com

REQUESTS FOR WAIVERS AND CHANGES IN ETHICAL CODE

      Waivers of this Ethical Code may only be granted by the Audit Committee of
the Board of Directors of the Company. The Audit Committee will not grant
waivers except under extraordinary circumstances. Any waivers that are granted
shall be publicly disclosed on a timely basis.

ANNUAL CERTIFICATIONS

      Annually each Senior Financial Officer shall certify in writing his or her
compliance during the prior year with this Ethical Code.