Exhibit 14


UNITED
WESTERN BANCORP, INC.
 CODE
OF BUSINESS CONDUCT AND ETHICS
 
 Introduction
 United
Western Bancorp, Inc.’s (the “Company”) reputation for honesty and integrity is
the sum of the personal reputations of our directors, officers and
employees.  It is the Company’s policy to conduct its business in
accordance with the highest ethical standards of the financial industry and to
comply with all laws regulating the conduct of the Company and its employees. To
protect this reputation and to promote compliance with laws, rules and
regulations, this Code of Business Conduct and Ethics (“Code of Conduct” or
“Code”) has been adopted by the Board of Directors. Every director, officer, and
employee is obligated to be familiar with and understand and comply with this
Code of Conduct. This Code of Conduct is only one aspect of our
commitment.
 
 You must
also be familiar with and comply with all other policies contained in the
Company’s Employee Handbook and all the written policies for the United Western
Bancorp affiliate company that employs you.
 
 This Code
sets out the basic standards of ethics and conduct to which all of our
directors, officers and employees are held. These standards are designed to
deter wrongdoing and to promote honest and ethical conduct, but will not cover
all situations. If a law conflicts with a policy in this Code, you must comply
with the law; however, if a local custom or policy conflicts with this Code, you
must comply with the Code.
 
 If you
have any doubts whatsoever as to the propriety of a particular situation, you
should submit it in writing to the Company’s Chief Operating Officer, who will
review the situation and take appropriate action in keeping with this Code, the
Company’s other corporate policies and the applicable law.
 
 If your
concern relates to that individual, you should submit your concern, in writing,
to the Chief Executive Officer of the Company. The mailing address of each of
those individuals is included at the end of this Code.
 
 Those who
violate the standards set out in this Code will be subject to disciplinary
action.
 
 1.
Scope
 If you
are a director, officer or employee (including temporary employee or independent
contractor) of the Company or any of its subsidiaries, you are subject to this
Code.
 
 2.
Honest and Ethical Conduct
 The
Company requires honest and ethical conduct from everyone subject to this Code.
Each of you has a responsibility to all other directors, officers and employees
of the Company, and to the Company itself, to act in good faith, responsibly,
with due care, competence and diligence, without misrepresenting material facts
or allowing your independent judgment to be subordinated and otherwise to
conduct yourself in a manner that meets with our ethical and legal
standards.
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 3.
Compliance with Laws, Rules and Regulations
 It is the
Company’s policy to comply with all applicable laws, rules and regulations. In
particular, the Company’s banking operations are subject to a variety of laws
governing the business of banking and the operations of the bank. You are
required to comply with all applicable governmental laws, rules and regulations,
both in letter and in spirit. The Company has in place a number of policies
designed to ensure compliance with those laws and regulations. Although you are
not expected to know the details of all the applicable laws, rules and
regulations, it is your obligation to become familiar and comply with the
various policies that pertain to your responsibilities with the Company. We
expect you to seek advice from the Company's Chief Operating Officer if you have
any questions about whether the requirement applies to the situation or what
conduct may be required to comply with any law, rule or regulation.
 
 4.
Conflicts of Interest
 You must
handle in an ethical manner any actual or apparent conflict of interest between
your personal and business relationships. Conflicts of interest are prohibited
as a matter of policy. A "conflict of interest" exists when a person's private
interest interferes in any way with the interests of the Company. For example, a
conflict situation arises if you take actions or have interests that interfere
with your ability to perform your work for the Company objectively and
effectively. Conflicts of interest also may arise if you, or a member of your
family, receive an improper personal benefit as a result of your position with
the Company.
 
 If you
become aware of any transaction or relationship that reasonably could be
expected to give rise to a conflict of interest, you should report it promptly
to the Company’s Chief Operating Officer, Compliance Officer or Chief Executive
Officer.
 
 Conflicts
of interest are prohibited as a matter of Company policy, except under
guidelines approved by the Board of Directors. The following standards apply to
certain common situations where potential conflicts of interest may
arise:
 
 A. Gifts and
Entertainment
 Consistent
with applicable law, personal gifts and entertainment offered by persons doing
business with the Company may be accepted when offered in the ordinary and
normal course of the business relationship. However, the frequency and cost of
any such gifts or entertainment may not be so excessive that your ability to
exercise independent judgment on behalf of the Company is or may appear to be
compromised, and should not be accepted.
 
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  B. Financial
Interests in Other Organizations
 The
determination whether any outside investment, financial arrangement or other
interest in another organization is improper depends on the facts and
circumstances of each case. Your ownership of an interest in another
organization may be inappropriate if the other organization has a material
business relationship with, or is a direct competitor of, the Company and your
financial interest is of such a size that your ability to exercise independent
judgment on behalf of the Company is or may appear to be compromised. As a
general rule, a passive investment would not likely be considered improper if
it: (1) is in publicly traded shares; (2) represents less than 1% of the
outstanding equity of the organization in question; and (3) represents less than
5% of your net worth. Other interests also may not be improper, depending on the
circumstances.
 
 C. Outside
Business Activities
 The
determination of whether any outside position an employee may hold is improper
will depend on the facts and circumstances of each case. Your involvement in
trade associations, professional societies, and charitable and similar
organizations will not normally be viewed as improper. However, if those
activities are likely to take substantial time from or otherwise conflict with
your responsibilities to the Company, you should obtain prior approval from your
supervisor. Other outside associations or activities in which you may be
involved are likely to be viewed as improper only if they would interfere with
your ability to devote proper time and attention to your responsibilities to the
Company or if your involvement is with another company with which the Company
does business or competes. For a director, employment or affiliation with a
Company with which the Company does business or competes must be fully disclosed
to the Company’s Board of Directors or the Nomination and Governance Committee
of the Board of Directors and must satisfy any other standards established by
applicable law, rule (including rule of any applicable stock exchange) or
regulation and any other corporate governance guidelines that the Company may
establish.
 
 D. Indirect
Violations
 You
should not indirectly, through a spouse, family member, affiliate, friend,
partner, or associate, have any interest or engage in any activity that would
violate this Code if you directly had the interest or engaged in the activity.
Any such relationship should be fully disclosed to the Company’s Chief Operating
Officer, Compliance Officer or the Chief Executive Officer (or the Board of
Directors or the Nomination and Governance Committee of the Board of Directors
if you are a director of the Company), who will make a determination whether the
relationship is inappropriate, based upon the standards set forth in this
Code.
 
 5.
Corporate Opportunities
 You are
prohibited from taking for yourself, personally, opportunities that are
discovered through the use of corporate property, information or position,
unless the Board of Directors has declined after full disclosure of all relevant
facts to pursue the opportunity. You may not use corporate property,
information, or position for personal gain, or to compete with the Company
directly. You owe a duty to the Company to advance its legitimate interests
whenever the opportunity to do so arises.
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 6.
Fair Dealing
 You
should endeavor to deal fairly with the Company’s suppliers, competitors and
employees and with other persons with whom the Company does business. You should
not take unfair advantage of anyone through manipulation, concealment, abuse of
privileged information, misrepresentation of material facts, or any other
unfair-dealing practice.
 
 7.
Public Disclosures
 It
is the Company’s policy to provide full, fair, accurate, timely, and
understandable disclosure in all reports and documents that we file with, or
submit to, the Securities and Exchange Commission and in all other public
communications made by the Company.
 
 8.
Financial Reporting Responsibilities
 As a
public company it is of critical importance that the Company’s filings with the
Securities and Exchange Commission be accurate and timely. Depending on their
position with the Company, employees may be called upon to provide information
to assure that the Company’s public reports are complete, fair and
understandable. The Company expects all personnel to take this responsibility
very seriously and to provide prompt and accurate answers to inquiries related
to the Company’s public disclosure requirements.
 
 9.
Confidentiality
 You
should maintain the confidentiality of all confidential information entrusted to
you by the Company or by persons with whom the Company does business, except
when disclosure is authorized or legally mandated. Confidential information
includes all non-public information that might be of use to competitors of, or
harmful to, the Company or persons with whom the Company does business, if
disclosed.
 
 10.
Insider Trading
 If you
have access to material, non-public information concerning the Company, you are
not permitted to use or share that information for stock trading purposes, or
for any other purpose except in the conduct of the Company’s business. All
non-public information about the Company should be considered confidential
information. Insider trading, which is the use of material, non-public
information for personal financial benefit or to "tip" others who might make an
investment decision on the basis of this information, is not only unethical but
also illegal. The prohibition on insider trading applies not only to the
Company’s securities, but also to securities of other companies if you learn of
material non-public information about these companies in the course of your
duties to the Company. Violations of this prohibition against "insider trading"
may subject you to criminal or civil liability, in addition to disciplinary
action by the Company.
 
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  11.
Protection and Proper Use of Company Assets
 You
should protect the Company’s assets and promote their efficient use. Theft,
carelessness, and waste have a direct impact on the Company’s profitability. All
corporate assets should be used for legitimate business purposes. The obligation
of employees to protect the Company's assets includes its proprietary
information. Proprietary information includes intellectual property such as
trade secrets, patents, trademarks, and copyrights, as well as business,
marketing and service plans, engineering and manufacturing ideas, designs,
databases, records, salary information and any unpublished financial data and
reports. Unauthorized use or distribution of this information would violate
Company policy. It could also be illegal and result in civil or even criminal
penalties.
 
 12.
Interpretations and Waivers of the Code of Business Conduct and
Ethics
 If you
are uncertain whether a particular activity or relationship is improper under
this Code or requires a waiver of this Code, you should disclose it to the
Company's Chief Operating Officer, Compliance Officer or the Chief Executive
Officer (or the Board of Directors or Nomination and Governance Committee if you
are a director), who will make a determination first, whether a waiver of this
Code is required and second, if required, whether a waiver will be granted. You
may be required to agree to conditions before a waiver or a continuing waiver is
granted. However, any waiver of this Code for an executive officer or director
may be made only by the Company’s Board of Directors and will be promptly
disclosed to the extent required by applicable law, rule (including any rule of
any applicable stock exchange) or regulation.
 
 13.
Reporting any Illegal or Unethical Behavior
 The
Company desires to promote ethical behavior. Employees are encouraged to talk to
supervisors, managers or other appropriate personnel when in doubt about the
best course of action in a particular situation. Additionally, employees should
promptly report violations of laws, rules, regulations or this Code to the
Company’s Compliance Officer, Chief Operating Officer or Chief Executive
Officer. Any report or allegation of a violation of applicable laws, rules,
regulations or this Code need not be signed and may be sent anonymously. All
reports of violations of this Code, including reports sent anonymously, will be
promptly investigated and acted upon in a timely manner. If any report of
wrongdoing relates to accounting or financial reporting matters, or relates to
persons involved in the development or implementation of the Company's system of
internal controls, a copy of the report will be promptly provided to the
chairman of the Audit Committee of the Board of Directors, which may participate
in the investigation and resolution of the matter. It is the policy of the
Company not to allow actual or threatened retaliation, harassment or
discrimination due to reports of misconduct by others made in good faith by
employees. Employees are expected to cooperate in internal investigations of
misconduct. Please see the Company’s Whistle Blower Policy for details on
reporting illegal or unethical conduct and the protections the Company
provides.
 
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  14.
Compliance Standards and Procedures
 This Code
is intended as a statement of basic principles and standards and does not
include specific rules that apply to every situation. Its contents have to be
viewed within the framework of the Company’s other policies, practices,
instructions and the requirements of the law. This Code is in addition to other
policies, practices or instructions of the Company that must be observed.
Moreover, the absence of a specific corporate policy, practice or instruction
covering a particular situation does not relieve you of the responsibility for
exercising the highest ethical standards applicable to the circumstances. In
some situations, it is difficult to know what action is appropriate. Because
this Code does not anticipate every situation that will arise, it is important
that each of you approach a new question or problem in a deliberate
fashion:
 
 (a)
              Determine
      if you know all the facts.
  (b)
              Identify
      exactly what it is that concerns
you.
  (c)
              Discuss
      the problem with a supervisor or, if you are a director, the Company's
      Chief Operating Officer.
  (d)
              Seek
      help from other resources such as other management personnel or our
      Company’s Chief Operating Officer.
  (e)
              Seek
      guidance before taking any action that you believe may be unethical or
      dishonest.
 
 You will
be governed by the following compliance standards:
  •
              You
      are personally responsible for your own conduct and for complying with all
      provisions of this Code and for properly reporting known or suspected
      violations;
  •
              If
      you are a supervisor, manager, director or officer, you must use your best
      efforts to ensure that employees understand and comply with this
      Code;
  •
              No
      one has the authority or right to order, request or even influence you to
      violate this Code or the law; a request or order from another person will
      not be an excuse for your violation of this Code and in fact, you should
      report such a request;
  •
              Any
      attempt by you to induce another director, officer or employee of the
      Company to violate this Code, whether successful or not, is itself a
      violation of this Code and may be a violation of
  law;
  •
              Any
      retaliation or threat of retaliation against any director, officer or
      employee of the Company for refusing to violate this Code, or for
      reporting in good faith the violation or suspected violation of this Code,
      is itself a violation of this Code and the Company’s Whistleblower Policy
      and may be a violation of law; and
  •
              The
      Company requires that every reported violation of this Code be
      investigated.
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  Violation
of any of the standards contained in this Code, or in any other policy, practice
or instruction of the Company, can result in disciplinary actions, including
dismissal and civil or criminal action against the violator. This Code should
not be construed as a contract of employment and does not change any person's
status as an at-will employee.
  This Code
is for the benefit of the Company, and no other person is entitled to enforce
this Code. This Code does not, and should not be construed to, create any
private cause of action or remedy in any other person for a violation of the
Code. Moreover, violations of this Code shall not be presumed to create a
violation of law, rule or regulation on the part of the Company.
 
 The
names, addresses, telephone numbers, facsimile numbers and e-mail addresses of
the Compliance Officer, Chief Executive Officer and the Chief Operating Officer
of the Company are set forth below:
 
 United
Western Bancorp, Inc.
 700
17thStreet, Suite
2100
 Denver,
Colorado 80202
 (303)
595-9898 Telephone
 (720)
946-1171 Fax
 
 Chief
Executive Officer
 Scot T.
Wetzel
 (720)
956-6577
 swetzel@uwbank.com
 
 Compliance
Officer
 Thomas J.
Loveday
 (720)
932-4295
 tloveday@uwbank.com
 
 Chief
Operating Officer
 Michael
J. McCloskey
 (720)
932-4282
 mmccloskey@uwbank.com
 
 
 Adopted
by Resolution of the Board of Directors
 August
4, 2008