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EXHIBIT 14

                                 CODE OF ETHICS

                  The Directors, officers and employees of Neffs Bancorp, Inc.
and its subsidiaries (the "Company") hold an important and elevated role in
corporate governance. They are vested with both the responsibility and authority
to protect and preserve the interests of all of the Company's constituents,
including shareholders, customers and citizens of the communities in which we
conduct business. The maintenance of extremely high standards of honest, ethical
and impartial conduct is essential to assure the proper performance of the
Company's business and the maintenance of the public's trust. This Code of
Ethics prescribes the policies and procedures to be employed and enforced in the
Company's operations. [THIS CODE AUGMENTS THE SUBSIDIARY'S COMPANY'S EMPLOYEE
HANDBOOK.]

             -    It is your responsibility to comply with the law and behave
                  in an ethical manner. This responsibility cannot be
                  delegated or assumed by the Company

             -    This Code cannot anticipate every possible situation or
                  cover every topic in detail. [MOST OF THE TOPICS COVERED IN
                  THIS CODE ARE EXPLAINED IN GREATER DETAIL IN THE
                  SUBSIDIARY'S EMPLOYEE HANDBOOK.] From time-to-time the
                  Company may establish compliance programs to address
                  specific subjects. If you are unclear about a situation,
                  seek guidance before taking action.

             -    The standards in this Code do not necessarily take into
                  account all legal requirements. Where more restrictive local
                  laws or requirements exist, those take precedence.

             -    Comply with all applicable governmental rules and
                  regulations. Failure to obey laws and regulations violates
                  this Code and may expose both you and the Company to
                  criminal or civil prosecution. Any violation of this Code or
                  other compliance programs may result in corrective action,
                  up to and including termination. The Company may also seek
                  civil remedies from you and even refer criminal misconduct
                  to law enforcement agencies.

             -    You are responsible for reporting suspected violations of
                  this Code.

             -    [IF YOU HAVE A QUESTION ABOUT A TOPIC COVERED IN THIS CODE,
                  PLEASE REVIEW THE SUBSIDIARY'S EMPLOYEE HANDBOOK.] If you
                  still have a concern regarding any unethical or illegal
                  conduct, please contact our Corporate Compliance Officer

Conflicts of Interest

         A "conflict of interest" exists any time one faces a choice between
what is in his/her personal interest (financial or otherwise) and the interest
of the Company. These situations are not always easy to avoid. When a conflict
of interest arises, it is important that officers act with great care to avoid
even the appearance that their actions were not in the best interest of the
Company. If you find yourself in a position where your objectivity may be
questioned because of individual interest or family or personal relationships,
notify our Corporate Compliance Officer, immediately.

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Ownership Interests

         Board of Directors approval is required for the Company to do business
with a company in which a member of the Board of Directors, an officer an
employee or a family member of a director, officer or employee owns - directly
or indirectly - an interest. [IF YOU OR A FAMILY MEMBER OWN OR ACQUIRE AN
INTEREST THAT IS GREATER THAN 5 % IN ANY COMPANY, BOARD APPROVAL IS NEEDED:

             -    IF THAT COMPANY HAS MORE THAN $1,000 IN DEPOSITS, LOANS OR
                  DOES MORE THAN $1,000 IN ANNUAL SALES OF GOODS OR SERVICES
                  TO THE COMPANY OR ITS AFFILIATES; OR

             -    IF YOU HELP MAKE THAT COMPANY'S PURCHASING OR LENDING
                  DECISIONS OR HAVE A PART IN PAYMENT FOR THE GOODS AND
                  SERVICES.

IF YOUR OWNERSHIP INTEREST DOES NOT MEET ANY OF THE ABOVE CRITERIA, BOARD
APPROVAL IS NOT NEEDED, BUT YOU REMAIN OBLIGATED TO KEEP THE COMPANY'S INTERESTS
FIRST IN MIND.]

Gifts, Meals, Services and Entertainment

         One should not request or accept anything that might be used as a means
to influence, or even appear to influence, you against the Company's best
interests. Personal gifts should not be accepted other than those considered
common business courtesies and for which one would reasonably expect to give
something similar in return in the normal course of business.

Safeguarding Company Assets/Accuracy of Books and Records

         The Company maintains internal controls to provide direction on
protecting Company assets and financial accountability. The controls are based
upon the following principles.

DO NOT:

             -    Make personal use of Company assets that creates any
                  additional costs for the Company, interferes with work
                  duties or violates any Company policies;

             -    Allow Company property to be used to help carry out illegal
                  acts;

             -    Manipulate financial accounts, records or reports for
                  personal gain;

             -    Maintain off-the-book accounts to facilitate questionable or
                  illegal payments; or

             -    Violate any law or regulation.

DO:

             -    Ensure effective internal controls and procedures are
                  designed and implemented;

             -    Prepare project budget proposals with accurate information;

             -    Maintain books, accounts and records according to generally
                  accepted accounting principles, using enough detail to
                  reflect accurately and fairly Company transactions;

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             -    Record transactions in a timely manner, so that no
                  misleading financial information is created. (These
                  transactions include, but are not limited to, income,
                  expense, indebtedness, obligation, reserves and acquisition
                  or disposition of assets, etc.); and

             -    Give full, fair, accurate, timely, and understandable
                  disclosure in any and all periodic reports filed with the
                  Securities Exchange Commission.

Insider Trading

         Insider trading is a crime that can carry severe penalties. If you know
material, confidential information about the Company or any company with whom we
have a business relationship and you trade Company securities, such as stocks or
bonds, while in possession of that information or tell others about it before it
is made public, you may have violated the insider trading laws.

         Material information is the type of news that would affect a reasonable
investor's decision on whether or not to invest in the Company's stock. Examples
include plans to issue securities, sharp changes in earnings patterns, changes
in dividend rates, changes in key management personnel, mergers, acquisitions,
and important regulatory actions affecting the Company. This policy forbids you
from trading not only in Company stock, but also in stock of our suppliers,
customers or other companies with whom we have a business relationship while in
possession of material inside information learned in the course of your
employment at our Company.

         We encourage all members of the Board of Directors and officers to
invest in our stock. However, if you have access to any information not readily
available to the public, you must be very careful when trading stock to be sure
you have not traded while in possession of material non-public information. When
you have such information:

             -    Do not tell anyone not authorized to have the information. A
                  casual remark to a friend may find its way to a broker and
                  eventually to the entire financial community thereby
                  requiring the Company to make a premature or unplanned
                  public announcement. This "tipping" may be illegal and
                  damaging to the Company.

             -    In compliance with the Sarbanes-Oxley Act of 2002, do not
                  trade and trading is prohibited in the Company's stock (or
                  that of an applicable outside company) until the news has
                  been made public for at least two full business days.
                  Circumstances suggesting the possibility of insider trading
                  may result in an investigation by governmental authorities
                  of the Company and stockbroker records of stock trading
                  transactions. This investigation could damage our Company's
                  reputation and result in liability or penalties, including
                  criminal charges and fines against the individual.

             -    This policy against insider trading also covers transfers
                  into and out of the Company stock or savings plans and
                  changes in patterns involving purchases of our stock within
                  the plans. However, generally, regular scheduled monthly
                  purchases of the Company stock within plans are not
                  prohibited.

If you are planning to effect a transaction in our securities, you must contact
our Corporate Compliance Officer, in advance.

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Bribery, Kickbacks and Other Improper Payments

         The Company, our Board of Directors, officers and employees must
maintain high ethical and professional standards in all dealings.

             -    Do not directly or indirectly promise, offer or make payment
                  in money or anything of value to anyone, including a
                  government official, agent or employee of a government,
                  political party, labor organization or business entity or a
                  candidate of a political party, with the intent to induce
                  favorable business treatment or to improperly affect
                  business or governmental decisions.

             -    Our Code does not take into account all local legal
                  requirements. Where more restrictive local laws exist, those
                  take precedence. In general, the Company does not consider
                  ordinary and reasonable business entertainment or gifts of
                  insubstantial value that are customary and legal in the
                  local market to be improper.

             -    Document any entertainment of and gifts to customers and
                  potential customers.

             -    Loans are not made by the Company to its Board members,
                  officers or employees. Loans may be made by our banking
                  subsidiaries and will comply with all federal and state
                  laws, statutes and regulations.