<PAGE>

                                                                    EXHIBIT 14.0

                           R & G FINANCIAL CORPORATION

                                 CODE OF ETHICS

                          STANDARDS OF PERSONAL CONDUCT

I.       PURPOSE

         This policy establishes the standards of ethical business behavior and
personal conduct for officers, directors and employees of R&G Financial
Corporation and its subsidiaries. Fundamental to our continued success is the
perpetuation of integrity and the highest ethical standards. The intent of this
policy is to safeguard R&G's tradition of strong moral, ethical and social
standard of conduct.

II.      SCOPE

         This policy applies to all officers, directors and employees of R&G.

III.     OVERALL POLICY

         R&G, as a business built upon public trust and confidence, depends upon
a favorable perception of conduct of its business by customers, federal and
state regulators, stockholders, and others in both the business and general
community. It is imperative that each officer, director and employee of R&G
views his/her business and personal actions, intentions and impressions upon
others objectively. Each of us must assure that no one observing our actions,
intentions or impressions would have reason to believe that even the slightest
irregularity in conduct exists or could be implied.

         To this end, this policy will address twenty eight (28) specific areas
that need immediate and continuing attention on the part of each officer,
employee and director of R&G, as follows:

1.       Equal Employment Opportunity.

2.       Employee Relations.

3.       Sexual and Unlawful Harassment.

4.       Employment Applications.

5.       Employment Reference Checks.

6.       Life Threatening Illnesses in the Workplace.

7.       Protection of Confidential Information.

8.       Investments and Insider Trading.

9.       Conflicts of Interest.


                                       1
<PAGE>

10.      Outside Activities.

11.      Board Directorships and Partnerships.

12.      Improper Payments.

13.      Money Laundering.

14.      Trade Associations and Relations with Competitors.

15.      Fair Dealing.

16.      Separation of the Trust Department.

17.      Advertising Policy.

18.      Political Action Committees/Corporate Payments.

19.      Public Statements.

20.      Recommendations to Customers.

21.      Financial Responsibility.

22.      Personal Conduct.

23.      Provision of Federal Legislation Prohibiting Bribery.

24.      Employment of Institution Staff by Other Parties.

25.      Protection and Proper Use of Company Assets.

26.      Corporate Opportunities.

27.      Standard for Disclosure of Information.

28.      Other Personnel Standards.

IV.      COMPLIANCE WITH LAWS, RULES AND REGULATIONS

         Obeying the law, both in letter and in spirit, is the foundation on
which R&G's ethical standards are built. All officers, directors and employees
of R&G must respect and obey all federal, state and local laws, rules and
regulations. Although not every individual is expected to know all the details
of these laws, it is important to know enough to determine when to seek advice
from supervisors, managers, company legal counsel or other appropriate
personnel.

         If a law conflicts with a policy in this Code, you must comply with the
law; however, if there is a conflict between the requirements of this Code and
the customs or practices of a



                                       2
<PAGE>

particular area, you should consult with management and company legal counsel to
determine the most appropriate course of action.

V.       SPECIFIC POLICIES

         1.       Equal Employment Opportunity

                  a.       In order to provide equal employment and advancement
                           opportunities to all individuals, employment
                           decisions at R&G will be based on merit,
                           qualifications and abilities. R&G does not
                           discriminate in employment opportunities or practices
                           on the basis of race, color, religion, sex, national
                           origin, age, disability, sexual orientation or any
                           other characteristics protected by law.

                  b.       R&G will make reasonable accommodations for qualified
                           individuals with known disabilities unless doing so
                           would result in an undue hardship. This policy
                           governs all aspects of employment, including
                           selection, job assignment, compensation, discipline,
                           separation and access to benefits and training.

                  c.       Any employees with questions or concerns about any
                           type of discrimination in the workplace are
                           encouraged to bring these issues to the attention of
                           their respective Department Head or to the Human
                           Resources Department. Employees can raise concerns
                           and make reports without fear of reprisal. Anyone
                           found to be engaging in any type of unlawful
                           discrimination will be subject to disciplinary
                           action, up to and including termination of
                           employment.

         2.       Employee Relations

                  a.       R&G believes that the working conditions,
                           compensation and benefits it offers are highly
                           competitive with those offered by other employers in
                           this area and in this industry. If employees have
                           concerns about any aspect of their employment, they
                           are strongly encouraged to voice these concerns
                           openly and directly to their respective Department
                           Head.

                  b.       Our experience has shown that when employees deal
                           openly and directly with supervisors, the work
                           environment can be excellent, communications can be
                           clear and attitudes can be positive. We believe that
                           R&G amply demonstrates its commitment to employees by
                           responding effectively to employee concerns.

         3.       Sexual and Other Unlawful Harassment

                  a.       R&G is committed to providing a work environment that
                           is free of discrimination and unlawful harassment.
                           Actions, words, jokes or comments based on an
                           individual's sex, race, ethnicity, age, religion or
                           any other legally protected characteristic will not
                           be tolerated. As an



                                       3
<PAGE>

                           example, sexual harassment (both overt and subtle) is
                           a form of employee misconduct that is demeaning to
                           another person, undermines the integrity of the
                           employment relationship, and is strictly prohibited.

                  b.       Any employee who wants to report an incident of
                           sexual or other unlawful harassment should promptly
                           report the matter to any of the designated officers
                           established in the Company's Human Resources Policy
                           Manual. Employees can raise concerns and make reports
                           without fear of reprisal.

                  c.       Any respective Department Head who becomes aware of
                           possible sexual or other unlawful harassment should
                           promptly advise the Director of Human Resources who
                           will investigate the matter in a timely and
                           confidential manner. Anyone engaging in sexual or
                           other unlawful harassment will be subject to
                           disciplinary action, up to and including termination
                           of employment.

         4.       Employment Applications

                  a.       R&G relies upon the accuracy of information contained
                           in the employment application, as well as the
                           accuracy of other data presented throughout the
                           hiring process and employment. Any
                           misrepresentations, falsifications or material
                           omissions in any of this information or data may
                           result in our exclusion of the individual from
                           further consideration for employment or if the person
                           has been hired, termination of employment.

         5.       Employment Reference Checks

                  a.       To ensure that the individuals who join R&G are well
                           qualified and have a strong potential to be
                           productive and successful, it is the policy of R&G to
                           check the employment references of all applicants.

                  b.       R&G will respond to reference check inquiries from
                           other employers. Responses to such inquiries will
                           confirm only dates of employment, compensation and
                           position held at time of leavings, provided that the
                           individual has given R&G written authorization and a
                           release.

         6.       Life Threatening Illnesses in the Workplace

                  a.       Employees with life threatening illnesses, such as
                           cancer, heart disease, and AIDS, often wish to
                           continue their normal pursuits, including work, to
                           the extent allowed by their condition. R&G supports
                           these endeavors as long as employees are able to meet
                           acceptable performance standards. As in the case of
                           other disabilities, R&G will make reasonable
                           accommodations in accordance with all legal
                           requirements, to allow qualified employees with life
                           threatening illnesses to perform the essential
                           functions of their jobs.

                                       4
<PAGE>

                  b.       Medical information on individual employees is
                           treated as confidential. R&G will take reasonable
                           precautions to protect such information from
                           inappropriate disclosure. Managers and other
                           employees have a responsibility to respect and
                           maintain the confidentiality of employee medical
                           information. Anyone inappropriately disclosing such
                           information is subject to disciplinary action, up to
                           and including termination of employment.

                  c.       Employees with questions or concerns about life
                           threatening illnesses are encouraged to contact the
                           Director of Human Resources for information and
                           referral to appropriate services and resources.

         7.       Protection of Confidential Information

                  a.       Financial institutions by their very name are privy
                           to a variety of confidential information which
                           includes plans, forecasts, decisions, problems,
                           capabilities, intentions, contingencies and timing of
                           actions by many individual and company clients of
                           R&G, and R&G itself. The proper use of this type of
                           information is to enable sound business decisions to
                           be made by R&G personnel regarding either the
                           business of a client, prospective client or R&G
                           itself.

                  b.       Under no circumstances will confidential information
                           be used for the personal benefit of an officer,
                           director or employee. To do so violates statutes and
                           the policy of R&G. In addition to the penalties
                           imposed by any statutes, such actions, if proven,
                           will subject the officer, director or employee to
                           removal from his/her position. The general rule is
                           that such confidential information not be divulged to
                           any person outside R&G, except for attorneys or other
                           agents in furtherance of a legitimate business
                           objective. This would include a family member or
                           associate of any officer, director or employee. It
                           applies even to other members of R&G staff unless
                           that person has a need to know in discharging his/her
                           duties.

                           It is understood that all sensitive information that
                           R&G has is considered confidential to R&G and R&G's
                           activities. This includes electronic records
                           containing such information. All officers, directors
                           and employees of R&G, as well as attorneys or other
                           agents, are bound to maintain the confidentiality of
                           R&G's sensitive information. Management, from time to
                           time to the extent required or otherwise deemed
                           appropriate, can request attorneys or other agents to
                           sign a nondisclosure agreement.

                  c.       No financial or other information regarding R&G or
                           any of its activities that could reasonably be
                           expected to affect R&G's position in the general
                           community is to be related to any person not employed
                           by R&G Financial, and other types of information that
                           are normally disclosed to the public as part of
                           disclosure requirement applicable to publicly held
                           companies are



                                       5
<PAGE>

                           not to be related to any person not an officer,
                           director, employee or responsible agent working on
                           R&G's behalf until it has been published in reports
                           to stockholders or otherwise made available to the
                           general public in accordance with specific procedures
                           established by R&G for the dissemination of such
                           information.

                  d.       Information regarding current or former employees is
                           confidential.

                  e.       Inquiries for such information, whether by tax
                           authorities, law enforcement agencies, attorneys or
                           private parties involved in litigation, must not be
                           divulged unless R&G has received either the written
                           consent of the customer, employee, officer or
                           shareholder or the appropriate court order or
                           subpoena and release has been authorized under normal
                           operational procedures.

                  f.       The protection of the confidentiality of customer
                           provided information is the responsibility of R&G.
                           Refer to R&G Customer Confidentiality policies for
                           specific standards, requirements and guidelines.

         8.       Investments and Insider Trading

                  a.       No investment interests, direct or indirect, in any
                           of R&G's customers or suppliers are permitted except
                           as outlined below in paragraphs b and c. Any
                           exceptions must be approved in advance and in writing
                           by the Chairman of the Board or President. This
                           prohibition applies to all officers, directors, and
                           employees and their families and to all forms of
                           investment including, but not limited to, securities,
                           investment in a proprietorship, joint venture or
                           similar business activities. Investments that qualify
                           as material should be promptly reported to the
                           Chairman of the Board or the President. Officers may
                           be asked to disclose such information in an annual
                           statement.

                  b.       Investments are permitted in companies who are
                           customer and/or suppliers if such securities are
                           listed on an organized exchange or are traded in the
                           over the counter market or if it is otherwise evident
                           and clear that such investments are not being made on
                           any terms that are more favorable than those terms
                           available to the general public; subject, however, to
                           the following restrictions:

                           i.       Caution should be exercised by each officer,
                                    director or employee to assure that the
                                    nature and amount of such permitted
                                    investments are in such amounts as are
                                    prudent for a person maintaining a
                                    conservative and passive investment.

                           ii.      Acceptance of an allocation of securities
                                    from a broker or investment banker that are
                                    or become "hot" issues may involve or lead
                                    to the perception of favorable treatment and
                                    is therefore prohibited.

                                       6
<PAGE>

                  c.       Investments in "limited partnership interests" will
                           be permitted if it is evident that such investments
                           are not being made on terms more favorable than those
                           that are available to the general public. In the case
                           of "limited partnership investments" an individual's
                           investment should be only one of several such
                           interests sold to the general public and in such
                           amounts as are consistent with a conservative and
                           passive investment.

                  d.       R&G has adopted an Insider Trading Policy which
                           specifically governs trading in the securities of
                           R&G. All officers and employees must follow the
                           Company's Insider Trading Policy.

         9.       Conflicts of Interest

                  a.       Officers, directors and employees of R&G are expected
                           to conduct their private business and personal
                           activities in a manner that avoids a conflict of
                           interest either with R&G or R&G's customers.
                           "Conflict of interest" is defined as any situation
                           where an individual has two or more duties or
                           interests that are mutually incompatible. Example: An
                           officer, director or employee has a personal
                           financial interest in a business or venture that
                           conducts business with R&G. That individual's
                           judgment might reasonably be influenced by that
                           non-bank relationship. No lending officer or employee
                           should loan, review a loan or make any decision
                           regarding a loan of any customer, syndicate or
                           corporation in which he or she has a present or a
                           prospective financial interest.

                  b.       No officer, director or employee nor any member of
                           his/her family (including spouse, parents, children,
                           brothers, sisters or other immediate relatives) shall
                           solicit, accept or retain any personal benefit from
                           any of the following:

                           i.       A customer of R&G.

                           ii.      Any individual or organization that is, or
                                    seeks to be a borrower, supplier or
                                    competitor of R&G.

                           A personal benefit is defined as any type of gift,
                           favor, service, loan, fee or other compensation.
                           Exceptions to those prohibitions are limited strictly
                           to normal business courtesies where there is no
                           concealment and where no improper influence to the
                           performance of an officer, director or employee of
                           R&G, is present or could be implied.

                  c.       All officers, directors and employees should disclose
                           any outside activities, financial interests, material
                           transactions or relationships that may present or
                           that reasonably could be expected to give rise to a
                           possible conflict of interest or the appearance of a
                           conflict to the Internal Auditor. Any known or
                           potential conflict of others should also be promptly
                           disclosed to the Internal Auditor or directly to the
                           Audit Committee of the Board of Directors.



                                       7
<PAGE>

                  d.       All officers, directors and employees should exercise
                           good judgment in all personal and business dealings
                           outside R&G and avoid actions or relationships which
                           might conflict or appear to conflict with the
                           responsibilities of such person's job or position or
                           the interests of R&G.

         10.      Outside Activities

                  a.       Officers, directors and employees have been and are
                           encouraged to be active and involved participants in
                           the community. Such activities should be limited by
                           the persons' own interests, and reasonable time
                           requirements; any major outside commitments must be
                           approved in advance by the immediate supervisor or
                           other designated member of Management. Other than the
                           community activity described above, officers,
                           directors and employees are discouraged from engaging
                           in any outside interest which will divert time or
                           attention from his/her duties.

         11.      Board Directorships and Partnerships

                  a.       No officer, director or employee shall serve as a
                           director of a board, except of a church or well-known
                           nonprofit organization, without the prior written
                           approval of the Chairman of the Board after
                           deliberation by the Board of Directors. Likewise, no
                           officer, director or employee shall become a partner
                           in an economic venture involving banking or mortgage
                           banking at all, or otherwise in an amount exceeding
                           5% of the venture's capital without prior approval of
                           the Chairman of the Board after deliberation by the
                           Board of Directors.

         12.      Improper Payments

                  a.       All officers, directors and employees are expected to
                           comply with all laws and regulations (federal, state
                           and local). The use of any R&G person or resource
                           which is in violation of any federal, state or local
                           law or regulation is strictly prohibited. Our policy
                           is to not make any improper payments to any
                           governmental, political, business or labor
                           organization or any individual.

                  b.       All transactions of R&G are required to be identified
                           precisely and recorded in the financial records of
                           R&G in accordance with generally accepted accounting
                           practices.

         13.      Money Laundering

                  a.       All officers, directors and employees are expected to
                           comply with all applicable money laundering laws. All
                           employees should follow the rules concerning
                           acceptable forms of payments and learn to identify
                           payments and deposits that have become associated
                           with money laundering activity. Any concerns should
                           be promptly raised with supervisory personnel and,



                                       8
<PAGE>

                           if appropriate, company legal counsel, and should be
                           resolved before proceeding further with the
                           transaction.

         14.      Trade Associations and Relations with Competitors

                  a.       R&G will act with trade associations and competitors
                           only on behalf of ethical and beneficial social
                           objectives and will not participate in business
                           activities that are or could be constructed to be in
                           violation of anti-trust laws.

         15.      Fair Dealing

                  a.       Each officer, director and employee should endeavor
                           to respect the rights of and deal fairly with the
                           company's customers, suppliers, competitors and
                           employees. No officer, director or employee should
                           take unfair advantage of anyone through manipulation,
                           concealment, abuse of privileged information,
                           misrepresentation of material facts, or any other
                           intentional unfair-dealing practice.


         16.      Separation of the Trust Department

                  a.       Various financial regulatory agencies require a
                           separate identity for the commercial banking and
                           Trust Department. The essential distinction between
                           these departments arises out of the fiduciary
                           responsibilities assumed by the Trust Department. The
                           fiduciary relationship between the Trust Department
                           and its customers and beneficiaries creates a moral
                           and legal obligation beyond the usual business
                           standard. It is the responsibility of every officer,
                           director and employee to be mindful of the separation
                           of the trust and commercial banking functions so that
                           all exchange of information and treatment of a
                           customer adheres to the separation of these two
                           functions.

         17.      Advertising Policy

                  a.       R&G advertising will insure that the ethical content
                           and moral impact of any advertising in any type media
                           made for or on behalf of R&G is made in accordance
                           with social values and accepted good taste.

                           Advertisements will comply with all regulatory
                           consumer compliance regulations and will be affirmed
                           by review of the internal audit department and R&G
                           attorneys, as applicable.

         18.      Political Action Committees/Corporate Payments

                  a.       It is R&G's policy not to contribute money, property,
                           or services to any government official, political
                           party, or candidate, whether local, state or federal.



                                       9
<PAGE>

                  b.       It follows that R&G is prohibited from offering or
                           allowing the use of its facilities, equipment and
                           personnel in connection with any federal, state or
                           local election or campaign.

                  c.       Officers, directors and employees may, and are
                           encouraged to, engage in any governmental, regulatory
                           and elective process in which they are interested.
                           This participation may be on an individual basis,
                           group basis or as a member of a political action
                           committee. Since R&G is without preference as to
                           political parties, candidates, and opinion, each
                           officer, director and employee must act only on
                           his/her own behalf and not give any representation
                           that he/she represent anyone other than
                           himself/herself. Written approval must be obtained
                           from the Chairman of the Board or the President
                           before seeking or accepting nomination or appointment
                           to any public office, whether paid or unpaid.

         19.      Public Statements

                  a.       Although R&G has a policy of maintaining good
                           relations with all news media and tries to
                           accommodate media inquiries, there is much
                           information concerning R&G that should not be made
                           available to the public. This includes information
                           about corporate customers which R&G has a
                           responsibility not to divulge as well as information
                           which would be valuable to a competitor.

                  b.       For these and other reasons, any inquiry made to
                           officers, employees or directors about R&G or about a
                           customer or stockholder of R&G by the news media
                           should be referred to the Chairman of the Board or
                           the President for proper action.

         20.      Recommendations to Customers

                  a.       Officers, directors and employees of R&G are not to
                           recommend attorneys, accountants, insurance agents,
                           stock brokers, real estate agents or similar
                           individuals or companies to customers or others
                           asking R&G's input unless several names are provided
                           without indication of favorites.

         21.      Financial Responsibility

                  a.       All officers, directors and employees of R&G should
                           conduct their financial affairs in such a responsible
                           manner as to be above criticism. The following list
                           is intended to be a guide, but not a complete nor
                           exhaustive list:

                           i.       Prompt payment of personal bills and debts.

                           ii.      Avoid overdrafts in personal checking
                                    accounts.



                                       10
<PAGE>

                           iii.     Use of any R&G credit cards, expense account
                                    reimbursements, equipment and supplies only
                                    for official R&G use.

                           iv.      Discourage of salary advances, even if
                                    allowed by R&G policy.

                           v.       Employee loans are to be in strict
                                    compliance with internal lending policies
                                    (Refer to R&G's Credit Policy).

                           vi.      Incurring indebtedness only for legitimate
                                    purposes made in accordance with the
                                    requirements of Regulation O and any other
                                    applicable laws, regulations or guidelines.

         22.      Personal Conduct

                  a.       Dishonesty

                           This institution is required by its various
                           regulatory agencies to consider ineligible for
                           initial employment or continued employment any
                           individual who fails to fulfill his or her legal and
                           ethical duties and obligations. Any employee who
                           commits an act constituting breach of trust or
                           dishonesty, i.e., theft, fraud or falsification of
                           R&G records, will be subject to disciplinary action
                           up to and including termination.

                  b.       Major Infractions

                           It is the policy of R&G to thoroughly investigate the
                           occurrence of any major infraction, and to take
                           appropriate and reasonable disciplinary action
                           involving any individual(s) connected with R&G, up to
                           and including termination or removal from the Board,
                           as applicable. Major infractions include but are not
                           limited to the following:

                           i.       Any action which renders an officer,
                                    director or employee an unacceptable
                                    security risk, adversely affects R&G's
                                    public image or causes embarrassment to R&G
                                    or its customers.

                           ii.      Release of confidential information or use
                                    of confidential information for personal
                                    gain.

                           iii.     Unauthorized possession, distribution or use
                                    of any drug or illegal narcotic.

                           iv.      Inability to perform work due to consumption
                                    of alcohol or any other controlled chemical
                                    substance.

                           v.       Fighting.

                           vi.      Removal or borrowing R&G property without
                                    permission.

                                       11
<PAGE>

                           vii.     Persistent financial irresponsibility.

                           viii.    Willful failure to follow instructions,
                                    insubordination,

                           ix.      Unauthorized possession of weapons.

                           x.       Willful destruction or waste of property
                                    belonging to R&G, fellow employees or
                                    customers.

                           xi.      Failure to report to work without proper
                                    notification to management or leaving R&G
                                    without proper authority.

                           xii.     Any other major violation as established in
                                    the Company's Human Resources Policy Manual

         23.      Provision of Federal Legislation Prohibiting Bribery

                  a.       All officers, directors and employees agree to report
                           the receipt of "anything of value" from a customer of
                           R&G in accordance with R&G's policy. While this
                           policy may be revised from time to time as
                           circumstances warrant, the basic requirements is that
                           no disinterested third party could reasonably feel
                           that the officer, director or employee would have
                           his/her judgment impaired or compromised by the
                           acceptance of such a gift.

                  b.       All officers, directors and employees should avoid
                           giving lavish gifts, meals or entertainment to other
                           officers, directors or employees of any federal or
                           state commercial bank, savings bank, savings and loan
                           association, bank and savings and loan holding
                           company or federally insured credit union. Gifts
                           intended to influence or that might give the
                           appearance of influencing a business decision should
                           be avoided.

                  c.       An officer, director or employee should never give
                           any gift, meal, or entertainment, if it could pose
                           danger of compromising the receiver's or attendee's
                           judgment.

         24.      Employment of Institution Staff by Other Parties

                  a.       All officers and employees of R&G shall refrain from
                           seeking and obtaining employment in any other
                           business organization which has an ongoing
                           relationship with R&G. The purpose of this section is
                           to avoid the possibility of a conflict of interest
                           situation arising from the above-described
                           circumstances.


                                       12
<PAGE>

         25.      Protection and Proper Use of Company Assets

                  a.       All officers and employees of R&G are responsible for
                           the safeguarding of all the property and records of
                           the company in a prudent and effective manner.

                  b.       All officers and employees should endeavor to protect
                           the company's assets and ensure their efficient use.
                           Theft, carelessness, and waste have a direct impact
                           on the company's profitability. Any suspected
                           incident of fraud or theft should be immediately
                           reported for investigation. Company equipment should
                           not be used for non-company business, though
                           incidental personal use may be permitted.

                  c.       No officer, director or employee may use official R&G
                           stationery for personal or non-job related purposes,
                           particularly when such use would imply endorsement by
                           R&G or make references to R&G employment in matters
                           of personal dispute.

         26.      Corporate Opportunities

                  a.       All officers, directors and employees are prohibited
                           from taking for themselves personally opportunities
                           that are discovered through the use of corporate
                           property, information or position without the consent
                           of the Board of Directors. No officer, director or
                           employee may use corporate property, information, or
                           position for improper personal gain, and no employee
                           may compete with the company directly or indirectly.
                           Officers, directors and employees owe a duty to the
                           company to advance its legitimate interests when the
                           opportunity to do so arises.

         27.      Standards for Disclosure of Information

                  a.       All officers, employees, directors, attorneys and
                           agents are expected to produce full disclosure of any
                           transactions and/or activities of any nature which
                           are relative to R&G's operations to the Board of
                           Directors and to the appropriate regulatory agency,
                           provided that submitting the aforementioned
                           information by itself does not violate any privacy
                           act or any other law which protects the
                           confidentiality of some acts or activities.

                  b.       All officers, directors and employees should maintain
                           complete and accurate records and accounts, and
                           provide timely and candid forecasts and assessments
                           to management to ensure full, fair, accurate, timely
                           and understandable disclosure in documents filed with
                           or submitted to the SEC or other regulatory agencies
                           and in other public communications.



                                      13
<PAGE>

         28.      Other Personnel Standards

                  a.       Other specific personnel standards requirements and
                           guidelines are outlined in the personnel manual
                           provided to all employees of R&G.

                  b.       Written acknowledgment of receipt and contents,
                           including the code of ethics is required by all R&G
                           personnel.

VI.      ADMINISTRATION AND RESPONSIBILITIES

         The primary accountability and responsibility for the Code of Ethics
and Standards of Personal Conduct rests with each individual officer, director
or employee. However, each supervisor and manager has the additional
responsibility to demonstrate by example what compliance with this policy means.

VII.     EXCEPTIONS TO THIS POLICY

         Exemptions to this Policy can be made in cases in which the underlying
objective of the Policy will not be violated and only for just cause. In those
cases, prior written approval from the Board of Directors will have to be
obtained. Any amendment to or grant of a waiver from a provision of this Policy
to any director or executive officer will be promptly disclosed to the extent
and as required by law.

VIII.    REPORTING ANY ILLEGAL OR UNETHICAL BEHAVIOR

         All officers, directors and employees of R&G should promptly report any
concerns about possible violations of the Code or any laws, rules or regulations
and any observed illegal or unethical behavior to the Internal Auditor or
directly to the Audit Committee of the Board of Directors.

         Officers, directors and employees of R&G are encouraged to talk to the
Internal Auditor, supervisors, managers or other appropriate personnel,
including legal counsel when deemed appropriate by senior management, when they
have questions about the application of any policy or when in doubt about the
best course of action in a particular situation. R&G prohibits any individual
from retaliating or taking adverse action against anyone for reporting
misconduct or for raising or helping to resolve an ethics concern. Every
officer, director and employee of R&G is expected to cooperate in internal
investigations of misconduct.

IX.      COMPLIANCE

         Any officer, director or employee of R&G who violates the letter or
spirit of R&G's Code of Ethics will be subject to disciplinary action, up to and
including termination of employment or removal from the Board, as applicable.
Conduct that may result in discipline includes failure to promptly report a
known or suspected violation of the Code of Ethics, failure to cooperate in
internal investigations of possible violations, and retaliation of any kind
against anyone who reports an ethics concern or violation. Violation of a policy
can also mean breaking the law and subject the individual to criminal penalties
or civil sanctions.

                                       14