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EXHIBIT 14
 SOUTHEAST BANK & TRUST
AND
SOUTHEAST BANCSHARES
 CODE OF ETHICS
CONFLICTS OF INTEREST POLICY
 Revised January 2, 2007
 Exhibit 14 - 1




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This policy was originally adopted by the SouthEast Bank & Trust Board of Directors on
January 27, 2004, and it revised on January 2, 2007 to incorporate the reorganization and share
exchange with the bank holding company, SouthEast Bancshares, Inc.
 INTRODUCTION
      POLICIES ON LEGAL AND ETHICAL STANDARDS
   Exhibit 14 - 2




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Proprietary Information
  Gifts Received by Employees
  Giving of Gifts
  Exhibit 14 - 3




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Preferential Treatment
  1.
    
    Special employee programs and services; or2.
    
    Purchase of property from the Bank provided the purchase price is at fair
market value, such valuation having been properly documented; or
  Political Contributions
  1.
    
    Establishing political action committees to solicit contributions to separate
political funds to be utilized for political purposes; or2.
    
    Communicating direct political messages to shareholders; or3.
    
    Implementing non-partisan voter registration or to get-out-the-vote
campaigns.
  Improper Transaction and Payments
 Exhibit 14 - 4




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1.
    
    All transactions or conduct of Bank business must be properly reflected in the Banks
books and records; and2.
    
    No secret or unrecorded fund of Bank money or other assets may be established
or maintained; and3.
    
    Any payment is prohibited if no record of its disbursement is entered in the Banks
accounting record; and4.
    
    Making false or fictitious entries in the books or records of the Bank or issuing false
or misleading documents is prohibited and in most instances will constitute a criminal
offense; and5.
    
    A Representative should avoid processing transactions for the Representatives
own personal account, an account on which the Representative signs with another
person, and accounts belonging to members of a Representatives family; and6.
    
    Representatives must also avoid participating in transactions, which gives the
appearance of circumventing established Bank policies. Any transaction which gives the
appearance of circumventing established Bank policies can be considered a violation of the
code of conduct. Transactions include but are not limited to deposits, processing of
payments, waiving fees or charges, making loans, etc.; and7.
    
    Representatives and their immediate families, acting either individually or as a
fiduciary, may not sell assets to or purchase assets from the Bank unless the purchase or
sell is at a fair market value price, documentation is maintained, and prior approval is
granted by the CEO or the President.
    Exhibit 14 - 5




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CONFLICT OF INTEREST
 Corporate Policy
  A potential conflict of interest exists
  Fiduciaries and Legacies
   1.
    
    Where such customer is a relative or the person involved; or2.
    
    The employee named in the legacy has never dealt with the grantor as a
representative of the Bank.
  Exhibit 14 - 6




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Lending
     Outside Employment
   Participation in Public Affairs
    Corporate Directorships, Public Office, and Commissions
  Exhibit 14 - 7




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with any financial services
institution
   1.
    
    Competes with the Bank; or2.
    
    Is in default to the Bank or any loan, contract or other obligation; or3.
    
    Is involved in a controversy or litigation with the Bank.
  Unusual Business Transactions
 without written approval
 Exhibit 14 - 8




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SECURITIES AND DISCLOSURES
 Accounting Policies
    
    
    Make or cause to be made a materially false or misleading statement, or
    
    Omit to state, or cause another person to omit to state, any material fact
necessary to make statements made not misleading
  Disclosure Policies and Controls
   Exhibit 14 - 9




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Insider Trading or Tipping
  
    
    Buy or sell securities (or derivatives relating to such securities) of the
Bank, including transfers in or out of the stock funds in any Employee Savings
Plan (other than pursuant to a pre-approved trading plan that complies with the
SEC Rule 10b5-1), or
    
    Pass on, tip or disclose material, nonpublic information to others outside the
Bank including family and friends.
   
    
    Undisclosed annual, quarterly or monthly financial results, a change in
earnings or earnings projections, or unexpected or unusual gains or losses in
major operations;
    
    Undisclosed negotiations and agreements regarding mergers, concessions,
joint ventures, acquisitions, divestitures, business combinations or
tender offers;
    
    An undisclosed increase or decrease in dividends on the Banks common stock;
    
    Undisclosed major management changes;
 Exhibit 14 - 10




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
    
    A substantial contract award or termination that has not been publicly
disclosed;
    
    A major lawsuit or claim that has not been publicly disclosed;
    
    The gain or loss of a significant customer or supplier that has not been
publicly disclosed;
    
    An undisclosed filing of a bankruptcy petition by the Bank or a significant
subsidiary;
    
    Information that is considered confidential; and
    
    Any other undisclosed information that could affect our stock price.
 Another Banks Securities
  Trades Following Disclosure
  ANTITRUST COMPLIANCE AND RELATIONS WITH COMPETITORS
   Exhibit 14 - 11




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1.
    
    That the customer obtain any additional service from another Bank
subsidiary; or2.
    
    That the customer provide some additional service to the Bank; or3.
    
    That the customer shall not obtain some other service other than loans from a
competitor of the Bank.
 ADMINISTRATION, REPORTING OF VIOLATIONS AND AMENDMENT
    Amendments and Modifications of this Code
   Exhibit 14 - 12




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Non-retaliation for Reporting
   Reporting of Code Violations
   Waivers
  Exhibit 14 - 13




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Employee/Director Signature:
 Date:
 PLEASE RETURN THIS PAGE TO HUMAN RESOURCES AND RETAIN THE POLICY
 Exhibit 14 - 14