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CODE OF ETHICS FOR CEO AND SENIOR MANAGEMENT
OF FIRST TRINITY FINANCIAL CORPORATION
  1.
    
    The CEO and all senior financial officers are responsible for full, fair, accurate,
timely and understandable disclosure in the periodic reports required to be filed by the
Company with the SEC. Accordingly, it is the responsibility of the CEO and each senior
financial officer promptly to bring to the attention of the Disclosure Committee
(consisting of the CFO, the President, the Vice President of Marketing and senior
accounting personnel) any material information of which he or she may become aware that
affects the disclosures made by the Company in its public filings or otherwise assist the
Disclosure Committee in fulfilling its responsibilities in preparation of the Companys
Financial Reporting and Disclosures.2.
    
    The CEO and each senior financial officer shall promptly bring to the attention of the
Disclosure Committee any information he or she may have concerning (a) significant
deficiencies in the design or operation of internal controls which could adversely affect
the Companys ability to record, process, summarize and report financial data or (b) any
fraud, whether or not material, that involves management or other employees who have a
significant role in the Companys financial reporting, disclosure, or internal controls.3.
    
    The CEO and each senior financial officer shall promptly bring to the attention of the
CFO, the President, or the Audit Committee any information he or she may have concerning
any violation of the Companys Code of Conduct, including any actual or apparent conflicts
of interest between personal and professional relationships, involving any management or
other employees who have a significant role in the Companys financial reporting,
disclosures or internal controls.4.
    
    The CEO and each senior financial officer shall promptly bring to the attention of the
CFO, the President, or the Audit Committee any information he or she may have concerning
evidence of a material violation of the securities or other laws, rules or regulations
applicable to the Company and the operation of its business, by the Company or any agent
thereof, or of violation of the Code of Conduct or of these additional procedures.5.
    
    The Board of Directors shall determine, or designate appropriate persons to determine,
appropriate actions to be taken in the event of violations of the Code of Conduct or of
these additional procedures by the CEO and the Companys senior financial officers. Such
action shall be reasonably designed to deter wrongdoing and to promote accountability for
adherence to the Code of Conduct and to these additional procedures, and shall include
written notices to the individual involved that the Board has determined that there has
been a violation, censure by the Board, demotion or re-assignment of the individual
involved, suspension with or without pay or benefits (as determined by the Board) and
termination of the individuals employment. In determining what action is appropriate in a
particular case, the Board of Directors or such designee shall take into account all
relevant information, including the nature and severity of the violation, whether the
violation was a single occurrence or repeated occurrences, whether the violation appears to
have been intentional or inadvertent, whether the individual in question had been advised
prior to the violation as to the proper course of action and whether or not the individual
in question had committed other violations in the past.