Corporate Statements

Anti-Bribery and Anti-Corruption Statement

At First Horizon, we are committed to conducting business ethically and prohibit our employees from participating in bribery and accepting improper payments. We operate in compliance with all applicable regulations and applicable laws, which include the U.S. Foreign Corrupt Practices Act and similar laws that prohibit improper payments. 


Anti-Money Laundering (AML) Statement

First Horizon is dedicated to being a trusted financial institution and combating money laundering practices. We diligently work to ensure that our banking services are used responsibly and ethically.

We verify our customers’ identities to prevent any misuse of our bank. We take pride in abiding by all laws pertaining to financial legality.

To maintain vigilance, all employees are required to complete annual trainings on the Bank Secrecy Act and Anti-Money Laundering, as well as targeted training on Commercial Loan Fraud and Fraud and Security Awareness training.


Code of Business Conduct and Ethics

First Horizon adopted our Code of Business Conduct and Ethics to set forth the overarching principles that guide the conduct of every aspect of our business. Among other topics, the code covers conflicts of interest, confidentiality, insider trading, political activities and employee matters. Our Code of Business Conduct and Ethics applies to all employees, officers and directors of First Horizon and its subsidiaries and, in certain cases, to its agents and representatives as well. First Horizon has also adopted a Code of Business Conduct and Ethics for Senior Financial Officers, a Compliance and Ethics Program Policy, and many other policies with specific guidance on ethical matters.

Our Human Resources, Legal, Compliance and Corporate Security teams work together to oversee the handling of hotline submissions, Electronic Incident Reports and annual training on matters relating to these ethics codes and policies. Anonymously report unethical or illegal activity in the workplace via the Ethics Hotline at 800-217-3031. Our Code of Business Conduct and Ethics is available on our website at www.FirstHorizon.com.


Code of Business Conduct for Suppliers

First Horizon seeks to outperform the competition fairly and honestly, and has a legacy of succeeding through such honest business competition. We seek competitive advantages through superior performance, not through illegal or unethical business practices.

Consistent with the First Horizon Code of Business Conduct and Ethics that sets the basic standards for employee conduct, we adopted a Code of Business Conduct for Suppliers that establishes our expectations for our suppliers (i.e., third parties that provide goods or services to First Horizon).

The Code of Business Conduct for Suppliers includes our expectations for suppliers related to conducting their business legally and ethically and covers topics such as bribery, confidentiality, fair dealing, human rights, non-discrimination and harassment, recordkeeping and reporting.


Data Privacy/Cybersecurity Statement

First Horizon is committed to protecting customers’ personal information from unauthorized access and use, and continues to remain vigilant with its measures to safeguard and secure all proprietary and confidential information.

We are steadfast in our commitment to safeguard our customer and financial data. Our business practices, processes and controls regarding the protection and privacy of customer data are subject to numerous federal regulations, including the Gramm-Leach-Bliley Act and the Health Insurance Portability and Accountability Act. Additionally, the Bank is routinely subject to regulatory scrutiny and examination from entities such as the Tennessee Department of Financial Institutions and the Federal Reserve Board.

We dedicate substantial resources to cybersecurity to protect the confidentiality, integrity and availability of financial and personal data, and First Horizon is continually making investments in new technologies and cybersecurity professionals to strengthen our defenses, mitigate cybersecurity threats and adhere to regulatory requirements.

Our employees receive fraud and information security training annually while dedicated personnel monitor FHNC systems and networks.


Diversity and Inclusion Statement

First Horizon is committed to providing a work environment that is free of harassment or discrimination, and has a strict policy prohibiting workplace harassment and discrimination.

We continue to take steps to ensure that we offer a diverse and inclusive workplace because we believe that it is the right thing to do for our company, our employees and our customers.

The Company is firmly committed to non-discrimination and equal opportunity for employees, customers and suppliers. Our company is open to applicants regardless of religion, race, color, age, sexual orientation, gender identity, disability or veteran status, and we encourage our employees to celebrate diversity and inclusion via ongoing training opportunities, participation in employee resource groups and volunteering in our communities.

We created and follow our Code of Business Conduct and Ethics and A Matter of Principles guidelines to help us provide a strong corporate culture that promotes, maintains and sustains a diverse and inclusive work environment.

We abide by regulations from the U.S. Department of Labor in developing and executing our hiring practices.


Firearms Statement

We continue to follow all laws, acts and applicable regulations in accordance with federal law related to the manufacturing, sale and use of firearms.

We believe gun policy and the associated applicable regulations are best served through the cooperation of the American public and policymakers.


Hemp and CBD Banking Statement

Our guidelines in relation to the hemp industry align with federal laws. The 2018 Farm Bill made an important distinction between marijuana, hemp and Cannabidiol (CBD), making CBD and hemp legal.

While First Horizon does not provide banking services to manufacturers or growers of marijuana-related products, we do have a process in place, for business customers who sell CBD and hemp, to evaluate and ensure their practices align with federal laws and the values of our company. 

As federal policy and state legislation continues to evolve, we will continue to evaluate our banking guidelines position based on our Code of Business Conduct and Ethics, Matter of Principles and business practices.


Human Rights Statement

First Horizon respects individual human rights and is committed to operating our company in an environment where everyone is treated with dignity. While we believe our government and policymakers are primarily responsible for the laws and regulations that enable the preservation and protection of human rights, our company values and business practices support our belief that all people should be treated fairly and with respect.

We are firmly committed to non-discrimination and equal opportunity for our employees, customers and suppliers. First Horizon’s Code of Business Conduct and Ethics outlines the principles that guide the conduct of every aspect of our business. Our Code of Business Conduct and Ethics applies to all employees, officers and directors of the First Horizon family of companies and, in certain cases, to our agents and representatives.

Our Commitment

Everyone will be treated without discrimination or harassment based on race, color, religion, sex, sexual orientation, gender identity, national origin, age, veteran status or disability.

First Horizon and our subsidiaries are also committed to a position of lending fairness and to making available meaningful services to all of our customers and communities on a fair and equitable basis.

Any employee who engages in unlawful activities or violates First Horizon’s Code of Business Conduct and Ethics or any of the Company’s policies is subject to disciplinary action, including dismissal.

First Horizon honors our commitment to human rights by:

  • Conducting our business in a manner that is consistent with the fundamental human rights principles described in the United Nations Universal Declaration of Human Rights.
  • Requiring all employees to complete Code of Business Conduct and Ethics training upon hire, and annually thereafter, and to certify upon completing each training session that they have read, and that they understand, the Code.
  • Providing all employees with an annually updated guidebook, called A Matter of Principles, to ensure that they understand and practice the principles outlined in our Code of Business Conduct and Ethics.
  • Instituting a Corporate Social Responsibility (CSR) Committee to help us build stronger communities and guide our responsible business practices. The CSR Committee meets quarterly to review, recommend and report to the Executive Management Committee and the Board of Directors on CSR and environmental, social and governance (ESG) business and reputation topics.
  • Protecting the privacy of customer information. All employees, even after leaving the company, must comply with the policies described in our Privacy Policy.
  • Establishing multiple ways for employees and customers to raise concerns, ask questions, and report potential policy violations or unethical or suspicious behaviors with confidence and without fear of retaliation.
  • Operating our business in accordance with all applicable lending, labor, safety, health, anti-discrimination, and other diversity and inclusion workplace regulations and laws.
  • Adopting a Code of Business Conduct for Suppliers that establishes our expectations for our suppliers (i.e., third parties that provide goods or services to First Horizon), consistent with the First Horizon Code of Business Conduct and Ethics that sets the basic standards for employee conduct.

Immigration Policy Statement

We believe topics related to immigration policy are best served through the cooperation of the American public and policymakers.

For more than 155 years, we have built our bank by valuing our people, standing behind our customers, strengthening our communities and being committed to fair lending practices.

We have considered both the implications of providing financing to organizations that provide government-funded services in support of immigration policy along with honoring the current contractual commitments to our customers.

For us, good corporate citizenship includes maintaining our customers’ privacy, and as such, we are not at liberty to discuss individual client business.

As we move forward and consider new commitments, our decisions will continue to be guided by our evaluation process that takes into account current lending regulations as well as our business goals, values and obligations to our stakeholders.