Code of Conduct

Hawaii National Bancshares, Inc. (the "Company") and Hawaii National Bank (the "Bank") depend upon the talents and efforts of their employees to serve their customers' banking needs in a totally proper and highly professional manner. The Company and the Bank intend to conduct their business by the highest ethical standards and to comply fully with all applicable laws and regulations. The Company's and the Bank's reputation for honesty, integrity and safety are perhaps their most valuable asset and are determined by their employees' conduct.

The Company and the Bank have an absolute duty to require the highest level of conduct and ethics of themselves and their employees. That duty shall extend not only to actual conduct but, also, to any act or activity which could be perceived by our shareholders, depositors, or the community as being inconsistent with the highest standards of professionalism and ethics.

It is not acceptable under any circumstances to further the Company's, the Bank's or one's own interests through any violation of law or regulation of the United States of America, the State of Hawaii, or any jurisdiction in which the Company or the Bank does business. To assure uniformity in standards of conduct, the Company and the Bank have established this Code of Conduct, Conflict of Interest and Prohibition Against Trading on Material Inside Information Policy ("Code"). This Code reaffirms and clarifies our basic policy that conflicts of interest are to be avoided, but should they occur, they will be quickly and satisfactorily corrected and otherwise resolved in such a manner so as to avoid any liability and injury to the reputation of the Company or the Bank. It applies to all employees, including officers, who are not subject to Regulation O, 12 CFR 215. Regulation O officers, directors, principal shareholders are covered under the Insider Activities Policy.

Each of us must manage our personal and business affairs to avoid situations that might lead to conflict (or even an appearance of conflict) between self-interest and responsibility to the businesses that employ us, or those that we serve, including their customers, the community and shareholders.

In situations involving ethical or moral judgments, it may be difficult to determine the correct course of action. In such instances, this Code requires that employees not rely solely on their own judgment, but discuss any such matter in full with their immediate supervisor. Full and accurate disclosure of the facts in a timely fashion in accordance with established procedures and obtaining written approval from the appropriate authority generally will serve to meet responsibilities with respect to this Code. Any matter specified herein as requiring Executive Management, Company or Management Committee approval is to be referred through normal supervisory channels.
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