CenterState Bank : Code of Ethics and Business Conduct

1. Whether or not a conflict of interest exists or will exist can be unclear. Conflicts of interest should be avoided unless specifically authorized as described in Subsection 3.3.
2. Persons other than directors and executive officers who have questions about a potential conflict of interest or who become aware of an actual or potential conflict should discuss the matter with, and seek a determination and prior authorization or approval from, their supervisor or the Chief Risk Officer. A supervisor may not authorize or approve conflict of interest matters or make determinations as to whether a problematic conflict of interest exists without first providing the Chief Risk Officer with a written description of the activity and seeking the Chief Risk Officer's written approval. If the supervisor is himself involved in the potential or actual conflict, the matter should instead be discussed directly with the Chief Risk Officer.

Directors and executive officers (i.e., those officers of the Company who are considered executive officers under Section 16 of the Securities and Exchange Act of 1934)) must seek determinations and prior authorizations or approvals of potential conflicts of interest exclusively from the Audit Committee or Board of Directors.

4. Compliance

4.1 Employees, officers and directors should comply, both in letter and spirit, with all

applicable laws, rules and regulations in the cities, states and countries in which the Company operates.

4.2 Examples of activities prohibited by these laws include but are not limited to:

1. Soliciting or accepting any gifts or items of value (as defined in the Company's employee handbook) for purposes of influencing any business or transactions or receiving confidential information.
2. Structuring or attempting to structure a financial transaction to evade the currency transaction reporting or record-keeping requirements of the Bank Secrecy Act or otherwise violate any anti- money laundering laws or laws safeguarding against terrorist activity.
3. Stealing, embezzling or misapplying the Company's or a customer's funds or assets or committing any other dishonest or fraudulent act.
4. Using threats, physical force or other unauthorized means to collect money.
5. Gaining unauthorized access to customer records.
6. Making false statements or reports to government officials.
7. Submitting false reports or documents or recording false entries.
8. Using Company funds or assets to finance campaigns for political office.
9. Making a loan or giving a gift to an examiner who has the authority to examine the Company, including any of its subsidiaries.
10. Entering into any arrangements with competitors to fix or control prices or otherwise to restrain competition or trade.
11. Engaging in illegal tying arrangements.

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1. Although not all employees, officers and directors are expected to know the details of all applicable laws, rules and regulations, it is important to know enough to determine when to seek advice from appropriate personnel. Questions about compliance should be addressed to the Chief Risk Officer/General Counsel.
2. No director, officer or employee may purchase or sell any Company securities while in possession of material non-public information regarding the Company, nor may any director, officer or employee purchase or sell another company's securities while in possession of material non- public information regarding that company. It is against Company policies and illegal for any director, officer or employee to use material non- public information regarding the Company or any other company to:

(a) Obtain profit for himself or herself; or

(b) Directly or indirectly "tip" others who might make an investment decision on the basis of that information.

The Company maintains insider trading policies addressing when and how it is appropriate to trade in the securities of the Company, which include black-out periods, where trading is prohibited, and pre-clearance procedures for trading by Company officers and directors.

5. Disclosure

5.1 The Company's periodic reports and other documents filed with the SEC, including

all financial statements and other financial information, must comply with applicable federal securities laws and SEC rules.

1. Each director, officer and employee who contributes in any way to the preparation or verification of the Company's financial statements and other financial information must ensure that the Company's books, records and accounts are accurately maintained. Each director, officer and employee must cooperate fully with the Company's Accounting and Internal Audit Departments, as well as the Company's independent public accountants and legal counsel, and not to improperly influence or attempt to improperly influence, coerce, manipulate or mislead any accountant engaged in the preparation of the Company's financial statements or other financial information.
2. Each director, officer and employee who is involved in the Company's disclosure process must:
3. 1. be familiar with and comply with the Company's disclosure controls and procedures and its internal control over financial reporting; and
   2. take all necessary steps to ensure that all filings with the SEC and all other public communications about the financial and business condition of the Company provide full, fair, accurate, timely and understandable disclosure.

6. Corporate Opportunities

All directors, officers and employees owe a duty to the Company to advance its interests when the opportunity arises. Directors, officers and employees are prohibited from taking for themselves personally (or for the benefit of friends or family members) opportunities that are discovered through the use of Company assets, property, information or position. Directors, officers and employees may not use Company assets, property, information or position for personal gain (including gain of friends or family members). In addition, no director, officer or employee may compete with the Company.

7. Confidentiality

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Directors, officers and employees should strictly maintain the confidentiality of information entrusted to them by the Company or by its customers, suppliers or partners, except when disclosure is expressly authorized under law or the Company's privacy policy, or legally required. Confidential information includes all non-public customer information and all other non-public information (regardless of its source) in any form or medium, related directly or indirectly to, without limitation, business processes, methods, policies, plans, strategies, agreements, contracts, trade secrets, computer programs and applications, operating systems, customer lists, designs, work in process, procedures, manuals, records, systems, vendor information, financial information, accounting records, marketing information, pricing information payroll and staffing information, sales, of the Company or any of its subsidiaries or affiliates or customers, suppliers, investors or other third parties given in confidence, whether or not such information might be of use to the Company's competitors or harmful to the Company or its customers, suppliers or partners if disclosed.

These restrictions on confidentiality apply to confidential information received by officer or employees prior to their employment with the Company and continue after their employment with the Company ends in perpetuity.

8. Reporting and Enforcement.

8.1 Reporting and Investigation of Violations.

1. Actions prohibited by this Code involving directors or executive officers must be

reported to the Audit Committee.

1. Actions prohibited by this Code involving any other person must be reported to the reporting person's supervisor, the Director of HR and the Chief Risk Officer.
2. Reporting of any alleged or potential violation of this Code, or other laws or Company policy can be made through the Company's anonymous EthicsPoint hotline service, information about which is located on the Company's employee portal and in the employee handbook.
3. After receiving a report of an alleged prohibited action, the Audit Committee,

in the case of a director or executive officer, or the Director of HR, in the case of other employees or persons must promptly take all appropriate actions necessary to investigate the allegations and resolve the allegation, as more fully described in Company policy and procedure. The Chief Risk Officer and the Director of Internal Audit shall be advised of the allegations and the results of any investigation.

1. All directors, officers and employees are expected to cooperate in any internal investigation of misconduct.

8.2 Enforcement.

1. The Company must ensure prompt and consistent action against violations of this Code.
2. If, after investigating a report of an alleged prohibited action by a director or executive officer, the Audit Committee determines that a violation of this Code has occurred, the Audit Committee will report such determination to the Board of Directors.

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1. If, after investigating a report of an alleged prohibited action by any other person, the relevant supervisor or the Director of HR determines that a violation of this Code has occurred, the Director of HR will report such determination to the Audit Committee and provide a copy of such report to the Chief Risk Officer and the Director of Internal Audit.
2. Upon receipt of a determination that there has been a violation of this Code, the Board of Directors, in the case of a director or an executive officer, or the Director of HR, in the case of other employees, will take such preventative or disciplinary action as it deems appropriate, including, but not limited to, reassignment, demotion, or dismissal. In the event of criminal conduct or other serious violations of the law, the Company shall notify appropriate governmental authorities through the appropriate channels.
3. The Chief Risk Officer shall be responsible for tracking violations of this Code of Conduct by directors or executive officers, and the Director of HR shall be responsible for tracking violations of this Code of Conduct for other employees.

8.4 Prohibition on Retaliation.

The Company does not tolerate acts of retaliation against any director, officer or employee who makes a good faith report of known or suspected acts of misconduct or other violations of this Code. This means that the Company will not terminate, demote or discriminate again any person for reporting in good faith any suspected violations of this Code.

Revised and Reaffirmed: April 26, 2018

Approved: April 2019, April 2020

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