V. EDUCATION AND TRAINING PROGRAMS TO ALERT EMPLOYEES AND OTHERS OF THEIR RESPONSIBILITIES

The Corporate Compliance Officer shall have general responsibility to oversee the development and implementation of education, training and communication programs to ensure compliance with the Corporate Compliance Plan by WNYIL Inc. directors, officers, council members employees, agents and representatives. The communication and training programs shall include the following areas:

A. New employee orientation to include coverage of ethics and legal compliance issues.

B. Department-specific training and educational programs in identified high-risk areas.

C. Annual review of ethics and legal compliance issues in departments at substantial risk and specific business practices.

D. A Code of Conduct, as set forth in Exhibit A to this Plan and as amended from time to time, which shall govern the proper conduct of WNYIL Inc. directors, officers, employees, agents and representatives. Employees shall be informed that strict compliance with both WNYIL Inc. Code of Conduct and the requirements of the Compliance Plan is a condition of employment, and that:

1. The promotion of and adherence to compliance with the Code of Conduct and the requirements of the Compliance Plan are elements of evaluating supervisors and managers; and

2. WNYIL Inc. has a policy not to employ or retain employees who are sanctioned for a violation of either the Code of Conduct or the requirements of the Compliance Plan.

E. Notice and education concerning the requirements of the federal laws summarized in Exhibit B hereto.