BANK MUTUAL CORPORATION 
CODE OF CONDUCT

II.     CONFIDENTIALITY OF INFORMATION

1 - Safeguarding Confidential Information
2 - Personal Use of Confidential Information - Strictly Prohibited
3 - Confidentiality of Information from Outsiders, Media, and Government Agencies
4 - Confidentiality of Security Systems
5 - Prevention of Violations
6 - Civil and Criminal Penalties

1. Safeguarding Confidential Information.

i. You shall safeguard confidential information. You shall not use confidential information for personal gain or to defraud or compete unfairly in the marketplace.

ii. You shall consider the following information to be confidential and proprietary:

a) Customer business plans, forecasts, decisions, and problems,

b) Examination reports,

c) Marketing surveys,

d) Lists of customers' names,

e) All information gained in the course of employment that is not publicly distributed, whether or not the information is obtained from a source doing business with Bank Mutual or from within Bank Mutual. NOTE: Any information that is not publicly available is considered to be confidential whether or not the information was explicitly identified as confidential,

f) All information available only by virtue of your position, and

g) All information concerning Bank Mutual and its customers.

iii. Except for routine responses to credit and personnel inquiries, you shall not release any customer information without -

a) The prior written approval by all persons listed in the records who have a right to expect Bank Mutual to safeguard the confidentiality of information, or

b) Upon valid service or legal process, such as a subpoena or court order. NOTE: You shall refer any such requests for confidential information to Bank Mutual's Vice President and Corporate Counsel.

iv. You shall not release any non-public financial information about Bank Mutual without prior written approval from Bank Mutual's Chief Financial Officer or Chief Executive Officer.

v. You shall secure all files and records of confidential information in a manner that ensures that information will remain confidential.

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2. Personal Use of Confidential Information - Strictly Prohibited.

i. Use of confidential information obtained as a result of your employment with Bank Mutual is strictly prohibited. You shall not use confidential and proprietary information for the purpose of furthering any private interest or for personal gain.

ii. You shall not use confidential and proprietary information for any other purpose including, without limitation:

a) Investment decisions, including any decision relating to Bank Mutual's stock,

b) Obtaining employment,

c) Obtaining any fee or payment, or

d) Any other personal financial gain.

iii. You shall not divulge confidential information to anyone except authorized persons who need to know.

iv. You shall not use confidential information in any manner except in the performance of your job duties.

v. You shall not discuss confidential information such as account balances, anticipated changes in the management or financial condition of Bank Mutual, or anticipated changes in the financial condition of a customer outside the normal and necessary course of your job function.

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3. Confidentiality of Information from Outsiders, Media, and Government Agencies.

You shall not divulge information about Bank Mutual or its customers to outsiders, media, or government agencies without prior approval from Bank Mutual's Chief Executive Officer.

In addition, Bank Mutual Corporation is a publicly-traded corporation whose stock trades on the Nasdaq Stock Market®. It is important that information about Bank Mutual reach the market in an orderly fashion. Therefore, no employee is authorized to make statements about Bank Mutual Corporation's business, finances or operation or the business of its subsidiaries to the news media or to any other outsider unless it is a specific part of your job duties or you are specifically authorized by an officer of Bank Mutual. You will comply with any policies relating to such disclosures which are from time to time adopted by the Board of Directors. If you have any questions about how you are authorized to make these statements, please ask the Chairman/CEO of Bank Mutual.

Although employees should not speak on behalf of Bank Mutual absent authorization, it is important that all of Bank Mutual's public statements, including its documents filed with or submitted to the SEC and other regulatory agencies, be complete and correct in all material respects. If you believe there are any inaccuracies in any statements made or documents filed by Bank Mutual, or believe that any of these statements or documents may not be complete or correct, we ask that you call any such matters to the attention of the Chief Executive Officer or the Chief Financial Officer of Bank Mutual Corporation. While submitting this information with your name will help Bank Mutual follow up on any concerns that you may have, you also may call any such matters to their attention anonymously. See also "Reporting a Discrepancy or Violation" below.

EXCEPTION: OSHA, EEOC and similar federal, state and local agencies have the right to speak with you on your own time or, with management's advance permission, on work time. You are free to speak with such agencies without fear of retaliation. However, we ask that you give us advance notice if you are contacted by such agencies. In addition, officers and other managers and supervisors are required to obtain advance approval from management before speaking with such agencies on behalf of Bank Mutual about any information they have in their role as an officer, manager or supervisor.

In addition, Bank Mutual will not take any negative action against you for any statement to any internal or external investigators, or appropriate regulatory, governmental or law-enforcement authorities, relating to violations of securities or anti-fraud laws. Bank Mutual will not retaliate if you provide truthful information about a federal offense to law enforcement officials.

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4. Confidentiality of Security Systems.

i. You shall not discuss or divulge any information concerning any portion of Bank Mutual's security system or program.

NOTE: If you reveal any such information, you will be subject to disciplinary action or dismissal.

ii. Supervisors and Department Managers - See Bank Mutual's Emergency Preparedness Policy 21 "Branch Security Program" for minimum security standards with respect to the installation, maintenance, and operation of security devices and procedures to discourage robberies, burglaries, and larcenies, and to assist in identifying and apprehending persons involved in such acts.

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5. Prevention of Violations.

i. Supervisors and Department Managers shall -

a. Review confidentiality and security procedures with their employees at least annually,

b. Question for understanding to ensure that employees understand the procedures,

c. Ensure that employees understand the confidentiality and security procedures,

d. Request each employee to sign a review acknowledgment and commitment.

ii. If a supervisor discovers that an employee has discussed or divulged any information concerning any portion of Bank Mutual's confidential information, products, services, or security program, the supervisor shall report such incident to the Human Resources Director. The Human Resources Director shall determine the appropriate disciplinary action up to and including dismissal.

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6. Civil and Criminal Penalties.

Use or disclosure of confidential or proprietary information can result in civil or criminal penalties for both you and Bank Mutual.

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Bank Mutual Corporation, August 2011