MUNCY COLUMBIA FINANCIAL Corp

The board of directors has adopted a Code of Conduct and Ethics governing the senior executive officers of the Company and Journey Bank. The Code of Conduct and Ethics also applies to employees, agents and representatives, and establishes guidelines for professional conduct in the workplace, including fair dealing with others, the handling of conflicts of interest, compliance with applicable laws, rules and regulations, including federal and state securities laws, honesty in the preparation of the Company’s financial statements and public reports, reporting of violations of and accountability for adherence to the Code of Conduct and Ethics. Pursuant to the Sarbanes-Oxley Act of 2002, the Code of Conduct and Ethics contains a whistleblower provision for a person to report an actual or apparent violation of the Code of Conduct and Ethics, as well with respect to accounting and auditing matters, to the Audit Committee without fear of dismissal or retaliation of any kind. All reports or complaints under this whistleblower provision are kept in confidence. The Code of Conduct and Ethics is available on the Company’s websiteat https://ir.journeybank.com/governance/governance-documents/default.aspx.

Insider Trading Policy