Insider Trading Policy

First Community Bankshares, Inc.

Insider Trading Policy

OVERVIEW

This document sets forth the Policy of First Community Bankshares, Inc. (the "Corporation") regarding trading in the stock and other securities of the Corporation by Insiders (as defined below) and, where applicable, the disclosure of such transactions.

PURPOSE

The purpose of this Policy is to promote compliance with applicable securities laws by the Corporation and all directors, officers, and employees thereof, as well as the directors, officers, and employees of its subsidiaries, in order to preserve the reputation and integrity of the Corporation and all persons affiliated with the Corporation.

GENERAL OBJECTIVES

Reserved.

STATEMENT OF NEED AND DEFINITION

If a director, officer or any employee of the Corporation or subsidiary or any agent or advisor of the Corporation or subsidiary has Material, Nonpublic information relating to the Corporation, it is the Corporation's policy that neither that person nor any Related Person (as defined below) may buy or sell securities of the Corporation (the "Corporation Securities") or engage in any other action to take advantage of that information or enable others to do so. This Policy also applies to material, nonpublic information relating to any other corporation with publicly-traded securities, including customers or suppliers of the Corporation, obtained in the course of employment by or association with the Corporation.

SPECIFIC GOALS

Reserved.

POLICY ELEMENTS

Board of Directors Responsibilities

The Board of Directors of the Corporation (the "Board") shall have responsibility for final approval of this Policy and ensuring management has sufficient resources to carry out the directives of this Policy.

The Audit Compliance and Enterprise Risk Committee

The Audit Compliance and Enterprise Risk Committee ("ACER") shall recommend changes to this Policy to the Board, as necessary.

Specific Management or Employee Responsibilities

GENERAL COUNSEL

The General Counsel shall be responsible for the formation and implementation of this Policy and for providing reports on ongoing insider trading compliance matters, including any disciplinary actions, regarding the Policy to ACER, or the full Board of Directors, if

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requested, as necessary. General Counsel in consultation with the Chief Executive Officer and President may add or remove individuals from the attached lists as necessary.

INSIDER TRADING OFFICER

The General Counsel or their designee shall serve as the Insider Trading Officer. The Insider Trading Officer shall perform, or ensure performance of, the following:

• Pre-clearingall transactions involving Corporation Securities by Section 16 Insiders, and as otherwise necessary for other Insiders.
• Assisting, as requested, in the preparation and filing of Section 16 reports (Forms 3, 4 and 5) for all Section 16 Individuals, and other applicable reports (whether filed by the Corporation or the individual).
• Coordinating with the Corporation's designated recipient of copies of reports filed with the SEC by Section 16 Individuals under Section 16 of the Exchange Act and other reports required by applicable disclosure rules.
• Ensuring that the Corporation will be able to comply with any securities law disclosure rules, either currently in force or that may be adopted in the future, that apply to the Corporation and relate to insider transactions involving Corporation stock. Performing periodic cross-checks of available materials, which may include Forms 3, 4 and 5, Form 144, officers' and directors' questionnaires and reports received from the Corporation's stock administrator and transfer agent, to determine trading activity by officers, directors and others who have, or may have, access to material nonpublic information.
• Insuring that a current version of this Policy is available at all times on the Corporation's Investor Relations site.
• Circulating this Policy to all employees and directors of the Corporation, on an annual basis, ensuring that this Policy is provided to new employees, and otherwise ensuring that appropriate education of affected individuals is accomplished.
• Annually obtaining a signed acknowledgment of receipt of the Policy from all employees and directors and employees and directors of subsidiaries.
• Quarterly announcing the ending of regular blackout periods and identifying and notifying all Insiders subject to any special blackout periods of the same.

Definitions

INSIDER

Any person who possesses Material, Nonpublic information is considered an Insider as to that information. Insiders include Corporation and subsidiary directors, officers, employees, independent contractors and those persons in a special relationship with the Corporation, such as its auditors, consultants or attorneys. The definition of Insider is transaction specific; that is, an individual is an Insider with respect to each Material, Nonpublic item of which he or she is aware.

To avoid even the appearance of impropriety, additional restrictions on trading Corporation Securities apply to directors, executive officers, and certain employees who are assumed

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to regularly possess inside information (the "Designated Insiders"). These Designated Insiders are identified on Attachment A and must comply with the Designated Insiders Addendum to this Insider Trading Policy in addition to the general requirements contained in this Policy.

MATERIAL INFORMATION

The materiality of a fact depends on the circumstance. Accordingly, it is not possible to define all categories of Material information. However, information should be regarded as material if there is a substantial likelihood that a reasonable investor would consider it important in making a decision to buy, sell or hold a security or where the fact is likely to have a significant effect on the market price of the security. Material information can be positive or negative and can relate to virtually any aspect of a corporation's business or to any type of security - debt or equity.

While it may be difficult to determine whether particular information is material or not, there are some categories of information that are particularly sensitive and that should almost always be considered material. Examples include, but are not limited to:

• Unpublished financial results and projections (especially to the extent the Corporation's own expectations regarding its future financial results differ from analysts' expectations);
• News of a pending or proposed corporate transaction, such as a merger or acquisition;
• Significant changes in corporate objectives or policies;
• Gain or loss of a major customer or supplier;
• Major changes to product offerings;
• Changes in executive management;
• Significant changes in the Corporation's accountants or accounting policies; or
• Any major problems or successes of the business.

Again, the categories on this list are only to be used as examples. Many other types of information may be considered Material depending on the circumstances. If an Insider has any questions regarding whether information he or she possesses is material or not, that person should contact the Insider Trading Officer.

NONPUBLIC INFORMATION

Information about the Corporation is considered to be Nonpublic if it is known within the Corporation but not yet disclosed to the general public. In order for information to be considered public, it must be widely disseminated in a manner making it generally available to investors. The Corporation generally discloses information to the public either via press release or in the regular quarterly and annual reports that the Corporation is required to file with the SEC. The circulation of rumors, even if accurate and reported in the media, no matter how widespread, does not constitute effective public dissemination.

In addition, even after a public announcement of Material information, a reasonable period of time must elapse in order for the market to react to the information. Accordingly, this

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Policy generally requires that, for information to be considered "public," it must have been publicly available, through press release or otherwise, for at least two full trading days unless the Corporation sets and communications an alternative time period in certain instances. If an Insider has any questions regarding whether any information he or she possesses is Nonpublic, that person should contact the Insider Trading Officer.

RELATED PERSON

For purposes of this Policy, a Related Person is an Insider's spouse, minor children and anyone else living in their household; partnerships in which they are a general partner; closely held corporations and LLC's for which they are an officer, manager or member; trusts of which they are a trustee; estates of which they are an executor; and other equivalent legal entities that they control. Although an Insider's other family members, such as parents or siblings, are not automatically considered Related Persons (unless living in the same household), they may be a Tippee (as defined below) for securities laws purposes.

For purposes of this Policy, any transactions involving Corporation Securities in which Related Persons engage, or by family trusts, partnerships, foundations and similar entities over which Insiders or Related Parties have control, or whose assets held for the benefit of Insiders or Related Parties, are the same as transactions by the Insider. Insiders are responsible for making sure that such persons and entities do not engage in any transaction that would violate this Policy.

General Rules

The following are the general rules of the Corporation's Insider Trading Policy that apply to Insiders. Additional rules apply to Designated Insiders. It is very important that all directors, officers, and employees understand and follow these rules because any violation may subject the offender to disciplinary action by the Corporation (including termination of employment for cause) andcivil and criminal penalties, including fines and imprisonment. This Policy is intended to assist in complying with laws against insider trading; however, it is each individual's responsibility to comply with said laws and exercise appropriate judgment in connection with any trade in Corporation Securities.

NON-DISCLOSURE OF MATERIAL NONPUBLIC INFORMATION

Material, Nonpublic information must not be disclosed to anyone, except the persons within the Corporation or third-party agents of the Corporation (such as investment banking advisors and outside legal counsel) whose positions require them to know it, until such information has been publicly released by the Corporation.

PROHIBITED TRADING IN CORPORATION SECURITIES

No person may place a purchase or sell order or recommend that another person place a purchase or sell order in Corporation Securities (including initial elections, changes in elections or reallocation of funds relating to 401(k) plan accounts) when he or she has knowledge of Material, Nonpublic information concerning the Corporation. Loans,

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pledges, gifts, charitable donations and other contributions of Corporation Securities are also subject to this Policy.

TWENTY-TWENTY HINDSIGHT

If securities transactions ever become the subject of scrutiny, they are likely to be viewed after-the-fact with the benefit of hindsight. As a result, before engaging in any transaction an insider should carefully consider how his or her transaction may be construed in hindsight. Again, in the event of any questions or uncertainties about the Policy, please consult the Insider Trading Officer or someone that he or she has delegated responsibility for advising of the Policy.

"TIPPING" INFORMATION TO OTHERS

Insiders may be liable for communicating or tipping Material, Nonpublic information to any third party (a Tippee), not limited to just Related Persons. Further, insider trading violations are not limited to trading or tipping by Insiders. Persons other than Insiders also can be liable for insider trading, including Tippees who trade on Material, Nonpublic information tipped to them and individuals who trade on Material, Nonpublic information which has been misappropriated.

Tippees inherit an Insider's duties and are liable for trading on Material, Nonpublic information illegally tipped to them by an Insider. Similarly, just as Insiders are liable for the insider trading of their Tippees, so are Tippees who pass the information along to others who trade. In other words, a Tippee's liability for insider trading is no different from that of an Insider. Tippees can obtain Material, Nonpublic information by receiving overt tips from others or through, among other things, conversations at social, business or other gatherings.

AVOID SPECULATION

Insiders and their Related Persons should not engage in any transactions that suggest they are speculating in Corporation Securities (that is, trying to profit in short-term movements in the stock price). Accordingly, Insiders and their Related Persons may not trade in options, warrants, puts and calls or similar instruments on Corporation Securities or sell Corporation Securities "short," or "sell against the box." A short sale involves selling shares that an Insider does not own at a specified price with the expectation that the price will go down so that person may buy the shares at a lower price before he or she must deliver them. A sale against the box is a sale of securities that are owned but are not delivered within 20 days or deposited in the mail for delivery within 5 days after the sale. A sale against the box has the same effect as a short sale.

In addition, Insiders and their Related Persons may not hold Corporation Securities in margin accounts. Investing in Corporation Securities provides an opportunity to share in the future growth of the Corporation. Investment in the Corporation and sharing in the growth of the Corporation, however, does not mean short-range speculation based on fluctuations in the market. Such activities may put the personal gain of the Insider in conflict with the best interests of the Corporation and its stockholders. Anyone may, of