Ethics Information

Ethics Information

Ethics Hotline 1-866-293-2338

Anyone who is aware of potential fraud, unlawful actions or ethical misconduct related to AgriBank can submit their concerns anonymously and confidentially through a third party.

AgriBank is committed to the highest standards of ethics and integrity in all of our business operations and customer interactions. To this end, the AgriBank Audit Committee approved the use of EthicsPoint®, a product provided by third-party vendor NAVEX, as an anonymous and confidential reporting tool to report misconduct and concerns related to accounting, internal accounting controls, or auditing matters.

If you are aware of potential fraud, unlawful actions or ethical misconduct related to AgriBank, you can submit your concerns anonymously to EthicsPoint® by phone at 1-866-293-2338 or via their secured website at www.ethicspoint.com. Enter AgriBank as the organization name to begin submitting your issue or concern.

Submissions to EthicsPoint® are kept in confidence and investigated by a team that may include representation from the AgriBank Audit Committee. A person who makes a complaint or tip will not be subject to retaliation from AgriBank or its directors or employees.

AgriBank Code of Ethics

I. Overview

AgriBank, FCB (the Bank”) has adopted this code of ethical conduct (the “Code”) which is applicable to every Director, Officer, and Employee. The Code reaffirms the high standards of business conduct required of and provides guidance to the Bank and its Directors, Employees, and Agents.1

II. Objective

The Bank is committed to conducting business in accordance with the highest ethical standards as set forth in the Standards of Conduct Policy. Moreover, the Bank is responsible for preparation and distribution of its financial statements and related disclosures and for providing relevant information that is true, accurate and complete to the Funding Corporation for use in preparing the Farm Credit system financial statements and related disclosures.

Accordingly, the Bank expects all of its Directors, Employees, and Agents to maintain the highest standards of personal and professional integrity in all aspects of their business transactions and activities. This includes complying with all applicable laws, rules, and regulations, deterring wrongdoing and abiding by its Standards of Conduct Policy and other policies and procedures adopted by the Bank that govern the conduct of its Directors, Employees and Agents. To achieve these high ethical standards, all Directors, Employees, and Agents should, among other things, avoid conflicts of interests.

This Code is intended to supplement the Bank’s Standards of Conduct Policy.

III. Requirements

A. All Directors, Employees, and Agents. All Directors, Employees, and Agents are required to:

  1. Maintain high ethical standards, including high standards of honesty, integrity, and fairness.
  2. Act in the best interests of the institution.
  3. Preserve the reputation of the institution and the public’s confidence in the Farm Credit System.
  4. Exercise diligence and good business judgement in carrying out official duties and responsibilities.
  5. Identify and disclose to the Standards of Conduct Official any conflicts of interest and/or circumstances or transactions that have the appearance of creating a conflict of interest.
  6. Refrain from participating in official action or discussion on any matter if you have an actual or perceived conflict of interest.
  7. Work with the Standards of Conduct Official to identify conflicts and resolve reported conflicts of interest and appearances of conflicts of interest.
  8. Avoid self-dealing or acceptance of gifts or favors that may be deemed as offered, or have the appearance of being offered, to influence official actions or decisions.
  9. Comply with all applicable laws, rules, and regulations, as well as the rules and regulations of self-regulatory agreements to which the Bank is a party.
  10. Promptly report any possible illegal or unethical activity, or violation of the Standards of Conduct Policy and the Code to the Standards of Conduct Official or through the anonymous reporting procedures.
  11. Take all reasonable measures to protect the confidentiality of non-public information about the Bank and its customers obtained or created in connection with its activities and to prevent the unauthorized disclosure of this information unless required by applicable law or regulation, or legal or regulatory process.

B. Directors and Senior Officers. In addition, Directors and Senior Officers are required to produce full, fair, accurate, timely and understandable disclosures of Bank financial statements and related financial reports or communications as well as reports and documents filed with, or submitted to, Funding Bank and the Farm Credit Administration. Directors and Senior Officers are explicitly prohibited from taking any action to fraudulently, coerce, manipulate, or mislead the Bank’s independent public accountant for the purposes of rendering the Bank’s financial statements misleading.

IV. Policy Compliance

Each Director, Employee, and Agent is responsible for reading and understanding this policy, and conducting their activities and business transactions accordingly.

The Bank reserves the right to audit/monitor systems on a periodic basis to ensure compliance with this policy. Compliance may be measured through various means, including but not limited to business tool reports, internal and external audits, and feedback.

Any exception to this procedure must be submitted to, and approved by the Bank’s Standards of Conduct Official.

V. Violations of the Code of Ethics

All Directors, Employees, and Agents will be held accountable for adherence to this Code. A failure to observe the terms of this policy may result in disciplinary action, up to and including termination of employment or removal from the board of Directors, as applicable. Violations of the Code also constitute violations of law and may result in civil or criminal penalties.

If you have any questions regarding the best course of action in a particular situation, contact the Standard of Conduct Officer.

VI. Acknowledgement

Each Director, and Employee shall be required to sign a statement annually that he or she has read and understands this Code.

VII. Definitions

Agent: Any person, other than a Director or Employee of Bank, with the power to act for the institution either by contract or apparent authority and who currently either represents the Bank in contacts with third parties or provides professional or fiduciary services to the Bank.

Conflicts of Interest: A set of circumstances or the appearance thereof where a person has a financial interest in a transaction, relationship, or activity that could or does actually affect (or has the appearance of affecting) that person’s ability to perform official duties and responsibilities in a totally impartial manner and in the best interest of the Bank when viewed from the perspective of a reasonable person with knowledge of the relevant facts.

Employee: Any individual employed on a part-time, full-time, or temporary basis by the Bank, including those identified as Officers of the institution. However, persons not maintained on the institution’s payroll (i.e., independent contractors and temporary workers provided through temporary services agencies) are not Employees for purposes of this definition.

Senior Officer: The Chief Executive Officer, the Chief Financial Officer, the Chief Credit Officer, the Chief Risk and Information Officer, and the General Counsel, or persons in similar positions; and any other person responsible for a major policy-making function.

1The Code is intended to comply with FCA Regulation Part 612, Subpart A, including 12 C.F.R. § of 612.2137(c), and terms used herein are defined in 12 C.F.R. § 612.2130.