March 19, 2020

1. Overview

The FHLB Cincinnati (FHLB) will adopt the necessary Board Level policies in accordance with the regulatory requirements of the Federal Housing Finance Agency (the “Finance Agency”).

2. Objective

The objective of this policy is to promote honest and ethical conduct, proper disclosure of financial information in the FHLB’s financial reports and compliance with applicable laws, rules and regulations by the FHLB’s senior officers who have financial responsibilities.

3. Scope

This policy applies to the FHLB’s Senior Financial Officers. The policy addresses activities, roles and relationships and outlines requirements to assure the highest standards of honest and ethical conduct are being maintained, and conflicts of interest are being avoided.

4. Definitions

Senior Financial Officer means the President and Chief Executive Officer and any officer who holds a position at the Executive Vice President or Senior Vice President level.

5. Roles and responsibilities

1. The Board is responsible for the approval of this policy.
2. The Audit Committee is responsible for the interpretation and the assessment of compliance with the policy.
3. The First Vice President, Human Resources is responsible for administration of this Code and collecting the annual certifications from each of the Senior Financial Officers.

6. Policy

In performing his or her duties, each Senior Financial Officer must:

1. Maintain high standards of honest and ethical conduct and avoid any actual or apparent conflict of interest;
2. Report to the Audit Committee of the Board of Directors any conflict of interest that may arise and any material transaction or relationship that reasonably could be expected to give rise to a conflict.
3. Provide, or cause to be provided, full, fair, accurate, timely and understandable disclosure in reports and documents that the FHLB files with or submits to regulatory authorities and in other public communications.
4. Promptly bring to the attention of the Audit Committee any information he or she may have concerning (a) significant deficiencies in the design or operation of internal controls which could adversely affect the FHLB’s ability to record, process, summarize and report financial data or (b) any fraud, whether or not material, that involves management or other employees who have a significant role in the FHLB’s financial reporting, disclosures or internal controls;
5. Comply and take all reasonable actions to cause others to comply, with applicable governmental laws, rules and regulations;
6. Promptly report to the Audit Committee evidence of any material violation of any law, rule or regulation applicable to the FHLB by the FHLB or by any of its employees or agents; and
7. Promptly report violations of this Code to the Audit Committee.

7. Compliance and enforcement

Each Senior Financial Officer must annually certify compliance with the principles and practices established within this Code of Ethics. The First Vice President, Human Resources will maintain the signed certifications which may include electronic signatures within the learning management system and immediately notify the Audit Committee of any exclusions or exceptions within the certifications.

8. Exception to policy

Exceptions to the Policy may only be granted by the Audit Committee.

8.1 Policy Waiver

Any request for a waiver of any provision of this Code must be in writing and addressed to the Audit Committee. Any waiver of this Code will be disclosed promptly as required by applicable law.

8.2 Policy Violations

Violations of this policy should be reported to the Audit Committee. The Audit Committee will report material violations and recommend appropriate action to the Board.