External Whistleblower Policy

November 9, 2017

1. Overview

The Federal Home Loan Bank of Cincinnati (FHLB) is committed to conducting its business with the highest degree of ethics and integrity and in compliance with all applicable laws and regulations, accounting standards, accounting controls and audit practices.

This Whistleblower Policy provides individuals other than FHLB employees with a means to communicate any incident or concern regarding the FHLB’s accounting, internal accounting control, and auditing practices (Questionable Accounting Matters).

2. Purpose

This policy sets forth procedures for the retention and treatment of all incidents or concerns reported to the FHLB by individuals other than FHLB employees.

3. Scope

A member institution, vendor or other individual (non-employee) engaged in business activity with the FHLB.

4. Definitions

Whistleblower - a person who exposes misconduct, alleged dishonest or illegal activity occurring in an organization.

Questionable Accounting Matters - conduct that appears to raise ethical or legal concerns in connection with the FHLB’s accounting, internal accounting controls, financial reporting or other auditing matters.

5. Roles and Responsibilities

The Audit Committee of the Board of Directors will oversee and interpret this policy, as well as, annually review and assess compliance. The Senior Vice President, Internal Audit is responsible for the administration of this policy.

6. Policy

A member institution, vendor or other individual (non-employee) is encouraged to report any incident or concern regarding a Questionable Accounting Matter, including, without limitation, the following:

• Fraud or deliberate error in the preparation, evaluation, review or audit of any FHLB financial statement;
• Fraud or deliberate error in the recording and maintaining of the FHLB’s financial records;
• Deficiencies in or noncompliance with, the FHLB’s internal accounting controls;
• Misrepresentations or false statements to or by a senior officer or accountant regarding a matter contained in the FHLB’s financial records, financial reports or audit reports;
• Deviation from full and fair reporting of the FHLB’s financial condition; or
• Securities fraud or violations of any rule or regulation of the Securities and Exchange Commission or any provision of federal law relating to fraud against stockholders.

Any individual who wishes to report an incident or concern regarding a Questionable Accounting Matter should contact EthicsPoint, a third-party provider specifically retained by the FHLB for confidential reporting purposes. EthicsPoint may be contacted at:

• Telephone: 888 – 323 – 8950
• Internet: www.ethicspoint.com

EthicsPoint will log the incident or concern and obtain as much specific information as possible from the individual, including names, dates, places and events which took place and the individual's perception of why the incident or concern may be a violation.

Upon receipt, EthicsPoint will notify the Audit Committee Chair that an incident or concern has been reported and the Chair will determine whether the matter is covered by this policy. If the matter is outside the scope of this policy, the Audit Committee may refer the incident or concern to Management for review and investigation as appropriate.

Additionally, EthicsPoint will send the reporting individual an acknowledgement of the reported incident and following review will notify the individual of the disposition of the incident.

The investigation of a report of a Questionable Accounting Matter is the responsibility of the Audit Committee. The Audit Committee may establish any procedures it deems necessary to properly investigate the reported incident or concern. Such procedures will be designed to conduct an adequate investigation and fulfill all legal requirements.

At its sole discretion, the Audit Committee may utilize appropriate FHLB staff to assist the Committee in investigating the reported incident or concern and may also hire legal counsel and other advisers.

Upon completion of its investigation, prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee.

7. Compliance and Enforcement

The Audit Committee will maintain a log of all incidents or concerns reported to EthicsPoint that documents their receipt, investigation and resolution of the incident. Copies of the log and any written complaint related to the incident or concern will be maintained for five years.

Notwithstanding the foregoing, the destruction of any documentation relating to a matter that is the subject of a known, contemplated or ongoing federal investigation or other official proceeding, or that is relevant to a Chapter 11 bankruptcy proceeding, is prohibited.

8. Exception to Policy

There are no exceptions to this policy.