Internal 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 controls and audit practices.
This Whistleblower Policy provides all employees with a means to communicate on a confidential and anonymous basis any incident or concern regarding the FHLB’s accounting, internal accounting controls, and auditing practices (Questionable Accounting Matters).

2. Purpose

This policy sets forth procedures for the retention and treatment of all incidents or concerns reported by FHLB staff.

3. Scope

All FHLB employees 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

FHLB employees are 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.

The FHLB is committed to providing a workplace conducive to open discussions of its business practices. All employees are encouraged to discuss an incident or concern with, or report evidence of a Questionable Accounting Matter to any Senior Officer or the Senior Vice President, Internal Audit who, after discussion, may be able to resolve the issue to the employee’s satisfaction.

However, should an employee feel uncomfortable discussing a Questionable Accounting Matter directly with a Senior Officer, the employee may report the incident or concern utilizing 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 employee’s report on an anonymous basis if the employee wishes. Employees are encouraged to provide as much specific information as possible, including names, dates, places and events which took place, the employee's perception of why the matter is questionable, and what action the employee recommends be taken.

Upon receipt, EthicsPoint will notify the Audit Committee Chair that an employee has reported an incident or concern, 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 it to Management for review and investigation as appropriate.

Additionally, EthicsPoint will privately post an acknowledgement of the reported incident and following review will privately post the disposition of the matter, as soon as reasonably practicable.

The investigation of an employee’s report of a Questionable Accounting Matter shall be 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 also be designed to protect the confidentiality of the employee to the fullest extent possible, consistent with the need 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 the investigation, prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee.

Any act of retaliation or reprisal against an FHLB employee who in good faith reports a Questionable Accounting Matter or who participates in or otherwise assists an investigation of a Questionable Accounting Matter will be considered a serious violation of this policy and will be subject to disciplinary action up to and including discharge from employment. Accordingly, an employee should immediately report any act of suspected retaliation, which will be promptly investigated and addressed.

Additionally, an FHLB employee may not be adversely affected because he or she refused to carry out a directive, which in fact, constitutes fraud or is a violation of state or federal law.

An FHLB employee shall not knowingly provide a false report of a Questionable Accounting Matter. Appropriate disciplinary action will be taken if it is determined that deliberately false statements have been made. However, complaints made in good faith even when erroneous are protected by law and this policy.

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. 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.