Code of Ethics

In accordance with its Code of Ethics, FCE directors, officers, and employees must uphold high standards of personal and professional conduct and carry out their duties in an impartial manner. The Association is committed to conducting business in accordance with the highest ethical standards. Moreover, the Association is responsible for preparation and distribution of its financial statements and related disclosures and for providing relevant information that is true, accurate and complete for use in preparing the Farm Credit System financial statements and related disclosures.

Accordingly, the Association expects all of its directors, officers, and employees 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 the standards of conduct policies and procedures adopted by the Association that govern the conduct of its directors, officers, and employees. To achieve these high ethical standards, all directors, officers, and employees should, among other things, avoid conflicts of interest.

Above all else, FCE directors, officers, and employees expected to be honest and truthful. In very basic terms, if employees, officers, and directors tell the truth and are honest, all ethical standards can be easily met.

FCE’s Code of Ethics requires employees, officers, and directors to:

• Maintain high ethical standards, including high standards of honesty, integrity, and fairness.
• Act in the best interests of the institution.
• Preserve the reputation of the institution and the public’s confidence in the Farm Credit System.
• Exercise diligence and good business judgment in carrying out official duties and responsibilities.
• 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 involving the employee, director, or officer and their family or reportable business entity.
• Refrain from participating in official action or discussion on any matter involving an actual or perceived conflict of interest.
• Work with the Standards of Conduct Official to identify conflicts and resolve reported conflicts of interest and appearances of conflicts of interest.
• 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.
• Comply with all applicable laws, rules, and regulations, along with the Standards of Conduct Policy and related materials.
• Promptly report any possible illegal or unethical activity, or violation of the Standards of Conduct Policy and Code to the Standards of Conduct Official or through the anonymous reporting procedures.
• Fulfill fiduciary duties to the Association and its stockholders, as applicable.
• Take all reasonable measures to protect the confidentiality of non-public information about the Association 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.

In addition, directors and officers are required to produce full, fair, accurate, timely and understandable disclosures in Association reports and documents filed with, or submitted to, the Farm Credit Administration, in information provided to the Funding Corporation, and in other public communications made by the Association.

Each director, officer, and employee is responsible for reading and understanding FCE’s Code of Ethics and conducting their activities and business transactions accordingly. All directors, officers, and employees should understand that they will be held accountable for adherence to this Code of Ethics.  The Association reserves the right to audit/monitor systems on a periodic basis to ensure compliance with the Code of Ethics. Compliance may be measured through various means, including but not limited to business tool reports, internal and external audits, and feedback.

The failure to observe the terms of this Code of Ethics 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 of Ethics may also constitute violations of law and may result in civil and criminal penalties.

If you have any questions regarding the best course of action in a particular situation, the Standards of Conduct Officer should be promptly contacted.