REPORTING ACCOUNTING, AUDITING OR POTENTIAL FRAUD CONCERNS
FHLBank is committed to sound corporate governance and aspires to conduct every aspect of its business in accordance with the highest ethical standards. To ensure FHLBank’s employees, officers, directors, consultants, vendors, contractors, outside agencies or other persons doing business with FHLBank operate in accordance with these ethical standards, FHLBank has adopted: (1) an Anti-Fraud Policy (which includes Whistleblower Procedures); and (2) a Code of Ethics. These policies establish the principles to ensure FHLBank maintains a legally compliant and highly ethical workplace.
FINANCIAL INSTRUMENT FRAUD REPORTING
FHLBank’s Anti-Fraud Policy not only addresses instances of fraud or possible fraud within FHLBank, but also includes financial instrument fraud or possible fraud detected in our dealings with our members and housing associates, Affordable Housing Program sponsors, vendors, counterparties, or any other third party with which the FHLBank does business. Financial Instrument Fraud includes fraud and possible fraud as it pertains to financial instruments and is defined as a misstatement, misrepresentation, or omission that cannot be corrected and that was relied upon by FHLBank to purchase or sell a loan or financial instrument. Federal Housing Finance Agency regulations place an affirmative duty on FHLBank to report suspected fraud when it is detected. FHLBank expects that any third party with which it does business will report to it any instances of suspected fraud involving FHLBank, whether it occurs inside or outside FHLBank. Such reports should be made via EthicsPoint, an independent service provider engaged by FHLBank, at www.ethicspoint.com or by calling toll-free, 866.294.4680.