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Code of Conduct for Senior Officers

A. Introduction

This Code of Conduct for Senior Officers applies to the Bank’s President, Executive Vice President, and Senior Vice Presidents (“Senior Officers”).

The Code of Conduct for Senior Officers is in addition to the Code of Conduct for all employees set forth in the Bank’s Employee Handbook, which also applies to Senior Officers. To the extent the Code of Conduct for Senior Officers requires higher standards of conduct than the Code of Conduct for all employees, other Bank policies, or applicable laws, rules or regulations, the Senior Officers will adhere to these higher standards.

Senior Officers should direct questions about the application of the Code of Conduct for Senior Officers to the Bank’s General Counsel or Director of Human Resources.

The Bank may revise the Code of Conduct for Senior Officers without prior notice at any time.

B. Standards of Conduct

Senior Officers will adhere to the highest standards of honest and ethical conduct at all times in connection with their employment with the Bank.

C. Compliance with Laws, Rules and Regulations

The Bank and all Senior Officers will comply with all applicable laws, rules and regulations. Senior Officers are expected to understand the laws, rules and regulations that apply to the Bank and to their respective areas of responsibility and to seek relevant information or assistance as needed.

D. Conflicts of Interest

A conflict of interest may occur when a Senior Officer’s private interests interfere or appear to interfere with the interests of the Bank or the Senior Officer’s responsibilities to the Bank. Senior Officers must avoid private interests that give rise to conflicts of interest or apparent conflicts of interest in connection with their Bank responsibilities; that interfere with their ability to act in accordance with the interests of the Bank; or that limit their ability to meet their Bank responsibilities objectively and effectively.

A Senior Officer must disclose any situation that could reasonably be expected to give rise to a conflict of interest or an apparent conflict of interest on the part of that Senior Officer or any other Senior Officer by providing relevant information to the Bank’s General Counsel or Director of Human Resources. The General Counsel or Director of Human Resources will assist the Bank and the Senior Officer(s) in determining how to address the reported conflict of interest or apparent conflict of interest.

The Bank will handle all reported conflicts of interest and apparent conflicts of interest with discretion and will maintain the confidentiality of the reported matters to the extent possible, consistent with legal requirements and the Bank’s obligation to address the reported matters.

E. Bank Records and Disclosures

The Bank requires complete, accurate and reliable records to serve as the basis for the Bank’s financial reporting and disclosures. Senior Officers will take appropriate steps in accordance with their respective responsibilities to ensure that the Bank’s records are complete, accurate and reliable in all material respects.

The Bank requires full, fair, accurate, timely and understandable disclosure in reports and documents filed with or submitted to the Securities and Exchange Commission and in other public communications made by the Bank. Senior Officers will take appropriate steps in accordance with their respective responsibilities to ensure that these Bank disclosures are full, fair, accurate, timely and understandable, and are prepared in compliance with applicable laws, rules, regulations, and accounting principles.

F. Reporting Code of Conduct Violations

All Senior Officers have a duty to report any known or suspected violation of the Code of Conduct for Senior Officers, including any violation of applicable laws, rules, or regulations, to the Bank’s President, Executive Vice President, General Counsel or Director of Human Resources, who will address the suspected violation in accordance with the Bank’s Reported Concern Response Procedures (“Response Procedures”). If the Senior Officer believes reporting to one of these individuals is not appropriate under the circumstances or believes the response is not satisfactory, the Senior Officer must report the known or suspected violation to the Bank’s Director of Internal Audit or the Chairman of the Audit Committee of the Bank’s Board of Directors, who will address the suspected violation in accordance with the Response Procedures.

G. Investigation and Accountability

Upon receiving a report of a known or suspected violation of the Code of Conduct for Senior Officers, the Bank’s President, Executive Vice President, General Counsel or Director of Human Resources will (i) initiate an investigation of the matter on behalf of the Bank, and (ii) report the matter to the Director of Internal Audit. The Bank will take appropriate action based on the results of the investigation. A Senior Officer who violates the Code of Conduct for Senior Officers will be subject to appropriate disciplinary action, which may include termination of employment, as determined by the Bank.

December 2011