Annual Report - CoBank

Code of EthicsCoBank, ACBCoBank sets high standards for honesty, ethics, integrity, impartiality and conduct. Each year, every associate certifiescompliance with the letter, intent and spirit of our Associate Responsibilities and Conduct Policy, which establishes the ethicalstandards of our organization, and each senior officer is required to disclose additional information. Additionally, our president andchief executive officer, chief operating officer, chief risk officer, chief credit officer, general counsel, chief financial officer and othersenior financial professionals certify compliance with the letter, intent and spirit of our Code of Ethics. Our Code of Ethicssupplements our Associate Responsibilities and Conduct Policy and establishes additional responsibilities specifically related to thepreparation and distribution of our financial statements and related disclosures. Details about our Code of Ethics are available atwww.cobank.com. At your request, we will provide you with a copy of our Code of Ethics, free of charge. Please contact:Corporate Communications DivisionP. O. Box 5110Denver, CO 80217(303) 740-4061CoBank 2011 Annual Report140