Third-Party Service Provider Guidelines

Farm Credit Bank of Texas (FCBT or the Bank) is firmly committed to a culture of integrity and honesty and conducting business in a legal and ethical manner as set forth in our Code of Ethics. Accordingly, the Bank requires that its Third-Party Service Providers likewise conduct their businesses in an ethical manner and comply with the Bank’s Third-Party Provider Guidelines set forth herein.

The following Guidelines set minimum standards for ethical conduct for Third-Party Service Providers¹ (TPSPs) who do business with the Bank:

• Perform services on behalf of the Bank in an ethical manner, avoiding any activity that involves the appearance of impropriety.
• Disclose known Conflicts of Interest. A Conflict of Interest is a set of circumstances or appearance thereof where a person has a financial interest in a transaction, relationship, or activity that could or does actually affect (or has the appearance of affecting) that person’s ability to perform official duties and responsibilities in a totally impartial manner and in the best interest of the institution when viewed from the perspective of a reasonable person with knowledge of the relevant facts. TPSPs must disclose known Conflicts of Interest to the Bank’s Standards of Conduct Official via the Conflict of Interest Disclosure Form for Third-Party Service Providers.
• Protect any confidential or proprietary information that belongs to FCBT. This requires that TPSPs take appropriate steps to ensure that confidential and proprietary information is used only for purposes of performing services for the Bank and that only authorize personnel of the TPSP have access to such confidential or proprietary information.
• Implement and maintain, for the duration of the contractual relationship with the Bank, an information security program designed to protect against the inadvertent disclosure of, or unauthorized access to, confidential information in light of the services and work to be provided by the TPSP; immediately notify the Bank of any inadvertent disclosure of or unauthorized access to, Confidential information.
• Comply with all applicable laws, codes, and regulations in the jurisdictions in which the TPSPs operate.

FCBT expects its TPSPs to inform and educate their employees, officers, directors, agents, and subcontractors about these Guidelines.

TPSPs may contact the Bank’s Standards of Conduct Official at amanda.schaeffer@farmcreditbank.com or (512) 465-0575 to notify the Bank of any required notifications above. Additionally, TPSPs are expected to report any violations of these Guidelines, laws or regulations, or the Bank’s Code of Ethics or other policies either directly to the Bank at the contact information above or via FCBT’s anonymous Ethics Helpline, available at (844) 363-2084 or www.farmcreditbank.ethicspoint.com.

¹ Third-Party Service Providers include any person or entity that has entered into a business arrangement with the Association, by contract or otherwise, that could have a conflict of interest impacting their ability to impartially perform services in the best interests of the Association.