Whistleblower Program

Purpose

It is the policy of AgWest Farm Credit that its operations are conducted according to the highest standard of integrity and that its officers, directors and employees observe high standards of business and personal ethics while conducting their duties and responsibilities. As representatives of AgWest, all applicable laws and regulations must be followed. Honesty and integrity must be practiced in fulfilling all responsibilities taken on behalf of AgWest.

The Whistleblower Program is intended to encourage and enable the reporting of concerns to prevent, detect and correct improper activities.

Scope

AgWest’s Whistleblower Program covers situations where any individual (the whistleblower) raises a concern about a risk or wrongdoing related to accounting, internal accounting controls, auditing matters, misconduct or fraud that affects stockholder-customers, employees, third-party agents or vendors of services, AgWest or the public interest.

Reporting

The AgWest Whistleblower Program is administered by the Chief Auditor and General Counsel and is overseen by the Audit Committee of the AgWest Board. A whistleblower may report a concern confidentially to Internal Audit or anonymously with an independent, third-party vendor – EthicsPoint.

To submit a report directly to Internal Audit, contact:
AgWest Internal Audit, Attn: M. Johnson
           3755 Atherton Rd     
          Rocklin, CA 95765

AgWest maintains the Ethics Point program as a confidential and anonymous vehicle for any and all whistleblowers to submit concerns and information.

EthicsPoint -Internet: http://www.ethicspoint.com
Or call toll-free (within the US): 1-866-295-3761
All reports will be treated with the highest degree of confidentiality

Protection for Whistleblower

Reprisal and retaliation for reporting of concerns or wrongdoing is prohibited by Federal laws and regulations.  However, action may be taken against an individual for knowingly making a false complaint or providing false information.