Credit Union National Association, INC. Code of Ethics

Credit Union National Association, Inc. (“CUNA”) is dedicated to upholding the highest ethical standards in conducting its business and in representing the interests of the credit union movement. By adopting the following Code of Ethics the Board of Directors accepts responsibility for complying with and enforcing the highest standards of conduct and principles of good corporate governance among its peers and among the officers of CUNA.

CUNA directors and officers are committed to carrying out their fiduciary duties of undivided loyalty, good faith and fair dealing in the conduct of the corporation’s business and to making informed decisions in the best interests of the corporation, consistent with the goals and mission of the corporation.

CUNA directors and officers will uphold the highest standards of honest and ethical conduct and avoid real or perceived conflicts of interest in their personal or professional relationships. No director or officer will use his or her official position for inappropriate personal gain.

CUNA directors and officers will comply with all applicable governmental rules and regulations, and with the corporation’s articles, bylaws and policies that are adopted from time to time by the Board of Directors.

All persons are to be treated fairly and with respect, regardless of such factors as race, religion, gender, disability, age or national origin. Directors and officers will conduct corporate business and will treat their colleagues with integrity, fairness, respect and confidentiality. Each director and officer will behave in a manner that will bring credit upon the corporation and maintain trust and confidence in the integrity of the corporation’s activities. Directors and officers will refrain from using profane, offensive or disrespectful language during any function or activity when representing the corporation or conducting the corporation’s business.

Directors and officers with financial reporting duties are expected to disclose financial information in a full, fair, accurate, timely and understandable manner in the financial statements and in public communications made by the corporation.

Directors of CUNA must notify the CUNA President and Chair if their status changes and they no longer meet the qualifications of director for the seat they occupy.

Any violation of the Code of Ethics should be reported to the General Counsel or the Ethics Committee, which will consider what action is appropriate to assure accountability for adherence to the Code.