Annaly is committed to maintaining a strong ethical culture and robust governance practices that benefit the long-term interests of its stockholders. The Board has adopted Corporate Governance Guidelines that set forth the Company’s corporate governance guidelines and practices. The Corporate Governance Guidelines address, among other things, the composition and functions of the Board and its committees, director qualification and independence standards, Board leadership, procedures for reporting concerns to the Audit Committee, management evaluation and succession and Director compensation. The Board has also adopted the Code of Business Conduct, which is applicable to all directors, officers and employees of the Company and its external manager. The Code of Business Conduct confirms the Company’s policy to conduct our business in accordance with the highest ethical standards and in compliance with applicable governmental laws, rules and regulations.

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