© 2023 Fannie Mae 1

 Our Code 

of Conduct
© 2023 Fannie Mae 2

Table of Contents

A Message From 

the Chief Executive Officer 3

Mission and Values 4

Responsibility for Our Code 5

Ethical Decision-Making 5

Principle 1 

We Value and Respect Others 6

Diversity and Inclusion

Discrimination and Harassment

Responsible Business Practices

Principle 2 

We Foster a Productive, 

Healthy, and Safe Workplace 9

Workplace Safety

Prohibited Products

Principle 3 

We Are Honest and Trustworthy 12

Accurate Records and Reporting

External Communications and Social Media

Anti-Fraud

Principle 4 

We Obey the Law 16

Antitrust

Insider Trading

Anti-Bribery and Anti-Corruption

Principle 5 

We Protect Fannie Mae’s 

Corporate Assets 19

Intellectual Property 

and Confidential Information

Use of Corporate Assets 

Principle 6 

We Avoid Conflicts of Interest 22

Conflicts of Interest

Business Courtesies

Political Activities

Principle 7 

As People Managers, 

We Set the Standard 26

Principle 8 

We Follow Our Code and Policies 29

Principle 9 

We Raise Compliance 

and Ethics Concerns 31

Seeking Guidance 

and Reporting Misconduct

We Do Not Tolerate Retaliation 

Our Investigations Process 

A Message From the Chief 

Compliance & Ethics Officer 35

Contacting Compliance & Ethics 36

Contacting the Audit Committee 

of the Board of Directors

Waivers

Revisions
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© 2023 Fannie Mae

A Message From the 

Chief Executive Officer

Colleagues,

We have the privilege to use our unique role in the housing 

finance system to address social and economic challenges and 

make lasting change. From housing affordability and sustainability 

to racial equity to efficiency in and stability of the mortgage 

market, we can better the lives of millions of people.

To achieve these goals, we must maintain the highest level of 

integrity. When we see something that seems wrong — or even 

something that isn’t quite right — we should feel empowered 

to say something. When we discover an opportunity to make 

something better, we need to pursue it.

That is why our Code of Conduct is crucial. The Code epitomizes 

ethical decision-making, responsibility, and respect in all aspects 

of our interactions and operations. It is our shared obligation to 

know and uphold our Code. It helps us manage risk, supports a 

safe and sound housing system, and guides us to get things done 

the right way, no matter the circumstance. 

If you ever find yourself unsure whether a particular action or 

decision is consistent with our Code, just ask. We have dedicated 

resources available to help — including FM Ethics — and are 

committed to fostering an environment of psychological safety 

that encourages us all to speak up without fear of retaliation.

Thank you for living our values and committing to our Code.

Priscilla Almodovar

A Message From the Chief Executive Officer
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© 2023 Fannie Mae

We Listen

We invite all voices, 

encourage new thinking, 

and welcome courageous 

conversations.

We Lead

We lead the market with 

responsible innovation 

and act confidently to align 

our partners in the housing 

industry with our Mission 

to serve homeowners 

and renters.

In

v

e

stabilit y

Safet y

&

So

u

n

d

n

e

s

s

We Strengthen

We

Lis

t

e

n

W

e

L

e

a

d

VALUES

Homeowners & Renters

VALUES

To facilitate equitable 

and sustainable access 

to homeownership and 

quality affordable rental 

housing across America.

OUR MISSION

OUR VALUES

We Strengthen

We bring extraordinary care, 

strong ethical principles, 

and a relentless focus on 

anticipating and managing 

risks to ensure a safe and 

sound housing system. 

Mission 

and Values 

Mission and Values
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© 2023 Fannie Mae

Ethical 

Decision-Making

If you are faced with a difficult situation and do 

not know the right answer, use our Code as a 

roadmap. Our Code’s ethical decision-making 

chart can guide your decisions and ensure they 

are rooted in our Mission and Values. FM Ethics 

is also here to help.

Is the 

decision 

legal?

Does it 

comply with 

our Code?

Does it comply 

with our related 

corporate policies?

Does it align 

with our 

Mission and 

Values?

Are we 

leading by 

example?

Are we getting 

things done right?

How would 

it look?

Would the 

decision 

stand the 

test of time?

Are we being 

reasonable 

and honest?

Responsibility 

for Our Code

At Fannie Mae, there are several organizations 

and many individuals responsible for our 

Code of Conduct — the Board of Directors, 

the Management Committee, and Compliance 

& Ethics, among others — but ultimately, the 

responsibility for our Code lives within each 

of us. Our Code applies to all employees, 

including senior management and officers.

Fannie Mae’s Service Requirements for 

Consultants and Contractors functions as 

our Contingent Worker Code of Conduct. 

It sets forth the ethical requirements for 

Fannie Mae’s contingent workers.

While our Code cannot possibly cover every 

situation we may encounter, it outlines key 

responsibilities in critical areas to guide us. 

It also provides examples under each guiding 

principle of potential Code violations (Code 

Breakers) and potential issues that may arise 

(What Ifs). In many cases, our Code, policies, 

standards, procedures, and guidelines 

establish minimum standards for complying 

with federal and state laws and regulations. 

However, by focusing only on compliance 

with the law, we miss a much broader goal 

and benefit: As employees, we share a duty 

and the ability to make Fannie Mae a better 

place for all of us.

Annually, we renew our commitment to this 

shared responsibility.

Responsibility for Our Code and Ethical Decision-Making
© 2023 Fannie Mae 6

We Value and 

Respect Others

We recognize and value each individual’s unique skills and 

perspectives. We treat each other with dignity and respect. 

We perform according to the high standards set by Fannie 

Mae’s Mission and Values. We foster a workplace free of 

discrimination, harassment, and retaliation. We extend our 

respect for individuals and their contributions to all our business 

relationships — with employees, stakeholders, contingent 

workers, suppliers, and business partners. 

We demonstrate good corporate citizenship and are dedicated 

to creating positive environmental, social, and economic 

outcomes for families and communities through responsible 

mortgage finance.

We Value and Respect Others

01

PRINCIPLE

DEFINITIONS

Employment discrimination:

Treating a person differently 

or less favorably by failing to 

hire, terminating, or otherwise 

affecting their compensation, 

terms, conditions, or privileges of 

employment, based on any factor 

protected by applicable federal, 

state, or local law, such as race, 

religion, color, or sex.

Harassment:

Harassment must be based on a 

protected characteristic and must 

be unwelcome verbal, visual, or 

physical contact that is severe 

and pervasive and affects working 

conditions or creates a hostile work 

environment.
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© 2023 Fannie Mae

Diversity and Inclusion

• We build relationships and foster a sense of teamwork on 

all projects, within and across teams, and proactively create 

an inclusive environment where all team members can 

contribute, develop, and fully use their talents. 

• We treat others with fairness, dignity, and respect, regardless 

of function or level. 

• We support diversity and inclusion in all aspects of our 

business, including in our workforce, supply chains, 

and industry.

Discrimination and Harassment

• We do not tolerate discrimination, harassment, or 

retaliation based on race, color, religion, sex, national 

origin, disability, or disability status, genetic information, 

age, sexual orientation, gender identity/gender expression, 

marital or parental status, family responsibilities, political 

affiliation, personal appearance, matriculation, veteran 

status, system of social stratification, or any basis protected 

by applicable federal, state, or local law. 

• We are committed to preventing discrimination, harassment, 

and retaliation and to ensuring we provide equal 

employment opportunities for employees and applicants. 

• We speak up when we observe or experience harassing, 

discriminatory, or retaliatory behavior.

Responsible Business Practices

• We act with a commitment to driving positive impact, 

building a stronger, safer, and more resilient housing finance 

system that creates equitable, affordable, and sustainable 

housing opportunities for homebuyers and renters. 

• We continually seek ways to better understand and 

mitigate climate change-related risks while reducing the 

environmental footprint of our operations.

DEFINITIONS

Retaliation:

This may occur when an individual 

provides information and/or raises 

concerns about compliance with 

our Code or other laws, regulations, 

directives, and/or policies that apply 

to Fannie Mae (covered activity), and 

that individual is then subjected to 

adverse action because they engaged 

in that covered activity.

We Value and Respect Others

WHAT IF ...

My coworker regularly makes 

demeaning comments to others on 

the team?

We are expected to engage respectfully 

with others in the workplace. 

Disrespectful behavior includes 

behavior that may disrupt the 

workplace and can include being rude, 

discourteous, or impolite or making 

demeaning comments. This behavior 

can impact morale and workplace 

productivity. Though all rude and 

disrespectful behavior should be 

addressed, the behavior may not be 

so severe as to raise a Code or policy 

violation. Raising concerns directly to 

your colleague, to your management, 

or to Human Resources may be a right 

first step. If you think that the behavior 

raises a Code or policy concern, please 

contact FM Ethics for review.
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© 2023 Fannie Mae

• We do not tolerate modern-day slavery, including risks 

from servitude, prison labor, human trafficking, child labor, 

or other types of forced or compulsory labor or labor for 

unreasonable wages. We comply with child labor, forced 

labor, slavery, human trafficking, and equal pay laws and 

engage with business partners that do the same.

Principle 1

CODE BREAKERS

• Requesting sexual favors or repeatedly asking a person 

out; using offensive sexual innuendoes; making unwanted 

or offensive sexual advances toward or physical contact 

with another individual in the workplace or at a workrelated event.

• Making obscene, profane, or derogatory comments or 

stereotypes; posting, emailing, or otherwise sharing jokes, 

stories, or images based on sex, race, national origin, or 

other characteristics identified in our policies, standards, 

or procedures.

• Asking a job applicant or an employee questions about 

their age, disability, marital status, and/or childrearing 

responsibilities that do not relate to their ability to 

perform the job.

We Value and Respect Others

WHAT IF ...

My manager gives me critical 

feedback that I don’t agree with?

If you believe the critical feedback 

raises a Code or policy violation, 

contact FM Ethics. Otherwise, you 

should consider engaging with your 

manager to review the feedback 

and discuss your perspective. If you 

are uncomfortable initiating that 

conversation, you should contact 

Human Resources, who can work with 

you on how to begin the conversation. 

While you may not always agree 

with your manager’s feedback, they 

ultimately assess your performance, 

so it is important that you work to 

meet their expectations.

My colleague sent our team a meme 

via the Teams chat that they thought 

was funny but seems racially 

insensitive?

Behavior such as this can impact 

morale and workplace productivity. 

Exercise caution in sending nonwork-related jokes and images in the 

workplace. Your colleagues do not 

all have the same sense of humor, 

and certain material can be viewed 

as disrespectful and potentially 

discriminatory. This behavior may 

also be so severe as to raise a Code 

or policy concern. Raise this concern 

with a People Manager, Human 

Resources, or FM Ethics so that it 

may be addressed promptly. SEE ALSO ...

• Equal Opportunity in Employment 

and Contracting Statement

• Employee Handbook — Equal 

Employment Opportunity (EEO) 

Non-Discrimination

• Employee Handbook — Employee 

Resource Groups

• Employee Handbook — Prohibition 

on Modern-Day Slavery

• Employee Handbook — Prevention 

of Sexual and Other Prohibited 

Harassment

• Employee Handbook — Standards 

of Professional Behavior

• Employment Policy

• Non-Retaliation Policy
© 2023 Fannie Mae 9

We Foster a Productive, 

Healthy, and Safe 

Workplace

At Fannie Mae, we are committed to fostering a productive, 

healthy, and safe workplace and encourage the same no matter 

the location in which we work. We know and comply with our 

policies, standards, and procedures to support our efforts 

related to health and safety. We design and maintain facilities to 

protect our employees, contingent workers, visitors, and physical 

resources, and we maintain a workplace that is free from the 

effects of drug and alcohol abuse. 

PRINCIPLE We Foster a Productive, Healthy, and Safe Workplace

02

PRINCIPLE
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© 2023 Fannie Mae

Workplace Safety

• We create and maintain a safe working environment 

wherever we work, and we observe safety regulations and 

exercise good judgment.

• We foster an environment that is free from threats of violence, 

intimidation, physical altercation, or destruction of property 

and speak up when we observe such behavior by others.

• We take appropriate steps to prevent accidents and eliminate 

hazards likely to cause accidents. 

Prohibited Products

• We understand that being under the influence of illegal drugs 

or alcohol on the job poses serious safety and health risks. 

• We do not work while under the influence of alcohol or while 

engaged in substance abuse, including illegal substances 

or controlled substances not taken in accordance with the 

dosage prescribed for our individual use.

• Fannie Mae prohibits the use of smoking products on 

its campuses. 

We Foster a Productive, Healthy, and Safe Workplace

WHAT IF ...

I think my coworker is behaving in 

a threatening manner?

You should immediately notify 

your manager, Human Resources, 

FM Ethics, or Workplace Safety 

and Security. If you believe that 

a threat is immediate, call 911.

My direct report appears to be 

working while under the influence 

of alcohol, including slurring 

their words?

Working while under the influence 

of alcohol poses serious safety and 

health risks to the user and those 

around them. It is prohibited at 

Fannie Mae and employees are 

expected to perform their job duties 

free from the influence of alcohol 

and illegal drugs. Employees are 

responsible for seeking assistance 

before substance abuse or alcohol 

misuse affects performance or causes 

other problems, and they may use 

the Employee Assistance Program 

(EAP) confidentially. If you believe a 

colleague or direct report is working 

under the influence, contact Human 

Resources or FM Ethics.

DEFINITIONS

Smoking products:

Any products that are smoked, 

vaped, or inhaled, including, but not 

limited to, marijuana, tobacco, cloves, 

cigarettes, bidis, kreteks, e-cigarettes, 

vapes, cigars, pipes, and hookahs.
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© 2023 Fannie Mae

We Foster a Productive, Healthy, and Safe Workplace

Principle 2

CODE BREAKERS

• Failing to report an unsafe work condition.

• Possessing any kind of weapon in Fannie Mae workspaces, 

unless such possession is supported by the express written 

consent of Fannie Mae.

• Possessing any kind of weapon while on other Fannie Mae 

premises (such as parking lots), unless such possession 

is supported by the express written consent of Fannie Mae 

or otherwise permitted by federal, state, or local law.

• Engaging in conduct that is commonly considered to be 

threatening and/or violent or that could incite, provoke, 

or lead to violence. 

SEE ALSO ...

• Employee Handbook — Alcoholic 

Beverages and Prohibited Products 

• Employee Handbook — Prevention 

of Sexual and Other Prohibited 

Harassment 

• Employee Handbook — Standards 

of Professional Behavior

• Employee Handbook — Substance 

Abuse

• Employee Handbook — Suspicious 

Packages 

• Employee Handbook — Workplace 

Non-Violence 

• Employment Policy 

• Enterprise Workplace Safety and 

Security Policy
© 2023 Fannie Mae 12

We Are Honest 

and Trustworthy

We treat one another, our stakeholders, business partners, 

suppliers, and regulators respectfully and in a straightforward 

manner. We protect the integrity of Fannie Mae’s transactions 

and ensure that all corporate records are accurate and complete. 

We are committed to exemplary financial and regulatory 

reporting. We support the company’s commitment to make 

disclosures to the public that contain full, fair, accurate, timely, 

and understandable communications. We cooperate with internal 

and external auditors and regulators.

PRINCIPLE We Are Honest and Trustworthy

03

PRINCIPLE

DEFINITIONS

Records:

Any recorded information having 

business value and maintained 

in connection with Fannie Mae’s 

business, whether generated 

internally or externally. 
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© 2023 Fannie Mae

Accurate Records and Reporting

• We are committed to reflecting transactions properly and 

accurately in all financial statements, books, or records. 

This includes compliance with applicable accounting rules, 

principles, and standards. 

• We comply with internal accounting, operational, and 

disclosure controls and procedures.

• We ensure that we are familiar with professional ethics, 

regulatory requirements, and internal procedures that affect 

or govern our work or that of our business units.

• We prepare public communications in compliance with 

Fannie Mae’s policies, standards, and procedures.

• We retain records in accordance with sound business 

practices, Fannie Mae’s policies, and applicable legal and 

regulatory requirements. 

External Communications and Social Media

• When we use social media internally or externally relating to 

Fannie Mae, we are respectful, and we do not use hateful, bigoted, 

defamatory, threatening, offensive, or obscene language. 

• We are truthful and transparent and do not mislead when 

we use social media internally or externally relating to 

Fannie Mae. We disclose our relationship with Fannie Mae 

when referencing Fannie Mae in social media.

• We protect the confidential information of Fannie Mae and its 

business partners when we communicate externally. If we have 

a question as to whether information is confidential, we ask.

• We seek approval from Marketing & Communications before 

we engage in any external speaking engagements on behalf 

of Fannie Mae, including with the public, the media, external 

parties, and government officials.

• Fannie Mae employees are prohibited from lobbying. We must 

provide notice or seek pre-approval from the Federal Housing 

Finance Agency (FHFA) for certain communications with 

government officials or agencies and the media.

DEFINITIONS

Confidential information:

Information, data, or technology 

relating to Fannie Mae’s products, 

services, business, personnel, or 

commercial activities that is not 

generally known to the public and:

• Derives actual or potential 

economic value from not being 

generally known; or

• Is of such character that Fannie 

Mae has a legitimate interest in 

maintaining its secrecy; or

• The unauthorized disclosure of 

which could be detrimental to the 

interests of Fannie Mae; or

• The unauthorized disclosure of 

which violates federal or state legal 

and regulatory requirements. 

We Are Honest and Trustworthy
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© 2023 Fannie Mae

Anti-Fraud

• We are truthful and transparent in all dealings. We deal fairly 

and do not take unfair advantage of others.

• We record time and expense reports accurately.

• We are aware and alert to the types of fraud that relate to our 

business dealings and take time to review items that are not 

accurate or do not make sense.

• We practice diligent oversight of suppliers and third parties.

• We work to prevent people and/or entities from using Fannie 

Mae’s products and services for money laundering or for the 

funding of terrorist or criminal activities.

• We do not engage in business transactions with parties on 

FHFA’s Suspended Counterparty List or on the U.S. Treasury 

Department’s Office of Foreign Asset Control (OFAC) 

sanctions lists.

• We report possible fraud or other suspicious activity.

We Are Honest and Trustworthy

WHAT IF ...

I want to share Fannie Mae’s social 

media content on my personal 

external social networking sites?

Employees are permitted to 

responsibly and generically share 

content through social networking 

that Fannie Mae publishes on social 

media, such as reposting Fannie 

Mae social media content or “liking” 

Fannie Mae posts. Be sure to follow 

the Social Media Use guidelines and 

never share or post Fannie Mae 

confidential information externally. 

I work on REO sales and notice that 

a purchaser attempted to transmit 

funds using several different wires 

from multiple financial institutions?

This behavior could be indicative of 

an effort to disguise criminal activity. 

If you are not aware of a reasonable 

explanation for the behavior, 

you should contact FM Ethics to 

discuss further.

I enjoy using Yammer and Teams 

chats. What rules apply?

Your conduct while using these 

platforms even internally can 

reflect on Fannie Mae. While using 

Teams, Yammer, and other internal 

messaging, you must avoid creating 

reputational concerns for the 

company and must comply with 

our Code and align with the Social 

Media Use guidelines. Be respectful, 

truthful, and transparent when 

communicating through these 

internal platforms. Also do not share 

Fannie Mae confidential information 

classified as restricted or highly 

restricted through broadly viewed 

internal channels.
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© 2023 Fannie Mae

SEE ALSO ...

• Anti-Money Laundering and Office 

of Foreign Assets Control Sanctions 

Compliance Policy

• Confidential Information 

and Privacy Policy 

• Disclosure Controls 

and Procedures Policy 

• Employee Expense 

Reimbursement Policy 

• Employee Handbook — Social 

Media Use 

• Employee Handbook — Verification 

of Employment and Employment 

References 

• Government and Industry 

Relations External Communications 

Standards for Enterprises in 

Conservatorship Policy

• Fraud Risk Management Policy

• Marketing & Communications Policy 

• Records and Information 

Management Policy

We Are Honest and Trustworthy

Principle 3

CODE BREAKERS

• Taking unfair advantage of others through manipulation, 

concealment, abuse of privileged or confidential 

information, or misrepresentation.

• Making false, misleading, or inaccurate statements or 

entries in our financial statements, trading records, books, 

or records, including failing to record or disclose an asset 

or liability, in order to deceive others.

• Making false or misleading statements about Fannie Mae 

to a regulator, auditor, or other government official in 

order to deceive.

• Communicating on behalf of Fannie Mae to the media 

without proper authorization. 

• Falsifying any expense reports, receipts, or time sheets.

• Destroying documents improperly or discarding records

prior to the expiration of the applicable retention period. 
© 2023 Fannie Mae 16

We Obey the Law

At Fannie Mae, we obey the letter and spirit of all laws and 

regulations in every area in which we do business, including 

antitrust, anti-money laundering, anti-bribery, anti-corruption, 

fair housing and fair lending, sanctions, wage and hour, privacy, 

information security, environmental laws, and laws that address 

child labor, forced labor, slavery, human trafficking, equal pay, equal 

employment opportunity, and occupational health and safety. 

We conduct our interactions with the government according 

to the highest ethical standards. We participate in government 

investigations, and we immediately inform Legal or Compliance 

& Ethics if we are contacted by a government official regarding 

an inquiry or proceeding concerning Fannie Mae. We ensure 

compliance with all contract provisions. We obey the regulations 

that govern Fannie Mae’s participation in the political process.

PRINCIPLE We Obey the Law

04

PRINCIPLE
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© 2023 Fannie Mae

Antitrust

• We compete fairly, ethically, and based on the merits of 

our products and customer service and do not abuse our 

position in the market.

• We do not enter into unlawful agreements with competitors 

to fix prices or the terms or conditions of purchase or sale, 

divide markets or business partners, or boycott businesses.

• We make decisions independently based on reasonable 

business judgments. 

Insider Trading

• We do not trade securities of any company when we have 

material, nonpublic information about the company or 

the securities.

• We follow other Insider Trading Policy restrictions, including 

not trading outside of trading windows and avoiding shortterm or hedging transactions in Fannie Mae securities.

• We ensure these same restrictions are followed by our 

spouses or partners, family members residing with us or 

dependent on us, and our household members, as well as 

brokers and others acting on our behalf.

• We do not “tip” anyone else to trade or share material, 

nonpublic information about Fannie Mae or other 

companies, without a legitimate business purpose or 

with anyone who is not authorized to receive it.

Anti-Bribery and Anti-Corruption

• We do not offer or accept bribes, kickbacks, or illegal 

payments in our business dealings. We expect our employees 

and our business partners to comply with all anti-bribery 

and anti-corruption laws where we and our business 

partners operate. 

We Obey the Law

DEFINITIONS

Material, nonpublic information:

Information is “material, nonpublic 

information” if: (1) either (a) there 

is a substantial likelihood that a 

reasonable investor would consider 

it important in deciding whether 

to buy, sell, or hold a security or 

(b) a reasonable investor would 

view the information as significantly 

altering the total mix of information 

available; and (2) the information 

has not been broadly disseminated 

to the investing public.

Insider trading:

Buying, selling, or otherwise trading 

in securities while aware of material 

information that is not generally 

known or publicly available.
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© 2023 Fannie Mae

We Obey the Law

Principle 4

CODE BREAKERS

• Making false or misleading statements to the Federal 

Housing Finance Agency, Department of the Treasury, 

Department of Housing and Urban Development, 

Securities and Exchange Commission, or other regulators.

• Making false or misleading statements about Fannie Mae 

or our competitors, suppliers, business partners, 

or employees.

• Agreeing to allocate market share with a competitor or 

group of competitors.

• Buying or selling stock of Fannie Mae or another company 

after hearing about or seeing material, nonpublic 

information.

• Failing to report a suspicious transaction involving 

Fannie Mae’s products or services.

• Offering, promising, paying, or giving anything of value — 

directly or indirectly — either to a government employee 

or official or to a foreign official, foreign political party, 

party official, candidate, or their staff in a manner 

inconsistent with applicable law or policy.

SEE ALSO ...

• Anti-Money Laundering and Office 

of Foreign Assets Control Sanctions 

Compliance Policy 

• Antitrust and Fair Competition Policy

• Enterprise Compliance Policy 

• Insider Trading Policy 

• Employee Handbook — Prohibition 

on Modern-Day Slavery

• Employee Handbook — Political 

Activities

WHAT IF ...

I didn’t realize I was not supposed to 

buy Fannie Mae stock. Should I sell it?

No. Employees are prohibited from 

buying and selling Fannie Mae 

stock except during announced 

trading windows and at times 

when they are not in possession 

of material, nonpublic information. 

You must contact FM Ethics 

immediately and prior to engaging 

in any further transactions to discuss 

appropriate steps.

My spouse handles all of our trades 

and just informed me this morning 

that she bought Fannie Mae stock 

two months ago?

Employees, as well as their spouses 

or partners, household and family 

members residing with or dependent 

on them, and brokers and others 

acting on their behalf, are prohibited 

from buying and selling Fannie Mae 

stock except during announced 

trading windows. Contact FM Ethics 

immediately and prior to engaging 

in any further transactions to discuss 

appropriate steps.

I was invited to participate in a 

housing industry roundtable with 

a variety of participants to discuss 

topics that could include pricing 

policies or commercial terms?

Any discussions by a Fannie Mae 

employee regarding nonpublic, 

commercially sensitive topics that 

could involve competitors can 

have antitrust implications. Before 

engaging in such a discussion, 

contact the Legal Department or FM 

Ethics immediately so that they may 

examine the situation, provide advice 

on what topics are prohibited, and 

discuss how to navigate the situation.
© 2023 Fannie Mae 19

We Protect Fannie Mae’s Corporate Assets

We Protect Fannie Mae’s 

Corporate Assets

We are careful stewards of Fannie Mae’s corporate assets. We have 

a responsibility to protect these assets from loss, damage, misuse, 

and theft. We can be counted on to safeguard both Fannie Mae’s 

physical assets and its intangible assets, such as its confidential 

information, intellectual property, name, and reputation. 

We also respect the property and privacy of others.

Intellectual Property and Confidential Information

• We protect Fannie Mae’s intangible assets — even after our 

employment ends.

• We respect the intellectual property rights of others, including 

those of our competitors, suppliers, and business partners.

DEFINITIONS

Intangible assets: 

Non-tangible assets used by Fannie 

Mae to conduct business and preserve 

its competitive advantage, such 

as Fannie Mae’s brand, goodwill, 

proprietary information, data, models, 

and intellectual property rights, such 

as copyright, trademark, trade secrets, 

and patent rights.

Confidential information:

Information, data, or technology 

relating to Fannie Mae’s products, 

services, business, personnel, or 

commercial activities that is not 

generally known to the public and:

• Derives actual or potential 

economic value from not being 

generally known; or

05

PRINCIPLE

continues on page 20
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© 2023 Fannie Mae

• We protect the confidentiality, security, and integrity of 

the personal information of others, such as nonpublic 

personal information about fellow employees, business 

partners, and individual borrowers.

• We understand that Fannie Mae owns, and we assign to 

Fannie Mae, any intellectual property rights that we may 

have in any work products and innovations that relate to 

Fannie Mae’s business that are made or conceived during 

the course of our employment with Fannie Mae. 

Use of Corporate Assets 

• If we observe someone using company resources for an 

improper purpose or in an illicit manner, we report the 

behavior. 

• If we have personal needs that require using Fannie Mae’s 

assets or technology resources, we make limited use of 

those resources. 

• We understand that there is no right to privacy when using 

Fannie Mae’s assets and that Fannie Mae reserves the right 

to monitor our use, make use of anything found, and 

disclose any wrongdoing that it uncovers.

• Is of such character that Fannie 

Mae has a legitimate interest in 

maintaining its secrecy; or

• The unauthorized disclosure of 

which could be detrimental to the 

interests of Fannie Mae; or

• The unauthorized disclosure of 

which violates federal or state legal 

and regulatory requirements.

Intellectual property: 

Copyrightable works, ideas, 

discoveries, inventions, trade secrets, 

and trademarks. Such property 

includes, but is not limited to, written 

documents, sound or video recordings, 

software, business methods, marks, 

slogans, and confidential information. 

Personal information: 

Any information relating to an 

identified or identifiable person. 

An identifiable person is an individual 

who can be identified, directly 

or indirectly, by reference to an 

identification number or factors 

specific to their physical, mental, 

economic, financial, or cultural 

identity. All personal information is 

confidential information. Data that 

is de-identified is not personal 

information.

Nonpublic personal information (NPI): 

Personal information that is personally 

identified or identifiable and not 

publicly available and warrants 

protection due to legal, regulatory, or 

contractual obligations. The following 

information is always considered NPI: 

Social Security number, driver’s license 

number, financial account number 

(e.g., bank account number), credit 

card number, and passport number.

We Protect Fannie Mae’s Corporate Assets

© 2023 Fannie Mae

continued from page 19
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© 2023 Fannie Mae

WHAT IF ...

I am retiring and want to take my 

favorite work accomplishments 

as mementos?

While you should be proud of your

 work, your contributions to Fannie 

Mae’s documents, innovations, 

and other intangible assets are 

Fannie Mae’s intellectual property 

and are not yours. You may not take 

Fannie Mae consumer information, 

confidential information, or 

intellectual property with you.

I am away from my Fannie Mae 

computer and need to text 

my manager about a critical 

work matter?

Employees have access to 

Fannie Mae-approved remote 

access and connectivity applications 

to perform certain work functions 

on their personal devices. You 

should use these applications to 

communicate with your manager 

when you are unable to use your 

computer. You may also call your 

manager by telephone. You may 

only send convenience texts, 

IMs, or email messages on 

non-Fannie Mae applications 

if they are strictly limited to 

confirming whereabouts or other 

practical and non-confidential 

information of a similar nature. 

We Protect Fannie Mae’s Corporate Assets

• Distributing any Fannie Mae confidential information

to an unauthorized third party, to a social media outlet, 

or to our personal email accounts or failing to protect 

such information in hard or electronic copy no matter 

our work location.

• Not protecting the nonpublic personal information (NPI)

of our business partners and Fannie Mae employees, 

including emailing unencrypted NPI labeled restricted, 

consumer data, and confidential – highly restricted 

information to external parties (including personal 

email systems).

• Using access credentials without proper authorization.

• Installing any unauthorized hardware or software that 

circumvents Fannie Mae security controls.

• Destructing or defacing Fannie Mae physical assets 

or property. 

Principle 5

CODE BREAKERS

SEE ALSO ...

• Confidential Information and 

Privacy Policy 

• Conflict of Interest Policy 

• Employee Handbook — Social 

Media Use

• Employee Handbook — Employee 

Information and Records

• Employee Handbook — International 

Telework

• Employee Handbook — Bring Your 

Own Device (BYOD)

• Employee Handbook — Termination 

of Employment

• Employment Policy 

• Information Security Policy

• Marketing & Communications Policy

• Technology Use Standard
© 2023 Fannie Mae 22

We Avoid Conflicts 

of Interest

We make business decisions based on the best interests of 

Fannie Mae. We also look at our decisions from the perspective 

of others — our investors, our business partners, and the 

communities we serve — to ensure that our actions are in line 

with our Mission and Values. While we strive to lead the market 

and serve our business partners, we seek to avoid any actual 

conflict; any potential conflict; the appearance of a conflict 

between Fannie Mae’s business interests and our personal 

interests, activities, and relationships; or a situation that could 

expose the company to reputational risk. We only offer and 

accept appropriate business courtesies to and from our business 

partners and government employees.

PRINCIPLE We Avoid Conflicts of Interest

06

PRINCIPLE

DEFINITIONS

Actual Conflict of Interest:

Where an employee has an interest, 

activity, or relationship and has 

the ability to make, recommend, 

or influence Fannie Mae business 

decisions that might impact that 

interest, activity, or relationship or 

the interest, activity, or relationship 

may materially interfere with their 

ability to perform their Fannie Mae 

job responsibilities.
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Conflicts of Interest

• We understand that there may be interests, activities, and 

relationships that we are obligated to disclose to FM Ethics 

and for which restrictions may arise, such as:

› Holding a financial interest in an entity that does 

business with, seeks to do business with, or competes 

with Fannie Mae.

› Serving on certain boards of directors or advisory 

bodies or committees, including nonprofits, for-profit 

companies, or government advisory committees. 

› Engaging in outside employment. 

› Transactions involving Fannie Mae real estate owned 

(REO) properties or short sale transactions related to 

any property that secures a Fannie Mae-owned loan.

› Engaging in outside activities or significant personal 

relationships that could be construed as raising 

a conflict with Fannie Mae’s business interests, 

including where a family member or someone with 

whom we have a significant personal relationship is 

employed by Fannie Mae in our business unit or in 

a role that relates to us. 

• We recognize that similar restrictions and obligations 

may arise as a result of the interests, relationships, and 

activities of our family members. We review and follow 

the conflicts of interest policies and procedures and meet 

our disclosure obligations with respect to certain family 

members’ interests, activities, and relationships. 

• We monitor our relationships and interactions to ensure 

we avoid situations that could impair our objectivity, 

interfere with our duties, or present a reputational risk 

to Fannie Mae.

We Avoid Conflicts of Interest

WHAT IF ...

I own individual stock in a large bank?

If you own stock in a bank that does 

business with, seeks to do business 

with, or competes with Fannie Mae, 

a conflict of interest may exist if you 

are in a position to make, recommend, 

or influence business decisions 

regarding this bank or its subsidiaries 

or affiliates. You must disclose this to 

FM Ethics. 

My daughter told me she is 

interested in buying a Fannie Mae 

REO property?

This is an especially acute risk due 

to the possibility of employees 

using insider information to profit 

from these types of transactions. 

Therefore, all employees, regardless 

of position, level, or department, as 

well as their close family members, 

are prohibited from transacting, 

purchasing, acquiring, or renting 

Fannie Mae REO property. If your 

daughter is a dependent, then she 

is a close family member, and the 

same prohibitions apply to her. 

Employees and their close family 

members are also prohibited from 

purchasing any property that 

secures a Fannie Mae-owned loan 

through a short sale transaction or 

at a foreclosure auction. 

I was recently asked to serve on a 

board of directors for a nonprofit 

organization that does business 

with Fannie Mae?

This might pose conflict concerns. 

You must make a timely disclosure 

to FM Ethics for review and approval, 

even if you are asked to serve as a 

part of your official Fannie Mae job 

responsibilities.
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© 2023 Fannie Mae

Business Courtesies

• We understand that there are restrictions regarding giving 

or accepting gifts, entertainment, meals, or other items of 

value with respect to individuals or entities doing business 

with or seeking to do business with Fannie Mae. The giving 

or receiving of business courtesies should never give the 

appearance of undue influence.

• We understand that strict rules regarding giving or accepting 

gifts, entertainment, meals, or other items of value apply 

when dealing with government employees, including FHFA.

• We review and follow the business courtesies policies and 

procedures. If we are not sure, we ask FM Ethics.

Political Activities

• While good citizenship and community participation is 

expressed through political activities and participation, 

we understand that Fannie Mae and employees acting on 

its behalf have limitations in these arenas.

• We conduct any political campaign volunteering or 

contributions on our own time, without company resources, 

and in a manner that makes clear that we do not represent 

Fannie Mae. We also do not solicit other employees for 

our personal causes in the workplace. 

• We disclose to FM Ethics before running for any political 

office or serving in an appointed political position.

• Fannie Mae and its employees may not lobby the 

government on any matters concerning Fannie Mae.

We Avoid Conflicts of Interest

WHAT IF ...

I work in Corporate Procurement 

and was asked by a former coworker 

to help them understand where 

their new company’s bid should 

come in so her company would be 

in line with competitors?

It is inappropriate to share Fannie Mae 

confidential information such as bid 

information. You should decline to 

do so, and inform your management 

team and FM Ethics about this 

situation. Also, certain former 

coworkers may need to refrain from 

representing themselves or their new 

employers to Fannie Mae altogether 

for a period of time under the Covered 

Employee External Employment 

Activities Standard. Contact FM Ethics 

with questions or concerns.

I work as a personal life coach as 

a second job. Is this OK?

Outside jobs should not interfere with 

your ability to perform your Fannie 

Mae job duties, be performed during 

your Fannie Mae working hours, or 

result in disclosure of Fannie Mae’s 

confidential information. You also 

must properly disclose outside 

employment to FM Ethics. Officers 

must disclose all outside employment 

for review, even if it occurs outside of 

the time that you typically perform 

work for Fannie Mae. Non-officers 

must disclose outside employment 

if it relates to Fannie Mae, it is in a 

Fannie Mae business area, or your 

role exceeds 10 hours per week.
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© 2023 Fannie Mae

• Making Fannie Mae business decisions for personal gain 

or to further personal business activities, interests, or 

relationships.

• Using Fannie Mae property, information, or our positions 

for our personal benefit or the benefit of family members 

or otherwise competing with Fannie Mae.

• Offering, promising, paying, or giving anything of value — 

directly or indirectly — either to a government employee 

or official or to a foreign official, foreign political party, 

party official, candidate, or their staff in a manner 

inconsistent with applicable law or policy. 

• Providing or receiving anything of value, including meals 

and refreshments, gifts, or entertainment, that are 

attempts to influence, gain preferential treatment, 

or serve as bribes or kickbacks. 

• Providing or accepting business courtesies to or from 

government employees other than light refreshments during 

a meeting unless approved in advanced by FM Ethics.

• Engaging in prospective employment discussions with 

a Fannie Mae supplier where you can make business 

decisions regarding the supplier without disclosure 

and approval from FM Ethics.

Principle 6

CODE BREAKERS

We Avoid Conflicts of Interest

SEE ALSO ...

• Business Courtesies Policy

• Conflict of Interest Policy

• Conflict of Interest Standard

• Employee Handbook — 

Employee Fraternization

• Employee Handbook — 

Employment of Relatives

• Employee Handbook — 

Non-Solicitation

• Employee Handbook — Political Activities

• Employee Handbook — Standards of 

Professional Behavior

• Employment Policy 

• FAA Personal Conflict of Interest Policy

• Fraud Risk Management Policy 

• Oversight of Designated Executive 

Officers’ Conflicts of Interest and 

Business Courtesies Matters Policy
© 2023 Fannie Mae 26

As People Managers, 

We Set the Standard

Every employee has obligations under our Code; however, 

People Managers have an especially important leadership role 

when it comes to compliance and ethics. People Managers can 

be counted on to lead by example and set the tone through their 

words and deeds.

As People Managers, we:

• Demonstrate our commitment to our Code on a daily basis, 

leading by what we say and what we do. We act as role 

models by demonstrating the standards in our Code and 

Fannie Mae’s Mission and Values and encouraging others 

to do the same.

PRINCIPLE As People Managers, We Set the Standard

07

PRINCIPLE
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© 2023 Fannie Mae

• Set realistic goals and expectations for our teams and keep 

our promises and commitments.

• See that all employees under our supervision are aware of 

their obligations under our Code. This includes encouraging 

participation in ethics training programs and providing 

positive feedback for ethical behavior.

• Maintain an environment that encourages open and inclusive 

communication and speak up about workplace ethics.

• Listen to compliance and ethics matters that come to our 

attention. We raise compliance and ethics concerns and 

any potential violations of our Code to FM Ethics in a timely 

manner and encourage others to do the same.

• Foster a culture in which employees are encouraged to raise 

compliance and ethics concerns without fear of retaliation. 

We do not retaliate against anyone for sharing concerns in 

good faith and for participating in investigations, and we let 

others know that we expect the same from them.

• Can be counted on to exercise good judgment and common 

sense when addressing compliance and ethics issues. 

We see that such concerns are addressed at an appropriate 

level within the organization and are escalated as necessary.

As People Managers, We Set the Standard

WHAT IF ...

An employee whom I supervise 

raised a potential ethics concern to 

me; however, she asked that I keep 

it confidential and not share it with 

anyone. Is this an option?

All employees have an obligation 

to escalate any actual or potential 

compliance and ethics concern that 

is identified to them. As a People 

Manager, you have a particularly 

acute obligation to raise such issues. 

You must report this concern to 

your own management, Human 

Resources, or FM Ethics so that it 

can be reviewed and addressed. 

You have various options to 

report matters confidentially or 

anonymously to FM Ethics.

An employee tells me they think 

I retaliated against them when 

I neglected to include them in a 

recent meeting?

Fannie Mae does not tolerate 

retaliation as described further in 

the Non-Retaliation Policy. Because 

the employee indicated that they 

think you retaliated against them, 

please contact FM Ethics directly so 

that we may speak to you in order 

to gather additional information. 
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© 2023 Fannie Mae

• Ensure that we assist our team in meeting their obligations 

under our Code as well as corporate policies and procedures.

• Take responsibility for our mistakes and quickly take 

appropriate action to correct mistakes.

• Recognize the importance of behaviors and performance and 

deliver clear, timely, and constructive feedback.

• Take morale and employee retention issues seriously and 

discuss concerns in a timely and appropriate manner, such 

as by escalating matters to Human Resources or FM Ethics. 

• Do not sacrifice accuracy or integrity to quickly fix problems.

As People Managers, We Set the Standard

• Retaliating against any employee who raises a compliance 

or ethics concern. 

• Failing to escalate or otherwise address compliance or 

ethics concerns raised by employees.

• Failing to act affirmatively to prevent prohibited conduct 

that you know or think an employee is engaging in or 

plans to engage in. 

Principle 7

CODE BREAKERS

SEE ALSO ...

• Employee Handbook — Equal Employment 

Opportunity (EEO) Non-Discrimination

• Employee Handbook — Prevention of 

Sexual and Other Prohibited Harassment

• Employee Handbook — Standards 

of Professional Behavior

• Employment Policy

• FM Ethics Policy

• Non-Retaliation Policy
© 2023 Fannie Mae 29

We Follow Our Code 

and Policies

Our Code and our policies, standards, and procedures are 

critical components of our commitment to making Fannie Mae 

a better place to work. Under our Code, we commit to being 

accountable for maintaining the highest standards of compliance 

and ethics.

• We follow our Code and recognize that compliance and 

ethics are shared responsibilities at Fannie Mae.

• We recognize that our policies, standards, and procedures 

are updated periodically and that we are each responsible 

for understanding changes that apply to our job 

responsibilities.

PRINCIPLE We Follow Our Code and Policies

08

PRINCIPLE
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© 2023 Fannie Mae

• We understand that if we violate our Code, policies, 

standards, or procedures, we can be subject to disciplinary 

action up to and including termination of employment. 

In addition, we understand that some reported conduct 

may result in a referral for outside investigation or civil or 

criminal prosecution.

• We acknowledge that compliance with our Code and policies 

is a condition of our employment. We also recognize that 

our Code does not alter our at-will employment relationship 

with Fannie Mae or expand our legal rights or the legal 

obligations of Fannie Mae.

• We support our strong governance structure and establish 

clear lines of accountability, which enables us to maintain 

responsible business practices in all that we do.

• When objectives conflict, we take the path forward that is 

ethical and in the best interest of the company.

• Violating our Code. 

Principle 8

CODE BREAKERS

WHAT IF ...

A policy changed and I didn’t 

realize it?

Policies and other governance 

documents change regularly. It is 

important that you check to see if 

a policy has changed before relying 

on it. You can do this either by 

searching for it directly in Fannie 

Mae’s policy repository available 

through HomeSite or by contacting 

FM Ethics. If you think that you acted 

inconsistently with a current policy 

or have questions regarding the 

application of the policy for whatever 

reason, please raise this concern to 

your manager, Human Resources, 

or FM Ethics.

SEE ALSO ...

• Employee Handbook — Employment 

At-Will

• Employment Policy

• Delegations of Authority Standard

• FM Ethics Policy

• Letter of Instruction Policy

• Management-Level Governance 

Policy

We Follow Our Code and Policies
© 2023 Fannie Mae 31

We Raise Compliance 

and Ethics Concerns

At Fannie Mae, discussion and disclosure of issues is a 

responsibility shared by all of us. We step up to address difficult 

issues and promptly raise compliance and ethics questions and 

concerns that come to our attention. We raise our concerns 

to an appropriate level and organization within Fannie Mae. 

Our obligation is to speak up.

Seeking Guidance and Reporting Misconduct

• We raise our questions or concerns with:

1. Any People Manager or Officer; 

2. Human Resources; or 

PRINCIPLE We Raise Compliance and Ethics Concerns

09

PRINCIPLE
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3. Compliance & Ethics via FM Ethics 

› FM Ethics Webline: fanniemae.com/fmethics

› Phone: 1-888-FM-ETHICS (1-888-363-8442)

› Email: fm_ethics@fanniemae.com

› Mail: Fannie Mae

FM Ethics

1100 15th Street, NW

Washington, DC 20005

• Fannie Mae takes seriously all compliance and ethics 

concerns that are raised and reviews such matters promptly. 

FM Ethics administers the Code and provides guidance on 

compliance and ethics issues. When reviewing concerns 

submitted to FM Ethics, it determines whether they raise 

a potential violation of our Code or Fannie Mae’s policies, 

standards, and procedures.

• Anyone may contact FM Ethics anonymously by webline, 

phone, email, or mail. The webline and phone offer unique 

capabilities to report anonymously and provide specific 

instructions on remaining anonymous.

We Raise Compliance and Ethics Concerns

WHAT IF ...

I want to contact FM Ethics 

anonymously?

There are several options if you prefer 

not to identify yourself. You may call 

1-888-FM-ETHICS (1-888-363-8442) 

and select the option to report your 

concern anonymously by using 

the password-protected voice mail 

system. The FM Ethics phone system 

will issue you a report identification 

number and a numeric password to 

raise a question or concern, check 

the status of your report, and share 

additional information, all while 

maintaining your anonymity. You 

may also contact FM Ethics through 

the FM Ethics Webline at fanniemae.

com/fmethics. The webline’s 

functionality is like the voice mail 

system and allows you and FM Ethics 

to communicate anonymously.
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• Regardless of whether you choose to remain anonymous, 

FM Ethics will keep all contacts confidential consistent 

with the law and pursuant to sound business practices. 

Concerns reported to FM Ethics are reviewed and 

documented promptly.

• We understand that compliance and ethics concerns must 

be raised in good faith. We recognize that Fannie Mae 

does not tolerate knowingly or falsely accusing others of 

wrongdoing or otherwise raising compliance or ethics 

concerns in bad faith. 

We Do Not Tolerate Retaliation 

• Fannie Mae does not tolerate retaliation against any 

individual or company who raises a compliance and ethics 

concern in good faith or participates in an investigation, 

and we comply with these obligations. 

• If we believe someone has been subjected to retaliation, 

we will raise this concern.

Our Investigations Process 

• Where FM Ethics determines that an issue raises a potential 

Code or policy violation and that an investigation is 

appropriate, Fannie Mae’s Investigations Group reviews 

the concern confidentially, using an objective process. 

If Investigations determines that misconduct has occurred, 

Fannie Mae takes appropriate disciplinary action to address 

the issue, up to and including termination of employment.

• We cooperate with any investigation of a compliance and 

ethics concern. We respect the investigations process and 

do not take actions that might interfere with or mislead 

the investigation.

• We may not always be notified how matters that we 

reported were resolved, but we understand that we played 

a critical role in upholding our Code and Fannie Mae’s Values.

We Raise Compliance and Ethics Concerns

DEFINITIONS

Retaliation:

This may occur when an individual 

provides information and/or raises 

concerns about compliance with 

our Code or other laws, regulations, 

directives, and/or policies that apply 

to Fannie Mae (covered activity), and 

that individual is then subjected to 

adverse action because they engaged 

in that covered activity.
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We Raise Compliance and Ethics Concerns

SEE ALSO ...

• Employee Handbook — Prevention 

of Sexual and Other 

Prohibited Harassment

• Employee Handbook — Standards 

of Professional Behavior 

• Employment Policy 

• FM Ethics Policy 

• Investigations Policy 

• Non-Retaliation Policy

WHAT IF ...

I want to raise a suspicion about 

fraud, but I am concerned about the 

confidentiality of the process and 

fear that something bad will happen 

to me if I report?

All reports and information provided 

to FM Ethics and Investigations are 

kept confidential, consistent with the 

law and sound business practices. 

Depending on the nature of the 

allegations, Investigations may be 

required to disclose information 

regarding an investigation pursuant 

to a legal order, to Fannie Mae’s 

conservator, and/or to Fannie Mae’s 

internal and/or external auditor.

Fannie Mae does not tolerate 

retaliation against any person for 

raising a good faith compliance and 

ethics concern. The Non-Retaliation 

Policy specifically prohibits 

employees from retaliating against 

an individual for reporting such a 

complaint or otherwise participating 

in an investigation.

I feel my supervisor is not handling 

the compliance concern that I raised 

appropriately?

If you remain concerned, please 

speak to someone else in your 

management chain, Human 

Resources, or FM Ethics.

• Failing to raise a suspected or known violation of our 

Code (including a violation of policy, law, or regulation) 

in an appropriate manner.

• Retaliating against an employee because they raised 

a question or filed a report that they made under our 

Code, policies, standards, or procedures.

• Failing to cooperate with, interfering with, or misleading 

an investigation. 

• Knowingly and falsely accusing another employee of 

wrongdoing.

Principle 9

CODE BREAKERS
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© 2023 Fannie Mae

A Message From the 

Chief Compliance 

& Ethics Officer

Colleagues,

Thank you for taking the time to refresh your knowledge of 

our Code of Conduct. The principles outlined in our Code govern 

our Mission and Values — fostering our strong ethical culture at 

Fannie Mae. 

We are all responsible for following these principles and 

demonstrating the highest level of integrity in any situation that 

may arise. Please refer to our Code regularly to ensure that you 

are making ethical decisions, fostering inclusion, and creating 

a safe workplace. 

As a reminder, you can ask questions or report misconduct 

anonymously, confidentially, and without fear of retaliation. 

If you observe conduct that makes you uncomfortable and want 

to raise a concern, don’t hesitate to contact FM Ethics for 

assistance. If you see or suspect illegal or unethical conduct, 

report it immediately.

Together, our actions matter. Thank you for doing your part to 

make Fannie Mae a respectful, inclusive, and ethical workplace.

Nancy Jardini

A Message From the Chief Compliance & Ethics Officer
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© 2023 Fannie Mae

Contacting Compliance & Ethics

Need more information about our Code of Conduct or want to raise a question or concern? 

Contact us: 

Mail: 

Fannie Mae 

FM Ethics 

1100 15th Street, NW

Washington, DC 20005

Webline: fanniemae.com/fmethics

Phone: 1-888-FM-ETHICS 

 (1-888-363-8442)

Email: fm_ethics@fanniemae.com

Contacting the Audit Committee of the Board of Directors

In addition to management, Human Resources, and Compliance & Ethics, the Audit Committee is 

available to receive reports of potential wrongdoing, especially relating to the company’s accounting, 

internal accounting controls, and auditing matters. Contact the Audit Committee by email at 

auditcommittee@fanniemae.com; by phone via FM Ethics listed above (please indicate that you 

want your report to go to the Audit Committee); or in writing to the Audit Committee, c/o Office of 

the Secretary of the Corporation, 1100 15th Street, NW, Washington, DC 20005. The Audit Committee 

accepts confidential and anonymous reports by any of these methods.

Waivers

Waivers of this Code will be granted only in exceptional circumstances. Only the Board of Directors 

or a designated committee of the Board may grant a waiver of any standard in this Code, and such 

waivers of our Code must be disclosed promptly.

Revisions

The Board reviews the adequacy of our Code at least once every three years for consistency with best 

practices and practices appropriate to Fannie Mae and makes revisions to our Code as appropriate. 

On April 20, 2023, our Code was amended to add, expand, or update its treatment of a number of 

topics, including discrimination, harassment, responsible business practices, anti-fraud, external 

communications, and non-retaliation.

Contacting Compliance & Ethics