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How We Make

Home Possible

Effective Date: January 1, 2023 | Revised Date: March 1, 2024

The Freddie Mac Code of Conduct
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Freddie Mac’s

VALUES

We are mission driven

We put the health of the housing finance market at the forefront 

of our business decisions

And Mission drives everything we do

We do the right thing

We lead the company and our industry with integrity

And we take responsibility for our actions

We perform with excellence

We thoughtfully approach challenges

And we reliably deliver on our commitments

We are inclusive

We embrace our differences

And we engage with respect and positive intent
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Freddie Mac’s mission to make home possible is an important one, impacting millions of families in America. 

As a trusted financial institution, we must focus not only on our mission and business goals, but also on the 

manner in which we reach those goals. We want to always do the right thing in the right way. 

Freddie Mac’s Code of Conduct helps guide us in that endeavor. It outlines the firm’s values and expectations

for operating ethically and always engaging with our stakeholders and with each other respectfully. 

Each of us should be familiar with this important document and refer to it as a tool to help with daily decisions, big 

and small. When in doubt, the Code of Conduct can help clarify and validate the best course of action, including 

when to speak up and escalate issues. Rest assured that concerns will always be addressed without retaliation. 

The Code of Conduct helps ensure we can fulfill our mission reliably and with integrity every day. 

Thank you for your commitment to following its principles.

Mike Hutchins

President

A Message from

THE PRESIDENT
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INTRODUCTION ............................ 1

• Our Code is a Foundation for Ethical Conduct

• Using the Code

• Our Managers and Executives Play a Key Role

SECTION 1 .....................................4

We create a safe, respectful, and inclusive 

work environment.

• Respect and Diversity

• Discrimination and Harassment

• Workplace Safety

SECTION 2 .................................... 7

We safeguard our company’s and our 

partners’ information and resources.

• Use of Company Assets 

• Information Protection

• Intellectual Property

• Records Management

• Information Security and Privacy

SECTION 3 .................................. 10

We put the company’s interests before our 

own and disclose conflicts of interest.

• Business Courtesies

• Personal Investments and Insider Trading

• Personal Political and Community Activities 

• Outside Activities & Family Member Employment

• Other Conflicts of Interest

SECTION 4 .................................. 13

We communicate truthfully and responsibly.

• Responsible Communication

• Social Media

• Truthful Reporting

SECTION 5 ................................... 15

We conduct our business lawfully 

and in good conscience.

• ESG Strategies

• Artificial Intelligence (AI) & Machine Learning (ML)

• Fair Competition

• Fair Lending

• Anti-Fraud

• Anti-Corruption

• Business Opportunities, Innovations, and Fair Dealing

SECTION 6 ................................... 19

We ask for guidance and report concerns.

• Seeking Advice and Reporting Misconduct

• No Tolerance for Retaliation

• Additional Resources

INDEX OF POLICIES ..................... 22

Table of CONTENTS

Navigating This Document

To go directly to a specific topic, click on the section in the Table of Contents below.

Gray highlighted copy within this document provides additional details about certain terms. 

The Blue hyperlinks are available only if you are connected to Freddie Mac’s secure network.
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Our Code is a Foundation for Ethical Conduct

Through our work at Freddie Mac, we make home possible for millions of Americans. To best fulfill our Mission, we must 

conduct business ethically and in compliance with both the letter and the spirit of the law, our policies, and our Values. 

We recognize that good ethics is good for business.

Our Code of Conduct sets critical expectations for the actions we take and competencies we demonstrate.

It outlines the responsibilities that we have to each other, our business partners, our competitors, and our customers. 

What is right, fair, or compliant isn’t always obvious, especially in the face of conflicting priorities or business 

pressures. The Code also provides us with ethical decision-making guidelines to help in those “gray areas”.

Does the Code apply to me? 

The Code applies to all full- and part-time employees, including senior management and executives. If you are an 

employee providing services under the Financial Agency Agreement between Freddie Mac and the Department of 

the Treasury, you are also subject to the Freddie Mac Making Home Affordable Code of Conduct, which contains 

more restrictive rules in some areas.

We also expect that those who work with Freddie Mac, including contingent workers, independent contractors, and 

consultants, will embrace the spirit of the Code and adhere to its standards. 

Any waiver of the Code for executive officers must be approved by the Board or a Board committee and 

promptly disclosed to the public on our website. This prevents waivers of the Code from being hidden from the public 

and complies with New York Stock Exchange (NYSE) requirements and similar rules under the Securities and Exchange 

Commission and the Sarbanes-Oxley Act of 2002.

Using the Code

Read the Code and take time to understand our Company’s expectations and how they apply to your role at Freddie 

Mac. Come back to the Code in situations where you’re not sure of the right answer — especially if there are likely legal 

or ethical risks to you or to the business.

INTRODUCTION
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What if I can’t find an answer in the Code?

While the Code strives to be comprehensive, it can’t anticipate every situation that you may encounter. For additional 

information, review the relevant policies or consult the Compliance & Ethics Helpline for guidance.

Where can I find our policies?

Company policies, and their associated standards, are available on HomeFront. Our policies and standards support the 

Code by presenting additional details and cover other topics not found in the Code. Relevant policies and standards are 

indexed at the end of the Code, to make it easy to find a specific resource when you need more detailed information. 

Each employee is responsible for understanding and following all of Freddie Mac’s policies and standards.

What happens if someone violates the standards in our Code or the law?

Complying with the Code of Conduct and applicable laws is a condition of employment. Failure to comply will result 

in corrective action, up to and including termination.

Who can I talk to if I have questions or concerns?

When facing a challenging situation, there are resources to help guide you. You can contact the Ethics Office or the 

Compliance & Ethics Helpline, Human Resources, the Legal Division, or a manager in your division.

Our Managers and Executives Play a Key Role

We are all responsible for our culture, but those who manage people — all people managers, including senior 

management and executives — have a special responsibility to lead the way.

We expect all people managers to:

• Act as role models

• Champion a culture of integrity and compliance

• Promote high ethical standards

• Recognize and reward behavior that exemplifies our Values and our Code

• Make sure employees are appropriately trained and competent

• Assist in enforcing the Code

• Report any violations or potential violations of the Code in a timely manner

Additionally, senior management is responsible for making sure the company has the resources to effectively 

execute our mission.

Certain members of leadership, including the CEO, President, CFO and Principal Accounting Officer/Controller, must 

also promote full, fair, accurate and understandable disclosures in filings with the Securities and Exchange Commission 

(SEC) and in other public communications regarding our financial condition. Their ethical actions in this area set the tone 

for how our company, and every individual who works on its behalf, are perceived by the outside world.

2

The Freddie Mac Code of Conduct | INTRODUCTION
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Bringing Our Values Home

Our Code requires that each of us demonstrate good judgment in our decisions and actions at work 

— not just occasionally, but consistently.

To do this, we must be able to accurately evaluate situations and make good choices.

If you’re facing a situation where the right choice is not clear, take a moment to assess your 

options in terms of our Values. And if you see something that may violate the Code, report it. 

We are mission driven

Am I making a decision that is in the best interest of Freddie Mac and its stakeholders and 

appropriately managing the related risks? 

We do the right thing

Am I acting with integrity and accountability?

We perform with excellence

Am I meeting my obligations by exhibiting Freddie Mac’s expected behavioral competencies?

We are inclusive

Am I creating space for those with different perspectives to be engaged?

For additional insight, consider the ethical issues at stake. Ask:

Right versus wrong: Am I being asked to do something that might be inappropriate? Are 

there legal or ethical concerns?

Potential consequences: Could someone or something be harmed by my decision?

Reputational effect: Would others understand my decision? Could I explain it to my manager, a 

friend or someone I admired? Could the decision reflect poorly on me or Freddie Mac?

Due diligence: Have I verified important facts and assumptions? If I’m not sure after trying to 

verify, have I asked others who may know? 

Throughout the Code you will find scenarios where we demonstrate how to apply our Values 

and use these additional questions. 

The Freddie Mac Code of Conduct | INTRODUCTION
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At Freddie Mac, diversity, equity, and inclusion (DEI) is more than a business imperative, it 

is a mindset. We are committed to promoting equity, igniting innovation through diverse 

perspectives, and instilling a culture where people feel comfortable to be their authentic selves 

in the workplace. We are also committed to the safety and security of our employees. 

Respect and Diversity

• Treat people fairly — with respect and dignity.

• Act professionally in all interactions — including conversations, meetings, email communications and 

online exchanges.

• Create an inclusive, equal opportunity work environment that values the differences and opinions of others.

• Engage others positively, without belittling or bullying behaviors.

• Support officers, directors, and managers in their efforts to foster a positive work environment.

• Consider diverse suppliers for your product and service needs in partnership with Enterprise Supply Chain.

Discrimination and Harassment

• Never discriminate based on race, color, religion, ethnicity, sex, pregnancy, age, national origin, disability, sexual 

orientation, gender identity/expression, parental status, marital status, military service or veteran status, genetic 

information, or any other status protected by applicable law.

• Base employment decisions on the individual’s qualifications, skills, and performance — not on personal 

characteristics or protected status.

• Promote non-discrimination within sourcing and procurement practices. 

• Do not use sexually explicit discussions, jokes, and material while at work or using company resources.

• Be careful not to harass others, even without intending to — joking, teasing, and commenting about sensitive and/or 

controversial subjects can offend others and create uncomfortable working conditions.

• Speak up if you witness or experience harassing, discriminatory or unfair behavior; HR Connect, the Employment 

Law & Employee Relations team and the Compliance & Ethics Helpline are all available to help ensure that you and 

others work in a safe and secure environment.

We create a safe 

and respectful 

work environment.

SECTION 1
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Workplace Safety

• Ensure your actions are not intimidating or threatening — and speak up about such behavior by others.

• Do not come to work or conduct any Freddie Mac business when under the influence of alcohol or illegal drugs, 

or when impaired by prescription medications.

• Do not use, purchase, sell, manufacture, or distribute illegal drugs or related material in the workplace or using 

Freddie Mac resources.

• Never carry or use weapons, even if licensed, on Freddie Mac premises.

• Exercise sound judgment when alcohol is served at business-related functions. Remember, you are 

representing Freddie Mac.

Bringing Our Values Home

“I was in a meeting led by the senior leader of my division to develop our succession plan, a 

plan at least two-deep for manager-level positions and above. This initiative is in response 

to several sudden departures, and I agreed to be on the task force. Unfortunately, this comes 

during our busiest time of the year. Some on the task force are anxious to get it done. They are 

advocating to simply name the two employees next in line to each position. This tactic would 

result in very little diversity among leadership. I don’t want to hold everyone up, but I think a 

more inclusive approach is necessary.”

Consider Our Values

We are Inclusive: Diversity in leadership, and at all levels, is crucial to our organization’s 

success, from performance and culture to employee recruitment and retention.

Consider the Ethical Issues at Stake

Potential Consequences: We have a duty to report to the Federal Housing Finance Agency 

(FHFA) on our DEI efforts in hiring and workplace practices. Fast tracking the succession 

planning process and overlooking the requirement to identify qualified diverse candidates 

can undermine our efforts to promote DEI and is counter to our stated goals. 

Due Diligence: Our policies contain guidance to help us make sure existing internal diverse talent 

is given opportunities while meeting our hiring standards and succession planning needs. 

The Freddie Mac Code of Conduct | SECTION 1
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Bringing Our Values Home

“I work closely with another leader who can come off as condescending and rude. She often 

belittles her direct reports in front of their peers and has sometimes resorted to shouting 

in meetings to get her point across. This behavior has created a very uncomfortable work 

environment for her team, colleagues, and me. I made some subtle comments to her after 

I witnessed a particularly tense exchange between her and a member of her team, but she 

brushed me off. Now our teams are working closely together on a project, and I’m worried my 

team members will be impacted by her behavior.”

Consider Our Values

We are Inclusive: We are each expected to engage respectfully with others, and people 

leaders have the extra responsibility to set the right tone for their teams. 

Consider the Ethical Issues at Stake

Right Versus Wrong: Raising concerns directly to your colleagues when you witness negative 

behavior from them is the right first step. We ask for help if our first attempt doesn’t work.

Reputational Effect: Rude and condescending behavior can create a negative work 

environment that impacts employee productivity and can cause good employees to leave 

the company.

The Freddie Mac Code of Conduct | SECTION 1
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At Freddie Mac, we are good stewards of our assets — including employee data, financial 

assets, intellectual property, data and information, and buildings and facilities — and those of 

third parties and FHFA. We protect all assets (for which we have responsibility) from theft, loss, 

unauthorized access, and misuse. We keep accurate and reliable records and avoid even the 

appearance of fraud or misconduct.

Use of Company Assets

• Treat company assets with care and use them only for business-related purposes.

• Leave conference rooms and public spaces the way you’d like to find them.

• All employee expenses must be reasonable and prudent and further a legitimate business purpose.

• Follow all Information Technology safeguards when using company systems whether accessing on-site or from 

another location.

• Managers must ensure that their people have appropriate access to systems and employees must notify their 

manager of any inappropriate access they have received.

• Reasonable and infrequent personal use of company technology assets is permissible, subject to compliance with 

company policies.

Information Protection

• Follow all applicable policies, standards, and procedures to keep Corporate Information, including 

Non-public FHFA information, safe. Freddie Mac classifies “Corporate Information” as Restricted, Confidential, 

Non-Public, or Public.

• For Restricted, Confidential, and Non-Public information: 

• Access, use, and store appropriately and only when authorized. 

• Share only with those who are authorized to receive it, using confidentiality agreements as appropriate when 

disclosing to third parties (this sharing rule does not prohibit employees from reporting wrongdoing to a 

government agency).

• Protect it while working remotely and even after your employment with Freddie Mac ends.

We safeguard 

our company’s 

and our partners’ 

information 

and resources.

SECTION 2
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Intellectual Property

• Our brand, trademarks, patents, and proprietary information about our business are among our most valuable 

assets — protect them from unauthorized use or disclosure, and never use them for personal gain.

• Inventions and ideas that you develop that are related to our business or created during your employment belong to 

Freddie Mac.

• Protect all intellectual property in your care, including intellectual property of our business partners.

• Speak up if you are aware of a possible misuse or unauthorized disclosure of any intellectual property.

Records Management

• Write clearly, professionally, and accurately in all documents (e.g., emails, texts, memos, reports and financial statements).

• Take responsibility for the integrity of records you create and manage. 

• Retain and dispose of records in compliance with the Records Retention Schedule and our Document Lifecycle & 

Legal Hold policy.

• Do not destroy or alter any documents that are covered by a “Legal Hold” initiated by the Legal Division.

Information Security and Privacy

• Be wary and report phishing — don’t click links or download attachments in suspicious emails.

• Recording conversations or meetings is prohibited (except management approved recordings within Microsoft Teams).

• Report occurrences of loss, unauthorized access, disclosure, or theft of Corporate Information — including 

Protected Personal Information (PPI) — involving personnel, suppliers, seller/servicers or others in possession of 

Corporate Information, or loss or theft of Freddie Mac assets (e.g., laptops) to:

• Privacy: privacy_incident_management@freddiemac.com

• information_security@freddiemac.com (or 703-450-3200)

• Division Privacy Liaison

The Freddie Mac Code of Conduct | SECTION 2
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Bringing Our Values Home

“My co-worker and I had a tight deadline on a project. We finished work on a key document 

right at the end of the day. Trying to make our deadline, my co-worker sent the document to 

his personal Gmail account to print from home and do his review from there. I didn’t think 

anything about it at the time, but later that night I remembered the document was marked 

“Confidential”. I also remembered it was against policy to email such documents to a personal 

account. The next day my co-worker and I let our manager know what happened, and she 

informed Information Security right away.”

Consider Our Values

We do the right thing: We all have a responsibility to speak up when we see a possible 

violation, or behavior that is concerning.

Consider the Ethical Issues at Stake

Potential Consequences: Sending and storing Freddie Mac Restricted, Confidential, 

or Non-Public information to a non-Freddie Mac computer leaves it vulnerable to a data 

breach. Additionally, ignoring such behavior from others weakens our ethical culture and 

hurts Freddie Mac. 

Reputational Effect: When we don’t appropriately handle information, we risk losing the 

confidence of our stakeholders to be a trusted partner.

The Freddie Mac Code of Conduct | SECTION 2
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To uphold our reputation as a trusted business partner, we must avoid conflicts of interest, 

and disclose any situation that could create even the appearance of a conflict. We are open 

and transparent when we hire. We offer and accept only appropriate business courtesies. 

We disclose outside activities such as second jobs and personal investments that may 

conflict with our responsibilities to Freddie Mac. We do not use our Freddie Mac positions for 

inappropriate gain.

Business Courtesies

• Business courtesies – gifts, meals, entertainment, or hospitality – should neither prevent you from making fair 

and impartial business decisions nor create an impression of impropriety.

• When offering business courtesies, make sure they are modest in value and given infrequently, without any 

expectation of reciprocity.

• Never offer or accept cash or cash equivalents, like gift cards.

• Do not offer or accept anything that could reflect poorly on the company.

• Strict rules govern courtesies to government employees – contact the Ethics Office before giving anything 

of value to a government employee, including an employee of FHFA.

Personal Investments and Insider Trading

• If you have material, non-public information (MNPI) about a company, do not purchase or sell securities in 

that company, and do not “tip” anyone else to trade.

• We prohibit employees and their Related Individuals from engaging in certain transactions, including 

purchasing Freddie Mac and Fannie Mae securities.

• If you already own Freddie Mac securities, only sell them after obtaining pre-clearance, and during an 

approved window period.

• Obtain pre-clearance for certain other transactions, including private placements. 

• Follow all Information Wall restrictions to prevent the flow of MNPI (including material non-public FHFA information) 

to your colleagues identified as Restricted Persons.

We put the 

company’s interests 

before our own and 

disclose conflicts 

of interest.

SECTION 3

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Personal Political and Community Activities

• Disclose any existing or planned political office or government-related positions.

• Conduct personal political and community activities on your own time, without using company resources, and be 

clear that you do not represent Freddie Mac.

• Never pressure or coerce others within Freddie Mac to support your personal political activity or charitable causes.

• Do not solicit political contributions during work hours or on Freddie Mac premises; managers are prohibited 

from soliciting within their reporting chain. 

• Soliciting contributions for charitable causes from others on Freddie Mac premises is allowed when not coercive 

or disruptive to Freddie Mac business operations.

Outside Activities & Family Member Employment

• Disclose any personal relationships that could pose a conflict at work, including, but not limited to: 

• Family members or romantic partners with whom you share the same first or second-level supervisor

• Being in a position to hire, terminate, promote or help advance family members, romantic partners, or close 

friends; or

• If a family member or romantic partner is offered or takes a job with one of our suppliers, business partners, 

or another Third Party.

• Disclose outside activities that could pose a conflict at work, such as: 

• Second jobs or board memberships with Third Parties,

• Real estate agent or broker activity, or 

• Other activities that might divide your loyalties or interfere with your obligations to Freddie Mac.

Other Conflicts of Interest

• Freddie Mac business opportunities should benefit Freddie Mac.

• Don’t take personal advantage of corporate opportunities and don’t try to persuade Freddie Mac to do business 

with a company because it might benefit you or a family member, romantic partner, or close friend.

• Don’t purchase Freddie Mac Real Estate Owned (REO) properties. You should inform your Immediate Family 

Members that this prohibition extends to them as well. 

• Avoid situations where actual or perceived conflicts of interest may arise when exchanging gifts, issuing internal 

recognition, and other solicitations between employees up or down your reporting line.

• Don’t provide personal loans to your management, executive officers, or members of the Board of Directors.

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The Freddie Mac Code of Conduct | SECTION 3
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Bringing Our Values Home

“Since the pandemic, my teammates and I have worked full-time remote. We depend on 

everyone working collaboratively to complete our projects. Many of us started noticing that 

our project manager rescheduled meetings at the last minute, was never on camera, and he 

didn’t engage in the discussion. Rumors started that he was working another full-time job or 

“daylighting” on Freddie Mac’s time. The project manager’s behavior affected our team’s 

morale, and, eventually, we missed a key deadline for a big project. I shared my concerns with 

our boss who hadn’t realized the extent of the problem.”

Consider Our Values

We perform with excellence: While employees are generally allowed to engage in 

outside activities, including second jobs, we must prioritize our Freddie Mac job duties 

and responsibilities. 

Consider the Ethical Issues at Stake

Right Versus Wrong: We owe it to our teammates to be accountable for our time and work 

output. If you notice a team member is not meeting their responsibilities, speaking-up to your 

manager is the right course of action.

Due Diligence: Before engaging in any outside activity, check the policy so you know how to 

avoid a conflict and when you are required to disclose to management and Ethics.

“During a conversation over lunch with a co-worker, he showed me a new investment app his 

spouse is now using. He explained the app is like other stock trading apps where you selfmanage your investment portfolio, but this app is focused solely on real estate investments. 

I asked if he had received approval to use the app, and he replied approval wasn’t needed 

since his spouse owns the account not him. I shared that before my kid opened a stock trading 

account as part of a college course, I reached out to Ethics for guidance. I suggested he do the 

same before his spouse goes much further with the app.”

Consider Our Values

We are mission driven: Employees are responsible for pre-clearing personal investment activities, 

including those of Related Individuals such as your spouse, to avoid potential conflicts of interest. 

This allows us to support our mission without the appearance of impropriety.

Consider the Ethical Issues at Stake

Right Versus Wrong: At Freddie Mac we speak up and inform our colleagues of potential 

actions that may violate our policies and Code of Conduct. 

Due Diligence: We are all expected to understand the Code of Conduct and its underlying 

policies. The expectations around the personal investment policy can be complex. Consult 

with Ethics for clarity on policy requirements. 

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The Freddie Mac Code of Conduct | SECTION 3
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Truthful and responsible reporting is critical to the integrity of the markets in which we do 

business and to Freddie Mac’s reputation. We communicate responsibly — whether we are 

working with regulators and government agencies, auditors, the media, the investment 

community, or anyone else outside our company’s walls. And we ensure that our disclosures 

are truthful and clear.

Responsible Communication

Working with Regulators, Other Government Bodies, and External Auditors

• Employees are prohibited from lobbying.

• Only authorized employees may communicate on behalf of Freddie Mac to regulators, Congress, state officials, other 

government officials, and/or external auditors in compliance with FHFA’s External Communications Standards. 

• Direct any requests for information from Congress or any state legislative body to Government & Industry 

Relations, and from government agencies to Legal.

• Respond to requests for data and information in an accurate and timely manner.

• Be professional and respectful; escalate issues for resolution when appropriate.

• Keep the Regulatory Affairs Team informed of requests from FHFA-Examinations and FHFA-OIG.

• Never obstruct an audit or conceal or misrepresent relevant information.

Interacting with the Media, the Investment Community and Others Outside Freddie Mac

• Only authorized employees may communicate on behalf of Freddie Mac to the public, the media, and other 

external parties in compliance with FHFA’s External Communications Standards.

• All external, business-related speeches, papers, postings and publication opportunities must be pre-cleared by 

Public Relations.

• Direct any requests for information from the investment community to Investor Relations. Direct all media 

inquiries to Public Relations.

We communicate 

truthfully and 

responsibly.

SECTION 4

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Bringing Our Values Home

“My teammate told me a reporter emailed her wanting information for a story about a key 

issue to our industry. My teammate knows how important this issue is to our company, so she 

wanted my help because she had never handled a request like this before. She wasn’t even 

sure how the reporter had found her email address, but she was ready to send any information 

she could. I told her she should not reply to the reporter but should send any requests from the 

reporter to Public Relations. She was disappointed but understood why we limit contact with 

the media to only authorized employees.” 

Consider Our Values

We perform with excellence: We speak up when our colleagues might be going down the 

wrong path.

Consider the Ethical Issues at Stake

Right Versus Wrong: We have policies and procedures about external communications to 

protect Freddie Mac; violating those policies and procedures, or letting others do so, is 

not appropriate.

Potential Consequences: Only authorized employees may communicate on behalf of 

Freddie Mac to the media, regulators, Congress, state officials, other government officials,

 and external auditors. This helps ensure that we provide complete, accurate, relevant, and 

up-to-date information. 

Social Media

• Take care when posting as your online conduct outside of work may reflect on the company.

• Ensure your comments on social media are attributed to you personally, and not as a representative of Freddie 

Mac. You should not engage in discussions about sensitive topics to the company, even with a disclaimer. 

• Never share Freddie Mac Restricted, Confidential, or Non-Public information on social media.

• Obtain authorization from Public Relations before using social media for business purposes and before 

posting on Freddie Mac’s behalf. All social media published by Freddie Mac is subject to FHFA’s External 

Communications Standards. 

Truthful Reporting

• Be complete and accurate when reporting assets, liabilities, revenues, and expenses.

• Never intentionally falsify a financial record or misrepresent the facts of a transaction.

• Use good judgment when creating or approving expense reports.

• Report issues, and actions to address them, transparently and accurately and in accordance with applicable 

Company policies and standards.

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The Freddie Mac Code of Conduct | SECTION 4
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We all benefit from fair competition and fair play. Being an ethical company means doing 

business transparently and honestly and seeking competitive advantage only through 

legal and ethical business practices. We endeavor to be aware of and comply with all laws 

and regulations that apply to Freddie Mac. We also integrate environmental, social and 

governance (ESG) strategies into our business and operations. Freddie Mac is not just a 

leader in the industry; we are also good stewards of the resources entrusted to us.

Sustainability Strategies

• In a changing world, our sustainability efforts help ensure we can continue to Make Home Possible 

equitably and responsibly for families across the nation.

• We work to reduce carbon emissions from our operations while promoting environmentally sustainable 

and resilient single-family and multifamily housing to reduce climate-related risks and increase affordability.

Artificial Intelligence (AI) & Machine Learning (ML)

• Our use of AI/ML is guided by our Values and the AI/ML Ethical Principles to include fairness, accountability 

and transparency. 

• We implement processes that drive fair and equitable AI/ML outcomes across all demographic groups.

Fair Competition

• Consistent with the antitrust laws, we compete lawfully based on the merits of our products and services. 

• Never enter into agreements with our competitors to fix prices or elements of pricing (such as credit terms),

 to divide up customers or markets, or to boycott a business.

• Do not limit the availability of products or services, or refuse to deal with specific business partners, unless we 

have a reasonable business justification for doing so.

We conduct our 

business lawfully 

and in good 

conscience.

SECTION 5
Have questions or concerns? | Call the Compliance & Ethics Helpline at 877-301-CODE (2633) or FreddieMacEthicsHelpline.com 16

Fair Lending

• We monitor, assess, and mitigate fair lending risk in our business and operations. 

• Do not discriminate in any manner in the purchase or servicing of any mortgage or the marketing or sale of 

REO properties. 

• Ensure that Freddie Mac Third Parties comply with fair lending laws and regulations at every stage of the 

mortgage life cycle.

• Promote fair lending compliance and further the purposes of fair lending laws in the mortgage markets among 

our business counterparties. 

• Cooperate with FHFA and the U.S. Department of Housing and Urban Development by sharing information from 

monitoring activities.

Anti-Fraud

• Never misstate the truth or conceal information, whether on behalf of the company or for personal gain.

• Understand how to identify and report suspicious activity, including internal and external activities that are 

conducted or attempted by, at, or through Freddie Mac.

• Refer instances of actual or possible suspicious activity to:

• Internal Fraud: Contact the Compliance and Ethics Helpline

• External Suspicious Activity:

• Call the Fraud Hotline 1-800-4FRAUD8 (1-800-437-2838)

• Email Single Family Division Risk Officer (for SF mortgage related fraud) 

mortgage_fraud_reporting@freddiemac.com

• Email Multifamily Division Risk Officer (for MF mortgage related fraud) 

MF_mortgage_fraud_reporting@freddiemac.com

• Email I&CM Division Risk Officer (for ICM related fraud) ICMCCRM@freddiemac.com

• Email Financial Crimes Risk Management (all other) FCSC_fraud_reporting@freddiemac.com

Anti-Corruption

• Never offer or accept bribes, kickbacks, or illegal payments.

• Immediately report any offers of improper payments to the Ethics Office.

• Carefully supervise all third parties who act on Freddie Mac’s behalf and verify that they play fairly.

The Freddie Mac Code of Conduct | SECTION 5
Have questions or concerns? | Call the Compliance & Ethics Helpline at 877-301-CODE (2633) or FreddieMacEthicsHelpline.com 17

Business Opportunities, Innovations & Fair Dealings

• Do not circumvent or take “short-cuts” around the procedures and controls designed to mitigate the risks 

inherent in your business processes.

• Ensure new business opportunities are aligned with the Freddie Mac Mission.

• Innovations must demonstrably support our Mission, not just disrupt our competitors.

• Conduct all Freddie Mac transactions and dealings fairly, consistently, transparently, and without prejudice or bias.

• Never take unfair advantage of another employee or other stakeholder through manipulation, concealment, 

abuse of privileged information, misrepresentation of material facts or other intentional unfair-dealing practices.

• When miscommunications and misunderstandings occur, assume good intent on the part of the other party and 

correct the situation quickly.

Bringing Our Values Home

“During a team meeting of asset managers for Freddie Mac’s REO properties, one of my 

employees raised an idea she believed would increase minority homeownership. Her idea 

focused on the allocation of Freddie Mac funding for repairs of REO properties. The whole 

team was eager to put her idea into action, so I gave my approval for them to start right away. 

In a separate meeting later in the day I shared the good news. Another leader reminded me 

that before we put her plan into action we would likely have to go through other reviews and 

approvals related to our fair lending program.”

Consider Our Values

We are mission driven: Appropriately managing the risks associated with our key 

obligations, such as fair lending laws and regulations, helps us focus on the health of the 

housing finance market.

Consider the Ethical Issues at Stake

Right versus wrong: Even ideas with good intent can have legal consequences; leaders must 

be mindful of both our ethical and legal obligations when approving new initiatives. 

Due Diligence: Freddie Mac is committed to complying with applicable fair lending laws and 

regulations and as such all new ideas and initiatives must be reviewed by the appropriate 

management committees. 

The Freddie Mac Code of Conduct | SECTION 5
Have questions or concerns? | Call the Compliance & Ethics Helpline at 877-301-CODE (2633) or FreddieMacEthicsHelpline.com 18

Bringing Our Values Home

“Just before a long holiday weekend, I unexpectedly received email instructions from a supplier 

I work closely with requesting a change in their payment method. The email asked if I could 

help the supplier get the payment processed before the holiday weekend and hinted at a cash 

flow issue. I wanted to support this supplier as they have always been good partners. I spoke 

with Supplier Administration, and they helped me spot a few “red flags” – i.e., the timing of 

the request, the email address was different from the one normally used, and our required 

documentation was missing from the request.” 

Consider Our Values

We perform with excellence: While we want to be responsive to our supplier, we must follow 

documented procedures, many of which are designed to uncover “red flags” of suspicious 

activity and prevent fraud. 

Consider the Ethical Issues at Stake

Potential Consequences: This email could be from a malicious party attempting to defraud 

Freddie Mac and/or the supplier. 

Due Diligence: Our policies, procedures, and other internal controls are there to help us 

effectively and efficiently do our work – in this situation, paying the party that actually provided 

the goods and/or services. They also are designed to help us avoid inadvertently violating 

laws, regulations, and other obligations. 

The Freddie Mac Code of Conduct | SECTION 5
Have questions or concerns? | Call the Compliance & Ethics Helpline at 877-301-CODE (2633) or FreddieMacEthicsHelpline.com 19

At Freddie Mac, each of us is accountable for strong individual and team performance. 

We want real results and not just the appearance of results. All companies — even those with 

strong cultures and good intentions — may experience episodes of misconduct. 

Our Values define who we are as a company and expectations for our business conduct. It is 

important that we speak up – even when uncomfortable — if there are questions or concerns.

Seeking Advice and Reporting Misconduct

If you suspect that something isn’t right, use our resources to help make sound decisions, ask questions, and seek 

guidance. Additionally, you must self-disclose certain criminal convictions. We’re counting on you to let us know of 

actual or potential concerns.

How do I ask for guidance or report misconduct?

Contact one of these resources:

• Your manager or another manager in your division

• The Ethics Office

• The Compliance & Ethics Helpline

• Phone: (877) 301-CODE (2633)

• Internet: FreddieMacEthicsHelpline.com

• HR Connect or Employee Relations

• The Chair of the Audit Committee of the Board of Directors

Remember, the sooner you raise questions or concerns, the sooner we can resolve them, thereby minimizing any 

potential harm which may arise.

We ask for 

guidance and 

report concerns.

SECTION 6
Have questions or concerns? | Call the Compliance & Ethics Helpline at 877-301-CODE (2633) or FreddieMacEthicsHelpline.com

How does the Helpline work?

You can seek advice or report suspected wrongdoing confidentially or anonymously by contacting the Helpline, 

24 hours a day, 365 days a year.

When you call the Helpline, a third-party service center operator will answer the call. This helps you to remain 

anonymous, if you so choose. You will be assigned an access code which you can use to log back in and check on 

the status of your report, to view any update posted, and respond to any follow-up questions from the Ethics Office. 

Whether or not you choose to remain anonymous, Freddie Mac endeavors to keep your information confidential, 

consistent with the law and good business practices.

If I report misconduct, what happens next?

All reports are taken seriously. We will investigate and review the facts promptly and fairly, using an established and 

objective process.

If we determine that misconduct occurred, we will take appropriate action – up to and including discipline or 

termination of employment for the individuals responsible.

You may be asked to provide information as part of the investigation. As Freddie Mac employees, it is our duty to 

cooperate fully, and to be truthful and forthcoming. It is against our Values and the Code to act in bad faith or to 

intentionally make a false complaint or statement as part of an investigation.

If you make a report, you may not always be notified about how a situation is resolved or what action the company has 

taken. But by bringing the matter to our attention, you will have taken an important step in preserving our company’s 

values and ethical culture.

No Tolerance for Retaliation

Freddie Mac is committed to maintaining a work environment where employees can ask questions, voice concerns, 

and make appropriate suggestions without fear of retaliation.

Freddie Mac will not tolerate retaliation against any company or individual who reports a concern about potential 

illegal or unethical conduct or a violation of Freddie Mac policies or who assists in the resolution of an investigation 

or proceeding.

Additional Resources

• Mortgage Concerns: Contact Freddie Mac’s Customer Support Department at (800) FREDDIE (373-3343)

• REO Property Questions: Contact HomeSteps’ Customer Support Department at (800) 972-7555

20

The Freddie Mac Code of Conduct | SECTION 6
Have questions or concerns? | Call the Compliance & Ethics Helpline at 877-301-CODE (2633) or FreddieMacEthicsHelpline.com 21

Bringing Our Values Home

“I had an issue that I wasn’t sure would be serious enough for an investigation. I decided to 

call the Compliance & Ethics Helpline to figure out what to do. The independent operators took 

down my question; I was even able to remain anonymous if I wanted. Less than a day later, 

someone from the Ethics Office responded to my question and provided clear guidance on the 

ways I could address my concern. My issue was stressful, but knowing my choices made me feel 

a bit more in control of the situation.” 

Consider Our Values

We do the right thing: Dealing with concerns and conflicts at work can be hard and 

maintaining Freddie Mac’s culture relies on each of us leading with integrity. 

Consider the Ethical Issues at Stake

Potential Consequences: Whether you identify yourself or remain anonymous, Freddie Mac 

treats inquiries and reports of wrongdoing confidentially. Seeking help allows the problem to 

be fixed, hopefully before it becomes a much bigger problem. 

Reputational Effect: Speaking up, seeking guidance, and reporting actual or potential 

violations maintains Freddie Mac’s high standards for ethical conduct.

The Freddie Mac Code of Conduct | SECTION 6
Have questions or concerns? | Call the Compliance & Ethics Helpline at 877-301-CODE (2633) or FreddieMacEthicsHelpline.com 22

Pol/Std No. TITLE Page in Code

1-144 Business Courtesies and Sponsorships 10, 11 and 16

1-145 Outside Activities and Family Member Activities 11

1-146 Personal Investments Policy 10 and 11

1-152 Investigations Policy for Complaints 19 and 20

1-166 Policy on Policies 1

2-306 Media Relations, Publications, Internet Postings and Speeches 7, 13 and 14

3-201 Equal Employment Opportunity, Anti-Harassment, and Reasonable Accommodation Policy 4

3-210 Workplace Violence Prevention Policy 4 and 5

3-214 Corrective Action 2

S03-216.1.A Post-Employment Corporate Information Protection 7

3-219 Alcohol and Drug Abuse Policy 5

3-225 Relationships in the Workplace Policy 11

3-227 Background Checks 19

3-282 Prohibition of REO Purchases 11

4-101 Financial Reporting Risk Policy 2

6-300 Acceptable Use and Management of End User Technology 7

7-105 Compliance with Antitrust Laws 10 and 17

7-115 Information Wall Policy 10

7-204 Fair Lending Policy 16

7-301 Diversity, Equity and Inclusion Policy 4

7-501 Regulatory Reporting 10

7-502 Responding to FHFA Examination and FHFA OIG Requests 13

7-600 Disbursements to Tax-Exempt Organizations and Prohibition of Corporate Political Activity 11

7-602 Personal Political Activities of Freddie Mac Employees 11

7-605 Contacts with Government Officials 11 and 13

7-710 Policy on Document Lifecycle and Legal Holds 8

8-300 Intellectual Assets 8 and 14

9-112 Travel and Business Expenses Policy 7

9-200 Procurement of Products and Services 4, 10, 11 and 16

9-400 Contractor Workforce Management 1 and 11

11-101 Enterprise Risk Policy 2

11-113 Information Risk Policy 7, 8, 13 and 14

S11-113.D Cybersecurity Standard 8

S11-113.E Information Privacy Standard 7 and 8

11-127 Financial Crimes Compliance Risk Policy 16

Related Policy/Standard Index
Have questions or concerns? | Call the Compliance & Ethics Helpline at 877-301-CODE (2633) or FreddieMacEthicsHelpline.com

This Code of Conduct, Freddie Mac Corporate Policy #1-140, has been approved by the Audit Committee of the 

Freddie Mac Board of Directors. It has an effective date of January 1, 2023. It contains information pertaining to 

certain Freddie Mac policies and practices. Every Freddie Mac employee is expected to read this Code carefully as 

it describes the standards of conduct that govern our business dealings. If you have any questions or concerns about 

this Code of Conduct, please consult your manager or the Ethics Office.

This Code and all Freddie Mac policies do not alter the at-will employment relationship between Freddie Mac and 

any employee. Nothing contained in this Code of Conduct or Freddie Mac policies constitutes a contract or creates 

any contractual or equitable obligations on the part of the company; nor does anything in this Code or Freddie Mac 

policies expand or increase any employee or third party’s legal rights or the company’s legal obligations.

Freddie Mac may elect to amend this Code at any time. A current version of the Code can be found on Freddie Mac’s 

internal and external websites.

Matters relating to the interpretation of this Code and your agreement to this Code, or to the interpretation of any 

other company policy, will be governed by the laws of the Commonwealth of Virginia, without regard to its conflict 

of law provisions.

This Code is the property of Freddie Mac and all rights are reserved.