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EEO and Harassment-Free Workplace Policy

Subject: EEO and Harassment-Free Workplace Policy

Policy Number: 3-201

Control Point: Director - Employee Strategies and Practices

Approval Authority: SVP - Human Resources

Signature: Keith Green [Signature on original kept by Legal]

Summary of this Policy

Freddie Mac is committed to providing its applicants, customers and company visitors with a professional environment, free from all forms of unlawful discrimination and harassment based on gender, race, color, religion, national origin, age, marital status, veteran status, sexual orientation, gender identity/expression, physical and mental disability, pregnancy, ethnicity, genetic information and other characteristics protected by law (collectively referred to as "protected characteristics").

Freddie Mac is committed to making employment-related decisions on the basis of legitimate, non-discriminatory business considerations. Discrimination on the basis of any protected characteristic is expressly prohibited. Freddie Mac will not tolerate conduct by an employee that harasses others, interferes with another's work performance or creates an intimidating, offensive or hostile environment on the basis of any protected characteristic.

I. Discrimination

Discrimination includes making employment-related decisions based on an individual's protected characteristics. Employment-related decisions include, but are not limited to, decisions with respect to hiring, termination, promotion, compensation, job assignment, and training opportunities.

II. Harassment

Harassment is any conduct that unreasonably interferes with an employee's work performance or creates an intimidating, hostile, or offensive work-related environment (including, for example, business travel, conferences, social events) for employees or applicants based on a protected characteristic.

For the purposes of this policy, the term "harassment" should be interpreted broadly. Examples of prohibited harassment include, but are not limited to, the following:

Verbal Harassment. Verbal harassment includes unwelcome or derogatory comments based on a person's protected characteristics. It also includes threats of physical harm, threats of adverse employment action and the distribution or display of written or graphic materials that are unwelcome and/or derogatory and are directed at a person or group of people because of their protected characteristic(s). The display of sexually suggestive or graphic material on Freddie Mac property falls within this definition and is strictly prohibited.

Physical Harassment: Physical harassment includes hitting, pushing, touching, or making inappropriate gestures or expressions towards a person or group of persons because of their protected characteristics. (Such conduct may also violate Freddie Mac's Corporate Policy 3-210, Workplace Violence Prevention Policy.)

Electronic Harassment: Electronic harassment includes the use, solicitation, access, or distribution of material by electronic means that is unwelcome, demeaning, and/or derogatory towards any person or group of persons because of their protected characteristics. It also specifically includes the use of the Internet on Freddie Mac property or using Freddie Mac systems or equipment for the purpose of accessing or viewing sexually suggestive or graphic materials, or materials that are otherwise derogatory, hateful, or demeaning towards any person or group of persons because of their protected characteristics. Further information regarding the use of electronic media can be found in Freddie Mac's Corporate Policy 6-300, Use of Freddie Mac Electronic Communications Facilities - Telephones, E-mail and the Internet Connection.

Employment in Exchange for Sexual Favors: Employment in exchange for sexual favors includes taking or refraining from taking any employment action on the basis of an employee's willingness to engage in a social, romantic or sexual relationship. Freddie Mac prohibits all forms of unwelcome sexual conduct or conduct of a sexual nature, whether verbal or physical, in the workplace including, among other things, sexual advances and requests for sexual favors, regardless of whether the conduct was designed or intended to promote an intimate relationship.

III. Reasonable Accommodations

Freddie Mac is committed to providing a professional environment free from unlawful disability discrimination. In considering requests for reasonable accommodations based on disabilities, Freddie Mac and the Wellness Center will comply with all applicable federal, state or local disability discrimination laws.

Employees who wish to request such an accommodation should follow the Job Modification Request Procedure located on HomeFront on the Human Resources website under Employee Resources. In addition, an applicant may inform his or her recruiter if s/he needs a reasonable accommodation during the pre- or post-offer stage of the hiring process.

IV. Reporting Violations of this Policy

Freddie Mac seriously considers every complaint of discrimination or harassment, will thoroughly investigate all such complaints in an impartial manner, and promptly take appropriate remedial action in response to violations of this Policy. Employees or applicants who believe they have observed or experienced actions in the workplace that may violate this policy are encouraged to immediately report the violation so that the company may investigate and take prompt remedial action, if appropriate. Employee reports of suspected violations of this policy shall be made to any one of the following:

  1. His/her immediate supervisor.
  2. His/her next level supervisor.
  3. Any Officer.
  4. Any HR Business Partner.
  5. Any member of the Employee Relations Staff of the Human Resources Division.
  6. Through the Corporate Compliance Hotline.

In addition, any member of management who becomes aware of facts that suggest that a violation of this policy may be occurring is required to report those facts to an Employee Relations employee. For purposes of this policy, member of management means any Freddie Mac officer, director- level employees, as well as any employee who has supervisory responsibilities (i.e. the authority to undertake a tangible employment action affecting an employee, such as hiring, firing, promoting, demoting or reassigning).

Once the Employee Relations Unit becomes aware of facts suggesting a possible violation of this policy, it will conduct an investigation. All employees are required to fully cooperate with any investigation. Failure to fully cooperate during the course of a company investigation, failure to respond to the company's request for information, failure to attend scheduled interviews, or failure to truthfully disclose all information related to the subject matter of the investigation will result in disciplinary action up to and including termination. An employee who knowingly makes a false claim may be subject to disciplinary action up to and including termination.

Non-employees of Freddie Mac, including customers, guests, independent contractors, and contingent workers, who believe this policy has been violated, should immediately report the violation to their own employers. Simultaneously, Freddie Mac encourages non-employees to make the Employee Relations Staff of the Human Resources Division or an HR Business Partner aware of the suspected violation. Applicants for employment should discuss concerns with the Recruiter they are working with.

V. Non-Retaliation

Freddie Mac strictly prohibits retaliation against employees or applicants who file complaints under this policy based on their reasonable belief that this policy has been violated. Freddie Mac also strictly prohibits retaliation against employees or applicants who participate in any investigation or resolution of potential violations of this policy. This prohibition on retaliation extends to negative employment or post-employment actions, verbal abuse, or other adverse treatment in the workplace by either supervisors or by other employees. Each member of management is responsible for implementing this non-retaliation policy in his or her work group.

VI. Confidentiality

Freddie Mac will treat every complaint and investigation confidentially to the extent practicable and disclosures will be made based on a business need-to-know basis.

Effective Date: April 13, 2011

Replaces Policy 3-201 dated November 4, 2010

Reviewed by Legal or Determined that No Legal Review Necessary

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