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Codes of Conduct

Freddie Mac has built our business on the basis of service, trust and confidence, making us a leader in the mortgage finance industry. How we conduct ourselves, both individually and collectively, represents the conduct of Freddie Mac. Freddie Mac has had a strong Code of Conduct for many years, with separate versions that apply to employees and Directors. In October 2014, the Audit Committee of Freddie Mac's Board of Directors (the "Audit Committee") approved revisions (effective October 8, 2014 and updated April 24, 2015) to the Employee Code that aligned the Code with certain policy updates relating to expense policies, procedures and compliance programs, as well as updated certain related policy references. Effective September 18, 2015, both Codes were updated to add clarifications regarding reporting wrongdoing. On January 26, 2016, the Employee Code was updated to reflect changes to policy references. On March 16, 2016, the Audit Committee approved revisions to the Employee Code and on March 17, 2016 Freddie Mac's Board of Directors (the "Board") approved revisions to the Director Code. In both instances the revisions were designed to add provisions that previously resided in three retired policies and to update provisions relating to personal investments. One additional revision to the Employee Code was designed to address the requirement of FHFA's new Corporate Governance Rule to include provisions applicable to the CEO, CFO, and Principal Accounting Officer/Controller pertaining to disclosures relating to the Company's financial condition. On September 8, 2016, the Audit Committee approved revisions to the Employee Code, which included aligning the Employee Code with the Company's updated Values and modernizing its layout and organization. The revised Employee Code became effective on January 1, 2017, with minor updates June 6, 2017, including certain policy reference updates. On September 9, 2016, the Board approved revisions to the Director Code consisting of minor technical changes. The Board approved additional minor technical changes on June 7, 2017. On February 26, 2018, the Employee Code was updated to reflect a change to the corporate values, adding the value of Diversity.

Audit Committee Complaint Procedures

Freddie Mac's complaint policy for accounting, internal accounting controls and auditing matters pertaining to the company's business has been created in accordance with the Sarbanes-Oxley Act of 2002 and the corporate governance rules of the NYSE. The policy establishes processes, and defines responsibilities for the receipt, retention and prompt resolution of complaints, including the confidential, anonymous submission by employees of concerns regarding questionable accounting or auditing matters.