Subject: Code of Conduct for Members of Freddie Mac’s Board of Directors

Policy Number: 1-141

Control Point: Chief Compliance Officer

Approval Authority: Board of Directors

Signature: ____________________________________

CODE OF CONDUCT
FOR
MEMBERS OF FREDDIE MAC’S BOARD OF DIRECTORS

A MESSAGE FROM THE CHAIRMAN OF THE BOARD

Every morning when Freddie Mac opens for business, its employees begin working with one goal in mind: to make home possible for America’s families. That’s a special mission – one we take very seriously. For more than 30 years we have fulfilled our duty to America’s homeowners and renters—saving those we serve tens of thousands of dollars on their individual mortgages—while delivering lasting value to all those who invest in Freddie Mac, because they believe in us and our mission.

The purpose of the Code of Conduct is to help us maintain the highest standards of business and ethical conduct as members of Freddie Mac’s Board of Directors. It is our guide to ethical standards of business conduct and decision-making. It requires that when we conduct Freddie Mac business we act at all times with integrity, avoiding conflicts of interest in personal and professional relationships. It also requires that we treat others with dignity and respect. Each of us is required, when we conduct Freddie Mac business, to act at all times in accordance with the terms of this Code.

Because it is impossible to anticipate and to provide standards for all matters that may arise in a business as complex as ours, the standards in this Code of Conduct are expressed generally and may not address every specific circumstance. Accordingly, several corporate policies, procedures and processes also govern specific actions related to your responsibilities as a Director. Each of us has an obligation to conform our conduct to the standards set forth in this Code of Conduct as well as in applicable corporate policies.

Compliance with the literal words of the Code may not be sufficient to ensure compliance with its spirit. As a shareholder-owned, government-sponsored enterprise, our obligation to uphold principles of ethical conduct is greater than that of other companies. We have a position of public trust and must never compromise it. Our conduct must always be above reproach. For all of these reasons, the guidance expressed in the Code should be considered minimum standards. If you have a question about whether certain conduct could give rise to the appearance of a conflict of interest, or raise other issues under the Code of Conduct, please consult with the Chief Compliance Officer.

As members of the Board of Directors, we must make a personal commitment to live by this Code of Conduct. The distribution of this Code of Conduct is not an end in itself, but a part of our ongoing commitment to ensuring ethical conduct in all business relationships at Freddie Mac. Through your interaction with other Directors and Freddie Mac employees, you should communicate your commitment to compliance with the requirements of the company’s Codes of Conduct and all other applicable corporate policies.

Each member of the Board should execute the attached Acknowledgment and Agreement to Comply with this Code of Conduct. This statement acknowledges our responsibility to become familiar with the contents of this Code of Conduct and constitutes our agreement to comply with its requirements.

Richard F. Syron
Chairman