Table of Contents

WHO MUST COMPLY WITH THIS CODE OF CONDUCT?

I. INTRODUCTION

A. How the Provisions of the Code Are Organized

B. Code Availability and Revisions

C. Corporate Policies and Procedures

II. BASIC STANDARDS OF ETHICAL CONDUCT AT FREDDIE MAC

IV. CONDUCT RELATING TO FREDDIE MAC AND ITS EMPLOYEES

A. Compliance with Legal Requirements

B. Giving and Receiving Gifts, Donations and Contributions

D. Freddie Mac Property and Information

1. Freddie Mac Property

2. Confidential Information

3. Responding to Requests for Information

E. Fraud and Dishonesty

F. Record Keeping and Reports

V. CONDUCT RELATING TO THIRD PARTIES

A. Improper Influence on Conduct of Audits

B. Corporate Opportunities

C. Receiving Benefits from Persons Outside of Freddie Mac

D. Providing Benefits to Third Parties, Including Members and/or Staff of a Legislative/Regulatory Body

E. Fair Dealing

F. Political and Other Personal Activities

G. Immediate Household Members, Family and Friends

VI. INVESTMENTS

A. Inside Information

B. Pre-Clearance of Transactions

C. Personal Securities Investments

1. Financial Interests Generally

2. Freddie Mac Options, Short Sales and “Short Sales Against the Box”

3. Public Offerings

D. Additional Rules Concerning Purchases and Sales of Freddie Mac Securities by Directors

VII. ENFORCEMENT

A. Questionnaire

B. Reporting Possible Violations of Law, the Code, or Company Policy

C. Anti-Retaliation

D. Investigations and Document Retention

E. Amendments, Waivers and Interpretation

F. Applicable Law

ACKNOWLEDGMENT AND AGREEMENT TO COMPLY