V. CONDUCT RELATING TO THIRD PARTIES
A. Improper Influence on Conduct of Audits
In accordance with legal and regulatory requirements, independent auditors periodically audit Freddie Mac’s financial statements. You may not, directly or indirectly, take any action to coerce, manipulate, mislead or fraudulently influence any independent or certified public accountant engaged in the performance of an audit or review of Freddie Mac’s financial statements for the purpose of rendering such financial statements materially misleading, nor may you direct any other person to do so. The same restrictions apply to the audit and examination activities of regulators and internal auditors.
You are required to cooperate fully, promptly and truthfully in your capacity as a Director in any audit of the company’s financial statements. This obligation includes, but is not limited to, responding to requests for information, participating in interviews, and disclosing all information relating to the subject matter of the audit.
B. Corporate Opportunities
Do not directly or indirectly take personal advantage of, use for your personal benefit or gain, or use for the benefit or gain of any other business entity any Freddie Mac business or other opportunities that you learn of through your position with Freddie Mac or through the use of Freddie Mac information or property. You should advance Freddie Mac’s business interests when the opportunity to do so comes to your attention as a result of your status as a Director of Freddie Mac or your use of Freddie Mac information or property. You should not engage in any business activities that create a conflict of interest given your position as a Director of the company.
C. Receiving Benefits from Persons Outside of Freddie Mac
You should refuse gifts, favors, travel, entertainment, loans, discounts or other preferential treatment from an outside source, or reimbursement for such items, if they could appear to represent an attempt by the outside source to obtain favorable treatment in its business dealings with Freddie Mac.
D. Providing Benefits to Third Parties, Including Members and/or Staff of a
Legislative/Regulatory Body
You may not give any gift, favor or any other item of value to a third party in order to influence the opinions expressed by, or information provided to, any investment banker, research analyst, investor or counterparty about Freddie Mac.
Current federal law creates potential liability for corporations whose representatives violate the Congressional gift rules. Therefore, when you are acting on behalf of Freddie Mac, you must obtain prior written approval from the Senior Vice President, External Relations, before providing any gifts, favors, food, refreshments or entertainment to any federal, state, or local government official or employee. You will be considered to be acting on behalf of Freddie Mac if you are performing your Freddie Mac duties or conducting Freddie Mac business. For example, you will be considered to be acting on behalf of Freddie Mac if you provide a gift in the course of a meeting or event related to Freddie Mac or provide a gift together with a communication related to Freddie Mac business. A gift for which you seek reimbursement from Freddie Mac also will be considered to have been made on behalf of Freddie Mac.
E. Fair Dealing
When fulfilling your responsibilities as a Director of Freddie Mac, you should deal fairly with all third parties, including competitors, financial institutions, business partners, customers, clients, vendors and all others with whom you interact in your capacity as a Director of Freddie Mac or for any Freddie Mac business-related purposes.
F. Political and Other Personal Activities
The conduct of Freddie Mac, like that of other large corporations, is subject to close scrutiny from many sources. For this reason, it is particularly important that any public statement or act attributable to Freddie Mac be carefully thought out and that your personal views be kept separate from corporate views.
Individual participation in the political process is an essential part of our society and you may fully engage in the political process consistent with your personal views, convictions and interests without regard to Freddie Mac’s business interests. However, you also must distinguish your views from those of Freddie Mac when engaging in personal political activity.
G. Immediate Household Members, Family and Friends
You may not evade the provisions of this Code or of any applicable Corporate Policy or Procedure by asking another person to do something that the Code or a Policy or Procedure prohibits you from doing personally. However, the Code does not prohibit Immediate Household Members, other family members, or friends from doing things in connection with their employment solely because you are prohibited from doing them as a Freddie Mac Director.