VII. ENFORCEMENT
A. Questionnaire
As part of its processes concerning compliance with applicable law and corporate policy, management conducts periodic audits of compliance with policies and procedures, including this Code.
You are required to respond to an annual Proxy Questionnaire that requires disclosure of certain relationships, including all relationships with Freddie Mac or a competitor, that existed during the previous year. Any changes in such relationships also must be reported.
Completing the annual questionnaire does not relieve you of your continuing obligation to make disclosures or to seek advice at any time that such disclosures or inquiries may be required under applicable law, any other provision of the Code or any applicable corporate policy or procedure. You are encouraged to seek advice and assistance in order to resolve any question about or gain an increased understanding of the requirements of applicable law, the Code or other corporate policy.
B. Reporting Possible Violations of Law, the Code, or Company Policy
As a Director of the Company, you should share any concern about possible violation of the terms of the Code, applicable law or corporate policy with the Chairman of the Board, or if the Chairman of the Board is an Employee, with the Lead Director.
C. Anti-Retaliation
You are prohibited from engaging, directly or indirectly, in any form of retaliatory, intimidating or discriminatory conduct toward any Freddie Mac Employee or any vendor who, based on his or her reasonable good faith belief of a violation of law, of the Code of Conduct or a policy or procedure adopted by the Board or management, engages in “Protected Conduct,” as defined below.
Protected Conduct includes any of the following actions:
- Making a complaint or causing a complaint to be made;
- Filing, causing to be filed or testifying in a proceeding;
- Providing information concerning or in connection with a complaint, inquiry, investigation or proceeding or causing such information to be provided; or
- Assisting or otherwise participating in the resolution of a complaint or in an investigation or proceeding.
The actions specified above include the communication of information to or through any of the following:
- Any complaint reporting mechanism established by the company;
- The employee’s supervisor;
- Any Freddie Mac officer or Employee with authority to investigate, discover or terminate misconduct; or
- A law enforcement, regulatory, or judicial authority or a committee or member of Congress.
D. Investigations and Document Retention
Consistent with applicable law, you are required to cooperate fully, promptly and truthfully in any investigation, including responding to requests for information, participating in investigatory interviews and disclosing all known information relating to the subject matter of the investigation. You should not destroy or alter any Freddie Mac business-related record with the intent to obstruct any pending or threatened investigation.
E. Amendments, Waivers and Interpretation
Only the Board has authority to make material modifications to this Code and to grant a waiver of any standard or requirement of the Code. Waivers will be disclosed to the company’s shareholders as required by applicable law. Waivers are disfavored and in no event will a waiver be granted in the absence of good cause based on exceptional circumstances.
The Board has final authority to determine whether any Director’s conduct or action violates the Code or any other applicable Corporate Policy.
F. Applicable Law
Matters relating to the interpretation of this Code will be governed by the laws of the Commonwealth of Virginia, without regard to its conflict of law provisions.
Effective Date:
New
Replaces Policy 1-141 dated June 27, 2005