Table of Contents

A Message from the Chairman and CEO

Our Mission

Our Values

Our Dedication to Risk Management Accountability

Purpose and Scope of the Code

Our Responsibilities

Our Responsibilities as Employees

Additional Responsibilities of Managers

Responsibilities of the Corporate Compliance Division

Where to Get Help

The Compliance & Ethics Helpline (877-301-CODE)

Reporting Potential Wrongdoing

Questions About the Code of Conduct

Non-Retaliation Policy

Who to Contact

Respect for Each Other

Diversity

Equal Opportunity and Nondiscrimination

Harassment

Giving and Accepting of Gifts Among Employees

Substance Abuse

Pornography

Violence

Confidentiality of Employee Information

Our Customers

Fairness

Confidentiality of Customer Information

Avoiding Conflicts of Interest

Accepting Gifts, Meals and Entertainment

Providing Gifts and Entertainment

Travel and Lodging Expenses

Loans, Discounts and Other Preferential Treatment

Bribes, Kickbacks and Other Illegal Payments

Outside Employment and Other Outside Activities

Immediate Family and Household Members

Relationships in the Workplace

Personal Investment Limitations

Our Investors

Inside Information

Information Wall and Restricted Persons

“Window Periods” and Pre-Clearance of Transactions in Freddie Mac Securities

Truthful and Accurate Reporting

Improper Influence on Conduct of Audits

Freddie Mac Property and Information

Fraud and Theft

Use of Freddie Mac Property and Systems

Internet and E-mail Communications

Corporate Opportunities

Intellectual Property

Confidential Information

Records Management

Post-Employment Restrictions

Our Vendors, Consultants and Other Business Partners

Fair Dealing

Documentation of Expenditures

Vendor Selection

Third-Party Information

Fair Competition

Anti-Competitive Activities

Competitive Information

Our Role in the Community

Compliance With Legal Requirements

Corporate Community Activities

Personal Community Activities

Interacting With the Media, the Investment Community and Others Outside Freddie Mac

Personal Public Statements and Publications

Political Activities