Our Responsibilities
The Code of Conduct is designed to make Freddie Mac a better place for all of us as employees. We all want to be proud of the place we work, and the Code supports this goal by helping to ensure that our business-to-business and employee-to-employee dealings and interactions are conducted with integrity and respect for one another. The Code is not simply a set of rules dictated by upper management, but rather represents a set of values and standards of behavior designed to ensure that all of us benefit from a healthy Freddie Mac business culture. By accepting employment with Freddie Mac and acknowledging the Code, each of us has joined this community and embraced these values and standards.
Our Responsibilities as Employees
As Freddie Mac employees, we are in the best position to enhance the Company’s reputation in the community and to make Freddie Mac a better place to work. Each of us is required to review and follow the Code, as well as Freddie Mac’s policies and procedures. Corrective action, including dismissal, may be taken against any employee who violates the Code or participates in any violation of the Code.
Each of us is responsible for fostering the integrity of our workplace by helping to enforce the Code’s provisions. If you become aware of any issue or practice involving a potential violation of a federal, state, local or foreign law, or Freddie Mac policy or procedure, including the Code, you are strongly encouraged to report the matter immediately to your manager, Corporate Compliance, or another appropriate person (see the “Where to Get Help” section in this Code). We are empowered to take action when necessary to help ensure that Freddie Mac’s operations will be undertaken ethically and lawfully.
Freddie Mac will investigate and resolve any known or suspected violation of applicable law, the Code or corporate policy in a prompt, fair and impartial manner, in accordance with applicable corporate policies and procedures. The scope and precise manner in which an investigation is conducted will vary depending upon the circumstances of the conduct being investigated. You are obligated to cooperate fully, promptly and truthfully in any internal investigation. This obligation includes, but is not limited to, responding to requests for information, participating in investigatory interviews, and disclosing all information relating to the subject matter of the complaint. Failure to cooperate fully, promptly and truthfully in an investigation or to keep an investigation appropriately confidential may be grounds for discipline, up to and including dismissal.
| Policies & Procedures | |
|---|---|
| Policy 1-150 | Complaint Policy for Accounting, Internal Accounting Controls and Auditing Matters Pertaining to Freddie Mac’s Business |
| Policy 3-201 | EEO and Harassment-Free Workplace |
| Policy 3-214 | Progressive Discipline |
| Policy 3-215 | Internal Complaints Excluding EEO/Harassment |
Additional Responsibilities of Managers
For purposes of the Code, “managers” includes officers and director-level employees, as well as any employee who has supervisory responsibilities (i.e., the authority to undertake a tangible employment action affecting an employee, such as hiring, firing, promoting, demoting or reassigning). In addition to their responsibilities as employees, managers must lead by example and set a tone that reinforces the importance of compliance. Managers cannot ignore potential Code, legal or Corporate Policy violations that they witness first-hand or learn about through other means, including communications with employees. They are required to report any such concern, and the basis for the concern, to the Corporate Compliance Division, either directly or through the Compliance & Ethics Helpline.
Managers must also make themselves available to employees who have ethical questions or wish to report possible misconduct. Managers must assist in enforcing the Code through appropriate corrective measures. Corrective action may be taken against someone who directly or indirectly supervises an employee who violated the Code, if the circumstances of the violation reflect inadequate supervision or a failure by the individual to promote ethical or lawful behavior among employees under his or her supervision.
Responsibilities of the Corporate Compliance Division
The Corporate Compliance Division works with Freddie Mac employees at all levels to foster a corporate culture of integrity. In that role, Corporate Compliance is responsible for administration and interpretation of the Code, except where corporate policy provides that a particular subject is to be administered and interpreted by another area.