Freddie Mac Property and Information
Information, computer and other Freddie Mac resources are vital assets that are owned by the Company, or, in some cases, third parties who make these assets available to Freddie Mac under a license agreement. As employees, we all have an obligation to protect Freddie Mac’s assets and promote their efficient use. The following sections discuss, in particular, the protection and use of Freddie Mac’s physical property and systems, intellectual property, and confidential information.
Fraud and Theft
It is the intent of Freddie Mac to promote ethical and professional behavior amongst its employees. In addition, Freddie Mac is committed to protecting its revenue, property, reputation and other assets. Any act by a Freddie Mac employee that involves theft, fraud, embezzlement or misappropriation of any property or funds (whether owned by Freddie Mac or someone else) is prohibited.
| Policies & Procedures | |
|---|---|
| Policy 1-150 | Complaint Policy for Accounting, Internal Accounting Controls and Auditing Matters Pertaining to Freddie Mac’s Business |
| Policy 3-214 | Progressive Discipline |
| Policy 11-213 | Mortgage Fraud Prevention, Detection and Resolution |
| Policy 11-214 | Mortgage Fraud Reporting |
| Policy 11-215 | Anti-Fraud Policy |
Use of Freddie Mac Property and Systems
We are responsible for safeguarding and maintaining any Freddie Mac property that is entrusted to our control. We will exercise reasonable care to avoid damage or unusual wear and tear. Similarly, we will protect Freddie Mac assets by refraining from installing or using unapproved or unlicensed software, bypassing the Company’s information security measures or otherwise tampering with systems or data in an unauthorized or harmful manner. In general, we will use Freddie Mac funds, resources, communication systems (such as e-mail, Internet access and telephones) and other assets only for business-related purposes and in a manner that complies with Company policy and promotes their efficient and legal use. Freddie Mac corporate policies, however, do permit the occasional, incidental personal use of Freddie Mac’s electronic communications systems and limited use of Company property for charitable, community or professional association activities, particularly those with which Freddie Mac is associated.
| Policies & Procedures | |
|---|---|
| Policy 6-300 | Use of Freddie Mac Electronic Communications Facilities — Telephones, E-mail and the Internet Connection |
| Policy 7-602 | Personal Political Activities of Freddie Mac Employees |
Internet and E-mail Communications
Freddie Mac encourages us to use the Internet and e-mail to make research and communications more effective and efficient. The main purpose of these systems is to facilitate the Company’s business objectives, and their use must be appropriate and consistent with corporate policies. We all have a responsibility to maintain and enhance Freddie Mac’s public image and to use all the Company’s assets, including communication systems, in a productive manner. The integrity of these systems also requires that we secure our passwords and other personal access information in order to prevent unauthorized access to Freddie Mac’s systems. Freddie Mac monitors activity occurring in the Company’s facilities, including electronic communications facilities, in such manner as Freddie Mac considers appropriate.
| Policies & Procedures | |
|---|---|
| Policy 6-300 | Use of Freddie Mac Electronic Communications Facilities — Telephones, E-mail and the Internet Connection |
Corporate Opportunities
Employees owe a duty to Freddie Mac to advance the Company’s business interests to the best of their abilities. In addition, Freddie Mac employees may not compete with Freddie Mac. For example, an employee may not take for himself or herself a business opportunity that is discovered in the course of Freddie Mac employment or representation, or that is developed through the use of corporate property, information or position, unless Freddie Mac has already been offered the opportunity and informed the employee in writing that it will not pursue the opportunity.
Intellectual Property
Freddie Mac’s intellectual property (such as ideas, inventions, discoveries, trade secrets, copyrighted material, patented material and trademarks) is a valuable corporate asset. Subject to certain exceptions described in the Freddie Mac policies referenced below, Freddie Mac owns everything (including products, processes, information, models, financial and data structures, software, documentation, methodologies and other materials, and all related intellectual property) that is created or modified by employees in connection with their jobs, produced using Freddie Mac resources, or related to Freddie Mac’s business or demonstrably anticipated research.
By signing (electronically or otherwise) the acknowledgment and agreement to comply with this Code of Conduct, each employee agrees that Freddie Mac owns, and assigns to Freddie Mac, all of the items and intellectual property described in the preceding sentence. This assignment does not apply to any invention that is created without using Freddie Mac equipment, supplies, facilities, confidential information or other resources and that is developed entirely on the employee’s own time, unless the invention relates to the business of Freddie Mac or to Freddie Mac’s actual or demonstrably anticipated research and development, or the invention results from any work performed by the employee for Freddie Mac. Additional information related to this assignment can be found in Freddie Mac’s Patent Policy.
| Policies & Procedures | |
|---|---|
| Policy 8-101 | Copyright Policy |
| Policy 8-200 | Trademark Policy |
| Policy 8-300 | Patent Policy |
To safeguard Freddie Mac’s intellectual property assets, we will:
- Protect Freddie Mac’s assets from unauthorized use, copying or disclosure;
- Affix appropriate trademark, service mark, and copyright symbols and confidentiality legends to Freddie Mac assets;
- Assist Freddie Mac, both during and after employment with Freddie Mac, to obtain patent and other intellectual property protection for Freddie Mac assets;
- Promptly disclose to management and the Legal Division any intellectual property we develop that Freddie Mac owns (as described above); and
- Assist Freddie Mac to identify situations where a third party is making unauthorized use of a Freddie Mac asset or intellectual property.
We also will respect the intellectual property rights of third parties, as further described elsewhere in the Code and in corporate policies.
Confidential Information
Information we develop, or to which we gain access, in connection with our employment at Freddie Mac is an important corporate asset that must be used only for Freddie Mac business purposes. This information also must be protected from inappropriate disclosure to customers, competitors, financial analysts, the media and other third parties. With the exception of information that is publicly available, all information concerning Freddie Mac or its business should be considered confidential. Certain information ( “confidential information”) must be handled with a particularly high level of care to avoid unauthorized disclosure and use.
Examples of confidential information include, but are not limited to the following items that have not been made publicly available by Freddie Mac: (1) Freddie Mac’s business plans, strategies and practices; (2) financial information, models and analyses; (3) information related to Freddie Mac’s software, databases and other systems including their structure and content; (4) matters related to legal advice or legal proceedings; and (5) non-public information about borrowers and employees. In addition, some personal information about borrowers and employees that is arguably available to the public is confidential information because we are obligated to keep it confidential under applicable laws, contracts or Company policies.
| Policies & Procedures | |
|---|---|
| Policy 7-115 | Information Wall Policy |
| Policy 8-400 | Confidentiality of Information |
| Policy 8-500 | Information Privacy |
| Policy 11-212 | Security of Corporate Information |
We will safeguard confidential information that belongs to or is in the possession of Freddie Mac by taking prudent steps to protect its confidentiality and restrict its use. Such steps include:
- Not discussing confidential information with anyone outside of Freddie Mac, including our immediate family or household members, unless we are authorized to do so;
- Not discussing confidential information with any other Freddie Mac employee or third party unless the individual in question has a Freddie Mac business-related need to know the information;
- Following Company policies and procedures for identifying, using, protecting and disclosing this information;
- Avoiding discussion of confidential information in public areas, such as restaurants, planes or taxis;
- Returning or otherwise taking reasonable precautions to protect against unauthorized access or use when disposing of confidential information;
- Keeping confidential information in protected places (such as secured offices, locked drawers, and password-protected computer systems);
- Taking appropriate precautions when transmitting confidential information, either within or outside the Company; and
- Taking such other steps as are required by law, contract or corporate policy.
Records Management
Records are Company assets that should be properly controlled, organized, and managed in ways that allow them to be found, retrieved and used by authorized individuals in the future. A record is any information, regardless of its format, storage location or medium, that is created or received in the conduct of business that must be preserved as evidence of the Company’s functions, policies, decisions, procedures, operations or other business activities. For example, a record may be an attestation, policy, control, employee file, financial statement, regulatory report, or audit report.
Length of record retention is determined by applicable legal, regulatory and business record-keeping requirements and is the responsibility of those business areas that own the record for the Company. If records must be retained, but are no longer needed on-site, they should be archived to a Company-approved off-site storage location. Only records that have met their retention requirements and that are not relevant to an ongoing litigation matter, investigation or audit may be destroyed. And when records are destroyed, they must be destroyed in a secure, confidential manner.
| Policies & Procedures | |
|---|---|
| Policy 7-800 | Corporate Records Management Policy and Retention Schedule |
Post-Employment Restrictions
We recognize that when our employment with Freddie Mac ends, we will continue to be bound by the rules set forth in this Section (“Freddie Mac Property and Information”) and in the related corporate policies.