Our Vendors, Consultants and Other Business Partners

We value the quality of our relationships with our suppliers and vendors and recognize that it is in Freddie Mac’s best interest to ensure that purchases of goods and services are based on quality, service, price and suitability. Individuals who have responsibility for engaging suppliers or vendors should approach these duties with diligence.

Fair Dealing

When conducting Freddie Mac business, we will deal fairly with all vendors, financial institutions, competitors and others with whom we interact for any Freddie Mac business-related purposes. When transacting business, we will not misrepresent material facts, manipulate or conceal non- confidential business information necessary to understand a proposed business transaction, disclose or threaten to disclose confidential business information or otherwise engage in any other type of unfair dealing or practice.

Documentation of Expenditures

We will make expenditures on behalf of Freddie Mac only if we are authorized to do so. Goods and services will be procured in compliance with the Company’s purchasing policies and procedures, and we will complete required documentation accurately and timely.

Vendor Selection

When purchasing materials or services, including the services of consultants, we will strive to ensure that Freddie Mac receives the best available materials and services based on competitive terms and prices.

Policies & Procedures
Policy 9-200	Procurement of Products and Services
Policy 9-400	Contingent Workforce Management

Self-Dealing

Q: Mary, a manager in my division, has contracted with ABC Company to provide contingent workers for a project she is managing. One of the contingent workers just told me that ABC’s team was subcontracted from XYZ Consulting, and that XYZ Consulting is owned by Mary’s husband. Mary never told anyone in the division about the source of ABC’s workforce or about her relationship to XYZ. Is Mary violating the Code of Conduct?

A: Yes, and here’s why. This is a matter of self-dealing. A conflict exists if the employee’s spouse (from the example above) runs a consulting company, and the employee uses her position to place contingent workers at Freddie Mac. This is particularly true if the spouse’s workers are placed under her direction. When the employee places (or attempts to place) workers from her husband’s consulting firm at Freddie Mac, she is creating a situation in which Freddie Mac is unknowingly negotiating with its own employee over the cost of contingent worker time. While some conflicts caused by family relationships can be addressed through disclosure and separation of duties, in this case, the contingent workers were being selected by, and reporting to, the person who had the conflict. If you are aware of a situation like the one described above, we encourage you to speak to your manager or to call the Compliance & Ethics Helpline
(1-877-301-CODE).

Third-Party Information

In the normal course of doing business, we may acquire confidential information about other companies or their personnel, including current or potential suppliers and vendors. We will safeguard such confidential information in accordance with applicable law, contractual obligations and Freddie Mac policies. As an example of this principle, we will not disclose to Freddie Mac or use any information that we learned while working for a former employer and are obligated to keep confidential, whether by the terms of our agreement with our former employer or otherwise.