Our Role in the Community
Compliance With Legal Requirements
Legal compliance is critical to all of us at Freddie Mac, whether we are in the workplace or acting on the Company’s behalf in settings outside of the workplace, such as business-related travel, meetings, conferences and training sessions. We will comply with all legal requirements that apply to our job duties or responsibilities or to our job-related conduct.
Officers are expected to take an active role in this area. Through their contacts with other officers, managers and other employees of Freddie Mac, officers are charged with communicating the Company’s commitment to compliance with all applicable legal requirements and promoting compliance with those requirements by all employees.
The Legal Division is responsible for advising business area management about legal requirements.
| Policies & Procedures | |
|---|---|
| Policy 7-101 | Compliance with Laws and Regulations |
| Policy 7-703 | Policies Governing Indemnification, Discipline and Restitution with Respect to Current and Former Directors |
Corporate Community Activities
Community involvement is an essential part of our corporate mission and it is very important that our corporate donations be aligned with our business strategies. Corporate contributions to tax-exempt organizations can be subject to external scrutiny and must be documented in accordance with corporate policies and procedures.
| Policies & Procedures | |
|---|---|
| Procedure 7-600 | Payments to Tax-Exempt Organizations and Payments that May Relate to Political Activities |
| Procedure 7-603 | Corporate Sponsorship of Political Fundraisers for Federal Candidates |
Personal Community Activities
When volunteering our personal time or resources to charitable, religious, professional, social, fraternal, recreational, public service or civic organizations, we will be sensitive to the need to distinguish our role as a private citizen from our role as a Freddie Mac employee. Freddie Mac endorses volunteerism, but does not necessarily approve or disapprove of the activities of any particular organization. Freddie Mac respects our right to choose our own affiliations. However, solicitation of employees to make donations or buy products sold by these organizations may place fellow employees, particularly those lower in the reporting chain, in an awkward or compromising position and such activities should be conducted in a manner that is consistent with corporate policies.
| Policies & Procedures | |
|---|---|
| Procedure 7-600 | Payments to Tax-Exempt Organizations and Payments that May Relate to Political Activities |
| Policy 7-602 | Personal Political Activities of Freddie Mac Employees |
| Policy 7-605 | Oversight of State and Local Lobbying Activities |
Interacting With the Media, the Investment Community and Others Outside Freddie Mac
Only authorized persons can speak as representatives of the Company. Requests for information from outside sources should be referred to the department identified in the applicable corporate policy (e.g., Shareholder Relations for inquiries from the investment community or Corporate and Marketing Communications for media inquiries). If you receive a request for any other type of information from a governmental agency, an attorney, paralegal, investigator or any other non-employee, or from a person whom you do not recognize, you should receive approval from the Legal Division prior to engaging in any discussion or providing any information.
If you are authorized to communicate on behalf of Freddie Mac, you must comply with applicable corporate policies and procedures when responding to media inquiries or making public statements as a representative of Freddie Mac.
| Policies & Procedures | |
|---|---|
| Policy 2-306 | Public Relations — Media Relations |
Personal Public Statements and Publications
The conduct of Freddie Mac, like that of other publicly-held corporations, is subject to close scrutiny from many sources. For this reason, it is particularly important that any public statement or act attributable to Freddie Mac be carefully planned and that our personal views be kept separate from corporate views.
Each of us must take steps to ensure that our private actions are not construed as Freddie Mac’s actions. For example, if we express personal opinions to an audience who may know of our affiliation with Freddie Mac, we will state clearly that our comments represent our personal opinions and not those of Freddie Mac.
Proposed articles or other publications authored, and speeches given, by Freddie Mac personnel that deal with the business of the corporation or our industry, relate to an individual’s work at Freddie Mac, or draw upon the knowledge or expertise of the individual, in his or her capacity as a Freddie Mac employee, must be forwarded to the Corporate and Marketing Communications Division for approval. In addition, Freddie Mac officers (and others specified in Company policies) must obtain Corporate and Marketing Communications Division approval for any articles, publications or speeches that could have an impact on Freddie Mac’s reputation if they were published or given by the individual in his or her capacity as a Freddie Mac employee, even if the individual makes it clear that opinions expressed are his or her own and not those of Freddie Mac.
| Policies & Procedures | |
|---|---|
| Policy 2-306 | Public Relations — Media Relations |
Political Activities
Personal participation in the political process is an essential part of our society and we may fully engage in the political process consistent with our personal views, convictions and interests regardless of Freddie Mac’s business interests. It is important to remember though, that there are restrictions on corporate involvement in the election process and corporate dealings with government officials. Accordingly, we must distinguish our individual actions and views from those of Freddie Mac when engaging in personal political activity. The use of Freddie Mac’s resources, property or vendors may be interpreted to be an indirect form of the Company’s political activity; therefore, we may not use Freddie Mac’s resources, property or vendors for personal political activity with the following limited exceptions:
- Use of a Freddie Mac vendor, at your own expense and with the prior written approval of the Vice President-Deputy General Counsel-Legislative and Regulatory Affairs;
- Occasional, isolated or incidental use of local telephone services, if Freddie Mac does not incur any incremental costs and the use does not exceed one hour per week or four hours per month; and
- Any e-mail received at work in connection with personal political activity may be forwarded to your personal e-mail account but may not otherwise be replied to or forwarded within or outside of Freddie Mac.
Federal and state laws generally prohibit a corporation from making contributions to candidates and political parties. FreddiePAC, the political action committee that is funded by employee contributions, is generally the only permissible Company-affiliated source of contributions to candidates and political parties. Freddie Mac employees may, however, solicit co-workers for political contributions in their personal capacities. It should be explicitly stated that the solicitations are personal in nature and are not connected to Freddie Mac. Also, such activity should not interfere with our job duties and should never involve coercion. In addition, we should be alert to the potential for misunderstandings that could occur in soliciting employees under our supervision.
To help ensure that conflicts are avoided, we will notify the Chief Compliance Officer of any political office or government-related positions, whether paid or unpaid, to which we have been elected or appointed.
| Policies & Procedures | |
|---|---|
| Policy 2-306 | Public Relations — Media Relations |
| Policy 3-203 | Outside Employment and Other Outside Activities |
| Policy 7-602 | Personal Political Activities of Freddie Mac Employees |
| Policy 7-603 | Corporate Sponsorship of Political Fundraisers for Federal Candidates |
| Policy 7-605 | Oversight of State and Local Lobbying Activities |