Codes of Conduct
Freddie Mac has built our business on the basis of service, trust and confidence, making us a leader in the mortgage finance industry. How we conduct ourselves, both individually and collectively, represents the conduct of Freddie Mac. Freddie Mac has had a strong Code of Conduct for many years, with separate versions that apply to employees and Directors. In 2004, we revised them to ensure that they met the highest standards of today's corporate governance practices and reflected all applicable requirements of the NYSE Rules and the Sarbanes-Oxley Act. In 2005, the Freddie Mac Board of Directors approved a restructured version of the Employee Code that is presented in a more easily readable and accessible fashion. In December 2007, Freddie Mac's Board of Directors approved revisions to the Employee Code and to the Director Code that reflect certain policy updates and technical amendments. Additional revisions reflecting policy updates and technical amendments were made to the Director Code, effective November 20, 2008. Additional changes were also made to the Employee Code of Conduct (effective December 19, 2008), including the addition of a new cover letter from our Chief Executive Officer and certain technical, administrative or other non-substantive amendments. On January 22, 2010, we removed the CEO cover letter from the Employee Code of Conduct, and on February 19, 2010 we inserted a new CEO cover letter. In June 2010, Freddie Mac's Board of Directors approved revisions (effective July 21, 2010) to both the Employee Code and the Director Code reflecting certain policy updates, as well as technical and administrative amendments. On December 13, 2012, Freddie Mac's Board of Directors approved revisions to the Employee Code that reflect certain policy updates and technical amendments as well as the addition of a new cover letter from our Chief Executive Officer. On December 4, 2013, the Audit Committee of Freddie Mac's Board of Directors approved revisions (effective January 1, 2014) to the Employee Code and on December 5, 2013, Freddie Mac's Board of Directors approved revisions (effective December 5, 2013) to the Director Code. In both instances the revisions were designed to simplify and streamline the Codes. In October 2014, the Audit Committee of Freddie Mac's Board of Directors approved revisions (effective October 8, 2014 and updated April 24, 2015) to the Employee Code that align the Code with certain policy updates relating to expense policies, procedures and compliance programs, as well as to update certain related policy references. Effective September 18, 2015, both Codes were updated to add clarifications regarding reporting wrongdoing. On January 26, 2016, the Employee Code was updated to reflect changes to policy references.
Audit Committee Complaint Procedures
Freddie Mac's complaint policy for accounting, internal accounting controls and auditing matters pertaining to the company's business has been created in accordance with the Sarbanes-Oxley Act of 2002 and the corporate governance rules of the NYSE. The policy establishes processes, and defines responsibilities for the receipt, retention and prompt resolution of complaints, including the confidential, anonymous submission by employees of concerns regarding questionable accounting or auditing matters.