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. Most recently, the Board of Directors approved additional minor technical updates to the Director Code on September 3, 2020, and on January 1, 2022 the Employee Code was revised to reflect changes to Freddie Mac’s corporate values.

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.

Post-Employment Restrictions for Corporate Information Protection

Certain employees are required to abide with six-month cooling-off periods following their termination of their employment with Freddie Mac. The cooling-off periods restrict specific types of engagement with Freddie Mac on behalf of the former employees' new employers. Knowing violations of the cooling-off periods may result in legal action. Third Parties may direct any questions about these restrictions to the Compliance & Ethics Helpline.