CORPORATE POLICY

Subject: Code of Conduct Policy Number: 1-140 Control Point: Chief Compliance Officer Approval Authority: Board of Directors Signature: William H. McDavid __________________________________________________________________________________ Effective Date: January 1, 2014

New Replaces Policy 1-140 dated December 13, 2012 Reviewed by Legal or Determined that No Legal Review Necessary

Code of Conduct

A Message from the CEO ................................ 1

Our History and Mission ................................... 3

Our Values ................................................................... 3

Living by Our Code ............................................... 4Our CodeApplication of the CodeMaking Home Affordable Compliance (MHA-C) Code of ConductAdditional Responsibilities of Officers, Directors, and ManagersWaiversEthical Decision-MakingAsking Questions and Raising ConcernsWho to ContactWhat Happens when a Question or Concern Is Raised?No Tolerance for RetaliationOther Resources

Our Workplace ......................................................... 9

We Treat Each Other with Respect and Value Diversity

We Do Not Tolerate Discrimination or Harassment

We Avoid Conflicts of Interest in the Workplace Gifts Among EmployeesLoans to Executive OfficersRelationships in the WorkplaceOutside Activities and Family Member Activities

We Keep Each Other Safe Substance AbuseViolence and Weapons

We Safeguard Our Confidential Information Confidentiality of Employee Information

Our Marketplace .................................................. 12

We Respect Our Customers and Protect Their Confidential Information

We Compete Fairly and Ethically and Comply with Applicable Laws Fair CompetitionAnti-FraudAnti-Corruption

We Avoid Conflicts of InterestSelf-Dealing and Corporate OpportunitiesPersonal Investment LimitationsBusiness Courtesies (Gifts, Meals, and Entertainment)

Accepting Business Courtesies from Interested Parties Providing Business Courtesies to Interested Parties Business Courtesies involving Government Officials

Our Company & Owners ................................ 16

We Protect Freddie Mac Assets and ResourcesUse of Freddie Mac AssetsIntellectual AssetsConfidential InformationRecords Management and Legal HoldsTruthful and Accurate ReportingInsider Trading“Window Periods” and Pre-Clearance of Transactions in Freddie Mac SecuritiesInformation Wall and Restricted Persons

We Communicate ResponsiblyWorking With Regulators and Government AgenciesWorking With AuditorsInteracting With the Media, the Investment Community and Others Outside Freddie Mac

Our Communities ................................................ 20

We are Environmentally Responsible

We Give Back to Our CommunitiesPersonal Community ActivitiesPersonal Political Activities

Table of Contents

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1

Freddie Mac was chartered more than 40 years ago with

a mission to help families achieve one of our nation’s most

cherished dreams — that of safe, affordable housing. We

do so by providing liquidity, stability and affordability to

the mortgage market. To be successful in fulfilling those

responsibilities, we must act in accordance with the highest

standards of integrity and fairness. Doing so demonstrates

our commitment to our mission and earns us the trust of our

customers, regulators, peers, business partners, and the

communities in which we live and work.

But Freddie Mac also has strong reasons beyond our mission

to insist on the highest standards of ethical conduct — we are

in conservatorship, a status that brings added scrutiny. The

government has placed its confidence in Freddie Mac and

entrusted us with special responsibilities. More than ever we

need to stay true to our values. Act with integrity. Do the right

thing. Treat others as you would like to be treated. Strive to

act consistently with the spirit of the Code, not just its letter.

Freddie Mac’s Code of Conduct is the guide for how we

should serve our mission and conduct our business. The

Code reflects our commitment to pursue our daily activities

and goals ethically and transparently at all times. Each

one of us is personally responsible for fostering an ethical

culture at Freddie Mac. Every action we take or decision we

make affects this company’s reputation and the results we

achieve. By adhering to the principles set forth in the Code of

Conduct, you can demonstrate leadership and commitment

to our Company and to America’s families.

An important part of fostering an ethical culture is speaking

up when there is questionable conduct. I am personally

committed to maintaining our culture where people are

encouraged to speak up and are protected from retaliation.

Whether you have a question about the Code or are reporting

possible misconduct, I urge you to make use of one of the

many options available to you, including contacting your

manager, the Compliance Division or the Compliance and

Ethics Helpline (www.freddiemacethicshelpline.com or

(877) 301-CODE (2633)).

Since the beginning of the housing crisis, Freddie Mac has

strengthened its credit and eligibility standards to produce

better quality loans that foster sustainable homeownership

opportunities for America’s families. Our results are paying

off and we are committed to supporting a strong housing

finance system that serves future generations. With talented

employees who are passionate about our mission, we will

continue to favorably impact the lives of millions of American

borrowers. Our work will help shape the housing finance

market for decades to come. I am very proud to be part of a

company that has such a vital public purpose and a strong

focus on integrity and ethical conduct. I hope you are too.

Donald H. LaytonChief Executive Officer

A Message from the CEO

Freddie Mac | Code of Conduct

2 Freddie Mac | Code of Conduct

3

Our History and Mission

Freddie Mac was chartered by the U.S. Congress in 1970 with a public mission to provide liquidity, stabilize the nation's residential mortgage markets, and expand opportunities for homeownership and affordable rental housing.

Simply put, our statutory mission is to provide liquidity, stability, and affordability to the U.S. housing market. The 2008 economic downturn put a special focus on a key aspect of our mission: helping families keep their homes. By carrying out our expanded mission, we are playing a vital role in the nation’s housing recovery.

Freddie Mac’s charter provides us with a clear mission requiring Freddie Mac to do the following:

n Provide stability in the secondary mortgage market

n Respond appropriately to the private capital market

n Provide ongoing assistance to the secondary mortgage market, including activities relating to mortgages securing housing for low- and moderate-income families (that may involve a reasonable economic return that may be less than the return on other activities) by improving the liquidity of mortgage investments and thereby attracting more capital to the mortgage market

n Promote access to mortgage credit throughout the nation, including underserved areas by improving the liquidity of mortgage investments and thereby attracting more capital to the mortgage market

Freddie Mac's Congressional charter lays the foundation of our business and the ideals that power our mission. The charter forms the framework for our business lines, shapes the products we bring to market, and drives the services we provide to the nation's housing and mortgage industry. Consistent with our charter, Freddie Mac provides a stable, liquid, and affordable flow of credit to the conforming residential mortgage market throughout the nation, both in good times and in bad.

Freddie Mac | Code of Conduct

Our Values

At Freddie Mac, we pride ourselves in helping America’s families. Our business efforts are focused on meeting the goals of our charter. We recognize that we cannot reach our full potential unless we embrace a set of values consistent with our mission.

Leadership and Accountability

We take the initiative to achieve our common purpose and are accountable for reaching our goals.

Integrity

We do the right thing — without compromise.

Customer Focus

We understand and focus on the needs of our customers.

People

We are fair, respect others, embrace diversity, work collaboratively, and recognize achievement.

Results

We strive to excel and embrace change to improve everything we do.

4

Living by Our Code

Our Code

Ethics and integrity are an important part of life, and are also important to running a successful business. To become successful and maintain a good reputation in the market, a business needs to be driven by strong ethical values and must act with the utmost of integrity. Good ethics are good for business.

This Code of Conduct (“Code”) is one way in which we incorporate ethics and integrity in our business. The Code is also designed to make Freddie Mac a better place for all of us as employees. The Code describes our guiding ethical principles and clarifies the responsibilities that we have to each other, our business partners, our competitors, and our customers. It describes the standards of conduct that govern our business dealings and highlights ethical considerations that should be evaluated when making difficult business decisions.

Application of the Code

The Code is a guide and resource to help each of us contribute to Freddie Mac’s integrity as we pursue our corporate mission. The Code applies to all full and part time employees. In addition, Freddie Mac expects all parties who work on Freddie Mac’s behalf, including contingent workers, independent contractors, and consultants, to embrace the spirit of the Code and adhere to its standards of conduct.

The Code contains general values and standards of behavior that are expanded upon in corporate policies and procedures. For your convenience, the Code contains references to many, but not all, of these policies. Should there be a conflict between the Code and any of the policies, the Code prevails.

As Freddie Mac employees, we are in the best position to enhance the Company’s reputation in the community and to make Freddie Mac a better place to work. Each of us must review and comply with the Code, as well as Freddie Mac’s policies and procedures. Our acknowledgement of and compliance with the Code is a condition of employment. And, as always, we must comply with applicable law.

The Compliance Division (“Compliance Division” or “Compliance”) works with Freddie Mac employees to foster a corporate culture of integrity. In that role, the Compliance Division is responsible for administering and interpreting the Code.

Making Home Affordable-Compliance (MHA-C) Code of Conduct

Employees providing services under the Financial Agency Agreement between Freddie Mac and the Department of the Treasury are also subject to the Freddie Mac Making Home Affordable Code of Conduct, which contains more restrictive rules on matters such as confidentiality, personal investments, gifts and entertainment, and other business courtesies.

Policy 1-143 Freddie Mac Making Home Affordable Code of Conduct

Additional Responsibilities of Officers, Directors, and Managers

Officers, directors, and managers are held to an even higher level of accountability for ethical behavior. They are expected to lead by example and set a tone that reinforces the importance of compliance and ethical business conduct.

Their added responsibilities include:

n Act as a role model

n Promote our culture of integrity

n Encourage open communications

n Recognize and reward behavior that exemplifies our ethical principles and values

n Assist in enforcing the Code through appropriate corrective measures

n Timely report possible violations of the Code, policies, or law to the Compliance and Ethics Helpline or the Compliance Division

Waivers

In limited circumstances, Freddie Mac’s Chief Compliance Officer may grant employees, other than executive officers, a waiver of a provision of the Code. Waivers of a Code provision for executive officers may be made only by the Board of Directors or its designated committee. Waivers are disfavored and will be publicly disclosed as required by applicable law.

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Whenever you are uncertain of the right thing to do, ask yourself the following questions:

Ethical Decision-Making

This Code does not describe every business practice or answer every question. We are all expected to conduct ourselves in accordance with the highest ethical standards.

If you answered “NO” to any of these questions, you need to exercise care before taking any action and are encouraged to seek guidance from Compliance

or another resource identified on the next page.

Are my actions legal?1 YES?

Are my actions ethical? YES?2

Do my actions reflect our values? YES?3

Do my actions conform with company policy?

YES?4

Am I comfortable with these actions — are they the right thing to do?

YES?5

Would I be comfortable if I were to see my actions reported in the media?

YES?6

Could I justify my actions to my co-workers, friends, and family? YES?7

Will I be comfortable with my actions a few days from now? YES?8

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Asking Questions and Raising Concerns

Each of us must take responsibility for acting with integrity at all times and should help ensure that Freddie Mac operates ethically and lawfully.

If you have questions about this Code, or concerns about potentially illegal or unethical business conduct, you are strongly encouraged to contact your manager, Compliance, or any of the resources below. Managers have the duty to timely report possible wrongdoing to the Compliance and Ethics Helpline or the Compliance Division.

Who to Contact

For assistance with questions about the Code or other ethics and compliance matters, you should contact your manager or Compliance.

There are several ways to report potential misconduct, including the following:

n Your manager

n Your next-level manager

n Compliance

n The Compliance & Ethics Helpline

Phone: (877) 301-CODE (2633)

Internet: www.FreddieMacEthicsHelpline.com

n Your Human Resources Business Partner or Employee Relations

n Internal Audit

n Any officer

n The Chair of the Audit Committee of the Board of Directors

The Compliance and Ethics Helpline is available for anyone to request information or report allegations of wrongdoing (such as violations of a law or regulation, this Code, or Company policies), on either an anonymous or confidential basis, 24 hours a day, 365 days a year. Freddie Mac uses a third-party service to help maintain anonymity when requested. When anonymity is requested, the identity of the callers will be kept confidential to the extent reasonably possible and consistent with the law and good business practices.

What Happens When a Question or Concern Is Raised?

Freddie Mac will respond to all requests for advice or information and will investigate, as appropriate, all reports of alleged violations of this Code, Company policies, and applicable laws or regulations in a prompt, fair, and impartial manner, in accordance with applicable corporate policies and procedures.

As Freddie Mac employees, it is our duty to cooperate fully with these investigations, to be truthful and forthcoming during the course of such investigations, and to keep such investigations appropriately confidential. It is unacceptable to act in bad faith or knowingly make a false complaint or statement in an investigation.

I talked to my manager about a situation in our team that I think violates the Code. She didn’t do

anything about it and told me not to worry about it. I am not comfortable with her response. What should I do?

You are encouraged to contact your manager because managers have an interest in promoting an ethical

environment and an obligation to uphold the Code. However, if for any reason that is not an option or you do not feel that your issue was addressed, you are encouraged to contact the Compliance and Ethics Helpline, your HR representative, your next-level manager, or any other contact listed above.

Q:

A:

Reporting Concerns

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No Tolerance for Retaliation

Freddie Mac is committed to maintaining a work environment where employees can ask questions, voice concerns, and make appropriate suggestions without fear of retaliation.

Freddie Mac will not tolerate retaliation against any company or individual who, based on his or her reasonable good faith belief, reports a concern about potential illegal or unethical conduct or a violation of Freddie Mac policies or who assists in the resolution of an investigation or proceeding.

Policy 1-150 Complaint Policy for Accounting, Internal Accounting Controls and Auditing Matters Pertaining to Freddie Mac’s Business

Policy 1-152 Investigations Policy for Complaints

Policy 3-214 Corrective Action

Other Resources

n To report an actual or suspected information security incident (i.e., loss, unauthorized disclosure or theft of confidential information, including Protected Personal Information), contact the Privacy Office at privacy_mailbox@freddiemac.com, or Information Security at information_security@freddiemac.com. Information Security incidents may involve data in electronic or paper format, or data stored on a Freddie Mac asset (i.e., laptop).

n To report possible financial instrument fraud (such as mortgage-related fraud), contact the Fraud Hotline at (800) 4FRAUD8 (437-2838) or email mortgage_fraud_reporting@freddiemac.com.

n If you have questions or concerns about your mortgage, contact Freddie Mac’s Customer Support Department at (800) FREDDIE (373-3343).

n If you have questions or concerns about a Freddie Mac REO property, contact HomeSteps’ Customer Support Department at (800) 972-7555.

I made a complaint about my manager to the Compliance and Ethics Helpline, but now I am concerned that he will be

angry with me and that this will affect my job. What can I do?

First, remember that we do our best to keep Helpline submissions confidential. Also, as part of our investigative process,

we will reinforce with everyone involved that Freddie Mac will not tolerate retaliation. If you ever experience or suspect retaliation, you should report it promptly to the Compliance and Ethics Helpline or the Compliance Division.

Q:

A:

What happens if someone makes a report about me, but I haven’t done anything wrong?

Freddie Mac does not assume that a violation has occurred just because a report is made. Instead, Freddie Mac

will initiate an impartial and objective investigation with no assumptions or presumptions about the complaint or the parties involved.

Q:

A:

Neutral & Objective Investigation

Non-Retaliation

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8 Freddie Mac | Our Workplace

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Our Workplace

We Treat Each Other with Respect and Value Diversity

At Freddie Mac, we recognize the importance of mutual respect when dealing with our fellow employees. We act fairly in dealing with our co-workers and treat them with respect and dignity. Freddie Mac officers, directors, and managers have a special responsibility to foster a workplace environment that supports honesty, integrity, respect, and trust.

We also recognize the contribution of our diverse workforce to our success as an organization, and value a work environment where diversity is embraced, and where our differences are respected. We welcome, accept, and value each person according to his or her contribution to the attainment of Freddie Mac’s goals and successes.

We Do Not Tolerate Discrimination or Harassment

Freddie Mac takes pride in maintaining an inclusive, equal opportunity work environment that respects the dignity of all individuals regardless of background and personal character-istics. Freddie Mac is fully committed to equal employment opportunity and seeks to recruit, hire, develop, and retain the most qualified people from a diverse candidate pool.

We will not discriminate based on race, color, religion, ethnicity, gender, pregnancy, age, national origin, disability, sexual orientation, gender identity/expression, marital status, veteran status, genetic information, or any other status protected by law or Freddie Mac policy. We will not engage in or tolerate any form of harassment. Managers are required and employees are strongly encouraged to report incidents of discrimination and harassment to our Human Resources Business Partners or Employee Relations.

Policy 3-201 EEO, Anti-Harassment, and Reasonable Accommodation of Disabilities Policy

We Avoid Conflicts of Interest in the Workplace

Gifts Among Employees

In some circumstances, giving or receiving gifts among employees may give rise to perceived obligations or may be viewed as preferential treatment. Subject to these consider-ations, employees may generally use their personal funds for

voluntary gifts or donations of a reasonable value for special occasions, such as births, marriages, illnesses, retirements, birthdays, and holidays. Even for such special occasions, however, managers may not ask employees within their chain of supervision for donations or contributions for a gift.

Also, as stewards of the taxpayers’ funds, we must be careful in our use of those funds. Thus, we must not use Freddie Mac funds to provide any gifts, entertainment, meals, refreshments, or other items of value to other employees except as permitted by our Business Courtesies policy.

Policy 3-202 Business Courtesies

Policy 5-208 Corporate Meeting Space and Catering

Can you give some concrete examples of conduct that can be considered offensive, intimidating, and/or discriminatory?

A few examples are:

n Making jokes or insults related to race, ethnicity, religion, age, sexual orientation, or gender

n Viewing or distributing obscene or otherwise inappropriate pictures, videos, or drawings

n Using email, voicemail, text messages, social media, or any other electronic devices to transmit derogatory or discriminatory information

n Making unwelcome sexual advances or suggestions or making unwanted physical contact

Q:

A:

Harassment

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Loans to Executive Officers

Freddie Mac is restricted by certain laws, regulations, and Company policies and procedures from making, or arranging for, loans and other extensions of credit to its executive officers or members of the Board of Directors.

Relationships in the Workplace

As Freddie Mac employees, we must ensure that our workplace is fair and untainted by perceptions of favoritism. Thus, we may not have a familial relationship, romantic relationship, or intimate personal relationship with a first or second level supervisor or subordinate. Such relationships are permitted between peers or colleagues who have the same first and second level supervisor, as long as the relationship is disclosed to management and any conflicts of interest are addressed. Employees engaged in such relationships are prohibited from participating in any employment decision regarding the other employee in the relationship.

Policy 3-225 Relationships in the Workplace

Policy 9-400 Contingent Workforce Management

Outside Activities and Family Member Activities

It is our responsibility to avoid situations in which our loyalty to Freddie Mac, or availability to perform our job duties, could be compromised or cause us to have a conflict of interest with Freddie Mac. In order to help us to determine whether such a conflict of interest exists, Freddie Mac has developed rules related to outside employment and activities. Determining whether a particular situation would create a conflict of interest requires the analysis of specific factual circumstances. The specific rules related to outside employment, participation on outside boards, and other outside activities can be found in the Outside Activities and Family Member Activities policy or by contacting the Compliance Division.

Policy 3-203 Outside Activities and Family Member Activities

I hold a realtor’s license and would like to work as a real estate agent part-time. Is this something I am allowed to do

as a Freddie Mac employee?

Consistent with the Outside Activities and Family Member Activities policy (3-203), Freddie Mac employees

seeking to work part time as a real estate agent or broker must obtain approval from both their first level officer and Compliance. Divisions’ policies (e.g., HomeSteps) may otherwise prohibit or limit such activity, so you must first obtain authorization from your first level officer before seeking Compliance approval.

Compliance will analyze each case on an individual basis before making a determination, but, in any event, Freddie Mac employees who obtain authorization to work as real estate agents or brokers may not:

n Work directly with the secondary mortgage market;

n Deal in properties that are owned by Freddie Mac; or

n Assist other employees with the purchase or sale of properties in connection with the Freddie Mac relocation program.

As with all outside employment, any such services must be performed on the employee’s own time and resources.

Q:

A:

Outside Employment: Employee Part-Time Job

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We Keep Each Other Safe

Substance Abuse

We may not report to work or conduct any Freddie Mac business while under the influence of alcohol or illegal drugs or while abusing any legal or controlled substance, including prescription or over the counter medications. We also may not purchase, sell, manufacture, or distribute illegal drugs, drug paraphernalia, or controlled substances in the workplace. Moderate consumption of alcohol while attending a Freddie Mac sponsored event or while attending a business-related function is permissible.

Policy 3-219 Alcohol and Drug Abuse

Violence and Weapons

Freddie Mac will not tolerate acts of violence, threats or physical intimidation of any kind, or any activity that advocates or is designed to incite violence. Freddie Mac strictly prohibits the possession or use of weapons, even if licensed, on Freddie Mac premises (other than by law enforcement or security personnel).

Policy 3-210 Workplace Violence Prevention Policy

We Safeguard Our Confidential Information

Confidentiality of Employee Information

Freddie Mac recognizes and protects the confidentiality of employee medical and personal information. Employees may not share such information inside or outside Freddie Mac, except (i) as required by law or appropriate legal process, (ii) in connection with an appropriate, lawful business use, or (iii) as authorized by the employee. Disclosure of such information under any other circumstances must be approved by the Legal Division.

Policy 8-400 Use and Disclosure of Information, including Confidential Information

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Our Marketplace

It is our goal to build long-lasting business relationships that are based on trust, honesty, and respect. We are committed to conducting business ethically and fairly and seek competitive advantage only through legal and ethical business practices.

We Respect Our Customers and Protect Their Confidential Information

We work to understand and meet our customers’ business needs, while always remaining true to our own ethical standards. We deal with customers and potential customers in a fair, cordial, and honest manner.

In order to serve our customers and compete in the marketplace, we often collect confidential information, including Protected Personal Information (PPI), from borrowers and customers. We will collect, maintain, use, and disclose such information lawfully and consistent with Company policies and our agreements with customers.

Policy 8-400 Use and Disclosure of Information, including Confidential Information

Policy 8-500 Privacy of Information

We Compete Fairly and Ethically and Comply with Applicable Laws

We must not take any action which violates any law, regulation, or internal policy. While other topics regarding compliance with laws or regulations are addressed elsewhere in the Code, this section presents additional topics regarding laws and regulations of which we must be aware.

Fair Competition

Competition laws, known in the U.S. as antitrust laws, are designed to promote competition and protect consumers from unfair business practices. These laws and our Company policies prohibit conduct that is deemed collusive or anti-competitive, including price fixing, bid rigging, dividing up customers or markets, limiting availability of products or services, or refusing to deal with specific business partners for impermissible reasons. At Freddie Mac, we compete lawfully based on the merits of our products and services and in accordance with antitrust laws.

Policy 7-105 Antitrust Compliance Manual

Anti-Fraud

Fraud is not only unethical but it is also illegal. Each one of us at Freddie Mac is responsible for preventing and reporting fraud. Fraud is defined as the use of misrepresentation or deceit to cheat, trick, steal, or lie (including lies of omission). Examples of fraud may include:

n Submitting false expense reports

n Misappropriating assets or misusing Company property

n Unauthorized handling or reporting of transactions

n Forging or altering any documents including checks

n Improperly changing financial records or financial statements

Instances of actual or possible financial instrument fraud (including mortgage-related fraud) perpetrated against Freddie Mac are investigated by the Financial Fraud Investigation Unit (FFIU) and should be reported to the Mortgage Fraud Hotline at (800) 4FRAUD8 (437-2838) or via email to mortgage_fraud_reporting@freddiemac.com. All other instances of fraud should be reported to the

May I disclose to Freddie Mac or use any information that I learned while working for a former employer?

You need to be careful here as you may be obligated to keep certain information that you learned in your previous job

confidential, whether by means of your agreement with your previous employer or otherwise.

Q:

A:

Third party information

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Compliance and Ethics Helpline via phone (877) 301-CODE (2633) or via website www.FreddieMacEthicsHelpline.com.

Policy 1-152 Investigations Policy for Complaints

Policy 11-213 Corporate Financial Instrument Fraud Policy

Anti-Corruption

We are committed to complying with U.S. and international anti-corruption laws and standards, including the Foreign Corrupt Practices Act (“FCPA”), which prohibits companies (including their agents, officers, and employees) from offering anything of value to foreign government officials to influence decisions, obtain or retain business, or secure any improper advantage. It is important to note that under the FCPA, employees of foreign government-owned entities, such as government-owned banks and financial institutions, are considered government officials.

We will never offer or accept bribes, kickbacks, or illegal payments. If we are offered such a payment, we will decline to accept it and report it to the Compliance and Ethics Helpline or the Compliance Division. We also must take care when using the services of third parties—such as broker dealers—who will deal with foreign government officials on behalf of Freddie Mac.

Learn more about the FCPA and our responsibilities for preventing violations here.

We Avoid Conflicts of Interest

We will avoid situations that could create or appear to create a conflict between our personal interests and the interests of Freddie Mac. Our business decisions must be governed not by our personal interests, but by good judgment, objectivity, and loyalty to Freddie Mac and our stakeholders. The rules set out below are designed to help us avoid impermissible conflicts of interest in certain situations.

Self-Dealing and Corporate Opportunities

We have a responsibility not to take corporate opportunities for ourselves and not to compete with Freddie Mac. Business opportunities that arise because of our position at Freddie Mac, or by using corporate property, information, or resources, belong to Freddie Mac. View an example here.

We will also not inappropriately influence or cause Freddie Mac to do business with a company in which our immediate family or covered household members (i.e., spouse, parents, stepparents, children, stepchildren, siblings, stepsiblings, same or opposite sex domestic partner, or anyone who resides in the same household) have an interest. We must disclose to our managers any situation where one of our immediate family or household members is employed by a current or prospective Freddie Mac competitor, vendor, or customer. View an example here.

Policy 3-203 Outside Activities and Family Member Activities

Policy 3-225 Relationships in the Workplace

Policy 9-200 Procurement of Products and Services

Policy 9-400 Contingent Workforce Management

Personal Investment Limitations

As Freddie Mac employees, we will not hold any investment that may cause us to have a conflict of interest with Freddie Mac. In order to help us to determine whether such a conflict of interest exists, Freddie Mac has developed rules related to specific limitations on investments. These rules apply even when the securities or other financial interests are held by immediate family or covered household members, through agents or fiduciaries, or intermediary entities whose investment decisions are controlled, individually or collectively, by a Freddie Mac employee or a covered household member.

Policy 3-206 Personal Securities Investments

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Business Courtesies (Gifts, Meals, and Entertainment)

Business Courtesies are gifts, meals, or offers of entertainment or any item of value to/from a third party for which fair market value is not paid.

View examples of situations involving Business Courtesies here.

Accepting Business Courtesies from Interested Parties

Business Courtesies that are accepted by Freddie Mac can be misinterpreted as an attempt by the donor to improperly influence our behavior. With this in mind, in our role as Freddie Mac employees, we may:

n Not solicit gifts, entertainment, travel, or anything else of value;

n Not accept cash, gift cards that can be used like cash, such as a VISA® gift card, or securities; and

n Not accept gifts totaling more than $100 in aggregate value from any one source during a calendar year.

We generally may accept the following as long as they are not being offered in exchange for preferential treatment from Freddie Mac:

n Meals that have a legitimate business purpose and at which the donor is present so long as the meals are reasonable, customary, an accepted business practice, and not lavish or frequent;

n Entertainment that legitimately furthers the business interests of Freddie Mac and is in accordance with generally accepted business practice, so long as the expenses for the entertainment do not exceed $100 per person;

n Gifts, including gift cards (other than gift cards that may be used like cash, such as a VISA® gift card), so long as the aggregate fair market value of the gifts from any one source does not exceed $100 per calendar year;

n Gifts from family or friends that are offered because of the personal/familial relationship and not because of our status as a Freddie Mac employee;

n Unsolicited Preferential Treatment that is offered to a broad group of individuals in order to encourage sales of a product or service to those individuals (e.g., an offer of discounted banking services or discount restaurant coupons to all Freddie Mac employees at the same geographic location or to all tenants in an office building that is occupied in part by Freddie Mac); and

n Fees, travel, and/or lodging associated with speaking at a conference that is provided by an Interested Party if (i) the employee is a speaker at the event; (ii) the conference fees, travel, and/or lodging are offered to all other speakers attending the conference; and (iii) the travel or lodging is not lavish or excessive.

Policy 3-202 Business Courtesies

Policy 9-112 Travel Policy

One of Freddie Mac’s business partners, ABC Company, just finished working on a large and time-consuming project. As

the project manager for Freddie Mac, I worked closely with the ABC Company’s project team. When the work was concluded, the project team presented me with a thank you gift and note saying, “It was great working with you. Enjoy the tickets and let me know how you enjoy the Super Bowl.” The gift consisted of four tickets to the Super Bowl. Am I allowed to accept this gift under the Code of Conduct?

No, and here’s why. The tickets to the sporting event are a gift because the business partner is not inviting you to

the event, but giving you tickets to it. Because the amount of just one Super Bowl ticket exceeds the $100 gift limit as outlined in the Business Courtesies policy, you would not be allowed to accept the gift. The acceptance of such a lavish gift could give the appearance of a conflict of interest.

Further, even if you were invited to attend the event with the business partner so that it would be considered business entertainment, you would not be able to accept the invitation. The guidelines for acceptable business entertainment set forth in the Business Courtesies Policy are that the business entertainment must further the business interests of Freddie Mac and may not exceed $100 in value per person. The acceptance of such lavish entertainment could give the appearance of a conflict of interest.

Q:

A:

Acceptance of Tickets to Entertainment Events

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Providing Business Courtesies to Interested Parties

We generally may not provide gifts or entertainment or other business courtesies to Freddie Mac customers, other business partners, industry members, or any other person or entity whose interests may be substantially affected by our actions or to whom we contribute funds or resources, or that is in the residential housing, mortgage, or mortgage securitization business.

We may provide onsite meals or refreshments to these parties if to do so furthers Freddie Mac’s business interests and the expense is reasonable and does not exceed $100 per person per day. We may provide offsite meals or refreshments to these parties only if the expenditure has been approved, in writing, in advance by the Chief Financial Officer or Chief Administrative Officer and the meal or refreshment serves a business purpose.

Business Courtesies involving Government Officials

Various laws, regulations, and rules limit or prohibit the giving of business courtesies to or the receipt of business courtesies from government employees and elected officials (including employees of the federal government, states, and municipalities, their investment and retirement funds, and foreign officials). No business courtesy, including meals, may be provided to any federal, state, local, or foreign government employee or official on behalf of Freddie Mac, unless prior approval is obtained as required by the Business Courtesies policy, other than light refreshments which may be provided to Federal government employees during a business meeting. Further, we may not provide a business courtesy that would violate the FCPA.

Employees can seek additional guidance for specific situations by consulting the relevant corporate policy or by contacting the Compliance Division.

Policy 3-202 Business Courtesies

We are in the process of negotiating a contract with a software supplier and have scheduled an on-site meeting to discuss

the terms of the agreement. Three representatives from the supplier will be on-site negotiating the agreement from 9am until 3pm. Is it possible to serve lunch?

Consistent with the Business Courtesies policy, Freddie Mac resources may be used to provide meals or refreshments

to Interested Parties that serve a Freddie Mac business purpose as long as one or more employees participate, the meals or refreshments are provided onsite at a Freddie Mac location, and the expenses related to the meals or refreshments do not exceed $100 per person per day (inclusive of beverages, tax and gratuity, and other related expenses). It is worth noting that the $100 limit is an outer limit and in this situation the cost per person of a meal provided by the onsite meal services vendor should be far less than the $100 limit.

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Business Courtesies to Third Parties

Freddie Mac | Our Marketplace

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Our Company & Owners

Each of us shares a responsibility for preserving Freddie Mac systems, information, records, and other tangible and intangible assets.

We Protect Freddie Mac Assets and Resources

Use of Freddie Mac Assets

In general, we may use Freddie Mac assets only for business-related purposes. Occasional, incidental personal use of Freddie Mac’s electronic communications systems is permitted, as well as limited use of other Company property for charitable, community, or professional association activities as long as consistent with Company policy.

We follow applicable corporate policies when using Freddie Mac systems, such as restrictions on use of unauthorized third party software. Also, we cannot transfer or store Freddie Mac related information on personal devices (including personal email accounts) or keep it in our home, absent an express exception.

All data stored on Freddie Mac computers and servers (including email) is Freddie Mac property, and employees have no expectation of privacy in such data or in their offices or workspaces.

We recognize that when our employment with Freddie Mac ends, we will continue to be bound by the rules set forth in this Section (“Our Company & Owners”) and in the related corporate policies.

Policy 6-300 Management and Use of Electronic Computing and Communication Facilities

Policy 6-500 Data Management Policy

Confidential Information

Nonpublic information concerning Freddie Mac or its business must be handled with care and in accordance with applicable corporate policies in order to avoid unauthorized disclosure. We use such information only to the extent necessary in connection with our work-related responsibilities and only for the benefit of Freddie Mac. Furthermore, we disclose such information only to those individuals with a need to know such information in connection with their duties. Before disclosing nonpublic information to a third party, we make sure that appropriate steps are taken to protect its confidentiality (e.g., a non-disclosure agreement). In addition, some information that is available to the public (including, but not limited to, personal information about borrowers and employees) must be kept confidential under applicable laws, regulations, contracts, or Freddie Mac policies.

Policy 8-400 Use and Disclosure of Information, including Confidential Information

Policy 8-500 Privacy of Information

Protected Personal Information (“PPI”) is one type of highly confidential information. PPI is the term used by Freddie Mac to designate information that can be used to uniquely identify, contact, or locate an individual, or to distinguish or trace an individual’s identity. Examples of PPI include Social Security Numbers, passport numbers, and driver’s license numbers of individuals, including employees. At Freddie Mac, collecting, accessing, and using PPI are permitted only to the extent necessary for legitimate Freddie Mac business purposes. All electronic transmittals of Freddie Mac PPI outside the Company’s firewall must be encrypted.

Have a question about whether specific data or information constitutes PPI or how to safeguard it from unauthorized access or use? Contact the Privacy Office at privacy_mailbox@freddiemac.com.

Privacy

Freddie Mac | Our Company & Owners

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Intellectual Assets

We will protect Freddie Mac’s assets, including intellectual assets such as data and other intellectual property, from unauthorized use and disclosure and will also not use it for personal gain. We will share Freddie Mac’s intellectual assets externally only after careful consideration of the costs and benefits to the Company of such sharing — IA Sharing Guidelines. The Legal Division can assist with questions related to Intellectual Assets.

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 Intellectual Assets policy, Freddie Mac owns everything 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 research.

Policy 8-300 Intellectual Assets

Records Management and Legal Holds

Each of us is responsible for the integrity of the documents and records under our control. We will maintain documents and corporate records in compliance with the Corporate Records Retention Schedule unless legal requirements obligate us to retain documents beyond the normal retention period, e.g., if the documents are subject to a legal hold.

Policy 7-710 Policy on Document Lifecycle and Legal Holds

Truthful and Accurate Reporting

We understand the importance of truthful and accurate records and reporting to Freddie Mac’s reputation and to the integrity of the markets in which we do business. Each of us is responsible for ensuring that Freddie Mac’s business records, records prepared for submission to a government agency, and public disclosures are truthful, complete, accurate, fair, and understandable given their intended use. If we prepare reports or Company records based on

information provided by others, we will exercise reasonable care to be sure that those reports or records do not contain misrepresentations or misleading information.

Policy 1-150 Complaint Policy for Accounting, Internal Accounting Controls and Auditing Matters Pertaining to Freddie Mac’s Business

Policy 9-112 Travel Policy

Policy 9-114 Disbursement Approval of General & Administrative Expenses

Insider Trading

The use of inside, or non-public, material information in connection with the purchase or sale of Freddie Mac securities (including its debt and mortgage-related securities) or any other company’s securities is unethical and is generally prohibited by law. Non-public material information includes information (about Freddie Mac or another company) that has not been effectively disclosed to the general public, if:

n There is a substantial likelihood that a reasonable person would consider the information important in deciding whether to buy, hold, or sell a security;

n There is a substantial likelihood that a reasonable investor would have considered the information to have significantly altered the “total mix” of information; or

n The information is reasonably certain to have a substantial effect on the market price of a security.

These restrictions apply whether we are trading for our own accounts, trading on behalf of Freddie Mac, or trading on behalf of any other person or entity. We may not disclose material, non-public information to others. If a person to whom we provided such information trades on that information, our “tipping” could also be a violation of federal securities laws.

Policy 7-110 Insider Trading and Securities Transaction Pre-Clearance

Freddie Mac | Our Company & Owners

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“Window Periods” and Pre-Clearance of Transactions in Freddie Mac Securities

To help protect against the appearance of insider trading, Freddie Mac designates periods when personal trading in Freddie Mac securities is permissible. We may not engage in personal transactions in Freddie Mac securities outside of a “window period” unless the transaction has been pre-cleared by the Legal Division.

Policy 7-110 Insider Trading and Securities Transaction Pre-Clearance

Information Wall and Restricted Persons

To ensure that Freddie Mac’s trading activities are conducted based on the same information that is available to other investors, Freddie Mac has established an “Information Wall” policy designed to restrict the flow of certain information to trading employees (referred to as “Restricted Persons”). We are responsible for knowing and complying with the Information Wall policy. Restricted Persons are identified on the Compliance Division’s site on HomeFront.

Policy 7-115 Information Wall Policy

Do the Company’s window period requirements apply to purchases of Freddie Mac securities as well as sales?

Yes. You and your immediate household members must not buy or sell Freddie Mac securities outside of

a window period. The Legal Division announces when there is an “open” window period. Exceptions require written pre-clearance by the Legal Division (note: some officers and other employees require pre-clearance even during a window period — please consult the appropriate policies for specific rules). Window periods exist to help prevent the appearance of insider trading. As Freddie Mac employees, we may be privy to material, non-public information (“inside information”) and trading on such information isn’t just against corporate policy, it’s against the law. Window periods typically follow a short time after Freddie Mac has publicly released its financial statements when the investing public presumably has received all material financial information about the Company. You should note, however, that you must not trade in Freddie Mac securities even during an open window period if you possess material, non-public information.

In your answer, you referred to the immediate household members of employees. So, Freddie Mac’s

restrictions on trading Freddie Mac securities don’t just apply to me, they also apply to my immediate household members?

Correct, the Company’s corporate policies on Freddie Mac securities also apply to employees’ immediate

household members, who are permitted to trade in Freddie Mac securities only during open window periods. This includes (i) any family members who reside with you, (ii) anyone else who lives in your household (whether or not related), and (iii) any family members who do not live in your household but whose transactions in Freddie Mac securities are directed by you or are subject to your influence or control (such as parents or children who consult with you before they trade in Freddie Mac securities). For additional information, see the Insider Trading and Securities Transaction Pre-Clearance policy (7-110).

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Insider Trading

Freddie Mac | Our Company & Owners

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We Communicate Responsibly

Working With Regulators and Government Agencies

We will act in a cooperative, constructive, and professional manner in our dealings with our regulator and conservator, the Federal Housing Finance Agency (“FHFA”) and the FHFA Office of Inspector General (“FHFA-OIG”). We will respond to requests for data and information in a responsive and timely manner in accordance with the corporate policies set forth below. We will also provide FHFA and FHFA-OIG with access to Freddie Mac personnel, premises, and systems as required to help them fulfill their statutory duties and responsibilities.

If we receive an inquiry from a representative of a government agency other than FHFA and FHFA-OIG (including law enforcement agencies), we will consult with the Compliance Division before providing any non-public information or copies of documents, emails, or other Company property directly to any such party.

Policy 7-502 Responding to FHFA Examination and FHFA-OIG Requests

Policy 7-501 Regulatory Reporting Corporate Policy

Working With Auditors

We will cooperate fully, promptly, and truthfully in any audit of the Company’s financial statements. This obligation includes, among other things, responding to requests for information, participating in interviews, and disclosing all information relating to the subject matter of the audit. This also applies to any audit or examination activities of our internal auditors.

Interacting With the Media, the Investment Community, and Others Outside Freddie Mac

It is important that we provide reliable information to the public and others about our operations, positions, policies, practices, performance, and outlook. Only authorized persons may speak as representatives of Freddie Mac and communicate with the public on behalf of Freddie Mac.

Requests for information from the investment community should be directed to Investor Relations and inquiries from the media should be directed to Corporate Communications and Marketing.

Similarly, Congressional inquiries, other than certain matters as to which employees have been directed that the matter is being handled by the Legal Division, should be directed to Government and Industry Relations. Prior to engaging in any discussion or providing any information with respect to a legal matter, we should seek guidance from the Legal Division.

Proposed articles or other publications authored, and speeches given, by Freddie Mac personnel that deal with the business of the Company or our industry must be forwarded to the Corporate Communications and Marketing Department for approval. In addition, Freddie Mac Officers (and others specified in Company policies) must obtain the Corporate Communications and Marketing Department’s approval for any articles, publications, or speeches that could have an impact on Freddie Mac’s reputation, even if the individual makes it clear that opinions expressed are his or her own and not those of Freddie Mac.

Policy 2-202 Web Content Management

Policy 2-306 Media Relations, Publications, Internet Postings and Speeches

Freddie Mac | Our Company & Owners

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Our Communities We are Environmentally Responsible

We recognize our responsibility to conduct business in a way that protects and improves the environment for future generations.

We Give Back to Our Communities

Community involvement is an essential part of our corporate mission and it is very important that our corporate expenditures be aligned with our business strategies. Corporate payments to tax-exempt organizations must be reviewed and processed in accordance with corporate policies and procedures.

Personal Community Activities

When we volunteer our personal time or resources, we need to be sensitive to the need to distinguish our role as a private citizen from our role as a Freddie Mac employee. As a general matter, on-site solicitation of charitable contributions by Freddie Mac employees is not permitted. Freddie Mac employees, however, may solicit charitable contributions from other Freddie Mac employees to support school, civic, religious, or community organizations (e.g., Girl Scout cookie sales) in a manner that is not disruptive to Freddie Mac’s business operations. Under no circumstances may

we coerce or pressure other employees to make charitable contributions and managers may not ask employees within their chain of supervision for donations or contributions. Furthermore, Freddie Mac employees may not solicit charitable contributions from Freddie Mac customers, dealers, vendors, and other business affiliates.

Policy 3-302 Fundraising for Others

Personal Political Activities

As Freddie Mac employees, we are free to engage in personal political activity, as long as (i) the activity does not interfere with the timely and satisfactory performance of our job responsibilities, (ii) we distinguish our individual actions and views from those of Freddie Mac, (iii) we do not use coercion, and (iv) we do not use any corporate resources, such as support staff, corporate reimbursement for expenses, office supplies, corporate contact lists, corporate vendors, or corporate telephone and Internet services. In addition, we may not engage in political campaign fundraising or solicitation activities on Freddie Mac’s premises or during work hours. Under no circumstances may we coerce or pressure other employees to make political contributions and managers may not ask employees within their chain of supervision for donations or contributions.

To help ensure that conflicts are avoided, we must notify the Compliance Division of any political office or government-related positions, whether paid or unpaid, to which we are seeking election or have been appointed.

Policy 3-203 Outside Activities and Family Member Activities

Procedure

7-600Disbursements to Tax-Exempt Organizations and Disbursements that May Relate to Political Activities

Policy 7-602 Personal Political Activities of Freddie Mac Employees

Policy 7-605 Contacts with Government Officials

Here are a few examples of things that you can do to become more environmentally responsible:

n Reduce your use of energy and turn off electric equipment when not in use

n Minimize the use of office products by using only what is necessary

n Minimize printing or other use of paper

n Recycle materials whenever possible

Helping the Environment

Freddie Mac | Our Communities

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This Code of Conduct, Freddie Mac Corporate Policy #1-140, has been approved by the Audit Committee of the Freddie Mac Board of Directors. It has an effective date of January 1, 2014. It contains information pertaining to certain Freddie Mac policies and practices. Every Freddie Mac employee is expected to read this Code carefully as it describes the standards of conduct that govern our business dealings. If you have any questions or concerns about this Code of Conduct, please consult your manager or the Compliance Division.

This Code does not alter the at-will employment relationship between Freddie Mac and any employee. Nothing contained in this Code of Conduct constitutes a contract or creates any contractual obligations on the part of the Company; nor does anything in this Code expand or increase any employee or third party’s legal rights or the Company’s legal obligations.

Freddie Mac may elect to amend this Code at any time. A current version of the Code can be found on Freddie Mac’s internal and external Web sites.

Matters relating to the interpretation of this Code and your agreement to this Code, or to the interpretation of any other corporate policy, will be governed by the laws of the Commonwealth of Virginia, without regard to its conflict of law provisions.

This Code of Conduct is the property of Freddie Mac and all rights are reserved.

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