Freddie Mac has built our business on the basis of service, trust and confidence, making us a leader in the mortgage finance industry. Freddie Mac’s Codes of Conduct set critical expectations for our behavior, with separate versions that apply to employees and Directors. Freddie Mac is required to review its Codes of Conduct at least once every three years. Most recently, the Board of Directors approved the revision to the Board Code of Conduct on September 7, 2023 (including only formatting updates). On January 1, 2023, the Employee Code of Conduct was revised to highlight additional areas of focus (including Fair Lending and Diversity, Equity and Inclusion) for the company and to generally refresh the document. On March 1, 2024, non-material updates were made to the Employee Code of Conduct reflecting policy number changes, sustainability language, and the leadership introductory message.

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.