Fannie Mae handbook: Illegal actions in a gray area?


This is largely gratuitous, but while tooling around Fannie Mae’s Web site, I came across their Employee Code of Conduct, revised in 2007. The opening includes this passage:

But in many situations the right course of action is not always obvious. So here are some questions that we can ask ourselves to help us navigate the shades of gray:

The first shade of gray?

Is the action legal?

In fairness, the preceding sentence tells employees, “Perhaps most importantly, our Code not only requires us to comply with the law, but it challenges us to promote ethical conduct in all that we do.” And of course, corporate ethics manuals rarely read like Aristotle. Still, it’s an unfortunate phrasing.

It was also jarring to read this violation of the code of conduct:

Offering, promising, paying or giving anything of value ” directly or indirectly ” either to a government employee or official, or to a foreign official, foreign political party, party official, candidate or their staff, in a manner inconsistent with applicable law or Policy

Showering campaign contributions consistent with the Federal Election laws on members of Congress, on the other hand, was apparently just fine.