eTrade 2011 Annual Report Download - page 190

Other than members of the E*TRADE Financial Corporation Board of Directors, who must adhere to the Corporate Governance
Guidelines adopted by the Nominating and Corporate Governance Committee (“Corporate Governance Guidelines”) including
seeking approval of such committee, your involvement in any outside business activities requires the prior approval of E*TRADE. If
you have any questions, review E*TRADE’s policies on “Outside Business Activities” outlined in this Code and/or contact the
Compliance Department.
Acceptance of Gifts, Meals or Entertainment
In general, employees and officers may not accept gifts or excessive entertainment from customers, vendors, suppliers or others
having or seeking business dealings with E*TRADE. Cash gifts or their equivalent may not be accepted under any circumstances (e.g.
gift checks); however gift cards which are non-redeemable for cash are permitted to be accepted as long as they otherwise comply
with the provisions of this Code. Non-cash gifts may be accepted when permitted under applicable laws, rules and regulations if they
are (1) nominal in value (i.e., less than or equal to US$100); (2) appropriate, customary and reasonable meals and entertainment at
which the giver is present, such as an occasional business meal or sporting event; or (3) appropriate, customary and reasonable gifts
based on family or personal relationships, and clearly not meant to influence E*TRADE business.
In addition to the restrictions in the paragraph above, nominal non-cash gifts (with a value less than or equal to US$100) and
entertainment should only be accepted if a reasonable person would be satisfied that the gift or entertainment did not influence the
employee’s or officer’s judgment or the performance of your duties. Under no circumstances may employees and officers accept any
gifts or entertainment that could create a conflict of interest or the appearance of impropriety. The Compliance Department maintains
a log of gifts received by all employees. Any employee who receives a gift must report it to the Compliance Department. If
employees and officers have any questions
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• causing E*TRADE to purchase services or products from family members or businesses in which you or your family have or
may have an interest, unless approved to do so after disclosing the pertinent facts to your direct supervisor as well as the Legal
and Com
p
liance De
p
artments;
• serving as a director, officer, employee, partner, consultant or agent of an enterprise that is a present or potential supplier, or a
com
p
etitor of E*TRADE; or that en
g
a
g
es or ma
y
en
g
a
g
e in an
y
other business with E*TRADE;
• ownin
g
a material amount of stock, bein
g
a creditor or havin
g
an
y
other financial interest in an enter
p
rise described above;
•
havin
g
an
y
other si
g
nificant direct or indirect
p
ersonal interest in a transaction involvin
g
E*TRADE;
• obtaining or using for personal benefit confidential information regarding an enterprise described above, or providing
confidential information re
g
ardin
g
E*TRADE or its business to such an enter
p
rise;
•
appropriating for personal benefit a business opportunity that E*TRADE might reasonably have an interest in pursuing, without
first makin
g
the o
pp
ortunit
y
available to E*TRADE; or
•
engaging in outside activities that detract from or interfere with the full and timely performance by an employee of all of his or
her duties for E*TRADE.