eTrade 2011 Annual Report Download - page 191

regarding the appropriateness of a gift or entertainment, employees and officers must contact the Compliance Department or send an
email to: [e-mail] before accepting the gift or attending the event.
Providing Gifts, Meals or Entertainment
E*TRADE policy, applicable laws, rules and regulations may prohibit employees and officers from giving gifts in excess of specified
monetary levels (or of any value) to customers, vendors, suppliers, E*TRADE employees and other third parties, including persons
employed with a stock exchange, regulatory authority, financial institution, broker-dealer, or the news or financial information media.
More specifically, SRO rules currently prohibit E*TRADE employees from providing gifts in excess of $100.00 per person annually
to the third parties outlined above. If you have any questions regarding these SRO rules, contact the Compliance Department or send
an email to: [e-mail].
When permitted by law and consistent with accepted business practices and ethical standards, employees and officers may give gifts
of nominal value or provide meals or entertainment to customers, vendors, suppliers and other persons who have business
relationships with E*TRADE. No gifts should be given or entertainment provided if public disclosure of the circumstances would
embarrass E*TRADE or the giver of such gift or provider of such entertainment.
Special restrictions often apply to gifts and entertainment of government employees, even of nominal value. In addition, political
contributions may be subject to the rules of the Municipal Securities Rulemaking Board and employees are required to comply with
such rules. If you have any questions regarding these rules, contact the Compliance Department or send an email to:
[e-mail].
Customer entertainment expenses are generally not considered gifts if employees are present, the provision of the entertainment is
routine, and the expense is not excessive. Please see the Section of this Code on the Foreign Corrupt Practices Act and contact your
supervisor or the Compliance Department for further details.
Employees and officers must provide complete and accurate expense reports for all gifts and entertainment expenses paid for by
E*TRADE.
Approval of Nonconforming Gifts, Meals or Entertainment
The Chief Executive Officer and the Executive Vice President responsible for each employee’s business unit, together with the
appropriate Compliance Officer and the Company’s Secretary and General Counsel, may approve, on a case-by-case basis, the
acceptance of a gift, meal or entertainment that is not specifically permitted under this Section or that is prohibited under this Section.
Any such approval must be in writing and pursuant to full written disclosure of all relevant facts, including the name of the donor, the
circumstances surrounding the offer and acceptance, the nature and approximate value of the gift or other event, and the reason why it
cannot or should not be returned or refused.
Selecting Suppliers
E*TRADE requires employees, together with the Procurement team, to evaluate competing suppliers by their long-term financial
stability and the price and quality of their products or services. Personal relationships should not be (or be perceived to be) a factor in
the decision to use a particular supplier.
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