eTrade 2011 Annual Report Download - page 193

the procedures outlined in subsequent pages of this Code entitled “Litigation, Investigations, Inquiries and Complaints.”
Corporate Communications must authorize participation in personal profiles or stories about “lifestyle” in which E*TRADE is
referenced. If employees and officers wish to appear in articles regarding their activities outside E*TRADE (philanthropic activities
or hobbies, for example), they may do so. However, do not identify yourself as an employee of E*TRADE or use the name or
facilities of E*TRADE in any way without approval from Corporate Communications.
All press releases and other written communications, including all articles and commentary, mentioning E*TRADE must be approved
by Corporate Communications, the Legal Department and Advertising Review in the Compliance Department before being released
by E*TRADE, its customers, suppliers or any other organization.
Employees may not endorse the products or services of suppliers or customers on behalf of E*TRADE unless expressly authorized by
Corporate Communications and the Legal Department. This includes commenting in press articles (including in-house publications),
broadcasts (including internet, radio and television) and participating in testimonial advertising, promotional brochures or annual
reports. In addition, employees may not permit third parties to use E*TRADE’s name for endorsements of their products or services
without the approval of Corporate Communications, the Legal Department and Advertising Review within the Compliance
Department.
Internet Access and Social Media
E*TRADE restricts internet access to certain websites, including websites commonly referred to as social media for all employees;
but recognizes that certain employees may have a business reason to access restricted websites. If you require such access, then you
must enter a Move, Add or Change (MAC) Request through My Channel*E which includes a valid business reason for the access.
Prior to receiving access to a restricted website, the employee will be required to agree to additional levels of oversight and
supervision by Brokerage Compliance. Additional detail regarding E*TRADE’s policies and procedures applicable to internet access
and social media websites is available on My Channel*E at https://mychannele.corp.etradegrp.com/web/life/policy/blogging and
https://mychannele.corp.etradegrp.com/web/life/policy/use
In addition to these restrictions, and regardless of whether an employee has been granted access to a restricted website, employees
may not post entries or participate in any chat rooms or bulletin board discussions (whether in real-time or not) during your assigned
work hours or from any E*TRADE equipment (whether using remote access, an E*TRADE laptop, a smart phone or other device) at
any time. In addition, whether at work or outside of work, employees may not in any way purport to represent E*TRADE or opinions
of E*TRADE or identify yourself as an E*TRADE employee. In short, you may not in any way discuss E*TRADE (by name or
otherwise) in a blog posting, chat room, bulletin board or any similar electronic or other venue.
Outside Lawyers
Only the Legal Department has the authority to hire outside lawyers on behalf of E*TRADE. Accordingly, you cannot retain any
lawyer or law firm on behalf of E*TRADE without the express prior approval of the General Counsel, and you must obtain approval
from the Legal Department before speaking to any outside lawyer regarding E*TRADE.
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