eTrade 2011 Annual Report Download - page 207

the investment objectives of customers. This conduct includes the timing of personal securities transactions. You should never
conduct personal trades at the same time or in advance of transactions in the same security when you know that similar transactions
are being planned by customers or their advisors. For additional information regarding this policy contact the Compliance
Department.
The Restricted List
The Restricted List, which is also discussed earlier in the Treatment of Outside Information section of this Code, is maintained by the
Compliance Department. The Restricted List is one of the tools E*TRADE uses to monitor and ensure that regulatory requirements
are met. Employees are not permitted to trade in the securities (or other instruments) of issues on the Restricted List except in
accordance with any guidelines set forth on the Restricted List. Consult the Compliance Department when questions arise or when
you believe an exception is warranted. If employees become aware of a violation, notify the Compliance Department as soon as
practicable, and in no event later than 24 hours following becoming aware of the violation. Corrective action should not be taken
without Compliance Department approval.
A company may be on the Restricted List for many reasons. Therefore, employees should not make any assumptions as to why an
issuer has been listed. Similarly, a company may not be on the Restricted List even though you (and others) may be in possession of
material non-public information about the company. The fact that a company is not on the Restricted List does not in any way convey
permission or approval to trade on Inside Information. The Restricted List regularly changes, so employees should consult the list
before trading.
The Restricted List constitutes Proprietary and Confidential information. Employees may not distribute the Restricted List, or any
portion thereof, outside E*TRADE. If employees have a joint account or an account in your name that is managed by another
pursuant to a power of attorney, it is the employee’s responsibility to ensure that no trades of securities on the Restricted List are
made in these accounts. It is always an employee’s responsibility to avoid trading on any Inside information. Additional detail
regarding the Restricted List is provided on My Channel*E at
https://mychannele.corp.etradegrp.com/web/guest/departments/brokeragecompliance/restricted.
Transactions in E*TRADE’s Securities
E*TRADE has specific rules, as set forth below, that govern your transactions in E*TRADE’s securities. You must follow these
specific rules:
29
•
The window period for transactions in E*TRAD
E
’s securities generally begins or “opens” at the close of market on the second
business day following E*TRADE’s earnings announcement and ends at the close of market on the 15 of the last month (or, if
the 15 is not a market day, the preceding market day) of each fiscal quarter. However, circumstances relating to E*TRADE’s
operations or plans may cause E*TRADE to close the trading window at any time, with or without any prior notice.
• Even during an open-window period, you may not transact in any of E*TRAD
E
’s securities if you have Inside information
about E*TRADE, and any questions you have about whether a proposed transaction is appropriate must be resolved by seeking
g
uidance from the Le
g
al and Com
p
liance De
p
artments.
•
You are not
p
ermitted to sell short or trade in derivatives involvin
g
an
y
E*TRADE securities.
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