eTrade 2012 Annual Report Download - page 219

Interaction with Business Partners, Potential Business Partners and Competitors
PURPOSE OF THE CODE
In order to ensure that E*TRADE’s employees conduct themselves in accordance with the highest standards of ethics, honesty and
integrity, E*TRADE has adopted this Code of, which sets forth standards for conduct for all of our employees.
It is the responsibility of each employee of E*TRADE to comply with the Code, as well as all applicable laws, rules and regulations
and all of E*TRADE’s corporate policies and procedures applicable to them. Because the Code does not address every possible
situation that may arise, E*TRADE employees also are responsible for exercising their best judgment, applying ethical principles, and
raising questions when in doubt. Integrity and good judgment enhance the E*TRADE brand, help build E*TRADE’s reputation, and
are the foundation of trust for our customer, supplier and community relationships.
Should anyone covered by this Code have questions regarding ethical principles or conduct, E*TRADE has a number of available
resources, including the following departments: Legal, Compliance, and Human Resources. In addition, E*TRADE employees are
encouraged to direct questions regarding business conduct to their supervisors.
The Code provides an overview of some of E*TRADE’s key policies and should be read in conjunction with all relevant E*TRADE
policies and procedures. It is your responsibility to become familiar with and adhere to all policies and procedures referenced in this
Code and any other policies or procedures applicable to your business unit or in the conduct of your duties as an employee of
E*TRADE. Most corporate policies are posted on My Channel*E. New employees, temporary agency employees, contractors should
ask their supervisor for all policies that apply to their business unit. We recognize that members of the ETFC Board of Directors are
subject to additional guidelines and policies which shall govern in the case of any conflict with the Code.
REPORTING VIOLATIONS
As an E*TRADE employee you are E*TRADE’s first line of defense against civil or criminal liability and unethical business
practices. If you know of, observe, suspect or otherwise become aware of a violation of applicable laws, rules, regulations, this Code
or any of E*TRADE’s other policies or procedures, you must report this information immediately. As an employee, such matters can
be reported to your direct supervisor or any other appropriate representative of E*TRADE senior management, which includes our
CEO and each of the Executive Vice Presidents (collectively “Senior Management”). If you believe that the
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• We do not tolerate anyone asking our employees, temporary agency employees, contractors and directors to break the law,
or violate E*TRAD
E
’s
p
olicies,
p
rocedures or values.
• We provide employees and directors with the information and necessary facilities to perform their jobs and functions in a
safe manner.
• We do not tolerate an
y
one usin
g
, brin
g
in
g
or transferrin
g
ille
g
al items on E*TRADE
p
ro
p
ert
y
.
• We re
q
uire
y
ou to re
p
ort an
y
sus
p
icious activities.
• We do not tolerate the use of E*TRADE resources for
p
ersonal
g
ain or an
y
non-business
p
ur
p
ose.
• We avoid conflicts of interest and work to identif
y
situations where the
y
ma
y
occur.
• We do not accept or give gifts, favors, or entertainment in excess of legal and regulatory limitations, as more fully
described in the Sections of this Code entitled “Acceptance of Gifts, Meals or Entertainment” and “Providing Gifts, Meals
or Entertainment.”
• We res
p
ect our com
p
etitors and do not use unfair business
p
ractices to hurt our com
p
etition.
• We do not have formal or informal discussions with our competitors on prices, markets, products, services or production,
service or inventor
y
levels.