eTrade 2012 Annual Report Download - page 220

person to whom you have reported a potential violation has not taken appropriate action, you must contact the Legal, Compliance, or
Human Resources Department directly. If you believe that you may have violated an applicable law, rule or regulation or this Code or
any other E*TRADE policy or procedure, you must immediately report such violation to the Legal, Compliance, or Human Resources
Department directly.
As an alternative to direct reporting to one of the Departments above, E*TRADE has engaged ListenUp, an outside firm through
which you may anonymously report any suspected violations of an applicable law, rule or regulation or this Code or any other
E*TRADE policy or procedure. You can access ListenUp at www.listenupreports.com. Additional information regarding ListenUp is
available on My Channel*E.
THE CODE OF PROFESSIONAL CONDUCT AND YOUR EMPLOYMENT
Code of Professional Conduct is Not an Employment Contract
As an employee of E*TRADE, this Code and the applicable policies and procedures contained in this Code form a part of the terms
and conditions of your employment and/or professional relationship with E*TRADE. However, the Code is not a contract, express or
implied, guaranteeing progressive discipline or employment for any specific duration or entitling you to bonuses or other forms of
compensation. Except in certain jurisdictions outside the U.S., employment at E*TRADE is “at will,” meaning that either E*TRADE
or you may terminate your employment relationship at any time, with or without cause.
Consequences of Violations of the Code of Professional Conduct
As an employee of E*TRADE, violations of the Code may subject you to disciplinary action by E*TRADE including — without
limitation — warnings, reprimands, temporary suspensions, probation, termination of your employment or other actions which may
be set forth in the specific E*TRADE disciplinary procedures applicable to the state or country in which you work or reside.
Disciplinary actions may be taken:
E*TRADE also must report certain activities to its regulators, which could give rise to regulatory or criminal investigations. The
penalties for regulatory or criminal violations may include significant fines, permanent bar from employment in the securities industry
and, for criminal violations, incarceration.
3
• against employees who authorize or participate directly, and in certain circumstances indirectly, in actions which are a violation
of a
pp
licable laws, rules or re
g
ulations, this Code or an
y
of E*TRAD
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’s other
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olicies and
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rocedures;
• against employees who fail to report or withhold information concerning conduct that they knew or should have known was a
violation of applicable laws, rules or regulations, this Code or any of E*TRAD
E
’s other policies and procedures, or withhold
information concernin
g
a violation of which the
y
become aware or should have been aware;
• against the violator’s supervisor(s), to the extent that the circumstances of the violation reflect inadequate supervision or lack of
dili
g
ence b
y
the su
p
ervisor(s);
• against employees who attempt to retaliate, directly or indirectly, or encourage others to do so, against an employee who reports
an actual or potential violation of applicable laws, rules or regulations, this Code or any of E*TRADE’s other policies and
p
rocedures; and
• a
g
ainst em
p
lo
y
ees who knowin
g
l
y
make a false re
p
ort of a violation.