eTrade 2012 Annual Report Download - page 228

laws. Additional obligations and restrictions are set forth in the new hire documents you received at the commencement of your
relationship with E*TRADE. Questions concerning these policies, rules and requirements can be directed to the Legal Department.
Privacy Laws and Regulations
E*TRADE is fully committed to complying with the privacy and data protection laws applicable to its worldwide operations.
E*TRADE employees are required as a condition of their employment to agree to maintain the confidentiality of Proprietary
Information (as defined below in this Code, including customer and employee information, to which they may have access during the
course of their employment. Disclosure of any such information must be done in accordance with internal policies and procedures and
E*TRADE’s privacy statement which is available on My Channel*E:
https://mychannele.corp.etradegrp.com/web/guest/departments/bankcompliance/policies
In addition to E*TRADE’s privacy statement, there may be other laws, regulations, contractual obligations or internal policies and
procedures, that require even stricter handling of information and in certain circumstances, may prohibit sharing of information
among E*TRADE entities and E*TRADE employees. For any questions regarding the disclosure of Proprietary Information, or
compliance with any privacy laws, regulations, contractual obligations or internal policies and procedures, please contact the Legal
Department or E*TRADE’s Privacy Officer, by sending an email to [e-mail].
Employee Accounts
To comply with industry regulations, employees and their immediate family members (members of the same household) must
maintain their securities accounts at E*TRADE, unless the employee receives prior approval from the Compliance Department. In
addition, employees of certain business areas may be subject to pre-clearance requirements in regard to their personal trading activity.
Additional information regarding this requirement can be accessed on My Channel*E:
https://mychannele.corp.etradegrp.com/web/guest/departments/brokeragecompliance/surveillance/associate
In addition, employees of E*TRADE who maintain bank or brokerage accounts at E*TRADE must keep those accounts in good
standing and conduct all transactions with integrity and good faith.
DEALING WITH THIRD PARTIES
Authority to Act on Behalf of E*TRADE
Employees cannot commit or bind E*TRADE to any contracts or other obligations unless they have the express authority to do so.
Except with respect to trading activities performed by registered brokers and customer service representatives on behalf of our
brokerage customers in the regular course of business, only certain individuals may enter into commitments on behalf of E*TRADE,
which include signing contracts on behalf of any E*TRADE entity in accordance with applicable policies and procedures. All
contracts with third party vendors must be reviewed by Procurement and approved by the Legal Department before they are signed.
Certain contracts also require approval of the Technology Infrastructure Committee, Vendor Management or Finance. In addition,
various business units and departments have special approval requirements for commitments of a certain size. You should consult
with your supervisor to learn of any such policies. E*TRADE’s Contract-Signing Authority Policy is posted on My Channel*E, and
you should contact the Legal Department with any additional questions regarding authority to bind E*TRADE to obligations with
third parties. This Policy can be accessed at:
https://mychannele.corp.etradegrp.com/web/guest/departments/legalaffairs/contracts.
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