eTrade 2012 Annual Report Download - page 229

Conflicts of Interest
Separate and apart from applicable laws, rules and regulations, employees have a primary business and ethical responsibility to
E*TRADE to avoid any activity or relationship that may interfere, or have the appearance of interfering, with the performance of your
duties in a loyal, efficient manner to the best of your ability. Such activities and relationships, called “conflicts of interest,” include
any interest, relationship or activity that is incompatible or has the appearance of being incompatible with the best interests of
E*TRADE, or which potentially affects or has the appearance of affecting your objectivity as an employee.
Depending on your particular responsibilities, potential conflict of interest situations may include, but are not limited to:
Your involvement in any outside business activities requires the prior approval of E*TRADE. If you have any questions, review
E*TRADE’s policies on “Outside Business Activities” outlined in this Code and/or contact the Compliance Department.
Acceptance of Gifts, Meals or Entertainment
In general, employees may not accept gifts or excessive meals and entertainment from customers, vendors, suppliers or others having
or seeking business dealings with E*TRADE. Cash gifts or their equivalent may not be accepted under any circumstances (e.g., gift
checks); however gift cards which are not redeemable for cash are permitted to be accepted as long as they otherwise comply with the
provisions of this Code. Non-cash gifts may be accepted when permitted under applicable laws, rules and
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• usin
g
E*TRADE’s
p
remises, assets, information or influence for
p
ersonal
g
ain;
• causing E*TRADE to purchase services or products from family members or businesses in which you or your family have or
may have an interest, unless approved to do so after disclosing the pertinent facts to your direct supervisor as well as the Legal
and Com
p
liance De
p
artments;
• serving as a director, officer, employee, partner, consultant or agent of an enterprise that is a present or potential supplier, or a
com
p
etitor of E*TRADE; or that en
g
a
g
es or ma
y
en
g
a
g
e in an
y
other business with E*TRADE;
• ownin
g
a material amount of stock, bein
g
a creditor or havin
g
an
y
other financial interest in an enter
p
rise described above;
• havin
g
an
y
other si
g
nificant direct or indirect
p
ersonal interest in a transaction involvin
g
E*TRADE;
• obtaining or using for personal benefit confidential information regarding an enterprise described above, or providing
confidential or Pro
p
rietar
y
Information re
g
ardin
g
E*TRADE or its business to such an enter
p
rise;
• appropriating for personal benefit a business opportunity that E*TRADE might reasonably have an interest in pursuing, without
first makin
g
the o
pp
ortunit
y
available to E*TRADE; or
• engaging in outside activities that detract from or interfere with the full and timely performance by an employee of all of his or
her duties for E*TRADE.