eTrade 2011 Annual Report Download - page 189

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, officers and directors 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. Remember, as employees, officers and directors
of E*TRADE, we each have a fiduciary duty to E*TRADE, and our actions must reflect this duty.
DEALING WITH THIRD PARTIES
Authority to Act on Behalf of E*TRADE
Employees and directors 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 (typically members of the entity’s board
of directors, and its officers, vice presidents (“VPs”), executive vice presidents (“EVPs”) or senior vice presidents (“SVPs”) may
enter into commitments on behalf of E*TRADE, which include signing contracts on behalf of any E*TRADE entity. All contracts
must be reviewed by Procurement and approved by the Legal Department (depending on the subject of the agreement) 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.
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:
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