eTrade 2011 Annual Report Download - page 201

employee takes such information out of the office for business purposes, keep it on your person or in a secure place at all times and
return it promptly to E*TRADE premises.
Communicating Proprietary or Confidential Information
Exercise care when sending or discussing data containing Proprietary or Confidential information on voicemail, electronic mail or
other electronic messaging, mobile or cordless phones, fax machines or message services. Make sure you use correct electronic mail
addresses, telephone extension numbers, fax numbers and, when applicable, use project and code names.
Within E*TRADE, communicate Proprietary or Confidential information only to employees who have a legitimate business reason to
know the information and who have no responsibilities or duties that could give rise to a conflict of interest.
Do not disclose Proprietary or Confidential information to any person outside E*TRADE (including family members), or use it or
permit any third party to use it without first obtaining approval from Legal.
Disposal of Proprietary or Confidential Waste
When no longer of use, Proprietary or Confidential information must be disposed of in a manner that renders it unreadable and non-
reconstructable, using means and methods approved by E*TRADE (for example, approved shredders or confidential waste bins),
consistent with E*TRADE’s records management and information security policies, applicable law and any applicable contractual
obligations. Information contained on electronic storage media (for example, a zip cartridge) should be destroyed in a manner that
renders it unreadable and unrecoverable.
Proprietary or Confidential Information Concerning Securities
When Proprietary or Confidential information might affect the price of a security or other financial instrument, or the decision to buy
or sell securities or other financial instruments, the laws concerning insider trading also govern your responsibilities, regardless of
whether you are given specific instructions or reminders that particular information may be “inside” information. E*TRADE has
developed strict procedures to ensure compliance with the laws of each jurisdiction in which it does business. These procedures are
critical to the protection of the E*TRADE franchise and are described in E*TRADE’s policy on the “Treatment of Inside
Information,” which is outlined in a subsequent section of this Code. Remember that these restrictions apply to information relating to
the stock of third parties as well as to E*TRADE stock.
Ownership of Intellectual Property
E*TRADE owns all rights in any intellectual property developed by you during your employment that relate to E*TRADE’s business,
even if invented or otherwise developed outside E*TRADE premises and even if no E*TRADE equipment was used in the process.
For this purpose, E*TRADE’s intellectual property includes any invention or design (whether or not patentable or reduced to
practice) and all related patents and patent applications, any copyrightable work, any trademarks or service marks (and related
registrations or applications for registration) and any trade secrets. Some E*TRADE intellectual property is Proprietary information
that should be treated in accordance with the standards set forth in this Code.
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