eTrade 2012 Annual Report Download - page 223

Proper Record-Keeping and Disclosure Requirements
E*TRADE requires honest and accurate accounting and recording of financial and other information in order to make responsible
business decisions and provide an accurate account of E*TRADE’s performance to its stockholders and regulators. E*TRADE
requires and has implemented disclosure controls and procedures to ensure that its public disclosures are compliant, and otherwise
full, fair, accurate, timely and understandable. Accordingly, employees responsible for preparing E*TRADE’s public disclosures, or
providing information as part of that process, are responsible for ensuring that such disclosures and information are full, fair, accurate,
timely and understandable in compliance with E*TRADE’s disclosure controls and procedures.
It is a violation of law and E*TRADE policy for you to attempt to improperly influence or mislead any accountant engaged in
preparing an audit or financial reports. E*TRADE is committed to full compliance with all requirements applicable to its public
disclosures, and requires that its financial and other reporting fairly present the financial condition, results of operations and cash flow
of E*TRADE and comply in all respects with applicable law, governmental rules and regulations, including generally accepted
accounting principles (“GAAP”) and applicable SEC, SRO OCC and Fed rules.
Insider Trading
Federal law and E*TRADE policy prohibits any E*TRADE employee from acting upon material non-public information to benefit
yourself or others. Information is “material” if there is a substantial likelihood that a reasonable investor would consider it important
in making an investment decision, or it could reasonably be expected to affect the price of an issuer’s securities.
At times, E*TRADE policies may limit your ability to enter into transactions. In addition, if you have ongoing possession of non-
public information, you may be prohibited from trading in the securities of the companies about which you have such information. If
you have access to confidential or non-public
6
• At any time during your employment, you are named as a defendant or respondent in any securities or commodities-related civil
liti
g
ation;
• At any time during your employment, you are named as a defendant or respondent in any proceeding brought by a governmental
a
g
enc
y
or SRO alle
g
in
g
a violation of an
y
securities law or re
g
ulation;
• At any time during your employment, you are found by any governmental agency or SRO to have violated any provision of any
securities law or re
g
ulation;
• At any time during your employment, you receive a subpoena, inquiry or request from a governmental, regulatory or
administrative a
g
enc
y
or a claimant,
p
laintiff or outside attorne
y
that involves, or has the
p
otential for involvin
g
, E*TRADE;
• At an
y
time durin
g
y
our em
p
lo
y
ment
y
ou receive a customer com
p
laint, whether made orall
y
or in writin
g
;
• At any time during your employment you made a compromise with creditors, filed a bankruptcy petition or have been the
sub
j
ect of an involuntar
y
bankru
p
tc
y
p
etition; or
• At an
y
time durin
g
y
our em
p
lo
y
ment
y
ou have an
y
unsatisfied
j
ud
g
ments or liens a
g
ainst
y
ou.