eTrade 2012 Annual Report Download - page 244

Employee Trading
The Employee Trading Policy is designed to prevent legal, business and ethical conflicts and to guard against the misuse of
P
roprietary or Confidential information.
All of your securities and futures trading activities must strictly comply with all federal, state and other jurisdictional laws, rules and
regulations and must be in accordance with the very highest ethical standards. You must not engage in trading that is or may appear to
be improper. You may not engage in personal trading on a scale or of a kind that would distract you from your daily responsibilities.
The policy described below reflects these governing principles.
E*TRADE Employee Trading Policies and Practices
E*TRADE maintains a number of policies and procedures that govern employee trading in order to ensure compliance with numerous
laws, regulations and rules. Accordingly, employees are required to comply with these policies and procedures. In addition,
E*TRADE monitors employee trading activity and maintains records of such activities, as required by applicable law. E*TRADE’s
key policy in this area is the Employee Trading Policy, which applies to all E*TRADE employees and can be accessed on My
Channel*E at:
https://mychannele.corp.etradegrp.com/web/guest/departments/brokeragecompliance/surveillance/associate
The Employee Trading Policy addresses the trading policies of all E*TRADE business units; sets forth the types of accounts covered
by policy; details the requirement that employees maintain all trading accounts at E*TRADE; and also covers trading in E*TRADE
stock and restrictions on engaging in outside business activities. Employees are required to review, understand and adhere to the
restrictions and requirements set forth in that policy, as well as in this Code. Employees must also be familiar with and abide by any
trading policies applicable to your business unit or department because those policies may contain restrictions beyond those imposed
by this policy.
In addition, as set forth in the Employee Trading Policy, E*TRADE promotes wise investment and long-term financial planning for
both customers and employees. We strongly discourage employees from engaging in excessive or inappropriate trading that may
interfere with an employee’s job performance or conflict with principles of financial responsibility and long term investment
strategies. For a detailed description of the trading policy, please refer to the Employee Trading Policy found in the above-referenced
link.
In certain circumstances, as an employee of E*TRADE, you may be deemed to have a “fiduciary” duty that requires you to conduct
your personal trading affairs in a manner that first benefits the investment
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