Business Ethics and Corporate Policy of Raymond James Financial, Inc.
Raymond James Financial, Inc. (the “Company” inclusive of all its subsidiaries and affiliates) expects its Associates, as well as independent contractor Financial Advisors and those affiliated with them, to exercise the highest degree of professional business ethics in all actions they undertake on behalf of the Company. In furtherance of that objective, the Company expects its Associates to act in accordance with the RJF Business Ethics and Corporate Policy, which is distributed to new Associates and affirmed annually by all Associates. Registered associates will also be responsible for reading and understanding the Financial Advisor Instructions. This annual affirmation of the RJF Business Ethics and Corporate Policy is a condition of continued employment or affiliation.
This RJF Business Ethics and Corporate Policy is being issued in addition to the Associate Handbook, which you have previously received if you are a Company employee. If you are an employee, by signing the Annual Certification Signature Page you are also representing that you have reviewed the Associate Handbook and understand and will abide by its contents. It is, therefore, important that all Company employees re-read the Associate Handbook at this time.
The RJF Business Ethics and Corporate Policy (the “Policy”) is not exhaustive; it provides guidance for carrying out your responsibilities on behalf of the Company and observing the highest standards of ethical conduct. Because the Policy does not address every possible situation that may arise, you are responsible for exercising good judgment, applying ethical principles, and raising questions when in doubt.
Confidential and/or Proprietary Information of the Company; Confidentiality of Customer Information
In carrying out the Company’s business, Associates often learn confidential or proprietary information about the Company and/or its customers.
The Company's business records, including but not limited to customer lists, customer data, sales information, business methodologies, compensation records, and/or similar information are considered to be trade secrets to be used solely in the conduct of the Company's business. No such information shall be obtained, used or revealed by Associates unless authorized by their supervisor in the course of their regular job functions. Unauthorized use of Company information or customer information, whether within or outside the Company, is a very serious violation and may result in immediate termination. Associates may not disclose Company’s business or customer information to anyone or any firm outside the Company unless (i) the outside firm needs to know the information in order to perform services for the Company and is bound to maintain its confidentiality; (ii) when the client has consented or been given an opportunity to request that the information not be shared; (iii) as required by law or self-regulatory organization; or (iv) as authorized by the Compliance Department or the Legal Department. Associates may not divulge proprietary or confidential information, either related to the Company or to customers of the Company, to other Associates unless otherwise required to fulfill their responsibilities to the Company. Likewise, unauthorized interception of Company communications, whether electronic (email), oral (telephonic), or documentary, is a violation of policy that may subject the violator to immediate termination.
Associates should be mindful of these obligations when using the telephone, fax, electronic mail and all other electronic means of storing and transmitting information. Associates should not discuss confidential information in public areas where it can be overheard, read confidential documents in public places or leave or discard confidential documents where they can be retrieved by others. Associates should shred all hard copy documentation when no longer needed, especially that containing personal or confidential customer or Associate information.
Theft or other misuse of trade secrets and/or proprietary information will be prosecuted to the full extent provided by law. Departing associates are not permitted to take or divulge any of the data described above in the event they leave the Company, except as permitted by the RJA Financial Advisor Instructions.
Conflicts of Interest
The Company expects the undivided loyalty of its associates in the conduct of Company business. It is important that associates be free from any financial interests or other relationships that might conflict with the best interests of the Company and/or cloud their judgment in carrying out the business affairs of the Company. A “conflict of interest” exists when a person’s personal or professional interest is adverse to, or may appear to be adverse to, the interests of the Company. A conflict of interest may arise when an associate or a member of the associate’s family receives improper personal benefits as a result of the associate’s position within the Company. Accordingly, associates must report any conflict of interest to their department head or the General Counsel.
Corporate Hotline (AlertLine)
The Company is committed to providing a working environment where each associate is proud of the Company's efforts, and is confident of the actions of fellow associates. Toward that end, the Company encourages associates to express any concerns they may have regarding actions they believe are inconsistent with the Company's ethical standards to their supervisor or, if they prefer, to the next level supervisor, or anyone else in the Company's management structure. Company management maintains an open door to listen to and respond to concerns of any RJF associate. The Company has long believed that employees should be encouraged to express their concerns and should be confident that there will be no retribution for doing so. If, however, associates feel it is inappropriate to approach their supervisor or another member of Company management, they can report concerns related to the Company’s ethical standards or simply get more information by logging on to the Company Hotline (AlertLine) website or by calling to speak to an AlertLine professional who can record the information and file a report.
Hotline (AlertLine) Website: https://raymondjames.alertline.com
Hotline (AlertLine) Number: 1-888-686-8351
In the conduct of business the Company and its associates collect and retain personal and confidential information about individuals. In order to strike a workable balance between the need for information and the privacy of individuals, associates shall be guided by the following principles in the collection, storage, use, and dissemination of information about the persons to whom the Company provides investments, insurance products, and other services.
Political Activities and Contributions
The Company will not make any contributions or expenditures to or for any political parties, committees, bond ballot campaigns or candidates for any public office, or to any persons for any political purpose whatsoever, regardless of whether it is proposed to be made in the United States or a foreign country or whether it would or would not be in violation of local law unless it is through a PAC established by the Company. "Contributions or expenditures" includes any direct or indirect payments, distributions, loans, advances, deposits, gifts, purchases, or tickets to dinners or other fund raising events, services (including transportation), equipment or any other items of value made to or for political candidates, parties, committees or bond ballot campaigns.
Although the Company encourages all associates to participate individually in civic affairs and in the political process, the Company will not reimburse associates for any expenses incurred in connection with those activities. Associates who engage in civic or political affairs must do so on their own time and at their own expense and may not use Company facilities or resources in doing so. Additionally, associates may not apply any pressure, direct or implied on any other associate that infringes on an associate’s right to decide whether, to whom and in what amount a personal political contribution is to be made. (See Community Activities on Company Property policy in the Associate Handbook under Company Policies).
Associates shall not make any contributions or expenditures to or for any candidates for any public office, or to any persons for any political purpose whatsoever that would violate the Company's policy on political contributions or any law, rule or regulation, and in particular MSRB Rule G-37 and SEC Rule 206(4)-5. For more information, refer to the Political Contributions & Activities Policy.
Recording and Auditing Transactions
The Company has a responsibility under the law to communicate effectively so that the public is provided with full and accurate information in all material respects. To the extent that the associate is involved in the preparation of materials for dissemination to the public, the associate should be careful to ensure that the information in these materials is truthful, accurate and complete. If the associate becomes aware of a materially inaccurate or misleading statement in a public communication, the associate should report it immediately to the General Counsel or through the Ethics, Accounting and Internal Control Hotline at 888-686-8351. Associates shall not intentionally falsify any memorandum, record or document of the Company or intentionally make a materially false or misleading statement to an accountant or representative of a regulatory agency in connection with any examination or audit of the Company's financial affairs.
Authority to open and maintain bank accounts and to arrange for the deposit or withdrawal of corporate funds has been delegated by resolution of the Board of Directors to specified personnel. All withdrawals from approved accounts shall be only by corporate check or by interbank transfer (including electronic fund transfers - EFTs/ACHs) to other Company accounts, and no check may be issued to "cash" or to a numbered bank account unless other information sufficient to identify the persons receiving the benefit of the payment appears on the face of the check. No check may be issued in a transaction that involves the direct or indirect setting aside or earmarking of funds, accounts, or monies that, regardless of purpose, are not clearly recorded and accessible to and understandable by the Company's auditors.
Link to the Company’s Arbitration Agreement.
Enforcement of the RJF Business Ethics and Corporate Policy
The Company shall determine appropriate actions to be taken in the event of violations of this Policy. Such actions are reasonably designed to deter wrongdoing and to promote accountability for adherence to the Policy and may include disciplinary action up to and including termination.
As amended by the Board of Directors on February 22, 2014