EXHIBIT 44¶
Code of Conduct 2011 AFFIRMATION RECORD¶
I hereby affirm that I have read. understand. and am in compliance with the JRMorgan Chase Code of Conduct. I also affirm that I am In compliance with any supplemental policies Mat apply to me, Including without limitation any supplemental personal investment policies. I agree, as a condition of my employment, to remain in compliance with !Mt Code and the supplemental polities that apply to me. all as amended from time to Time.¶
I affirm that I nave reported any violations of the Code. Internal firm policies, or laws or regulations applicable to the firm’s business which I know of or suspect, as required by Section 1.S of me Code. I understand tnat failure to do so can result in disciplinary action up to and including termination of employment.¶
I understand mat the Code is updated periodically as necessary, and that the most current version is posted on the Pffilorgan Chase Intranet.¶
I acknowledge that I am a Senior-Level Emplc= for purposes of me Code and supplemental policies. As such.¶
- I am required to discuss any planned transactions In “Morgan Cnase securities, for my own account or mat of any of my employee-associated accounts, with a supervisor in advance. I agree to abide by this requirement.
- I have certain responsibilities that will continue after my employment witn the firm terminates, including restrIttions on hiring or soliciting the firm’s employees and soliciting the firm’s customers. I agree to abide by chose responsibilities after my employment terminates.
If you are an employee in an area chat requires pre-clearance of personal securities transactions andior maintenance of your employee and employee-associated accounts with a designated broker, you further certify the following:¶
To the extent required by personal trading policies and procedures applicable to me¶
- all securities transactions for my own account, or for any of my employee•associated accounts. are being pre•cleared by Compliance, and
- all of my employee and employee-associated accounts are maintained with a designated broker or will be moved co a designated broker within the applicable time period, except for any accounts that have been granted a written exemption by Compliance.
• A Senior-Level Employee is any employee wnose fa) annual base salary rate is USS1S0,000 (or the local currency equivalent) or higher, OR (b) total annual cash compensation is USS293,000 (or the local currency equivalent) or higher Total annual cash compensation means the employee’s annual base salary rate plus job/shift differentials as of the last preceding August 1, plus cash earnings under any Incentive plans or programs (e.g.. annual bonus, commissions, draws, overrides, and special recognition payments or Incentives) that are paid to or deferred by the employee during the 12-month period ending the last preceding July 31. It does not include overtime pay. (For US employees, total annual cash compensation is the amount used for medical plan purposes. as shown on the Benefits Web Center.)¶
Srandard ID. 0093791¶
Name: Staley. James¶
Department IB EXEC 2¶
Affirmation Date: 02 Jun 2011¶
A CODE AFFIRMATION BY THE ABOVE-NAMED EMPLOYEE WAS RECEIVED BY THE OFFICE OF THE SECRETARY¶