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MAY 2009
CODE OF CONDUCT
 
 
 
 
INTRODUCTION
Our integrity and reputation depend on our ability to do the right thing, even when it’s not theeasy thing. The Code of Conduct is a collection of rules and policy statements intended to assistemployees and directors in making decisions about their conduct in relation to the firm's business. The Code is based on our fundamental understanding that no one at JPMorgan Chaseshould ever sacrifice integrity -- or give the impression that they have -- even if they think itwould help the firm's business.Each of us is accountable for our actions, and each of us is responsible for knowing and abiding by the policies that apply to us. Managers have a special responsibility, through example andcommunication, to ensure that employees under their supervision understand and comply withthe Code and other relevant policies.You can look to the Code of Conduct to guide your decisions in a variety of circumstances.However, no rulebook can anticipate every situation. Ultimately, the personal integrity andhonesty of every JPMorgan Chase employee define the character of our company. Never underestimate the importance of your own ethical conduct to the business and success of JPMorgan Chase.
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