Electronic Communication Policy and Code of Conduct

History

Since 1994 APIC has provided the means for members to exchange ideas and gain insight into problem solving and to provide information to help members be more competitive in the marketplace. Originally conceived by the Sales and Marketing Committee, the APIC Chalkboard (an email List-Serve) was an invaluable tool for the members.

In developing the concept of the Chalkboard, the committee brainstormed several ideas, including "E-mail server" and "chat room". The final mechanism afforded members the opportunity to request information and offer suggestions and advice. Since the web site had not yet been built, this was the most effective way for members to learn without having to wait for the annual conference.

Early in 2002 the Board ratified the APIC Chalkboard Etiquette protocol and delivered the new protocol to the membership. As an addendum to the overview of Chalkboard Etiquette, the Board adopted a more detailed set of guidelines with which to govern the use of the Chalkboard, the APIC Chalkboard Code of Conduct.

With the advent of our new communication server and collective intelligence retention system, APIC StreetSmarts™, the Board has updated and revised the Chalkboard Etiquette and Code of Conduct, creating the Electronic Communication Policy and Code of Conduct to better reflect the intent, nature and power of our new system, APIC StreetSmarts™.

Electronic Communication Policy and Code of Conduct

It is the responsibility of each member to be thoroughly familiar with the Electronic Communication Policy and Code of Conduct set forth in this document. StreetSmarts™ posting is a privilege of membership. Like any privilege, it must be protected from certain abuses that could be injurious to APIC or the Firm. StreetSmarts™ is not a place for personal commentary. In that regard, it is incumbent upon any member who wishes to use StreetSmarts™ to thoroughly understand the governing policy. All members are required to abide by this policy as a condition of membership renewal and as a condition of usage of StreetSmarts™. Members in violation of the policy will be subject to remedial actions, which may include termination of their StreetSmarts™ privileges.

APIC StreetSmarts™ is a free benefit of APIC Membership. It is intended to be a communication mechanism, intelligence library and information-sharing resource. Most interaction begins with a member query or request for information or assistance. Those members who have skill or experience in the area requested are encouraged to respond, in the tradition of APIC, by openly offering their wisdom in this forum.

1). Electronic Communication Conduct Subcommittee

There shall be formed a standing Sub-committee of the Membership Committee, the Electronic Communication Conduct Subcommittee, that will respond to and evaluate usage believed by a member to be in violation of this Policy. The Subcommittee will be chaired by the Chairman of the Membership Committee and will have six additional members. One will be the President Elect, and the balance will be five voting members of APIC who are not on the APIC Board. Each member, including the Chairman and the President-Elect shall have one vote. The five voting members will be selected at random and serve a one year term ending at the annual conference. The Board Liaison to the Membership Committee may serve as a resource and consultant as needed, but has no vote.

2). Violations

Use of APIC StreetSmarts™ is subject to few, but important, rules of behavior. In general a positive tone is good - a negative, overly critical or unconstructive tone is not. The following are specific examples of undesirable behavior, and they are subject to the enumerated penalties.

Needless, one or two word responses (such as ditto, right on, yea or I agree), or responses that are clearly directed toward one member, not the membership at large.
Direct comments about other APIC members or Citigroup employees that are abusive, derogatory or defamatory.
Comments that could be reasonably interpreted to be malicious in intent toward APIC members or other Citigroup employees.
Unnecessarily or intentionally negative or unconstructive tone in comments, opinions or suggestions about the firm, APIC or fellow members.
Comments that are divisive with intent to segregate or polarize the membership.
Posting statements with blatant, malicious, unsubstantiated inaccurate or deceptive information.
Posting unsubstantiated comments, negative or positive, about APIC stakeholders such as Investment Advisors or software providers.
Forwarding StreetSmarts™ posts to non-APIC members, except as specifically permitted herein.
Comments regarding Firm compensation policy, including compensation of FA staff and Team members.

3). Complaint Process

Any APIC member may initiate a formal complaint regarding use believed in violation of this policy. Complaints of offensive posts will be directed to Association Manager.

The complaint shall contain specific language as to why the email is offensive or in violation of this Electronic Communication Policy and Code of Conduct. Consequently, it is the active APIC membership that polices electronic communication conduct.

The Association Manager will forward the complaint to the Conduct Subcommittee of the Membership Committee and to the originator of the offensive post. The Conduct Sub-committee will gather required background information, review this document and evaluate the validity of the complaint.

The violator will have an opportunity to offer a defense.

By majority vote the Electronic Communication Conduct Subcommittee will determine whether the complaint is affirmed or denied. If affirmed, the following penalties shall be levied, in order, as described.

a) The first confirmed violation shall result in a written warning explaining the specific use deemed offensive.

b) The second confirmed violation shall result in suspension for three months of the individual's privilege to post any comments to StreetSmarts™. The individual will be able to view APIC StreetSmarts™ and will continue to receive regular email communications from the system server. The individual will need to apply for reinstatement after the penalty period has expired.

c) The third confirmed violation shall result in suspension for 6 months of the individual's privilege to post any comments to StreetSmarts™. The individual will be able to view APIC StreetSmarts™ and will continue to receive regular email communications from the system server. The individual will need to apply for reinstatement after the penalty period has expired.

d) The fourth confirmed violation result in permanent denial of the individual's privilege to post any comments to StreetSmarts™. The individual will be able to view APIC StreetSmarts™ and will continue to receive regular email communications from the system server.

e) Forwarding StreetSmarts™ posts to non-APIC Members will result in suspension of all StreetSmarts™ access for the 3 months, 6 months periods or permanently (with no warning) as established in a), b), c) and d) above.

f) If the Board of Directors determines that the violation is so egregious that it could bring harm to the Association or the Firm, the Board reserves the right to take any action it deems necessary to protect the Association.

4). Appeals

A member may appeal directly to the Board of Directors at any point in this penalty process.

5). Team Members

With regard to Section 2, violation number 8 (forwarding StreetSmarts™ email or posts to non-members) an exception is made for Smith Barney FC Teams. APIC members who are members of an FA Team (as defined in the APIC Governance and Policy Manual) may pass StreetSmarts™ emails to their team members. Team leaders will be responsible for ensuring that team members do not forward StreetSmarts™ emails beyond the team. The team leader will be liable for any violation of policy by any non-APIC team member..

General Information

APIC StreetSmarts™ is an open discussion forum, making communication with other members effortless and free. This is a members-only service offered by APIC.

Note that while this is a private forum, and StreetSmarts™ is a relatively secure storage and retrieval technology, email is NOT a secure medium. Since the portal to StreetSmarts™ is Smith Barney's email server, please use good judgment regarding sensitive issues and language in your postings.

Adopted by the APIC Board of Directors as of November 4, 2002.
Amended January 2005

Ground Rules, Guidelines and Helpful Netiquette Hints

The best discussions take place in an open, inclusive, non-threatening environment. In addition to its formal rules of conduct (see below), this list is also governed by guidelines and informal conventions for making contributions to this list. Please take a moment and look them over.
Please do not post using all CAPS. Text done in all caps is difficult to read. The list is not moderated, per se -- that is, your messages will not be screened before they are sent to everyone - but we do ask that participants follow the guidelines below, be civil and courteous to one another. All messages should be guided by a constructive purpose. It is expected that a member would not use StreetSmarts™ to defame or otherwise become emotional or biased toward the firm or any individual or department.