Overview of Personal Investment Policy


As an intern, you will have two options regarding Personal Trading, which you will select when completing your new hire compliance certification once you join the Firm:

  1. No Personal Trading – You agree to refrain from all personal trading throughout your internship. If you select this option, you must certify that you will not trade in your personal accounts and you will not have any disclosure or reporting obligations for your Covered Accounts.
  2. Limited Personal Trading – If you select this option, you will have the ability to trade on a limited basis during your internship subject to the following requirements. Trading is only permitted in the Covered Account types listed below and these must be held at a Designated Broker. These accounts must be disclosed to Compliance and all trading must be done in accordance with the Personal Investment Policy. You are not permitted to trade in any other accounts, including Family Member accounts, during your internship.

All non-public information that you have access to throughout your internship belongs to Citadel Group and may not be used to inform personal investment decisions. The time you spend managing your personal investments should not interfere with, or distract from, your work responsibilities.

Covered Accounts include the following types of accounts where you can and do direct trading:

  • Trading Accounts – Accounts that can or do hold equity or debt securities, futures, REITs, FX or derivatives.
  • Self-Directed Retirement Accounts – Retirement accounts where you direct trading activity (e.g., IRAs, SIPPs, ISAs). This does not include 401K accounts or accounts that can only hold mutual funds.
For each Covered Account that you will use to trade during your internship, you will need to disclose the following information within one week of joining the firm and receive approval prior to engaging in any trading activity in the account during your internship:

  • Account Name
  • Account Number
  • Brokerage Firm/Financial Institution where the account is held
  • Account Type
  • Provide the most recent account statement or holdings report

You may contact EmployeeCompliance@Citadel.com with any questions or to obtain the Designated Broker list for your region.

 

Outside Business Activities

Once hired, interns are expected to devote their business time and attention to the performance of their duties for Citadel.

You must receive approval from your manager and Legal and Compliance to continue any preexisting outside business activity during your internship. Approval will only be granted in limited circumstances.