THE SCHWAB FUNDS
CODE OF BUSINESS CONDUCT AND ETHICS
FOR PRINCIPAL EXECUTIVE AND SENIOR FINANCIAL OFFICERS
Provide shareholders with the most useful and ethical Mutual Funds in the world.
Be fair, empathetic and responsive in serving our shareholders.
Strive relentlessly to innovate what we do and how we do it.
Always earn and be worthy of our shareholders trust.
The Schwab Funds Principal Executive Officer and Principal Financial Officer and any other
officers who serve a similar function shall endeavor to act in the best interests of the Schwab
Funds and their shareholders.
The Schwab Funds Code of Business Conduct and Ethics (Code) covers all of the investment
companies within the Schwab Funds complex. This Code applies to the Schwab Funds Principal
Executive Officer and Principal Financial Officer and any other officers who serve a similar
function (each an Officer).
The Schwab Funds are committed to the highest standards of ethical conduct in the fulfillment of
our Vision and Values. We are proud of our long-standing reputation for integrity and honesty that
strengthens our Vision to provide our shareholders with the most useful and ethical mutual funds in
the world. This reputation is not just a source of competitive advantage in the financial services
industry; it is fundamental to the way we do business.
This Code provides guidance on how you, as an Officer, uphold these ethical standards. It applies
to your service to the Schwab Funds.
The Code consists of an outline of policies regarding conduct in several key areas: ethical
behavior and legal compliance, conflicts of interest, confidentiality and business practices. You
are responsible for reviewing the Code and for acting in compliance with the Code in your daily
The Code is not exhaustive; it provides guidance for carrying out your responsibilities on behalf
of the Schwab Funds and observing the highest standards of ethical conduct. Because the Code 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. Your integrity and good
judgment enhance the Schwab Funds brand, build the Schwab Funds reputation, and are the
foundation of trust for our shareholder and business relationships.
General Schwab Funds and Personal Standards of Conduct
As an Officer you have a responsibility to act in a manner in which you earn the publics trust and
confidence. Your conduct is guided by our values, which are to:
||Be fair, empathetic and responsive in serving our shareholders.
||Strive relentlessly to innovate what we do and how we do it.
||Always earn and be worthy of our shareholders trust.
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