Code of Business Conduct and Ethics (2009)Full Document 

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THE SCHWAB FUNDS
CODE OF BUSINESS CONDUCT AND ETHICS
FOR PRINCIPAL EXECUTIVE AND SENIOR FINANCIAL OFFICERS
OUR VISION
Provide shareholders with the most useful and ethical Mutual Funds in the world.
OUR VALUES
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.
SHAREHOLDER VALUE
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.
Introduction
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 activities.
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 public’s 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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Schwab Funds Conduct
The following general principles guide our Schwab Funds conduct:
  §   You will act in accordance with applicable laws and regulations and will not tolerate behavior that is otherwise.
 
  §   You will make public disclosures as required by law and regulation and as deemed appropriate to enable reasonable evaluation of the Schwab Funds.
 
  §   You will strive to provide an equitable return for our investors.
 
  §   You will provide products and services designed to help shareholders achieve their financial goals.
 
  §   You will conduct business fairly, in open competition.
Individual Conduct
The following general principles guide your individual conduct:
  §   You will not take any action that will violate any applicable law or regulation.

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