Jenner & Block

Client Advisory: Code of Ethics for Principal Executive Officer and Senior Financial Officers

An article discussing the final rules under Section 406 requiring a public company to disclose whether or not it has adopted a code of ethics (the "Code of Ethics") for its principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, and requiring it to make a copy of its Code of Ethics publicly available to investors.  Public companies will also be required to publicly disclose any amendments to the key portions of its Code of Ethics, as well as any waivers thereto.  The rules are effective for annual reports for fiscal years ending after July 15, 2003.