Privacy Policy

As companies continue to expand their use of technology, employees increasingly make use of many electronic forms of communication and information exchanges. Employees have access to one or more forms of electronic media and services, such as computers, laptops, e-mail, telephones, voicemail, fax machines, on-line services and the Internet. The ability to provide these resources represents a considerable commitment by The Company for telecommunications, networking, software, storage and technology in general. This policy is designed to help employees understand the expectations for the use of these resources. It applies to employees, contractors, consultants, temporary employees and other workers at The Company, including all personnel affiliated with third parties. This policy applies to all equipment that is owned or leased by The Company, as well as equipment used or supplied by the employee on company premises or for company purposes.

Electronic media and services are business tools for employees to use during the work day. They include Internet/Intranet/Extranet-related systems, computer equipment, software, operating systems, storage media, network accounts providing electronic mail, World Wide Web browsing and File Transfer Protocol (FTP). Employees are expected to use these resources for business-related purposes only (e.g., to communicate with customers, to research relevant topics and obtain useful business information, etc.). It is important that employees conduct themselves appropriately while using these resources, and respect the copyrights, software licensing rules, property rights and privacy of others, just as they would in any other business dealings. All existing company policies apply to employee conduct while using these resources, especially those that deal with privacy, misuse of company resources, sexual harassment and confidentiality. Employees are expected to exhibit the same high level of ethical and business standards when using technology as they do with more traditional workplace communication resources.

The use of electronic media and services is a privilege extended by The Company which may be withdrawn at any time. Any employee’s use of The Company’s electronic media and services may be suspended immediately upon the discovery of a possible violation of these policies. There are software and systems in place or available that can monitor and record Internet, e-mail, telephone and other usage of company telephonic and electronic resources. The Company has systems capable of recording and monitoring each Internet (World Wide Web) site visit, chat, newsgroup or e-mail message and each file transfer into and out of our internal networks, and The Company has the right to do so at any time. No employee should have any expectation of privacy as to his/ her use of any company property or with regard to use of their own property if brought on site and used in conjunction with company systems.

The Company reserves the right to inspect any and all files stored in private areas of the network in order to assure compliance with this policy. This inspection also includes personal folders, machine hard drives and archived Compact Discs (CDs), employee-owned devices that they bring to work, cell phones and more.

Although employee passwords are required for use of some electronic media and services, this does not guarantee confidentiality. Note that even though files, data or messages may appear to be deleted, procedures to guard against data loss may preserve material for extended periods of time. In addition, in the unlikely event of certain types of legal proceedings, these types of communications may be subject to discovery. Employees are, therefore, reminded to conduct themselves in a professional manner when using these systems.

With the ever-changing nature of electronic media, this policy cannot set forth rules to cover every situation. Instead, it expresses The Company’s philosophy and states general principles to be applied in the use of electronic media and services.

The following policies relate to the responsible use of electronic media and services:

General

Do not disclose any confidential, sensitive or proprietary company information. (“Confidential information” is defined in his handbook. Confidential, sensitive or proprietary information shall be jointly referred to as “confidential” in this policy.)
Employees are responsible for protecting their own passwords and may not reveal their passwords to others or allow use of their account to others. This includes family or household members. Accessing other employees’ voicemail or e-mail without company authorization is prohibited. In addition, providing information to non-authorized individuals on how to access or use company equipment is prohibited. Employees may need to periodically change their password to assure protection to the systems.
If access to company systems is granted on an employee’s personal computer, that personal computer is subject to the same guidelines as those applied to company provided equipment.
The Company may have a litigation hold policy that applies to certain electronic information which may need to be made available during covered litigation. All employees must follow the hold policy once a hold is announced.
These resources are company property and are to be used solely for business purposes. For instance, The Company strongly discourages sending e-mails, phone messages or other communiqués containing individual political, religious, moral, etc. viewpoints.

E-mail

Fraudulent, harassing, threatening, discriminatory, derogatory, off-color, obscene messages or materials, or those containing sexual innuendo or off-color jokes, are not to be transmitted, printed, requested or stored. Chain letters, solicitation and other forms of mass mailings are not permitted.
Messages may not be transmitted, printed, requested or stored which are illegal, against company policy or contrary to The Company’s interest, including message spoofing. Under no circumstances is any employee to engage in any activity that is illegal under local, state, federal or international law while utilizing company-owned resources.
Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs or other codes.

Because internal e-mail addresses indicate an affiliation with The Company, no messages may be posted on an Internet bulletin board, blog, in a forum or any other publicly available Internet site that in any manner refers to The Company, or that might be interpreted as stating a company position or policy.
Company employees, contractors and consultants with remote access privileges to The Company’s corporate network must not use non-Company e-mail accounts (e.g., Yahoo, AOL, Hotmail, etc.) or other external resources to conduct company business. This will ensure that official business is never confused with personal business.
The exchange of confidential information (e.g., financial information, social security numbers and other information identified as “confidential”) should be conducted using high grade encryption. Secure File Transfer Protocol (SFTP) is a security program that allows users to encrypt and decrypt e-mail.

Internet

Employees may not download software images unless there is an explicit business-related use for the material. Entertainment software, games and related downloads are specifically prohibited.
Employees should be aware that by merely visiting a Web site, their address will be left behind, indicating at that site that they and The Company have visited it.
The transfer of company information to a non-company Internet email account is prohibited.
Blogging or visiting chat rooms using company resources is prohibited.

Telephone

Personal long-distance phone calls are prohibited. Employees who have personal or confidential matters to communicate should not use company equipment to do so.

Software and Hardware

Employees may not remove company owned resources, such as computers, laptops, printers, copiers, electronic media, flash drives, data or any hardware peripherals such as keyboards, mice, mouse pads, etc. from company premises unless they obtain written authorization using an equipment check-out form.
Do not use or distribute copyrighted software or information without proper authorization from the copyright holder.
Do not install any programs on a personal computer. Employees should contact the manager before making any software, hardware or configuration changes to their computer.
Do not attach any hardware devices to the CPU (such as a flash drive or external drive), monitor, phone, keyboard, etc.
Treat all downloaded software as if it may have viruses; any file downloaded needs to be first scanned with a virus detection program.

Social Media Policy

At The Company, we understand that social media can be a fun and rewarding way for employees to share their lives and opinions with family, friends and co-workers around the world. However, use of social media also presents certain risks and carries with it certain responsibilities. To assist employees in making responsible decisions about the use of social media, we have established these guidelines for appropriate use of social media.

This policy applies to all employees who work for The Company or one of its subsidiary companies in the United States.

GUIDELINES

In the rapidly expanding world of electronic communication, social media can mean many things. Social media includes all means of communicating or posting information or content of any sort on the Internet, including to an employee’s own or someone else’s web log or blog, journal or diary, personal web site, social networking or affinity web site, web bulletin board or chat room, whether or not associated or affiliated with The Company, as well as any other form of electronic communication.

The same principles and guidelines found in The Company’s policies and three basic beliefs apply to employee activities online. Ultimately, employees are solely responsible for what they post online. Before creating online content, consider some of the risks and rewards that are involved. Keep in mind that any conduct that adversely affects an employee’s job performance, the performance of co-workers or otherwise adversely affects members, customers, suppliers, people who work on behalf of The Company or The Company’s legitimate business interests may result in disciplinary action, up to and including termination of employment; know and follow the rules.

Employees should carefully read these guidelines and any other related company policies to ensure their postings are consistent with these policies. Inappropriate postings that may include discriminatory remarks, harassment and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject an employee to disciplinary action, up to and including termination of employment. Carefully read The Company’s policies on standards of conduct, discrimination and harassment, prevention, workplace violence prevention and the electronic media policy, and ensure postings are consistent with these policies. Inappropriate postings that may include discriminatory remarks, harassment and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject an employee to disciplinary action, up to and including termination of employment.

BE RESPECTFUL

Always be fair and courteous to co-workers, customers, members, suppliers or people who work on behalf of The Company. Also, employees should keep in mind that they are more likely to resolve work related complaints by speaking directly with co-workers or by utilizing our open-door policy than by posting complaints to a social media outlet. Nevertheless, if an employee decides to post complaints or criticism, they should avoid using statements, photographs, video or audio that reasonably could be viewed as malicious, obscene, threatening or intimidating, that disparage customers, members, co-workers or suppliers or that might constitute harassment or bullying. Examples of such conduct might include offensive posts meant to intentionally harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of race, sex, disability, religion or any other status protected by law or company policy.

BE HONEST AND ACCURATE

Employees should make sure they are always honest and accurate when posting information or news, and if they make a mistake, correct it quickly. They should be open about any previous posts they have altered. Remember that the Internet archives almost everything; therefore, even deleted postings can be searched. Employees should never post any information or rumors that they know to be false about The Company’s co-workers, members, customers, suppliers or people working on behalf of The Company or competitors.

POST ONLY APPROPRIATE AND RESPECTFUL CONTENT

Maintain the confidentiality of The Company’s trade secrets and private or confidential information. Trade secrets may include information regarding the development of systems, processes, products, know-how and technology. Do not post internal reports, policies, procedures or other internal business-related confidential communications.

Respect financial disclosure laws. It is illegal to communicate or give a “tip” on inside information to others so that they may buy or sell stocks or securities. Such online conduct may violate policies and laws related to insider trading.

Employees should not create a link from a personal blog, website or other social networking sites to The Company’s website without identifying themselves as an employee of The Company.

Employees should express only their personal opinions and never represent themselves as a spokesperson for The Company. If The Company is a subject of the content an employee is creating, he/she should be clear and open about the fact that he/she is an employee and make it clear that his/her views do not represent those of The Company’s co-workers, members, customers, suppliers or people working on behalf of The Company. If an employee does publish a blog or post online related to the work he/she does or subjects associated with The Company, he/she should make it clear that he/she is not speaking on behalf of The Company. It is best to include a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of The Company.”

USING SOCIAL MEDIA AT WORK

Refrain from using social media while on work time or on equipment we provide, unless it is work-related as authorized by the manager or consistent with other company practices or policies. Do not use The Company’s e-mail addresses to register on social networks, blogs or other online tools utilized for personal use.

RETALIATION IS PROHIBITED

The Company prohibits taking negative action against any employee for reporting a possible deviation from this policy or for cooperating in an investigation. Any employee who retaliates against another employee for reporting a possible deviation from this policy or for cooperating in an investigation will be subject to disciplinary action, up to and including termination of employment.

MEDIA CONTACTS

Employees should not speak to the media on The Company’s behalf without contacting the appropriate person at the worksite employer.

The Company respects its employees’ rights under the National Labor Relations Act, such as the right to discuss terms and conditions of their employment. Accordingly, nothing in this policy is meant to be a limitation upon or a chilling of employees’ rights under the NLRA.

FOR MORE INFORMATION

Employees who have questions or need further guidance, should contact their supervisor or Oasis DEG Human Resources Manager