Use of Information Technology

The following policies shall apply to all use of the network by users of the Company. The network includes, without limitation, all computer systems, electronic and other communication and storage systems, email, telephone and facsimile equipment, data communication facilities and the internet.

1. Access to the Network through use of the Company facilities is provided for bona fide Company business purposes. To the extent that occasional personal use of the network does occur, such use must not, in the Company’s sole judgment, exceed a reasonable level or distract or disrupt normal work activities. Furthermore, the Company provides no assurance of privacy with respect to any business or personal use of the Network or any other facilities.
2. Network users must comply with all Company access procedures, including use of assigned user IDs and properly licensed software. Once a user receives a user ID to access the Network and related systems, he/she is solely responsible for all actions taken while using those user IDs. Users IDs may not be shared with others. Users may not use email IDs assigned to other individuals to send or receive messages, except in the case of administrative assistants. To maintain system integrity, all employees are required to change their password(s) periodically. A password containing a random mixture of letters and numbers provides the best security. Individual passwords do not guarantee confidentiality or prevent access by the Company, and the Company reserves the right to override passwords and access any part of the Network at any time. In addition, each user should note that he/she may not:
   1. Use the Network or other systems to gain unauthorized access to other information or systems.
   2. Place personal encrypted material on the network.
   3. Copy Network or other files without authorization or use or copy copyrighted materials, such as third-party software, without the proper license or the express written permission of the owner.
   4. Except in “unusual circumstances” share with or use another person’s ID or password that may help to gain access to the Network. These unusual circumstances might include sharing an ID and password with a personal assistant (or other direct report) in order to provide him/her with temporary access to information when you do not have your normal access capabilities due to an equipment malfunction or an inability to connect to the Network from a remote location. Also, it is sometimes necessary to share a password with local IT personnel in order to assist them in troubleshooting a particular problem. In each of these situations however you should change your password after the event so that under normal circumstances no one else knows it.
3. Any email or other communications sent or received via the Network and particularly the internet must be appropriate for the workplace. The language of user email should meet community standards for decency and not make degrading or defamatory remarks about any employee, vendor or customer. Sending anonymous email is forbidden. Email is a relatively permanent form of communication. Users should not transmit any information in email messages that would be inappropriate in a written letter or memorandum. Deletion of an email message does not eliminate backup copies of the messages, which are automatically stored.
4. Only legally-acquired and licensed software is allowed on the Company Network. Users must comply with software license agreements and applicable laws at all times. Copying software in violation of copyright laws is strictly prohibited.
5. Employees are expected to act in a responsible and professional manner when they use the Network and all other Company facilities. Actions that may cause interference with the Network or disruption of work activities are prohibited.
6. Regardless of available encryption methods or other security, it should be assumed that the internet is not adequately equipped to protect data that is considered highly sensitive, confidential or personal. Dissemination of business or technical information of a sensitive, proprietary, confidential or internal nature is not permitted without prior approval.
7. Software, databases and similar ‘live’ technology may not be sent or received via the internet without (a) prior approval, (b) appropriate virus screening, (c) proof that the owner has authorized applicable copying, transmission and use thereof, and (d) use of encryption and other security procedures as appropriate.
8. Users may not agree to a license to download any materials without first obtaining the express permission of their IT Department.
9. The Company reserves the right to access or monitor (with or without notice) at its discretion any use of the Network or other Company facilities, any transmission and information prepared, stored or transmitted on the Network. Such access or monitoring may include retrieving business information, investigating or resolving network or communication problems, preventing network misuse, ensuring compliance with policies for use of third-party software, ensuring compliance with legal and regulatory requests and enforcing Company policies. The Company reserves the right to disclose, without notice, such communication to third parties at its discretion. The network and related materials, including all data files, is the property of the Company, and the Company reserves the right to view and erase any programs (including games), electronic messages or data files of a personal nature that may reside on the Network.
10. Sexual, racial or other offensive, inappropriate or unlawful remarks, jokes, slurs and obscenities are prohibited. Use of the Network to view, access, upload, download, store, transmit, create or otherwise manipulate pornographic, sexually explicit or other offensive materials the Company considers inappropriate is expressly prohibited. Further, such uses of the Network may violate, among other things, the Company’s sexual harassment policy.
11. Use of the Network is subject to all other Company policies.
12. Each employee agrees, recognizes and hereby consents to the Company’s access to his or her email and computer files generated or otherwise created in the Company’s electronic systems. Each employee consents to the Company’s review of such electronic files without prior notification.
13. The Network and any file created on it or with it are not confidential and the employee files will likely be reviewed by the Company.
14. Users who become aware of or who are victimized by prohibited activities should report the violations to their supervisors immediately.

Any violation of the above policies may result in disciplinary action, which could include reprimand, probation, suspension, reduction in salary, demotion or dismissal as determined by the Company in its sole judgment and by applicable law.

There is a corporate and an individual obligation to fulfill the intent of these policies. Any director, officer or employee who discovers any matter that is or appears to be in violation of these policies must report the matter promptly to his/her supervisor or Human Resources. As an alternative, you may report violations 24 hours a day, seven days a week to the Oldcastle Ethics and Compliance Hotline at 1-888-312-2698. Callers may remain anonymous if desired.

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