IMPORTANT DISCLOSURES

Social Media, Internet and Email Policy and Procedures

PURPOSE: To ensure appropriate use of Company-provided Internet access and Internet e-mail by Company staff. Our Social
Media Officer is Aleksandre Vayshelboym.

APPLICABILITY: This policy applies to all staff of the Company who utilize the internet, e-mail, and computers on Company
premises, or who utilize Company-sponsored/provided internet sites, services, software, or e-mail off of Company premises.

BACKGROUND: In the interest of providing current technology for the use of employees who are required to research corporate issues
or communicate with others through electronic mail services, the Company has authorized and paid for Internet access for many of the staff
members. This allows users to access many other non-work related computer information sites once an individual is connected to the
service through their computer.

POLICY: It is essential for each social media/internet/e-mail user to recognize his/her responsibility in having access to vast services,
sites, systems and people. The user is ultimately responsible for his/her actions in accessing network services and the Internet.

Social Media. We define social media as all forms of electronic communication through which users create online communities to
share information, ideas, personal messages, and other content (such as video, blogs, wikis, photos, podcasts, social networking,
mashups and virtual worlds).
All employees should be aware of their employment association in online social networks. If staff identifies himself or herself as a
our employee or has a public facing position for which association with us is known to the general public, he or she must be certain
that his or her profile and related content is consistent with how he or she wishes to be presented as our professional.
Published content is persistent in the public domain. When staff is representing us in an official capacity, we are responsible for
the content published on blogs, wikis or any other form of user-generated media. Staff must assume communications are public
domain, available for publishing or discussion in all forms of media.
Internet. Internet service provided by the Company be used for business purposes or e-mail (electronic mail). The Company
understands that some personal use of e-mail or internet browsing/shopping may occur from time to time, and has no restrictions as such
when this activity is performed during non-paid hours, using the same professional/business protocols as described in this policy.
Any improper use of the internet service provided by the Company for viewing, downloading or accessing information (offensive, lewd,
pornographic, violent, et al.) not needed for Company business, for sending documents or other proprietary material that result in
damage to the Company, or for spending excessive company-paid time using the Internet for personal purposes may be subject to
discipline up to and including termination.
E-mail. Using e-mail to send messages outside the Company makes the sender an official representative of the Company. Generally, email
is to be used for official communications only (again, some use of e-mail for personal issues is acceptable when done on non-paid time
using the same professional/business protocols as described in this policy). Securing an email is very difficult. Securing an email
requires special software and training. Transferring sensitive documents should never be done with email unless it’s password
protected.
Use of e-mail provided by the Company expressly prohibits the following:

• Dissemination or printing of copyrighted materials, including articles and software, in violation of copyright laws.
  o Sending, receiving, printing or otherwise disseminating proprietary data, trade secrets or other confidential information of the
  Company in violation of Company policy or proprietary agreements.
• Offensive or harassing statements or language including disparagement of others based on their race, national origin, sex, sexual
  orientation, age, disability, religious or political beliefs.
• Operating a business, usurping business opportunities or soliciting money for personal gain, or searching for jobs outside the
  Company.
• Sending chain letters.
• Gambling or engaging in any other activity in violation of local, state or federal law.
• Transmitting documents/pictures containing pornographic or other sexually explicit materials.
• “Spams” or anonymous mailings
• Propaganda (religious or political doctrine)
  As an official communication tool, it is subject to the same standard of professionalism and prohibition of discriminatory or inflammatory
  remarks/jokes/photographs or any other medium, as required in all other conduct of Company business.
  * Under United States law it is unlawful to transmit unsolicited advertisements to other fax machines or computers. The law allows
  individuals to sue the sender of such illegal “junk mail” for $500 per copy. Most states will permit such actions to be filed in Small Claims
  Court. Keep this in mind as you plan your marketing approaches.
  Downloads and E-mail Attachments. Downloads of software, shareware, graphics, documents, etc., are the heart and soul conveniences of
  the Internet. Since so many computer viruses are spread through these downloads, the Company highly recommends that all
  computers are installed with a good virus protection program. All users should get the approval of their managers before downloading
  any software onto Company-owned computers. If a virus is encountered with a stand-alone PC (non-networked), only the files on that
  PC may be damaged. If a virus is encountered with a networked PC, chances are very good that all PC’s linked to the network will be
  damaged.
  Company management reserves the right to monitor employee e-mail and Internet usage. As a general rule, the Company will make
  every effort to keep employee e-mails private. There may come a time, however, where access to e-mail messages may become a necessity
  (such as unexpected employee absences, or to conduct investigations where illegal activity is suspected). The Company reserves the right
  to view saved e-mail messages without verbal or written notice.
  If, at any time, the Company chooses to install Internet monitoring devices, users will be notified in advance, in writing.
  Personal Web Pages, Web Sites and Links. Personal web pages or web sites created using the company name in any variation within
  the domain name or within web pages is strictly prohibited. Also prohibited are any web sites or personal pages of any future divisions,
  affiliated companies or subsidiaries of the above, or any name variation thereof. Links or key words for search engines (included in the
  unseen html code used to create web pages) that are included with personal web pages or web sites are also strictly prohibited.
  Exceptions will be considered in writing to the President. Links by other companies to the Company web site is not prohibited.
  PROCEDURES:
  Adding new staff
  All new personnel will be assigned a Company e-mail account by the IT supervisor.
  Maintenance
• Check e-mail frequently (but no less than once per day).
• Delete unwanted messages immediately since they take up storage on the computer system (also run the utility from Outlook to
  empty deleted mailbox by going to Tools, then choosing Empty Deleted Items). Print or store on diskette or hard-drive those messages and/or attachments that fall under record keeping guidelines.
• Keep downloaded files to a minimum. Downloaded files should always be virus checked. Files should be downloaded to your personal computer’s hard drive or to diskettes. It is the user’s responsibility when downloading programs to check for copyright or licensing agreements. If the program is beneficial to your use, pay any authors registration fee. If there is any doubt, don’t copy it. Support for any downloaded programs should be requested from the originator of the application.
• Routinely and frequently virus-scan you system, especially when receiving or downloading files from other systems to prevent the spread of a computer virus. *Note to office managers: in order for anti-virus software to be effective, it must be upgraded with the latest virus information on a consistent basis (such as weekly or monthly). Your software vendor’s installation instructions will give you greater detail.
• Your files are accessible by persons with system privileges; so do not maintain anything private on your computer.
  RECORDS RETENTION: Any e-mail communication that is sent or received by the Company or its representatives is open to government rules and regulations for record keeping, including personnel issues. All e-mail messages that need to be preserved should be
  converted into another form (i.e. a Microsoft Word or Wordpad document, or printed on paper, etc.).

POLICY VIOLATION: Disciplinary action for violation of this policy may include, but is not limited to, termination, suspension, or
transfer of the offending employee. In cases involving less serious violations, disciplinary action may consist of warning or reprimand.
Remedial action may also include counseling, changes in work assignments, or other measures designed to prevent future misconduct. The
measure of discipline will correspond to the gravity of the offense as weighed by its potential effect on the Company and fellow employees.