Company Policies

Whether or not you as an employee of [COMPANY] choose to create or participate in a blog, wiki, online social network or any other form of online publishing or discussion is your own choice. In general, what you do on your own time is your business. However, activities that affect your job performance, the performance of other [COMPANY] employees, or business interests are still covered by company policies and guidelines. This applies whether you engage in these activities in or outside of work, and whether or not you identify yourself as an employee of [COMPANY].

If you choose to participate in these types of online activities, it is important that you understand what is recommended, expected and required, whether at work or on your own time. Accordingly, we have developed the following guidelines for you to follow when posting to a blog or some other form of social media like Facebook, MySpace, Twitter, Reddit or Linkedin.

Be thoughtful about how you present yourself in online social networks.

The lines between public and private, and personal and professional are blurred in online social networks. If you identify yourself as an employee or officer of [COMPANY] or are known to be one, you are now connected to your co- workers, Leaders and even customers. You should ensure that content associated with you is consistent with [COMPANY] policies.

Respect your audience and your coworkers. 

Remember that [COMPANY] is a professional organization whose employees and customers reflect a diverse set of customs, values and points of view. Don’t be afraid to be yourself, but do so respectfully. This includes not only the obvious (no ethnic slurs, personal insults, obscenity, etc.) but also topics that may be considered offensive or inflammatory. Use your best judgment, but if you need further guidance regarding what constitutes inappropriate communications please consult with HR, your Leader or immediate supervisor.

Respect the privacy of your coworkers. 

Blogs, wikis, social networks and other tools should not be used for internal communications among fellow employees. It is fine for [COMPANY] employees to disagree, but please don’t use your external blog or other online social media to air your differences. Do not discuss your co-workers without their permission, and ask permission before posting their picture. By respecting your co- workers’ privacy you will be helping to maintain the professional work environment at [COMPANY].

Respect the privacy of our customers. 

It is a priority that we respect the privacy of our customers. Do not use or discuss any information regarding customers for any purpose. This includes contacting customers for social reasons or soliciting outside business. If you need further guidance in this area, please refer to policy regarding customer private information.

Use a disclaimer. 

When [COMPANY] wishes to communicate publicly as a company it has well established means to do so. Only those individuals officially designated by [COMPANY] have the authority to speak on behalf of the company. If you identify yourself as an [COMPANY] employee, however, people may confuse your opinions with those of the company. In order to avoid this problem you must make clear that you are writing for yourself and on your own behalf, and not for [COMPANY]. At a minimum, we strongly recommend that you include a disclaimer similar to the following: “the postings on this site are my own and do not represent opinions or positions.”

Protect confidential information.

As an employee of [COMPANY] you have an obligation to protect the confidential, proprietary and trade secret information of the company. This obligation is laid out in several places including the Intellectual Property Agreement you signed when hired and in the Confidential Information Policy. For example, do not discuss any [COMPANY] confidential information including your store’s financial or business performance, and the timing, pricing or design of products. Also, do not post pictures of the inside of the [COMPANY] premises, offices or stores as those are not generally made public. Finally, do not post or disclose the contents of any [COMPANY] policy. These documents are intended for the use of [COMPANY] employees, and not for public distribution.

Respect copyright, fair use laws. 

For protection as well as your own, it is critical that you comply with all laws governing copyright and fair use of copyrighted material owned by others. For example, this means you should not be using [COMPANY] logos or images for your own personal use. Also, you may not copy, digitize, alter or distribute any part of a copyrighted work without first obtaining written permission from the copyright owner. For more information please refer to our copyright policy.

Do not use your [COMPANY] email for personal use.

Your [COMPANY] email address has been given to you for use at work.
Therefore you should not use your [COMPANY] email address on your personal blog or when posting on social network sites. Please use your personal email address for those types of communications. You may obtain free ones from Gmail.com, Mail.com, Hotmail.com, Yahoo.com or many other free email providers.

In summary, use your best judgment. Remember there may be consequences to what you post or publish online including discipline if you engage in conduct that [COMPANY] deems inappropriate or violates any [COMPANY] policies.

If you’re about to post something and you are concerned whether you are following these guidelines or any [COMPANY] policy, please discuss it with your immediate supervisor, HR or the PR Department before posting.

Confidential, Proprietary, and Trade Secret Information:

[COMPANY] recognizes that its confidential, proprietary, and trade secret information and that of third parties constitute our competitive advantage in the marketplace. [COMPANY] takes steps to protect its own confidential information and respects the confidential information of others. As a result, [COMPANY] expects all employees to take responsibility for protecting these sources of confidential information. [COMPANY] identifies, classifies, and protects all of its valuable business information from intentional or inadvertent disclosure, loss, modification, destruction, and copying. You may not disclose [COMPANY] confidential information to an outside party unless a written agreement or license has been previously signed and approved by the division vice president or PR Department.

Likewise, [COMPANY] respects the confidential information of others. You may not use or disclose any such third-party information unless you are authorized by the third party to do so and until you have signed a confidentiality agreement with [COMPANY].

Examples of [COMPANY] confidential information include, but are not limited to the following:

• sales and financial information including your individual metrics
• product/service availability and constraints
• information shared through internal meetings, corporate meetings, the corporate intranet
• [COMPANY] resources

• hiring and training information including salaries and bonus programs
• [COMPANY] policies and procedures
• [COMPANY] employee gossip, rumors, innuendo

Retail Store Websites
As an employee of [COMPANY], you may not create store websites displaying company-related activities.

Employee Personal Websites:
As an employee of [COMPANY], you are often the first to see and touch new [COMPANY] products. While you may create personal websites, you may not display photographs, articles, or commentary about [COMPANY] products, services, or initiatives.

Posting Messages on Related Websites:
As an employee of [COMPANY], you represent the [COMPANY] brand. While you are free to view any website on your own time, you may not post messages or commentary on [COMPANY]-related websites, whether you identify yourself as an employee of [COMPANY] or not.

Speculating on Rumors:
Refrain from speculating on anything [COMPANY] has not officially announced, even if a customer presses you for a personal opinion or indicates an interest in making a substantial purchase.

Information leaks can potentially damage interests, and [COMPANY] has zero tolerance for those who leak information.

When you began working for [COMPANY], you agreed to keep confidential information within the workplace, including any information you receive from an internal [COMPANY] source. Be cautious of conversations with other employees on the sales floor.

Customers often overhear these conversations which can lead to misinformation. Do not confirm or deny any information, even if customers pressure you by saying they are about to make or influence a substantial purchase or refer to non-[COMPANY] websites as sources of information.

Refer to the following speaking points:

• [COMPANY] does not comment on rumors about decisions, products, programs, or promotions that have not been officially announced by [COMPANY].
• By withholding comment, [COMPANY] hopes to protect customers from making decisions based on information that is incomplete, inaccurate, or subject to change before the formal announcement. [COMPANY] believes this is the best way to ensure that all customers are treated fairly.

In addition to the above, speculating on rumors with internal [COMPANY] colleagues is strictly prohibited. Only those individuals on the Company’s official disclosure list are entitled to receive and discuss information pertaining to unannounced Company information.

The Way We Do Business Worldwide:
[COMPANY] conducts business ethically, honestly, and in full compliance with all laws and regulations. This applies to every business decision in every area of the company worldwide.

Principles of Business Conduct:
success is based on creating innovative, high-quality products and services and on demonstrating integrity in every business interaction. principles of business conduct define the way we do business worldwide. These principles are:

• Honesty. Demonstrate honesty and high ethical standards in all business dealings.
• Respect. Treat customers, suppliers, employees, and others with respect and courtesy.
• Confidentiality. Protect the confidentiality of information and the information of 
our customers, suppliers, and employees.
• Community. Conduct business in a way that benefits the communities in which we 
operate.
• Compliance. Ensure that business decisions comply with all applicable laws and 
regulations. 


Making the Right Decisions: 

When facing a tough decision: Use good judgment. Apply principles of business conduct, review our policies, review legal requirements, and then decide what to do.

Need some help? When in doubt about how to proceed, discuss pending decisions with your Store Leader, your Human Resources representative, or the Legal Department. If you need more support, contact the Business Conduct Helpline.


Your Responsibilities: 

 business conduct policy and principles apply to employees, independent contractors, consultants, and others who do business with [COMPANY]. All such individuals are expected to comply with business conduct policy and principles and with all applicable legal requirements.

[COMPANY] retains the right to discipline (up to and including termination of employment) or end working relationships with those who do not comply. 
Please see details of the Business Conduct policy on the HR Web. [COMPANY] Retail may have policies that supplement what is communicated in this link for our employees.

If you have any questions, please do not hesitate to contact: [CONTACT PERSON]

Employees should all be aware that email is not a secure nor private means of communication and that there is no expectation of privacy. One should never send an email that they would not want to be published in the newspaper, read by the police or even a family member.
Emails can be ‘sniffed’ by software that may capture them over the internet and may be made public by parties who may not have your best interest in mind. Be aware of the risks – email messages, once sent, cannot be recalled and may be uncovered years after sending them.

Scope
This policy covers appropriate use of any email sent from a [COMPANY] email address and applies to all employees, vendors, and agents operating on behalf of [COMPANY] whom are permitted to use the company’s email infrastructure.

Best Practices
Each email you send, reflects upon your level of professionalism, courtesy and behavior. When representing the company, always pay attention to grammar and usage – some key points to keep in mind are:

1. Do not write emails in capitals, this is the equivalent of shouting
2. Enable spell checking,
3. Read the email before you send it. (Read twice, send once.)
4. Include a signature conforming with the company format,
5. Use proper grammar and punctuation.
6. Include instructions on compressing attachments to save bandwidth.
7. When forwarding emails to parties outside of the organization, be sure to read the entire chain of replies to be sure the no confidential or proprietary information is inadvertently passed on to others.

Confidential Data
Employees are advised to be aware of inadvertently passing on confidential company data. This may happen when long chains of emails with replies are passed on to new parties, who may read the entire document history. A good practice is to keep each email restricted to one subject and have that subject in the ‘subject’ line of the message.

Passwords
Passwords should be changed regularly and should be reasonably secure to prevent the unauthorized use of your email. Do not share your password with anyone. Do not reveal your password over the telephone to anyone professing to be from the “IT Department”, they do not need your password.

Prohibited Use.
The [COMPANY] email system shall not to be used for the creation or distribution of any disruptive or offensive messages, including offensive comments about race, gender, hair color, disabilities, age, sexual orientation, pornography, religious beliefs and practice, political beliefs, or national origin. Employees who receive any emails with this content from any [COMPANY] employee should report the matter to their supervisor immediately.

Personal Use.
Using a reasonable amount of [COMPANY] resources for personal emails is acceptable, but non- work related email shall be saved in a separate folder from work related email.
Sending chain letters or joke emails from a [COMPANY] email account is prohibited. Virus or other malware warnings and mass mailings from [COMPANY] shall be approved by [COMPANY] VP Operations before sending. These restrictions also apply to the forwarding of mail received by a [COMPANY] employee or coworker.

Monitoring
[COMPANY] employees shall have no expectation of privacy in anything they store, send or receive on the company’s email system. [COMPANY] may monitor messages without prior notice. [COMPANY] is not obliged to monitor email messages. [COMPANY] assumes no responsibility for the content of any employees emails which do not comply with this policy.

Document Retention Policy
All emails sent through the company’s email system may be retained for document archivization purposes. These documents will be retained for a duration deemed suitable by the company and in full compliance with all applicable laws, rules and regulations.

Enforcement
Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment. Illegal use of the company email system may even result in prosecution if deemed necessary.

User Compliance

I understand and will abide by this Email Use Policy.
I further understand that should I commit any violation of this policy, my access privileges may be revoked, disciplinary action and/or appropriate legal action may be taken.

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             Employee Signature                          Date