Online Resources Policy

This Policy of the Company applies to your access to and use of Online Resources with regard to the Company. The Company recognizes that engaging online can be a great way to connect with family, friends, colleagues, customers and potential employees. The Company manages and participates in several branded Online Resources, some available for employees only, and others available to the public. Current examples of these branded Online Resources include collaboration platforms, internal and external blogs, social networking sites, and content posting sites, including Support Central, Colab, Facebook, Twitter, LinkedIn and YouTube. These resources can be used as powerful communication tools that can have significant impacts on organizational, professional and individual reputations.

WHAT TO KNOW

The Company supports online communities where customers, shareholders, employees and others associated with the Company can take advantage of social media to share information and ask questions. The Company also supports employee’s rights to engage in lawful social networking activities inside or outside of work which comply with laws and regulations related to developing technologies and information sharing. We encourage engagement with the Company and other OutageBuzz followers on the socials networks. However, we do not allow advertising or soliciting through our OutageBuzz profiles. Solicitations for employment, services or products will not be accepted or permitted via OutageBuzz social media. The same principles and guidelines found in Company policies apply to your activities online. Ultimately, you are responsible for what you post online. Before creating online content, consider some of the risks and rewards that are involved. Whether speaking on behalf of the Company or personally, employees should follow the same standards of behavior “online” as they would “in person”. Keep in mind that any of your conduct that adversely affects your job performance, the performance of fellow employees or may otherwise adversely affects members, customers, suppliers, or 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.

This policy applies to all employees who work for the Company. Managers, supervisors and facilitators should also refer to the section titled General Guidance for Managers and Facilitators. This policy’s expectations and principles also apply to any engagement or use of the Company’s Online Resources by anyone.

GENERAL GUIDANCE FOR ALL EMPLOYEES

Do not represent yourself as a spokesperson for the Company when expressing personal opinions and ideas. When the Company is a subject of the content you are creating, be clear and open about the fact that you are an employee, and make it clear that your views do not represent those of the Company, shareholders, fellow employees, customers, suppliers or people working on behalf of the Company. If you do publish a blog or post online related to the work you do or subjects associated with the Company, make it clear that you are 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 Viceroy/APM/APM Canada/APCom.”

Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. Be open about any previous posts you have altered. Remember that the Internet archives almost everything. Therefore, even deleted postings can be searched. Never post any information or rumors that you know to be false about the Company, shareholders, fellow employees, customers, suppliers or people working on behalf of the Company or competitors.

Do not express, communicate or link to comments that are vulgar, obscene, threatening, pornographic, harassing or defamatory or which are a violation of the employer’s workplace policies against sabotage, discrimination, hostility or harassment on account of age, race, religion, sex, ethnicity, nationality, disability, or other protected class, status, or characteristic.

The HR Team is responsible for providing references to employees, in accordance with Company policy as well as to comply with federal and state employment laws. Managers and supervisors should never provide references for current or former employees via social networking sites (such as LinkedIn).

Testimonials or endorsements about the Company or its products or services should be avoided. In the event that an employee uses an Online Resource for any testimonials or endorsements of the Company or its products or services, the employee must clearly and conspicuously disclose his or her relationship to the Company to members and readers of the Online Resource.

Maintain the confidentiality of trade secrets and propriety or confidential information belonging to the Company, shareholders, customers and suppliers. Trades secrets may include information regarding the development of systems, processes, products, services, know-how and technology. Do not post internal reports, policies, procedures or other internal business-related confidential communications on any Online Resource. Refer to the Confidentiality and Assignment of Employee Innovations Agreement for further definition.

In accordance with state and federal law, employees are prohibited from posting confidential personal information about customers or employees (such as social security numbers, protected health information, credit card numbers, drivers’ license numbers, mother’s maiden names, complete dates of birth, minor children’s names) on any Online Resource that does not have the appropriate access parameters specific to the data.

Employees also may not use any client or vendor trademarks or logos for commercial use without the express permission of the owner on any Online Resource. The Company expects all employees to abide by all Copyright laws.

Employees may opt not to socialize with their co-workers via Online Resources, such as social networking sites. To this end, employees are not required to connect with any co-worker or to “friend” them or “like” them on social networking sites. Employees are prohibited from threatening other employees to coerce them to engage in social networking activities.

Refrain from using Online Resources while on work time or on IT equipment that the Company provides, unless it is work-related as authorized by your manager or consistent with the Information and Communications Systems Policy. Do not use Company email addresses to register on social networking sites, blogs or other Online Resources utilized for personal use.

While some employees may be able to access and post to personal Online Resources from work, subject to this policy, you should not use Company resources to create, host or maintain external Online Resources unless there is a specific business need and you have obtained manager approval.

Employees are reminded that they should have no expectation of privacy when using Online Resources, which includes social networking sites, during working time or when using Company equipment, in accordance with Information and Communications Systems Policy.

This policy applies even when accessing Online Resources while traveling, from home or from a personally owned computer or mobile device.

GENERAL GUIDANCE FOR MANAGERS AND FACILITATORS

As a general guideline, do not express your personal opinions when representing the Company. Instead, express the policies of the Company as a whole. In social networking posts, it is acceptable to incorporate a sense of personality and creativity to enhance the interest, while maintaining a high level of professionalism. You are acting as a spokesperson for the Company. It is important to be thorough with informational posts, being sure to check your grammar and spelling. Your professionalism will be an accurate representation of the Company brand image.

The Company encourages all managers and leaders to get engaged with our Online Resources. For these tools to have a powerful and significant impact on the organizational reputation and the Company brand image, all teams must connect and add value to the Online Resources. All site content, including web pages, forms, data, photos or blog posts must be coordinated through the appropriate facilitators for publishing. New ideas are welcome and will be given full consideration for implementation by the appropriate facilitators.

Testimonials or endorsements about the Company or its products or services should be researched and confirmed for accuracy before posting and making available to customers and employees.

In the event that an employee uses one of the Company’s Online Resources for any testimonials or endorsements of the Company or its products or services, you as the facilitator must reply to the comments, making clear to other readers that the employee is not a spokesperson for the Company. If the comment is derogatory or defacing to the Company brand image (with the exception of constructive criticism; see the Communications Team for guidance), remove it immediately.

The Company acknowledges that it is the sole right of its employees to utilize these Online Resources. Managers, supervisors and facilitators are prohibited from threatening other employees to coerce them to engage in social networking activities.

Only use Company resources to create, host or maintain other Online Resources when there is a specific business need and you have obtained manager approval.

REPORTING VIOLATIONS

When in doubt if a post or comment is a violation of a Company policy, proceed to ask. If you observe postings on an Online Resource that you believe may violate a Company policy, including but not limited to this policy, by placing confidential and/or proprietary information in the public, consult the HR and Communications Teams immediately.

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

SECURITY WARNING

People who communicate with you online may not be who they claim to be. They could be competitors, media, regulators, or others seeking “insider information” about the Company. They could also be dangerous. Be cautious when clicking on links embedded in Online Resources. Even well-known sites have occasionally displayed links to malicious applications that can damage computers and/or steal information. Exercise caution in extending or accepting friend requests to and from people you do not know well. It is important for the Company to be cautious and strategic in the associations made online. Avoid offers or requests that sound too good to be true – they
probably are. Remember that information posted to external Online Resources can become an easy target for cybercriminals.

DISCLAIMER

This policy is not intended to restrict or interfere with any employee’s federal or state labor law rights, including any and all rights under the National Labor Relations Act, or any whistleblower protections under federal or state law.

On most Company managed and branded Online Resources, comments and posts will be reviewed for appropriateness and relativity before the content is allowed to be published publicly. Any posts/comments of a derogatory nature or that deface the Company brand image will not be published online. Such cases of intentional insult will be dealt with on an individual basis.

Any case of report violations will be taken seriously and investigated fully. In cases where posts/comments are found to be inappropriate or a violation of Company policy, the content will be immediately removed and appropriate disciplinary action will be taken. In some cases, there may be a need for the appropriate facilitator to make a statement on behalf of the company in response to the incident.