Electronic Communications Policy

KENMOVER has established systems that are Internet-connected and will use the Internet to facilitate customer service and otherwise contribute broadly to the mission of the Company. This Electronic Communications Policy (‘‘ECP’’) applies to all Users, wherever they may be located and regardless of whether they are accessing the Information System through a computer or other device (such as, PDAs, telephones, smartphones, televisions, or any other device used to access the Information Systems) that is provided by KENMOVER or personally owned by the User of any other individual or entity.

Information Systems. For purposes of this ECP, the term ‘‘Information Systems’’ or ‘‘Information and Communications System’’ refers to all of the Company’s electronic networks, electronic devices, computer equipment and hardware, electronic communications, telecommunication networks, and telecommunications equipment that may be connected to such networks, equipment, systems or devices by other (however structured, including wireless), including, without limitation, servers, computers, software, software accessories, documentation supporting any electronic communications, stored data and files, storage devices (including flash or thumb drives), laptops, handheld computers, PDAs, iPads, tablets, mobile messaging and other telephones, voicemail systems, web pages, Internet, and any data and information contained or processed by such systems or equipment.

Permissible Uses of Information Systems, In General. The Information Systems were created and are maintained to facilitate the Company’s business, which includes servicing customers. Since the Information Systems are intended primarily for business, Users must use the Information Systems, including e-mail and access to the Internet, consistent with all other applicable Company policies and legal requirements. All uses of the Information Systems must be in compliance with all software license, copyrights, and all other state, federal, and international laws, including those governing intellectual property and online activities.

Impermissible Uses of the Information Systems. Unless permitted by KENMOVER or required by applicable law, the Information Systems may not be used in ways that would violate law or Company policy. The following are examples of ways the Information Systems may not be used and activities that may not be performed using the Information Systems:

• To access, store, print, download, transmit or communicate material that is fraudulent, harassing, sexually explicit, profane, obscene, intimidating or otherwise unlawful, or prohibited by the
Company’s Non-Discrimination and Anti-Harassment Policies, or any other Company policy. This includes sending such material by way of e-mail, text message or other form of electronic
communication, or displaying such material;
• To disseminate or store commercial or personal advertisements or solicitations such as fund-raisers, political or religious activities;
• To transmit or post any material in violation of federal, state or other privacy laws:
• To conduct Company business through personal e-mail accounts issued by public e-mail providers such as Google, YAHOO, AOL, etc. All Company business must be conducted through Company provided email:
• To download or use encryption software without first obtaining permission from the Company;
• To duplicate or use copyrighted materials (including programs, software, files information, archives, pictures, articles, etc.) without appropriate permission or authority;
• To acquire, possess, trade, or use hardware/software tools on the Information Systems that could be employed to evaluate or compromise system vulnerabilities, without first obtaining written permission from the Company;
• To ‘‘hack’ or break into any computer, database or network or engage in ‘‘snooping’’ or ‘‘pretexting’’ or to intentionally introduce any computer virus, worm, lock-out or disabling device, or otherwise engaging in purposeful conduct to adversely affect the Information Systems or any other system;
• To engage in activities designed to derive personal commercial gain;
• While representing yourself as being someone else (e.g, sending electronic mail so that it appears to have come from someone else);
• To send, forward, redistribute or reply to ‘‘chain’’ letter;
• To interfere with normal business functions in any way;
• To conduct unauthorized fundraising of any kind;
• To engage in excessive personal use or otherwise use the Information Systems so as to waste or unfairly monopolize resources to the exclusion of others; or
• To download for business or personal use (except as specifically authorized by the Company) any software, including without limitation file-sharing (‘‘per-to-peer’’) software (such a LimeWire, BitTorrent or others) or any form of computer programs, utilities, music, videos, screensavers or executable files.

Impermissible Websites. The following are examples of Web site categories that may not be accessed via the Information Systems:
• Sexually explicit adult material (adult content, nudity, sex)
• Gambling
• Illegal web sites
• Information technology related to hacking, proxy avoidance, pretexting, snooping, and/or URL translation
• Militancy or extremist
• Racism or hate
• Violence
• Weapons
Monitoring. KENMOVER has significant business interest for regulating usage of its Information Systems and monitoring Users, communication on the Information System. Including but not limited to for the purpose of protecting the Company’s assets, protecting Users and customers, and ensuring compliance with applicable laws and Company policies.
At all times, KENMOVER has the right to access, monitor, and record Information Systems usage, activity and information. Although limited personal use that does not violate any Company policy or otherwise interfere with job duties is not prohibited in all cases, Users should not expected that such use entitles them to any expectation of privacy in anything that they access, view, create, store, transmit or receive on or through the Information Systems, including any personal messages. This includes personal messages sent or received from personal email or similar accounts, such as Yahoo and Google web-based email accounts which may remain, be accessed, or be viewed on the Information Systems and may be retrieved and monitored by the Company.
KENMOVER assumes no liability for loss, damage, destruction, alteration, disclosure or misuse of any personal data or communications transmitted over or stored on the Information Systems. KENMOVER accepts no responsibility or liability for the loss or no-delivery of any personal electronic mail or voicemail communications or any personal data stored on the Information Systems. KENMOVER strongly discourages employee from storing any personal data on the Information Systems.
Company Email. KENMOVER does not allow forwarding messages from Company emails to personal email accounts or otherwise outside of the Company’s Information Systems. Of course, forwarding emails to clients, business partners and others, as necessary and appropriate to carry out User’s assigned job responsibilities are permitted. Consistent with this policy, KENMOVER email address assigned to a User is primarily for business. Distribution of a User’s email address should be done with discretion. User’s Company email address should not be used to register for personal email subscriptions, fantasy sports teams, or other similar publications or notifications. Distribution of User’s Company email address for personal banking , mortgages, billing notifications and other services in discouraged. The sharing of Company email address makes KENMOVER susceptible for phishing attempts, spam and other security breaches.
Company email and its content is the sole property of KENMOVER and an employee has no right to this content after his or her employments ends.
Safeguards/Security. KENMOVER maintains a range of policies and procedures designed to safeguard information that is maintained on the Information Systems, including customer and employee information. Without limiting those policies and procedures which are incorporated herein by reference, below are some best practices Users should be following to help ensure the security of the information on the Information Systems;
Unattended Equipment and Laptop Computer. User must protect unattended equipment from unauthorized access. For example, workstations should be locked when unattended and active login sessions should be terminated when completed. All laptop computers must be stored in a secure place. Computers and computer equipment may not be taken from the premises without approval of the Privacy Officer.
Accessing Other User’s Files. Absent express authorization by the author (as permitted under Company policy) or by the Company, User may not access, alter or copy any information, data or materials created by another User that is not made generally available on the Information Systems.
Personal Home Computers and Other Devices. Except as otherwise permitted by the Company, Users should not use their personal home computer or other non-Company portable device (such as, PDAs, telephones, smartphones, flash drives, external hard drives, or any other similar device) to store, retain or archive Company records or documents. Any such records or documents residing on such a device shall at all times remain Company property and must be returned to KENMOVER or discarded in accordance with Company policy. In addition, in order to connect to the Information Systems using such equipment such as over high-speed home connections (i.e. DSL lines, Cable Modems, etc.), a Company-approved VPN solution must be utilized.
Accessing Other Computers and Networks. A User’s ability to connect to other computer systems through KENMOVER network or by a modem (including wirelessly) does not imply a right to connect to those systems or to make use of those systems unless specifically authorized by KENMOVER and/or the owners of those systems. Users entrusted with access to the Computer network through laptops using VPN must prohibit use of the Information Systems by anyone other than the User, including family members.
Virus Detection. Viruses can cause substantial damage to computer systems. Users must make reasonable precautions to ensure that they do not introduce or propagate viruses on or through the Information Systems. The Company’s Internet connection uses a firewall and proxy protection system designed to protect the Company’s internal network. These facilities may block or prevent certain Internet activities, such as unauthorized access. All incoming Internet e-mail, including attachment, will be scanned for viruses. However, new computer virus strains are routinely being created and may penetrate virus-scanning procedures currently in place. Therefore, Users should avoid opening suspicious e-mails from unknown sources.
If a User becomes aware of a virus infection or any other security violation (whether internally or for external source), he or she should immediately contact the KENMOVER IT Department.
Uses of Passwords/Access. Users are allowed to access the Information Systems using their unique username and password. Passwords must be developed in accordance with the requirements established by IT and safeguarded by each User. Users should not share their username and password with anyone other than KENMOVER IT. In the event there is a pressing need to share one’s username and password, the users must use extreme caution in allowing anyone, including administrative assistants, to access the Information Systems using the User’s unique username and password, such as to access the User’s e-mail, or electronic records.
Discipline. Any violation of this ECP by a User may result in KENMOVER limiting or terminating User’s privileges concerning the Information System. termination of User’s business relationship with the Company, and/or potential legal action against the User. If the User is an employee, any violation of this ECP also may result in disciplinary action, up to and including termination of employment, in addition to the steps noted in the prior sentence.