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     Company Assets

1.1             Protection and Proper Use of company’s Assets

 

All employees, officers, executives and directors shall protect the company’s assets and ensure their efficient use. Theft, carelessness, and waste have a direct impact on the company’s profitability. All company’s assets are to be used for legitimate company’s purposes. Any suspected incident of fraud or theft shall be immediately reported for investigation. Company’s assets shall not be used for noncompany business.

The obligation of employees, officers, executives and directors to protect the company’s assets includes the company’s proprietary information. Proprietary information includes intellectual property such as trade secrets, patents, trademarks, and copyrights, as well as business, marketing and service plans, engineering and manufacturing ideas, designs, databases, records, salary information and any unpublished financial data and reports. Unauthorized use or distribution of this information is a violation of company’s policy. It could also be illegal and result in civil or criminal penalties.

Safwan is committed to respecting the intellectual property rights of third parties. Safwan expects that all its employees take the intellectual property rights of third parties into due consideration in their daily work.

We are all expected to:

  • Safeguard and protect Safwan’s intellectual property rights.

  • Respect the intellectual property rights of third parties and clarify the situation with the experts in case of doubts.

Example

  1. What can I do as an employee to protect Safwan’s intellectual property rights?

  • Whenever you become aware that any of Safwan’s intellectual property rights are violated by a third party, speak up and inform the relevant department.

     

  1. I work in the Marketing Department and would like to copy an article from a scientific magazine and to distribute it to the participants of a workshop. Am I allowed to do so?

  • You have to keep in mind that copyrights of third parties have to be taken into due consideration on a case-by-case basis. If you have any doubts about the copyright situation, seek clarification from your Line Manager.

     

1.2             Confidentiality

Employees, officers, executives and directors shall maintain the confidentiality of proprietary information entrusted to them by the company or its customers or suppliers, except when disclosure is authorized in writing by Legal Team and Chief Operating Officer or required by laws or regulations. Proprietary information includes all non-public information that might be of use to competitors or harmful to the company’s or its customers or suppliers if disclosed. It includes information that suppliers and customers have entrusted to the Company. The obligation to preserve proprietary information continues even after employment ends.

Confidential information could include one of the following:

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    • Expected financial results/forecasts and projections

    • Technical data not published previously

    • New product announcements of a significant nature

    • Marketing strategies/campaigns

    • Personnel information/salaries

    • Changes in dividend policy

    • Significant litigation exposure

    • Proposed Acquisitions/Mergers 

    • New equity or debt offerings

    • Stock splits

    • Material pricing changes

       

      Classification of Confidential Information: To guide employees in the handling of confidential information, including that contained in e-mails. The Company has established the following classifications:

       

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      1. Confidential - Internal Use Only

        Information with this classification is not highly sensitive and can be distributed within Safwan without restrictions. Examples of information included in this category are internal telephone listings, email address listings and policy manuals.  

      2. Confidential - Need to Know

        This information is more sensitive and valuable than “Internal Use Only” documents. Its dissemination is limited to employees who need the information to do their jobs. Information in this category might include new product information, project details, and personnel information.

      3. Confidential - Registered

        This is the most sensitive of all information. Registered documents shall be numbered and each copy assigned to a specific recipient. These documents shall be kept in a secure place at all times and shall not be duplicated, except by their originator. Information in this category may include pre-release financial information, financial forecasts, new product plans and trading information.

        Disclosure of Confidential Information: The Company’s proprietary information shall be disclosed to potential business partners during the course of business. However, such disclosure shall never be done without carefully considering its potential benefits and risks. If an employee determines in consultation with supervisor and other appropriate company management, that disclosure of confidential information and financial information other than that required by statutory reporting requirements are necessary, the approval of Legal Team and Chief Operating Officer shall be obtained before any disclosure takes place.

        Additionally, specific policies shall also be established regarding who may communicate information to the press and the financial community. All inquiries or calls from the press shall be referred to Legal Team and Chief Operating Officer or those delegated this responsibility.

        Requests for Confidential Information:

  1. Written Requests: All written requests for additional information concerning details of published financial statements, litigation progress, etc. shall be forwarded to Legal Team and Chief Operating Officer. Legal Team and Chief Operating Officer shall decide whether such information shall be disclosed to the requesting party after instructing the related Department Heads.

  2. Verbal Requests: All verbal requests shall be referred to Legal Team and Chief Operating Officer. If the request is by telephone or a personal visit to the company’s premises, the requester shall be referred to Legal Team and Chief Operating Officer. If unavailable, the requester shall be asked to provide their name, company, telephone number and address, if possible. Also they shall be asked the reason for the request and a brief description of the information desired. This information shall be forwarded to Legal Team and Chief Operating Officer for his approval.  

    Email Communication: E-mail containing confidential information shall not be sent outside the company’s network, unless there is a confidentiality notice appended in the E-mail.

    Verbal Communication: All employees need to use carefulness when verbal communication is being used outside of work such as at social gatherings, conferences and meetings.

    Communication with Vendors and Customers: Employees shall also caution and discretion when communicating with vendors and customers. Before disclosing information, employees shall:  

  • Check to ensure the appropriate non-disclosure agreements are in place whenever applicable.

  • Disclose only the information necessary to complete the project or contract.

  • Remind the vendor/customers or the importance of keeping the company’s information confidential.

  • Consult with the immediate supervisor before providing access to non-company individuals.

 

If the confidential information is shared with third parties, we ensure that the third party takes appropriate measures steps to protect such information. We respect the confidential information belonging to third parties and take appropriate measures to protect such information. This responsibility is imposed by law, and may also arise out of agreements with the customers, or be based on internal rules adopted by the company.

We have to be aware that in a competitive environment, third parties strive to get access to confidential information related to our business. Therefore, we must be extremely careful how we handle confidential information in public places, such as airplanes, trains, restaurants, social media and non-approved communication tools.

We are all expected to:

  • Only share confidential information with a person who needs to know such information and who is entitled to receive it.

  • Respect and protect confidential information belonging to third parties.

  • Be aware that in case the confidential information comes up to third parties that could harm Safwan’s assets and interests.

  • Respect the contractual confidentiality obligation even after the end of employment.

     

     

     

Example:

  1. I am travelling together with a colleague and discuss confidential and critical information with her/him. Is this okay?

  • Always be alert! You must be extremely careful how you handle confidential information in public places, as well as in social media and non-approved communication tools.

     

     

  1. I have just joined Safwan from a competitor and brought with me lots of information which I think would be useful to the company. Is it okay to share said information with my new team?

  • No, you are not allowed to share information if it is of a confidential nature. You must respect the contractual confidentiality obligation even after the end of the employment contract with your former employer.

     

1.3             Record-Keeping, Financial Controls and Disclosures

 

The company requires honest, accurate and timely recording and reporting of information in order to make responsible business decisions.

All business expense accounts shall be documented and recorded accurately in a timely manner. 

All of the company’s books, records, accounts and financial statements shall be maintained in reasonable detail, shall appropriately reflect the company’s transactions, shall be promptly disclosed in accordance with applicable laws and regulations and shall conform both to applicable legal requirements and to the company’s system of internal controls.

Records belong to Safwan and not to an individual, employees need to apply the following principles whenever they create and manage a record:

  • Think before writing and decide whether it is necessary to create a record;

  • be factual, do not make assumptions and avoid misleading and suggestive wording (e.g. in mail or social media postings);

  • make sure that the record is in compliance with applicable laws and regulations;

  • Be mindful of the level of confidentiality by sharing and storing it in a way that the assigned confidentiality can be ensured. Do not share a record with recipients, especially externally, if there is no need for them to have access to it.

     

 Avoid exaggeration, derogatory remarks, guesswork, or inappropriate characterizations of people and companies that may be misunderstood. This applies equally to e-mail, internal memos, and formal and informal reports. Records shall always be retained or destroyed according to the company’s record retention policies (minimum ten years).

Records that relate to any actual or imminent legal proceeding or regulatory investigation are subject to compulsory retention (so-called “legal hold” or “law hold”); Safwan employees are not allowed to destroy these records and must retain them until such hold is lifted.

We are all expected to:

  • Manage Safwan records and information with due attention.

  • Never destroy any records that relate to any actual or imminent legal proceeding or regulatory investigation.

     

     

     

Example:

  1. Why is it important that I adhere to Safwan standards of care whenever I create a record in my business activities?

  • Be aware that any record can be used as evidence in a legal procedure or regulatory investigation against Safwan; e.g. misleading and suggestive statements may trigger an investigation against Safwan as a company as well as against the employee involved.

  1. I have inherited documents and e-mails from my predecessor which could have been destroyed as the legally specified retention period has expired. Now I have heard there is a legal case and I think that the documents could be used against Safwan. Am I allowed to discard them?

  • No, you must not destroy any records that relate to any actual or imminent legal proceeding or regulatory investigation. The discarding of these documents would be considered as obstruction of justice, which is subject to severe sanctions. Therefore, you must preserve the records that could be relevant. Contact the Legal Department for further advice.

     

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