ETHICS POLICY

BACKGROUND

Citadel100’s code of ethics requires compliance with the law of every country in which we do business. Our standards go beyond the legal minimum and require a high level of conduct. Citadel100’s employees are expected to comply with all laws affecting our business, and to act in every respect with honesty, fairness and integrity. The ethical code described should be regarded as more than a set of rules. It is a statement of beliefs that should guide employees’ conduct in most situations. You can resolve most ethical questions in your workplace by taking time to consider whether you are acting fairly and honestly towards your fellow employees, the customer, suppliers and general public who rely on our Company.

POSITIVE RESPONSIBILITIES

Each Citadel100 employee has an individual responsibility to deal ethically with our customers and suppliers, fellow employees and the general public. All employees are expected to do more than merely avoid unethical conduct. They must also take the initiative and assume positive responsibilities for quality, honesty and fairness. Employees are expected to raise ethical concerns and report any actual or suspected ethical misconduct to their Manager or any Director as appropriate. Honesty also requires that employees refuse to participate either actively or passively in any cover-up of such misconduct. Each employee is expected to co-operate fully in any investigation of ethical matters by Citadel100. ‘Looking the other way’ on potential ethical questions is in direct contradiction to Citadel100’s commitment to honesty and integrity and is not acceptable.

CONFLICTS OF INTEREST

Employees, their spouses and other close family members are expected to avoid outside interests or activities that could be advanced at the expense of Citadel100’s interests. Such involvement may divide an employee’s loyalty between Citadel100 and the outside interest and create a potential conflict of interest. Non-Citadel100 business involvement with a competitor, supplier or customer is strictly prohibited. Such interest could affect an employee’s objectivity in the promotion of Citadel100 interests. Employees may not work for or provide advice or consulting services to a competitor, supplier or customer. Employees should not run any side business in their free time which will compete with, sell to, or buy from Citadel100 and should avoid any financial investments in competitors, suppliers or customers other than nominal investments in public companies.

RECEIPT OF GIFTS

Gifts from suppliers, customers or competitors to Citadel100 employees raise the appearance, if not the reality, of dishonest or unfair dealings. It is Citadel100’s policy that all business decisions be made impartially and fairly, and not on the basis of gratuities offered to employees. No employee, or any of his or her family, may solicit or receive favours, gifts, loans or other benefits (including service and discounts as well as material goods) from any supplier, customer or competitor. The only exception to this policy is that employees may receive reasonable hospitality and gifts (other than money) of nominal value which are customarily offered to others having a similar relationship with the supplier, customer or competitor. Citadel100 employees should exercise good judgement in deciding whether to accept a gifts of nominal value or reasonable hospitality and should resolve all doubts and questions in favour of declining to accept the offer.

USE OF CITADEL100 RESOURCES

Each of us has a responsibility to use Citadel100 resources, including time, materials, equipment and proprietary information for Citadel100 business purposes only and not for personal benefit. Any such personal use, without proper permission amounts to theft. Citadel100 property, such as shop equipment and tools, office materials and facilities, are not to be used by employees other than for Citadel100 purposes. Use of such property in connection with community or employee social or personal activities may be authorised only by your Manager or a member of the Group Executive Management team.

All employee requests for reimbursement from Citadel100 whether for medical claims, travel expenses or other business-related items must be legitimate, properly documented and in accordance with policy. All employees receive Citadel100’s business and technical information and know-how in trust and are expected to maintain such information in confidence and not disclose or use it other than for Citadel100 business and for Citadel100 benefit. This information includes, for example, names of customers, suppliers, employees, manufacturing processes and equipment, plant layout, engineering drawings, product development plans, information systems, business plans, financial and marketing information and all documents and data which relate to such items. All of Citadel100’s business and technical information and know-how is a part of the value of the Citadel100 Group. Employees are expected actively to protect these assets. Persons who use any of this information for their own personal gain or give or sell this information to outsiders will be dismissed and may be subject to prosecution.

ENTERTAINMENT AND GRATUITIES

Citadel100 believes that business decisions by its customers should be made solely on the basis of Citadel100’s quality, service, price and other competitive factors. Gifts of nominal value and reasonable hospitality may be offered for the purpose of promoting Citadel100’s image, presenting its goods and services and promoting good relations with business partners. If the gifts and hospitality go beyond this and make the customer feel obligated to offer any special consideration to Citadel100, they are unacceptable.  Gifts and hospitality must not be used with the intention of persuading anyone to act improperly or to influence a public official in the performance of his duties.   Citadel100’s policy is to avoid even the appearance of improper conduct.

Employees must exercise good judgement and moderation.  Special consideration must be given in the case of gifts or entertainment offered to government employees. Many government agencies around the world have strict rules which prohibit employees from accepting even the smallest business gifts. These rules may also apply to government prime contractors.  It is Citadel100’s policy that no financial or other advantage should be offered to any public official with the intention of influencing the official in the performance of his duties.   Where there is any doubt about whether a gift or the provision of hospitality is appropriate no gifts or hospitality should be provided.

PAYMENTS TO THIRD PARTIES

Payments should be made by Citadel100 to third parties only for services or products properly provided to Citadel100. No Citadel100 employee shall make any direct or indirect payment in the nature of a bribe or payoff to secure or maintain business or for any other purpose to any government employee or the personnel of any customer, supplier or competitor. In order to avoid even the appearance of improper payments, no payments are to be made by Citadel100 in cash, other than documented petty cash disbursements. No Group cheques are to be written to ‘cash’ , ‘bearer’, or third party designees of the person entitled to payment. Cash payments may never be made to employees of competitors, suppliers, customers or government agencies. Payments to employees, agents, consultants or others outside their country of residence are prohibited where they violate the laws of that country.

MARKETING PRACTICES

Citadel100’s policy is to comply with all competition and trade regulation laws and to use only ethical and proper methods to market Citadel100 products. All Citadel100 customers will be treated fairly and even-handedly, and no preferential trade terms or other treatment will be extended to any customer in violation of any law. To avoid the appearance of improper action, Citadel100 absolutely prohibits consultations with competitors regarding prices, customers or territories. Commissions and other payments must be adequately documented and reported to government authorities as required. Advertising must always be in good taste. All claims made in advertisements must be fully supportable.

ENVIRONMENTAL PROTECTION

Citadel100 fully supports the belief that each of us has a responsibility to protect the environment and human health. It is imperative that each Citadel100 employee accepts responsibility for the observance of laws and regulations governing the protection of the environment and human health. No individual will knowingly buy for use at Citadel100, or dispose of, other than in accordance with the law, any chemical or other substance which is illegal. Managers are expected to keep up to date with all relevant laws and regulations concerning the protection of the environment, to seek professional guidance when necessary, and to assure observation of the laws and regulations. Citadel100 will continue to seek alternatives to hazardous methods, substances or products to assure protection of the environment and personal safety. Individuals who knowingly violate any environmental law or regulation will be subject to dismissal. Accidental incidents which affect the environment are to be reported immediately to the appropriate outside authorities as well as to senior management.

RESPONSIBILITIES TO EMPLOYEES

Citadel100 believes that all of its employees should have a safe work place and equal opportunities for promotion and advancement. Citadel100 will comply with all Health, Safety, Equal Opportunities legislation and other similar laws and regulations. Citadel100 is committed to maintaining safe working conditions in all of its facilities. Employees are expected to assume individual responsibility for safety procedures, following all necessary precautions, avoiding any activity that might endanger themselves or fellow employees, and notifying supervisors and management of any potentially dangerous conditions in the workplace. Management and supervisors are expected promptly to correct any serious safety hazards and to stop any production process involved until the hazard has been corrected. Citadel100’s policy is that all of its employees will enjoy a work environment free from sexual harassment. Sexual harassment it totally unacceptable and will not be tolerated. Sexual harassment includes unwelcome sexual advances or requests for sexual favours and the creation of an intimidating, hostile or offensive work environment through unwelcome sexual conversations, advances, jokes or suggestive objects or pictures. Any complaint of sexual harassment will be immediately investigated and appropriate action, which may include dismissal, taken.

USE OF ALCOHOL AND DRUGS

The Citadel100 Group is strongly committed to the prevention of illegal activities, and to the protection of its employees, Citadel100 property and the public from any danger which might result from the use of drugs or alcohol. It is Group policy to provide a safe drug-free and alcohol-free work environment. In the workplace, drug and alcohol abuse can create hazardous situations, lower productivity and can cause potential problems with outsiders with whom Citadel100 does business. We must ensure we maintain the reputation of Citadel100 and its people as good, responsible citizens. Use or possession of illegal drugs or alcohol during working hours or on Citadel100 premises is strictly forbidden, and is cause for discipline up to and including dismissal. Employees reporting to work under the influence of drugs or alcohol are subject to discipline up to and including dismissal. It is the policy of Citadel100 to provide assistance to employees who seek the Group’s help in overcoming any addiction to or dependence upon alcohol or drugs. Volunteering to participate in an employee assistance programme will not necessarily prevent disciplinary action for violations of the policy which have already occurred.

REPORTING PRACTICES AND FINANCIAL INFORMATION

Whilst honest differences of opinion are expected, and can indeed be useful in examining all sides of an issue, we must base our action on facts, logic and fair play. We cannot use shaded opinions or distorted facts to justify actions, nor should we allow facts or opinions to be covered up to make a situation look different from what it really is. All reporting at all levels throughout the Group must be factual and open. Citadel100’s business integrity will be reflected in accurate and complete accounts and records. Employees are responsible for ensuring the accuracy and reliability of the Citadel100 accounts. Fictitious, improper, deceptive, undisclosed or unrecorded accounts of funds or assets are a serious ethical abuse and illegal. It is the policy of Citadel100 that all accounts and records conform to accepted accounting principles and to all applicable laws and regulations. All transactions must be accurately documented and accounted for in the accounts and records of the Group. All entries must contain appropriate descriptions of the underlying transactions and no false or deceptive entries shall be made. No employee shall enter into any transaction with the understanding that it is other than as described in the supporting documentation. No employee shall participate in obtaining or creating false invoices, payroll records or other misleading documentation or inventing or using fictitious entities, sales, purchases, services, loans or other financial arrangements for any purpose. Citadel100 will not maintain or use any anonymous (‘numbered’) bank account or other account that does not identify Citadel100’s ownership.

PRODUCT INTEGRITY

Strict product integrity is necessary for Citadel100 to achieve its quality objectives and to maintain its reputation for quality products. It is Citadel100’s policy never wilfully to conceal defective work or material, falsify records or make false certification or claims regarding its products. In some instance, particularly in connection with government contracts or subcontracts, it is necessary for employees to make specific product certifications, generate records and supply other information or statements concerning product integrity. It is unlawful intentionally to falsify such records for the purpose of misleading or defrauding the government or any other customer. All employees are responsible for ensuring the integrity of the products under their control and for the accuracy of the documentation supporting the product integrity. Incidents of suspected or known concealment of defective work or material or falsifications of records are to be immediately reported to management.

COMMUNITY RESPONSIBILITY

No community’s standard should ever be damaged or debased by reason of Citadel100’s presence but rather should be improved. All employees have an obligation to ensure that their personal behaviour reflects this policy. Those managers with lead responsibility of a Citadel100 establishment in any community must ensure Citadel100 makes an appropriate contribution to that community’s overall well being.

INDUSTRY REGULATION

It is in all employees’ interests to make a positive contribution to the reputation of our industry by supporting the industry’s education and community relations programmes etc. as appropriate. Employees should also avoid all forms of publicity that will reflect negatively on the industry e.g. by refraining from disparaging or slandering our competitors and their products or services.

HUMAN RIGHTS AND ETHICAL TRADING

Citadel100 is committed to human rights and ethical trading in its business activities and employment practices. Citadel100 will:

conduct its business with integrity, recognising the economic, social, cultural, political and civil rights of those involved in the company’s operations and respecting the different cultures and the dignity and rights of individuals in the countries where it operates;

comply with national laws and be guided by the general principles of international law, especially for the purposes of this policy with respect to human rights;

accept that we have an obligation to promote respect for and observance of human rights and fundamental freedoms for all, without distinction as to race, creed, colour, nationality, ethnic origin, age, religion or similar belief, political affiliation, gender, gender reassignment, sexual orientation, marital status, family connections, membership or non-membership of a trade union disability or any other group;

• not employ underage staff;
• encourage suppliers and subcontractors to abide by the same principles;
• ensure that for staff, subcontractors, and suppliers, the terms of engagement will be clear, fair and reasonable in comparison with those offered by similar companies;
• strive, at all times, to provide customers with the standards of products and services that have been agreed.

APPLICATION OF THE CODE

All employees are expected to be familiar with and to observe the ethical standards outlined in this code. Abuse of Citadel100’s ethical code may be grounds for dismissal and the abuser could be subject to legal action. Managers are responsible for ensuring the application of this ethical code by monitoring and enforcing the code within their areas. Application of the Code will be one of the performance standards by which all managers will be measured. All of Citadel100’s managers are expected to lead by example and communicate a real concern for the observance of these ethical guidelines.

PERSONAL RESPONSIBILITY

Each of us should take pride in the high standard of conduct that has always identified us as Citadel100 employees. Let us resolve together to continue to be a Group which will tolerate nothing less than complete honesty, fairness and integrity in our dealings with all individuals, social groups, businesses and government institutions that depend on us.

ENVIRONMENTAL HEALTH & SAFETY POLICY

Citadel 100 commit to conducting our operations in an environmentally friendly manner and to protect the safety, health and welfare of our employees and those affected by our activities.

We have set the following core values as underpinning this commitment:

• The prevention of pollution, injury and ill-health;
• Compliance with all relevant environmental health and safety legislation and other requirements applicable to our business;
• Continual improvement of our integrated management system;
• The setting, reviewing and updating of environmental health and safety objectives, and
• The provision of resources for environmental health and safety;

Our overall aim is to minimise adverse impacts on the environment and keep our employees, contractors and visitors safe and well while on our site. This commitment shall be reviewed at the annual management review and through ongoing monitoring.

We encourage the active participation of all our employees to ensure we meet the commitments outlined above, and to this end this policy shall be communicated to all employees and others working on our behalf. It shall also be made available to the public on request.

QUALITY  POLICY

Citadel 100 is committed to promoting service excellence and 100% commitment to meeting our client service level agreements.

Our strategy is based on a policy that places our customers’ needs above all and aims to provide a consistent, professional and quality service.

As we continue to build on our experience and success, we will constantly review and meet on an on-going basis the changing needs of our customers.

We will do this by working together in partnership, with a clear focus and commitment to serving our customers.

In the provision of services to meet our customers’ needs and requirements, we have implemented a Quality Management System (QMS) that is a fundamental element of our business approach and conforms to ISO9001: 2008.

We expect and encourage continual improvement from our employees’ and welcome all input through communication and regular review of objectives in our Quality Management System.

Citadel 100 ensures all employees and agents understand their responsibility for quality and encourage a policy of open communication and involvement throughout the company.

Quality is an integral part of everything we do. Our business is keeping our Customers business always online.

Our customers expect nothing less than reliability, consistency and 100% delivery – at Citadel 100, our Quality objective is to provide this.

INFORMATION SECURITY MANAGEMENT POLICY

Citadel100’s objective is to preserve the confidentiality, integrity and availability of information that it either owns or is entrusted with.

To achieve the stated objectives, the company has implemented an Information Security Management System (ISMS) in accordance with the international standard ISO/IEC 27001.

The purpose of this policy is to protect Citadel100’s assets from all relevant threats, whether internal or external, deliberate or accidental.

It is the policy of Citadel100 that:

• Information is made available with minimal disruption to staff and customers as required by the business process;
• The integrity of this information is maintained;
• Confidentiality of information is preserved;
• Regulatory, legislative and other applicable requirements related to information security are met;
• Appropriate information security objectives are defined and where practicable, measured;
• Appropriate Business Continuity arrangements are in place to counteract interruptions to business activities and these take account of information security;
• Appropriate Information security education, awareness and training is available to staff and relevant others working on behalf of the company;
• Breaches of information security, actual or suspected, are reported and investigated through appropriate processes;
• Appropriate access control is maintained and information is protected against unauthorized access;
• Continual improvement of the information security management system is made, as and when appropriate.

This policy is approved by senior management and is reviewed at regular intervals or upon significant change.

This policy is communicated within Citadel100 and is available to interested parties upon request.

SUPPLIER STANDARD

Suppliers are required to comply, where applicable, with the requirements and principles of the Citadel100 Group’s Ethics Policy and to perform all activities associated with the supply of goods and services in compliance with all applicable laws and regulations, including those relating to environmental and health and safety matters.

Suppliers are required to ensure that no goods or services supplied to any member of the  Citadel100 Group are produced utilising forced, indentured or convict labour or the labour of persons in violation of the laws in the country of manufacture concerning minimum working age, minimum wage, hours of service or overtime.

Suppliers are required:

• not to give or receive bribes in connection with the supply of goods or services  to members of the Citadel100 Group
• to use reasonable endeavours to ensure that their employees, associated companies, agents or suppliers  do not give or receive bribes  in connection with the supply of goods or services to members of the Citadel100 Group.

For this purpose, a bribe means any financial or other advantage given to:

• someone to persuade them to act improperly or to reward them for acting improperly;
• a public official to influence them in carrying out their duties.

Suppliers are required to have established an effective program to ensure all suppliers it utilises to provide any goods or services to any member of the Citadel100 Group will comply with the requirements set out in this Standard.

If the Supplier commits any material breach of this Standard, any Supply Agreement in force with that Supplier may be immediately terminated.

ANTI-BRIBERY POLICY

Citadel100 are committed to the highest standards of honesty and integrity. Employees and Third Parties are required to report any circumstances which are in breach of Citadel100’s Anti-Bribery and Corruption policy to the CEO or Board of Directors. All reported incidences of actual or suspected bribery or corruption will be promptly and thoroughly investigated and dealt with appropriately.

The purpose of this policy is to protect Citadel100 and its employees from breaches of anti-bribery and corruption laws. Breaches of bribery and corruption laws could seriously damage Citadel100’s reputation as a responsible, ethical company and potentially damage our relationships with customers and suppliers. In addition, the penalties for infringing these laws are extremely serious, both for our business and our employees.

Citadel100 does not tolerate any employee or third party being involved in any level of bribery or corruption. Citadel100 is committed to complying with applicable anti-bribery and corruption laws in all countries in which it conducts business.

Who is covered by the policy?

This policy applies to all individuals working at all levels and grades, including senior managers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, and any other person providing services to us.

What is a bribe?

A bribe is a financial or other advantage offered or given:

– to anyone to persuade them to or reward them for performing their duties improperly or;

– to any public official with the intention of influencing the official in the performance of his duties.

Gifts and Hospitality

This policy does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, in certain circumstances gifts and hospitality may amount to bribery and all employees must comply strictly with Citadel100’s ethics policy in respect of gifts and hospitality. We will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a public official in the performance of his duties.

Facilitation payments and kickbacks

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. Kickbacks are typically payments made in return for a business favour or advantage.  All employees must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Donations

We do not make contributions of any kind to political parties. No charitable donations will be made for the purpose of gaining any commercial advantage.

Record Keeping

We will keep financial records and have appropriate internal controls in place which will evidence the business reason for making any payments to third parties.

All expense claims relating to hospitality, gifts or expenses incurred to third parties must be submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

Raising Concerns

Employees will be encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No employee will suffer any detriment as a result of raising genuine concerns about bribery, even if they turn out to be mistaken.

TECHNOLOGY EQUIPMENT DISPOSAL POLICY

Technology equipment often contains parts which cannot simply be thrown away.  Proper disposal of equipment is both environmentally responsible and often required by law.  In addition, hard drives, USB drives, CD-ROMs and other storage media contain various kinds of CITADEL100 data, some of which is considered sensitive.  In order to protect our company and customer data, all storage mediums must be properly erased before being disposed of.  However, simply deleting or even formatting data is not considered sufficient.  When deleting files or formatting a device, data is marked for deletion, but is still accessible until being overwritten by a new file.  Therefore, special tools must be used to securely erase data prior to equipment disposal.

Purpose

This policy has been developed to define the requirements for proper disposal of technology equipment at CITADEL100.

Scope

This policy applies to all technology equipment owned by CITADEL100.

Policy

Technology Equipment Disposal

• When technology assets have reached the end of their useful life they should be sent to the Information Technology Services Company contracted by CITADEL100 for proper disposal.
• The Information Technology Services Company will securely erase all storage mediums in accordance with current industry best practices.
• Equipment which is working, but reached the end of its useful life to CITADEL100, will be made available to local schools or charities for their own use.
• A lottery system may be used to determine who has the opportunity to receive available equipment.
• All equipment donated must go through the lottery process.
• All decisions on who receives technology equipment are final.  No warranty or support services will be provided with any equipment donated to local schools/charities. Warranty or support services will be the full responsibility of the organization which receives the equipment.
• Any equipment not in working order or remaining from the lottery process will be disposed of according to current environmental best practices.  The Information Technology Services Company will contract an appropriate organization to dispose of outdated technology assets in accordance with current environmental best practices.

 Citadel100 Ramifications

Failure to properly dispose of technology equipment can have several negative ramifications to Citadel100 including fines, negative customer perception and costs to notify customers of data loss or inadvertent disclosure.

Enforcement

Any employee found to have violated this policy may be subject to disciplinary action.

EMAIL POLICY

Electronic mail (email) is a computerised electronic communications system that you are required to use in the performance of your duties as a Citadel100 employee.

While email is important to the normal conduct of business, it also carries considerable risks, if used inappropriately. The intention of this email policy is to help Citadel100 staff use electronic mail properly, to reduce the risk of intentional or inadvertent misuse and to ensure that official Citadel100 information transferred via email is properly handled. For that reason the use of electronic mail in Citadel100 is governed by acceptable use as stipulated by this policy.

Scope

This policy covers the use of email services by Citadel100 employees. Contract and temporary staff using Citadel100’s computing resources must also be made aware of, and comply with this policy.

It may be amended from time to time and employees will be notified of amendments to the policy by way of written notice and/or electronic notice (which may be by email or by notice on the staff intranet).

Privacy

All intellectual property rights in documents generated on Citadel100 systems, and documents sent via Citadel100’s email, rest with Citadel100. If there is a personal element to the email, the email nevertheless belongs to the organisation and will be open to such monitoring and dealings as are appropriate within the organisation.

Citadel100 regularly backs-up information stored on its network, including information relating to email messages. Accordingly, you have no expectation of privacy in relation to the sending, or storing of email messages.

While Citadel100 may randomly monitor the content of email messages, it may also, for computer maintenance and other purposes, analyse emails (individually or collectively).

Circumstances giving rise to such analysis include, but are not limited to:

• investigations triggered by indications of misconduct,
• the detection of computer viruses,
• monitoring proper use,
• the location of information required for Citadel100’s business,
• responding to legal or regulatory requirements and/or
• fulfilment of obligations to customers, clients, third parties and relevant regulatory authorities.

Acceptable use of email

Email as a resource is primarily to be used for authorised business purposes.

Personal use of email should be kept to a minimum such that it does not interfere with work commitments and is undertaken in your own time.

Such use must also comply with the requirements of this policy.

You must protect your user ID and system from unauthorised use. You are responsible for all activities carried out under your user ID, and originating from your system.

Remember that external email should be considered a public, visible postcard, without any security. You must assume that any correspondence sent via the internet can be read by anyone desiring to do so.

You must use email as you would any official company communications tool. This implies that when the email is sent, both the sender and the reader should ensure that the communication complies with normal communications guidelines.

No communication sent via the Citadel100 email system should be unethical, be perceived to be a conflict of interest, or contain confidential information.

 Inappropriate use

In making use of email, you must NOT:

• use someone else’s ID to send mail;
• use email to circulate offensive joke mail or chain letters, internally or externally;
• use email to harass or intimidate another person, broadcast unsolicited messages, or send unwanted mail;
• communicate to another in any manner which could cause him/her distress, embarrassment, or unwarranted attention. There must be no personal attacks, inclusive of those based on gender, race, national origin, ethnicity, religion, disability, sexual orientation, or affiliation;
• use email, or other system resources to gain access to, or possession of pornographic materials;
• accept/open electronic mail messages that might be harmful to Citadel100’s computing resources or to information stored thereon;
• use vulgar, abusive, or hateful language;
• save, download, transmit or purposely view sexual, pornographic, racist, profane or other offensive material;
• download software, graphical or other forms of information for personal use;
• produce advertising or listings for personal benefit;
• use the email system to send mail, which may be damaging to Citadel100’s corporate image;
• engage in any activity which is in competition with the commercial interests of Citadel100;
• subscribe to any contracts unless you are authorized to do so within the terms of Citadel100’s policy on purchasing;
• accept any material by email which may give rise to a breach of the intellectual property rights of any outside party;
• engage in any other activity that does not comply with the principles presented above.

Potential risks

The Internet is the medium for external email communications. Because of its design, the internet cannot guarantee security or message integrity. There are many risks attached to the sending of emails including the following.

• Email messages to a particular addressee may be intercepted, viewed by other persons in the addressee organisation, forwarded without your knowledge, altered, or cut and pasted into another email or medium without authority.
• An email message may go to persons other than the intended recipient. If the email contains confidential or commercially sensitive information this could be damaging to Citadel100.
• Emails should be regarded as potentially public information. There is therefore a heightened risk of legal liability for the sender, the recipient and the organisations for which they work.
• Email is a form of publishing. Therefore, defamation laws apply to emails.
• Personal data contained in emails may be accessible under Data Protection legislation. Furthermore emails to Government and other public bodies may be accessible under Freedom of Information legislation.
• Email is speedy and therefore messages written in haste, or written carelessly can be sent without the opportunity to check or rephrase. This could give rise to legal liability on Citadel100’s part such as claims for defamation, etc.
• Information contained in, or attached to emails may belong to others and there may be copyright implications in sending or receiving them without permission.
• An email message may legally bind Citadel100 contractually in certain instances without the proper authority being obtained in-house.
• Email messages can carry computer viruses that are particularly dangerous to Citadel100’s computer operations.

You are required to be conscious of the above risks and to ensure that, in your use of email or other Citadel100 resources, you do not expose Citadel100 to any such risks.

 Protection of Citadel100 staff

Citadel100 is committed to protecting our staff from the effects of inappropriate use of email by others.

If you receive any offensive, unpleasant, harassing, or intimidating messages via the email you should inform your manager/director immediately. It is important that such emails are traced as quickly as possible. The message should be printed and kept for investigative purposes.

Enforcement

If any breach of this email policy is observed then disciplinary action up to and including dismissal may be taken.

This policy is not exhaustive. In situations which are not expressly governed by this policy, you must ensure that your use of email is at all times appropriate and consistent with your responsibilities towards Citadel100. In case of any doubt, you should consult with your manager/director.

INTERNET USAGE POLICY

The internet is a vital resource for the business of Citadel100. However, the internet suffers from significant and widespread security and integrity risks and has the potential to be used in ways that are inappropriate to the aims and goals of Citadel100. Therefore, the use of the internet in Citadel100 is regulated by standards of acceptable use as set out in this policy.

Access to the internet

All connections to the internet on Citadel100 computers must be through the Citadel100 approved internet service provider (ISP).

Access to the Internet is to be limited to matters which are relevant to your work for Citadel100. Internet access for recreational or private purposes is not permitted [except as provided for below].

Your use of the internet in Citadel100 must at all times comply with the rules outlined in this policy.

Browsers

Software is required for browsing the Internet. This software is installed on Citadel100 computers by the designated IT Supplier. Only software approved by the IT Supplier and installed by them may be used to access the internet on Citadel100 computers.

Password access

Staff may use individual user passwords to the Internet. Such passwords must consist of a minimum of 8 alphanumeric characters. Common names or phrases should not be used.

 Monitoring access

Access to the Internet from Citadel100 computers is managed by the designated IT Supplier and all incoming and outgoing traffic is constantly monitored for performance analysis and for other appropriate purposes. This traffic analysis shows date and time of internet access, user name, sites visited, and requests for information.

This information will be used to identify areas of non-compliance with this policy. Citadel100 managers/directors will be informed of non-compliance and appropriate action will be taken.

Appropriate use of the internet

Citadel100 internet connections are intended for activities that either support company business, or the professional development of staff. Use of the Internet is to assist staff to achieve stated business goals and objectives. This may include use of email, World Wide Web and File Transfer. All staff have a responsibility to use the internet in a professional, ethical and lawful manner at all times. Legal and contractual requirements concerning the intellectual property rights of outside parties must be strictly adhered to.

Computer software must not be downloaded from bulletin boards, the internet, or any other source without prior approval of the IT Unit.

The integrity of critical software will be reviewed on a regular basis and the presence of unauthorised files or amendments formally investigated.

Misuse of facilities and services is prohibited.

You must at all times respect copyright and intellectual property rights of information you encounter on the internet. This may require obtaining appropriate permission to make use of information. You must always give proper credit to the source of the information used for Citadel100 purposes.

Material in which Citadel100 has a proprietary interest – such as software, documentation or other internal information – must not be transmitted, sold or otherwise transferred to any outside party except in pursuance of Citadel100’s legitimate business interests. Any departure from this policy requires the written authorisation of the C.O.O./C.E.O.

Inappropriate Use of the internet from Citadel100 computers

You are prohibited from accessing, requesting or sending sexual, pornographic, racist, profane, violent or other offensive material via the internet.

You are prohibited from saving, downloading, transmitting or purposely viewing sexual, pornographic, racist, profane or other offensive material.

You are prohibited from sending chain letters, other forms of mass mailing and spamming (sending unsolicited emails to a number of people).

Citadel100 reserves the right to remove without notice any files or data from its information systems, including any information it views as offensive or potentially illegal.

Inappropriate use of the internet from other computers

You are prohibited from using the Internet on computers outside the workplace where such use has the potential to negatively affect Citadel100 or its staff.

Examples of such behaviour include:

• Publishing material which is defamatory, abusive or offensive in relation to any employee, manager, office holder, shareholder, customer or client of Citadel100.
• Using the Internet in a manner which amounts to bullying or harassment.
• Publishing any business-sensitive information about Citadel100.
• Publishing material which might reasonably be expected to have the effect of damaging the reputation or professional standing of Citadel100.

 Access to internet from a Citadel100 computer must never be used:

• to represent yourself as someone else;
• to post or download messages that will reflect poorly on Citadel100 name and professional reputation;
• to advertise, or otherwise promote, unauthorised or illegal activities;
• to promote or engage in any commercial activity which is in competition with Citadel100’s commercial activities;
• to process the personal data of any person in a manner inconsistent with the

Data Protections Acts 1998 and 2003;

• to transmit confidential information without the approval of a Citadel100 Manager.

Security

The Internet is not a secure medium. Access to the Internet, no matter how well set up, always poses some security risks. Accordingly, virus scanning software is installed on Citadel100 computers. Staff must not provide or use their Citadel100 login password to any Internet request for a password. Staff must not provide any information relating to the Citadel100 network to any outside party, whether through the Internet or in any other way.

Reliability of internet information

There is no quality control process on the internet and a considerable amount of information published on the Internet is outdated, inaccurate or deliberately misleading. All information obtained from the Internet should be considered with caution until confirmed by a reliable source.

Impact on other users

When using the Internet please be aware of your impact on others. Intense browsing or downloading during peak usage periods can impact on other people’s work.

 Enforcement

Non-compliance with the general principles and conditions of this internet policy may lead to disciplinary action, including the possibility of dismissal.

This policy is not exhaustive. In situations which are not expressly governed by this policy, you must ensure that your use of the Internet is at all times appropriate and consistent with your responsibilities towards Citadel100. In case of any doubt, you should consult with your Manager/Director.

Personal use of the internet

A limited amount of personal use of the Internet on Citadel100’s computers is permitted provided the following rules are observed.

• Personal use must not interfere with your work commitments.
• Personal use, including any downloading of data for personal use, must comply with the requirements and general principles of this policy and all other Citadel100 Policies. In particular, the above provisions regarding “Inappropriate use of the Internet from Citadel100 computers” and “Security” apply to personal use as well as normal business use.

Normal monitoring of internet use by the designated IT Supplier will apply to personal use as well as normal business use.