ICD property including, ICD information, equipment, funds, supplies, facilities and other assets, as well as services and labor of other ICD employees, must be used only for legitimate business purposes on behalf of ICD. Employees may not take for themselves personally opportunities that are discovered using ICD property or information or which arise due to their position at ICD. All ICD records must be kept fully and accurately, and ICD confidential information must be protected at all times.
CONFIDENTIAL ICD INFORMATION: During employment with ICD, employees will learn and be entrusted with confidential information relating to ICD’s operations, financial condition, and potential transactions (including acquisitions). Some examples of information that are confidential include financial information, business projections, personnel records, and any information that is marked confidential. Because this information has substantial value to ICD, employees must not disclose any confidential information, even inadvertently, to any unauthorized person in or outside ICD. This obligation continues after your employment ends.
CONFIDENTIAL INFORMATION BELONGING TO THIRD PARTIES: Employees must maintain the confidentiality of information entrusted to them by ICD’s customers and vendors, and any other confidential information that comes to them, from whatever source, except when disclosure is authorized or required by laws or regulations or permitted to be used by such third party. Confidential information includes proprietary drawings and other technical or commercial information that is useful in the conduct of our business.
MAINTAINING ACCURATE BOOKS AND RECORDS: Each employee must maintain accurate and complete business records. It is against ICD policy, and in some circumstances illegal, for any employee to cause books and records to be inaccurate in any way. Some examples of prohibited record keeping include making the records appear as though payments were made to one person when in fact they were made to another, setting up unauthorized funds or accounts, and submitting expense accounts that did not accurately reflect the true nature of the expenses.
We must ensure that ICD provides full, fair and accurate, timely and understandable disclosure in all reports and documents filed with any governmental agency, as well as in all public communications and disclosures made by ICD. Employees must immediately inform ICD’s CFO of any significant issues they become aware of relating to ICD’s inventory accounting or auditing policies or practices or our financial statements.
REPRESENTING ICD: No employee will, under any circumstances, act as a potential spokesperson for ICD in response to inquiries by the news media, financial analysts, or other similarly interested persons. Employees should not grant interviews or release statistical or printed information of any kind. If you are approached for information, you should politely forward all requests to the CEO.
ICD SYSTEMS, ELECTRONIC MEDIA, AND SERVICES: ICD-supplied systems, including our computer systems, e-mail system, telephones, voice mail, fax machines, on-line services, internet access, and mobile phones belong to ICD and not to employees. Use of these systems for personal reasons in any manner that is abusive, excessive, or unauthorized is against ICD policy. We will exercise the right to monitor and audit each employee’s use of ICD’s systems, including e-mail and the internet.
Use of the computer systems to make, download, or forward discriminatory, harassing, derogatory, obscene, defamatory, threatening, or offensive remarks to other people is prohibited. In addition, downloading, transmitting, or creating, through the Internet or otherwise, material that is offensive or illegal because of characteristics such as race, sex, sexual orientation, or national origin is prohibited. Finally, you may not download to any ICD computer system software not provided to you by ICD.
PRIVACY OF PERSONAL INFORMATION: Records containing information about employees, customers, investors, vendors and suppliers must be kept confidential. Access to these records is limited to those employees with a specific need to use the information in the performance of their duties
