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Acceptable Use Policy

Overview

• InfoSec’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Win Thein & Sons’s established culture of openness, trust and integrity. InfoSec is committed to protecting Win Thein & Sons's employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.

• Internet/Intranet/Extranet-related systems, including but not limited to computer equipment, software, operating systems, storage media, network accounts providing electronic mail, WWW browsing, and FTP, are the property of Win Thein & Sons. These systems are to be used for business purposes in serving the interests of the company, and of our clients and customers in the course of normal operations. Please review Human Resources policies for further details.

• Effective security is a team effort involving the participation and support of every Win Thein & Sons employee and affiliate who deals with information and/or information systems. It is the responsibility of every computer user to know these guidelines, and to conduct their activities accordingly.

Purpose

• The purpose of this policy is to outline the acceptable use of computer equipment at Win Thein & Sons. These rules are in place to protect the employee and Win Thein & Sons. Inappropriate use exposes Win Thein & Sons to risks including virus attacks, compromise of network systems and services, and legal issues.

Scope

• This policy applies to the use of information, electronic and computing devices, and network resources to conduct Win Thein & Sons business or interact with internal networks and business systems, whether owned or leased by Win Thein & Sons, the employee, or a third party. All employees, contractors, consultants, temporary, and other workers at Win Thein & Sons and its subsidiaries are responsible for exercising good judgment regarding appropriate use of information, electronic devices, and network resources in accordance with Win Thein & Sons policies and standards, and local laws and regulation. Exceptions to this policy are documented in section 5.2

• This policy applies to employees, contractors, consultants, temporaries, and other workers at Win Thein & Sons, including all personnel affiliated with third parties. This policy applies to all equipment that is owned or leased by Win Thein & Sons.

Policy

General Use and Ownership

• Win Thein & Sons proprietary information stored on electronic and computing devices whether owned or leased by Win Thein & Sons, the employee or a third party, remains the sole property of Win Thein & Sons, you must ensure through legal or technical means that proprietary information is protected in accordance with the Data Protection Standard.

• You have a responsibility to promptly report the theft, loss or unauthorized disclosure of Win Thein & Sons proprietary information.

• You may access, use or share Win Thein & Sons proprietary information only to the extent it is authorized and necessary to fulfill your assigned job duties.

• Employees are responsible for exercising good judgment regarding the reasonableness of personal use. Individual departments are responsible for creating guidelines concerning personal use of Internet/Intranet/Extranet systems. In the absence of such policies, employees should be guided by departmental policies on personal use, and if there is any uncertainty, employees should consult their supervisor or manager.

• For security and network maintenance purposes, authorized individuals within Win Thein & Sons may monitor equipment, systems and network traffic at any time, per InfoSec’s Audit Policy.

• Win Thein & Sons reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.

Security and Proprietary Information

• All mobile and computing devices that connect to the internal network must comply with the Minimum Access Policy.

• System level and user level passwords must comply with the Password Policy. Providing access to another individual, either deliberately or through failure to secure its access, is prohibited.

• All computing devices must be secured with a password-protected screensaver with the automatic activation feature set to 10 minutes or less. You must lock the screen or log off when the device is unattended.

• Postings by employees from a Win Thein & Sons email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of Win Thein & Sons, unless posting is in the course of business duties.

• Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain malware.

Unacceptable Use

The following activities are, in general, prohibited. Employees may be exempted from these restrictions during the course of their legitimate job responsibilities (e.g., systems administration staff may have a need to disable the network access of a host if that host is disrupting production services).

• Under no circumstances is an employee of Win Thein & Sons authorized to engage in any activity that is illegal under local, state, federal or international law while utilizing Win Thein & Sons owned resources.

• The lists below are by no means exhaustive, but attempt to provide a framework for activities which fall into the category of unacceptable use.

System and Network Activities

The following activities are strictly prohibited, with no exceptions:

1. Violations of the rights of any person or company protected by copyright, trade secret, patent or other intellectual property, or similar laws or regulations, including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by Win Thein & Sons.

2. Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books or other copyrighted sources, copyrighted music, and the installation of any copyrighted software for which Win Thein & Sons or the end user does not have an active license is strictly prohibited.

3. Accessing data, a server or an account for any purpose other than conducting Win Thein & Sons business, even if you have authorized access, is prohibited.

4. Exporting software, technical information, encryption software or technology, in violation of international or regional export control laws, is illegal. The appropriate management should be consulted prior to export of any material that is in question.

5. Introduction of malicious programs into the network or server (e.g., viruses, worms, Trojan horses, e-mail bombs, etc.).

6. Revealing your account password to others or allowing use of your account by others. This includes family and other household members when work is being done at home.

7. Using a Win Thein & Sons computing asset to actively engage in procuring or transmitting material that is in violation of sexual harassment or hostile workplace laws in the user's local jurisdiction.

8. Making fraudulent offers of products, items, or services originating from any Win Thein & Sons account.

9. Making statements about warranty, expressly or implied, unless it is a part of normal job duties.

10. Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient or logging into a server or account that the employee is not expressly authorized to access, unless these duties are within the scope of regular duties. For purposes of this section, "disruption" includes, but is not limited to, network sniffing, pinged floods, packet spoofing, denial of service, and forged routing information for malicious purposes.

11. Port scanning or security scanning is expressly prohibited unless prior notification to InfoSec is made.

12. Executing any form of network monitoring which will intercept data not intended for the employee's host, unless this activity is a part of the employee's normal job/duty.

13. Circumventing user authentication or security of any host, network or account.

14. Introducing honeypots, honeynets, or similar technology on Win Thein & Sons network.

15. Interfering with or denying service to any user other than the employee's host (for example, denial of service attack).

16. Using any program/script/command, or sending messages of any kind, with the intent to interfere with, or disable, a user's terminal session, via any means, locally or via the Internet/Intranet/Extranet.

17. Providing information about, or lists of, Win Thein & Sons employees to parties outside

Win Thein & Sons

Email and Communication Activities

When using company resources to access and use the Internet, users must realize they represent the company. Whenever employees state an affiliation to the company, they must also clearly indicate that "the opinions expressed are my own and not necessarily those of the company".

Questions may be addressed to the IT Department

1. Sending unsolicited email messages, including the sending of "junk mail" or other advertising material to individuals who did not specifically request such material (email spam).

2. Any form of harassment via email, telephone or paging, whether through language, frequency, or size of messages.

3. Unauthorized use, or forging, of email header information.

4. Solicitation of email for any other email address, other than that of the poster's account, with the intent to harass or to collect replies.

5. Creating or forwarding "chain letters", "Ponzi" or other "pyramid" schemes of any type.

6. Use of unsolicited email originating from within Win Thein & Sons 's networks of other Internet/Intranet/Extranet service providers on behalf of, or to advertise, any service hosted by Win Thein & Sons or connected via Win Thein & Sons 's network.

7. Posting the same or similar non-business-related messages to large numbers of Usenet newsgroups (newsgroup spam).

Blogging and Social Media

1. Blogging by employees, whether using Win Thein & Sons’s property and systems or personal computer systems, is also subject to the terms and restrictions set forth in this Policy. Limited and occasional use of Win Thein & Sons’s systems to engage in blogging is acceptable, provided that it is done in a professional and responsible manner, does not otherwise violate Win Thein & Sons’s policy, is not detrimental to Win Thein & Sons’s best interests, and does not interfere with an employee's regular work duties. Blogging from Win Thein & Sons’s systems is also subject to monitoring.

2. Win Thein & Sons’s Confidential Information policy also applies to blogging. As such, Employees are prohibited from revealing any Win Thein & Sons confidential or proprietary information, trade secrets or any other material covered by Win Thein & Sons’s Confidential Information policy when engaged in blogging.

3. Employees shall not engage in any blogging that may harm or tarnish the image, reputation and/or goodwill of Win Thein & Sons and/or any of its employees. Employees are also prohibited from making any discriminatory, disparaging, defamatory or harassing comments when blogging or otherwise engaging in any conduct prohibited by Win Thein & Sons’s Non-Discrimination and Anti-Harassment policy.

4. Employees may also not attribute personal statements, opinions or beliefs to Win Thein & Sons when engaged in blogging. If an employee is expressing his or her beliefs and/or opinions in blogs, the employee may not, expressly or implicitly, represent themselves as an employee or representative of Win Thein & Sons. Employees assume any and all risk associated with blogging.

5. Apart from following all laws pertaining to the handling and disclosure of copyrighted or export controlled materials, Win Thein & Sons’s trademarks, logos and any other

Win Thein & Sons intellectual property may also not be used in connection with any blogging activity

Policy Compliance

Compliance Measurement

The Infosec team will verify compliance to this policy through various methods, including but not limited to, business tool reports, internal and external audits, and feedback to the policy owner.

Exceptions

• Any exception to the policy must be approved by the Infosec team in advance.

Non-Compliance

• An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

Related Standards, Policies and Processes

• Data Classification Policy

• Data Protection Standard

• Social Media Policy

• Minimum Access Policy

• Password Policy

EMPLOYEE AGREEMENT ON USE OF NETWORK & INTERNET

I have read, understand, and agree to comply with the foregoing policies, rules, and conditions governing the use of the company network & internet. I understand that I have no expectation of privacy when I use company network. I am aware that violations of this guideline on appropriate use of the network and Internet systems may subject me to disciplinary action, including termination from employment, legal action and criminal liability. I further understand that my use of the network and Internet may reflect on the image of Win Thein & Sons to our customers, competitors and suppliers and that I have responsibility to maintain a positive representation of the company. Furthermore, I understand that this policy can be amended at any time.

DATED:

EMPLOYEE COMPANY

Authorized Signature Authorized Signature

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