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1. Adoption of Policy

This policy statement was adopted by the Board of Directors of Win Thein & Sons Co., Ltd and must be complied with by all employees and contractors that are provided with access to certain Internet and Intranet services of the company, including but not limited to Internet access, Email, FTP, local area network, stand alone computer terminals, and laptop computers.

The Company offers certain Computer and Internet Services as a tool for employees to utilize in connection with their job related functions. It is the philosophy of the Company that these services can be used to enhance the productivity of our employees and further the efficient accomplishment of tasks that benefit the business and prospects of the Company.

2. Employee Email

Company Email Addresses

All employees with a bona fide need will be issued an Email address for use only in connection with bona fide business on behalf of the Company.

No Privacy In Company Email

The Company respects the privacy rights of its employees. At the same time, Company Email usage is given only for Company use and in furtherance of Company activities and not for the private or personal use of the employee. Employee’s privacy is not extended to employee’s ob related functions, which are the only functions for which Email may be used. As such, employees should have no expectation of privacy with respect to use of the Company provided Email address.

Employee Email Passwords

Each employee who is issued an Email account shall be issued a password with which to gain access to such account. The password shall also be logged and retained by the CIS Director. Employees are put on notice that the password does not secure privacy of such Email account or mean that the contents of Email files are private or personal to employee. All passwords shall be the property of the Company. Employees are not authorized to make any changes to such passwords without obtaining approval and issuance of a new password from the CIS Director.

Company Management Right To Review Email Information

Employees are provided with Email addresses only for Company-related matters. The Email accounts and all information transmitted through these accounts are the property of the Company and not of the employee and shall be considered to be Company records. The contents of the Company Email account will be available at all times to access by Company management. Employees should have no expectation that any information contained in Email that they send and receive. All Email contents shall be accessible by company management. The Company routinely backs up this information, so the employee’s Email will normally be accessible to the Company from backup files, even after it is deleted by the employee. You should also be aware that the contents of Email transmission to or from you may be disclosed within the Company for any purpose, including but not limited to decisions relative to employment matters. The contents of your Email and other information on the Company systems are subject to periodic unannounced inspections. YOU SHOULD NOT ASSUME THAT ANY EMAIL MESSAGES THAT YOU SEND OR RECEIVE ARE CONFIDENTIAL. THEY ARE NOT.

Passwords and Encryption Keys

Only passwords that are assigned to you by the CIS Director may be used. If you wish to change your password, you must first notify the CIS Director. You are not authorized to make changes in your password. Any requested changes are to be accomplished by the CIS Director. You are not authorized to use any encryption devices or encryption keys unless you first notify the CIS Director. You shall also provide the CIS Director with the means of access to such encrypted transmissions. The Company recognizes that in certain instances encryption of Email transmissions are in the best interests of the Company and the protection of the Company’s information. As such, employees are encouraged to be sensitive to the necessity of encryption in some instances and are encouraged to utilize encryption subject to the necessity of receiving prior approval and providing necessary information to the CIS Director. Employees are prohibits from using the passwords and encryption devices of other employees or of the Company. In the event that a password or encryption device of another employee or of the Company comes into the knowledge of the employee, the employee shall immediately notify the CIS Director. Employees are prohibited from using the Email addresses of other employees.

Personal Email

The Email account that you are assigned is to be used only for Company business and to assist you in the performance of your employment related activities. You are prohibited from using the Email accounts for personal reasons. You should only give out your Email address for business purposes. You should not give out your Email address to individuals who have no business purpose. The Company has the unrestricted right to access and disclose as all messages transmitted to and from its Email system regardless of whether the content is business-related or personal in nature. This means that your personal messages will be accessible by Company management at all times and without any notice to you. You should not transmit any messages over the Company Email that you would not want to have disclosed to a third party. Company Email should not contain personal information about yourself or other parties, whether they are employees of this Company or not.

Occasional Unsolicited Personal Email

Occasional unsolicited personal Emails may be unavoidable and will not be a violation of this policy. However, these occasional unsolicited Emails will be treated in the same way as business related Emails by the Company and you will not have any expectation of privacy in them. We recommend that you respond to unsolicited personal Emails received at your Company Email address stating that you are not permitted to receive personal Emails on your Company Email address, that there is no expectation of privacy when this Email address is used, and referring the sender to your own private personal Email address, if you have one, for future transmissions.

Professional Tone

Employees should use the same level of care and draftsmanship in Email transmissions as they do with respect to business letters. Emails should be professionally written with a professional tone, correct business form and style should be used.

Prohibited Email Content

You are not permitted to transmit any Email over the Company systems that contain and illegal, defamatory, insulting, vulgar, rude, disruptive, offensive, derogatory, harmful or immoral content. Prohibited transmissions include, but are not limited to sexually-explicit or sexually oriented materials, cartoons or illustrations, jokes, romantic oriented materials, anything that could be deemed to be sexually harassing, any sexual innuendos or references, propositions of love, whether wanted or unwanted, ethnic or racially oriented references or slurs, or any other materials that could be considered by the recipient to constitute sexual harassment or harassing or disparaging based upon sex, sexual orientation, race, ethnicity, national origin, or religious or political beliefs or practices.

Violation of Policies

Violations of these policies may subject to the Employee to discipline under the Company’s employment policies, including but not limited to termination of employment.

3. Requirement of Written Approval

Each employee shall be provided with a company Email account to be used only in connection with job related tasks. Only those employees with a bona fide need will be permitted other types of access to the Internet using company facilities. Internet Access using the company’s facilities is only permitted for employees who first receive written approval from [title of officer giving approvals] and the Computer Information Service Department Supervisor (CIS). Approval shall only be given for the scope of access that is reasonably necessary to meet the employee’s job functions. Access beyond the scope of access that is approved shall require separate approval. The CIS shall be responsible for maintaining a register of company employees who have access to the Internet using company facilities. The CIS shall also be responsible for maintaining a register of Email addresses and passwords for all company employees.

4. Procedure For Obtaining Internet Access Approval

As stated above, Internet access will only be permitted to employees who first receive written approval. Access is permitted only within the scope of the approval that is given. The employee must demonstrate a bona fide job related need for Internet access.

The following are the procedures for obtain approval of Internet access using the Company’s facilities:

a. The employee must first be certified by the CIS Director as meeting the minimum requirements established by the CIS Director relative to knowledge and skills of the Internet and Internet browser software.

b. The CIS shall inspect the employee’s computer system and environment and certify that minimum hardware, software and network access requirements are met and security is present.

c. The employee shall submit a request for Internet Access on the forms that can be obtained from the CIS Director. The request form shall include a description of the bona fide reason why Internet access is necessary to fulfill the employee’s job functions as well as the scope of access that is being requested.

d. The completed and executed request form must be submitted to the Director of CIS.

e. The Director if CIS shall review the request and consult with any necessary supervisors of the employee and Company management where necessary. Following a review, the CIS Director shall notify the employee whether the request is granted or denied. The CIS Director may modify the scope of access granted.

5. Restrictions On Use

a. Any access to the Internet which is approve as aforesaid, will be subject to the following policies and conditions whether or not they are referenced in any approval for access. Internet access through the Company systems is a privilege and not a right of any employee. Approval granted shall be deemed to impose certain responsibilities on the employee.

b. No access shall be for personal reasons or personal browsing. Access shall only be permitted within the parameters for which approval was granted. Access is only permitted for bona fide business purposes and for furthering the interests of the Company.

c. Only properly licensed software and browsers that are placed on the Company computer terminal by the CIS Department may be used to gain access to the Internet.

d. No software, executable files, databases or other “live” technology may be received through Email, downloaded from the Internet, installed from external discs, or otherwise placed on the Company’s computer system without the prior approval of the CIS Director. Prior to any approval, the CIS Director shall assure that the information is appropriately licensed for use installed on Company machines and is free from viruses.

e. The Company shall have the right to monitor and inspect the computer systems (hard drives and external drives), history files, log files and all other aspects of the Company computers and software for any reason at its discretion. Employees have no right of privacy as to any item or communication using property of the Company.

f. Company property shall not be used for personal browsing, including but not limited to accessing any sexually explicit or sexually oriented materials.

g. All of the policies set forth above with respect to use of Email shall apply equally to use of general Internet access, including but not limited to Web Based Email application, chat room participation, Usenet and newsgroup access and all other Internet related use and access.

h. Any violation of these policies may lead to disciplinary actions, including potential termination.

i. All employment policies of the Company shall apply equally to employee use of Internet and computer technology.

6. Security of Information

6.1 Each employee using any Internet technology shall do so with sensitivity to the need to protect confidential and proprietary information of the Company. You must always assume with regard to each transmission of data, that the Internet does not provide adequate measures to protect the security and confidentiality of items that you may transmit. You should also assume that you have no control over dissemination of information once it is received by the intended recipient. Each employee must take all steps necessary to protect the confidential, proprietary, and trade secret information of the Company. Employees are NOT authorized to transmit any such information over the Internet without the advanced consent of the CIS Director. This prohibition is applicable regardless of the use of any encryption technology.

6.2 In the event that an employee finds it necessary to transmit any confidential, proprietary, or trade secret information over the Internet for a compelling business reason, the employee shall first inform the CIS Director and transmit such information only under the supervision of the CIS Director. If the information cannot be transmitted with adequate assurances of protection and security, other available methods of transmission should be used.