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The following sample company policy sets forth the guidelines for employee Internet access and access to the Internet via a company network. ***SAMPLE POLICY*** The following is a statement of Company’s policy for Internet access and use by Company employees and others authorized by Company to access the Internet via the Company network (“Company Users”). The purpose of such a policy is to minimize the potential risks associated with connecting to the Internet without unduly limiting the potential benefits offered by speedy access to global information. 1. Permitted Purposes Company Users may access the Internet through the Company network solely for the purpose of conducting Company business. Viewing, downloading, copying, sending, or processing information outside the scope of Company business is strictly prohibited. Company provides Internet access through the Company network to Company Users as a business privilege which is conditioned upon an adherence to Company’s policies and rules regarding Internet access. 2. Permitted Users Internet access through the Company network is limited to Company employees and such other persons as Company may specifically authorize. 3. Authorized Company Activities Since all Internet transactions conducted from the Company network could be perceived as authorized Company activities, Company Users must follow all applicable laws, regulations and policies when accessing the Internet. 4. Publishing on Behalf of Company Company Users placing information on the Internet are, in effect, publishing such information on Company’s behalf. Only authorized personnel shall engage in such publishing activities, other than the sending or receiving of e-mail. Authorized personnel shall observe all existing standards, policies and regulations regarding materials published on Company’s behalf, and shall establish accountability for all information regarding Company business or publications posted on the Internet for public access using the World Wide Web, Gopher, FTP, or other Internet information access functions, including information obtained through “hyperlinks” to externally stored information. 5. Copying Company Users shall refrain from illegally copying protected works, or making available copies of such works. Company Users are responsible for observing copyright and licensing agreements that may apply when downloading files, documents and software. Company Users must obtain approval from Company supervisory personnel before downloading any materials for which a registration fee is requested. 6. Other Third Party Rights Company Users are prohibited from sending or posting messages that contain abusive or objectionable language, that defame or libel others, or that infringe the privacy rights of others. 7. Obscenity Company Users shall not view, download, copy, send, post or access information that is illegal or obscene. 8. Interference with Work Company Users shall not congest the network or interfere with the work of others when accessing the Internet, including the transmission or posting of messages that are intended or likely to result in the loss of the recipient’s work or systems. 9. No Expectation of Privacy Company reserves the right to access and disclose the contents of Internet communications, including e-mail, conducted through the Company network. All Company Users waive any right to privacy in Internet communications, and consent to access and disclosure of Internet communications by authorized Company personnel. 10. Company Network Security Company Users shall access the Internet in a manner which does not compromise the security and integrity of the Company network, such as allowing intruders or viruses into the Company network. Company Users wishing to download any document, file or software from non-Company sources must observe Company policies and procedures for virus checking and system security. 11. Connection to the Internet When using any computer attached to the Company network, users shall not access the Internet except through a Company-approved Internet firewall. Company Users shall not access the Internet directly, whether through a modem or otherwise, unless their accessing computer is disconnected from the Company network. 12. Encryption Functionality Authorized personnel shall take precautions that software containing encryption functionality is not placed on the Internet for downloading outside the United States, because U.S. export control laws closely regulate such software. ***** This sample policy is intended to serve solely as an exemplar and may need to be modified to conform to the legal requirements of your jurisdiction. It in no way constitutes legal advice. Julian S. Millstein, Jeffrey D. Neuburger and Jeffrey P. Weingart are partners with the law firm of Brown Raysman Millstein Felder & Steiner, www.brownraysman.comin New York. For information on purchasing the book, “Doing Business on the Internet: Forms and Analysis,” please go to http://www.lawcatalog.com/ product_detail.cfm?affil=lawcom&productID=1084.

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