neaPay Email and Communication Policy

7. Email and Communication Policy

Email Policy

1 Overview Electronic email is pervasively used in almost all industry verticals and is often the primary communication and awareness method within an organization. At the same time, misuse of email can post many legal, privacy and security risks, thus it’s important for users to understand the appropriate use of electronic communications.

2 Purpose The purpose of this email policy is to ensure the proper use of neaPay email system and make users aware of what neaPay deems as acceptable and unacceptable use of its email system. This policy outlines the minimum requirements for use of email within neaPay Network.

3 Scope This policy covers appropriate use of any email sent from a neaPay email address and applies to all employees, vendors, and agents operating on behalf of neaPay.

4 Policy

4.1 All use of email must be consistent with neaPay policies and procedures of ethical conduct, safety, compliance with applicable laws and proper business practices.

4.2 neaPay email account should be used primarily for neaPay businessrelated purposes; personal communication is permitted on a limited basis, but non- neaPay related commercial uses are prohibited.

4.3 All neaPay data contained within an email message or an attachment must be secured according to the Data Protection Standard.

4.4 Email should be retained only if it qualifies as a neaPay business record. Email is a neaPay business record if there exists a legitimate and ongoing business reason to preserve the information contained in the email.

4.5 Email that is identified as a neaPay business record shall be retained according to neaPay Record Retention Schedule.

4.6 The neaPay email system shall not to be used for the creation or distribution of any disruptive or offensive messages, including offensive comments about race, gender, hair color, disabilities, age, sexual orientation, pornography, religious beliefs and practice, political beliefs, or national origin. Employees who receive any emails with this content from any neaPay employee should report the matter to their supervisor immediately.

4.7 Users are prohibited from automatically forwarding neaPay email to a third party email system (noted in 4.8 below). Individual messages which are forwarded by the user must not contain neaPay confidential or above information.

4.8 Users are prohibited from using third-party email systems and storage servers such as Google, Yahoo, and MSN Hotmail etc. to conduct neaPay business, to create or memorialize any binding transactions, or to store or retain email on behalf of . Such communications and transactions should be conducted through proper channels using neaPay-approved documentation.

4.9 Using a reasonable amount of neaPay resources for personal emails is acceptable, but non-work related email shall be saved in a separate folder from work related email. Sending chain letters or joke emails from a neaPay email account is prohibited.

4.10 neaPay employees shall have no expectation of privacy in anything they store, send or receive on the company’s email system.

4.11 neaPay may monitor messages without prior notice. neaPay is not obliged to monitor email messages.

5 Policy Compliance

5.1 Compliance Measurement The Infosec team will verify compliance to this policy through various methods, including but not limited to, periodic walk-thrus, video monitoring, business tool reports, internal and external audits, and feedback to the policy owner.

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

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

6 Related Standards, Policies and Processes • Data Protection Standard

7 Definitions and Terms None.