Confidential Information Policy

We, like most companies, have information not generally known outside our organization, which is commonly referred to as “Confidential Information”. Most of this information is produced through the individual and collective efforts and talents of our employees, and it includes such items as research results; financial data; engineering designs; customer lists; planning strategies; management decisions; contracts and licenses; merchandising and selling techniques; personnel information; purchasing information; accounting data; business systems and computer programs, in short, anything that is generally not available outside our Company. Confidential information would also include any information that we received and hold in confidence from someone outside the corporation, e.g., suppliers, customers, research organizations, etc.

We consider our Confidential Information, and that which we hold in confidence from people or organizations from outside our Company, as a valuable asset which if properly used, can provide us with a competitive edge in our markets. Accordingly, we encourage our employees to use our Confidential Information as necessary to do their jobs in an efficient and professional manner, but we also ask them to use common sense when using it. As such, our own Confidential Information should be made available to our employees on a need-to-know basis only, and it should not be disclosed to anyone outside of the Company unless first approved by a Company officer. Confidential documents should bear an appropriate legend, such as “Confidential” or “Secret”, should be copied only as required, and kept in secured files when not in use. Visitors should not be permitted access to work areas in which our Confidential Information may be observed through casual inspection. Moreover, we expect our employees to treat all of our information, whether marked as confidential or not, as confidential information, unless they clearly know it to be otherwise. When in doubt, review the matter with your supervisor.

Before closing this section on keeping our Confidential Information inside our Company, caution must be advised about receiving information or samples from persons not employed by us. Employees should not agree to obtain any oral or written information, samples or prototypes from any person outside the Company on a secret or confidential basis. An officer of the Company must approve all agreements, which would bind our Company to obligations of secrecy or confidentiality. Violation of this rule could hamper our own research and development efforts or possibly expose our Company to liability. Problems can arise even with verbal information or informal arrangements. If you have any particular questions about the propriety of accepting information or about other arrangements with persons outside our Company, contact your supervisor.