It is imperative that all employees, officers, managers and directors keep confidential all information about Company operations and business activities that has not been made public or that is not common knowledge among investors, competitors, customers, suppliers and others, including other employees, officers, managers or directors who do not have a valid business reason for obtaining the information.
Employees, officers, managers and directors must not disclose to others (including family members), use for themselves or others, or duplicate for themselves or others any confidential information about the Company or its customers which he or she has originated or acquired in connection with employment or service to the Company. In addition, employees should not attempt to obtain or learn confidential information that they do not need to know unless it relates to performing their own employment duties. This non-disclosure obligation not only applies to employees, officers, managers and directors during their period of employment or service, but also after termination of employment or service or retirement. If an employee, officer, manager or director believes it is appropriate for business reasons, or required by law or regulation, to disclose or use confidential information outside the Company, such person should first contact the General Counsel and, if necessary, discuss the proper protective measures. Any employee, officer, manager or director who questions whether information he or she originates or acquires is confidential has a responsibility to determine its classification by asking his or her immediate supervisor or Company legal counsel. This obligation is in addition to contractual obligations an employee, officer, manager or director may have under any employment agreement or other arrangement.
All Company documents, records, memoranda, emails and other written materials (and all copies) are solely the Company’s property and must be returned immediately to the Company upon termination of employment.
It is not possible to list all the types of information that must be treated as confidential. The following are examples of confidential information to assist in observing this important policy:
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Information about contractual arrangements and other business dealings between suppliers, contractors or customers that has not been publicly disclosed by management.
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Information about other Company transactions, including proposed transactions such as acquisitions or dispositions of stock or assets, which have not been publicly disclosed by management.
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Financial, accounting and cost information about the Company that has not been publicly disclosed by management.
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Information that reveals the Company’s plans and strategies that have not been publicly disclosed by management.
Employees, officers, managers and directors should be guided by the general principle that the Company considers confidential any information that is not officially disclosed or publicly known and which might be useful to or desired by others for any reason, such as using the information to compete against Alpha or any of its subsidiaries. Officially disclosed information is considered to be that which is contained in official reports, news releases and other forms of communication that have been released by management to the public through established communication channels.
In addition to the general requirement that employees, officers, managers and directors protect the confidential information of the Company, it is important that such persons also recognize that other companies regard their confidential information as extremely valuable as well. Therefore, if the Company executes a confidentiality agreement with a third party regarding confidential information with respect to that third party to be disclosed to the Company, all employees, officers, managers and directors of the Company are expected to honor the terms of such agreement.
Any technical innovations, discoveries, system designs, or technical enhancements that an employee designs or conceives while at Alpha are the sole property of Alpha. The employee must disclose such discoveries and innovations at Alpha.