1.  Policy Statement

Filtronic plc, (including its subsidiary companies and business units) aims to ensure that it had adequate IT systems in place to conduct the business of the company and that these systems are used properly and effectively to promote and protect the company’s interests.
The Management of each Business Unit within the Filtronic Group shall ensure that relevant local legislative requirements are addressed and shall brief, train their employees on the existence and content of this Policy and shall and monitor compliance. Each Business Unit shall adapt this Policy where necessary to reflect the legal requirements of the territories within which they operate.

2.  IT Policy Implementation

This section explains:

• how you may use email, telephones and the Internet using the Company’s facilities;
• how you or the Company may be liable in law for misuse of email or the Internet;
• how your interests and the Company’s interests can be protected; and
• disciplinary action that may be taken against you if you fail to comply with the rules set out in this policy.

You must read this policy and apply it to your everyday work.  If you have any questions as to the meaning or effect of this policy you should contact your manager or a member of the HR or IT Departments.

This policy is not however a definitive statement of the purposes for which the Company’s facilities must not be used.  You must conduct yourself, at all times, in a trustworthy and appropriate manner so as not to discredit or harm the Company or its staff and in accordance with the spirit of this policy statement.

This policy applies to all telephone and computer users within the Company (including, without limit, all Directors, employees and third parties) who use email, bulletin boards, intranet, the world-wide web and the Internet through computers based at the Company’s premises or through any computers located at other sites (including private equipment) via the Company’s network or using the Company’s telephone lines.

Failure or refusal to comply with this policy is a disciplinary offence that may lead to disciplinary action, up to and including, dismissal without notice.  For further details please refer to the Company’s Disciplinary Procedure.

NB       All communications and stored information sent, received, created or contained within the Company’s systems are the property of the Company and accordingly should not be considered private or personal.

2.1  Telephone Use

Personal calls should not usually be made or received except in an emergency, when permission to make or take the call should be first obtained from your Line Manager.  If a public payphone is not provided on Company premises for employees’ private use the telephone at reception may be used.  Calls to and from telephones will not be monitored. Private calls should be made during lunch and rest breaks where possible.

2.2  E mail and Internet - Authorised Use

The Company encourages staff to use email as a prompt and effective method of communication.  It will not always be appropriate to communicate by email and you should always consider whether there is a more suitable method (for example in circumstances where there is a need to preserve confidentiality or in the case of sensitive issues which should be communicated face to face).
 
Your use of email and the Internet is only authorised for bona fide purposes directly connected with your work or the Company’s business. All communications and stored information sent, received, created or contained within the Company’s systems are the property of the Company and accordingly should not be considered as private or personal.  As detailed below, the Company reserves the right to access such communications and information.

You must act responsibly and appropriately when using the Company’s computers and when sending email, whether internally within the Company or externally using the Internet.  Remember that email sent via the Company’s system may be legally regarded as bearing the Company letterhead and should therefore be treated the same way.

You may only set passwords and security codes for your computer, the system or any part of it or documentation held on it in accordance with Company policy from time to time.  The use of someone else’s identity and password to access the Internet or send email is strictly forbidden and will result in disciplinary action.

Internet access is provided for business purposes.  You will need to be familiar with the type of information that the Company deems to be sensitive or secret and you must ensure that this is not made available to the public via the Company’s email system.  Employees who routinely work from home must use a Company supplied laptop computer or have a dedicated workstation supplied by the Company.  Any other employees that need to use a home computer for work purposes on an occasional basis should only do so with the express permission of their line manager and must ensure they take all reasonable measures to protect and maintain the integrity and confidentiality all Company information in doing so.  Employees working offsite must use a Company provided e-mail system for Company business, and not a private or public e-mail account such as Hotmail, Yahoo, etc.
 
The amount of time spent browsing should be kept to a minimum by using search engines to locate what you are looking for.

Do not subscribe to any bulletin boards, news groups or any other Internet services or download software without the prior written permission of the IT Systems Manager who may seek approval of Senior Management (if appropriate).

Incidental personal use of the Internet and the Company’s email may be permitted but should be kept to a minimum and extended use for personal or non-company business, use for the operation of a personal business or activity intended to achieve personal financial gain, or use that could bring the Company’s name into disrepute or be commercially damaging to the Company, is inappropriate and unacceptable.

You must not deliberately visit, view or download any of the following material and you are strictly prohibited from sending any material, whether downloaded from the Internet or otherwise which contains or refers to such as:

• Sex or pornography whether illegal material or material comparable to that available on the top shelf in a newsagent
• Terrorism, Cults
• Controlled Drugs
• Extreme material which may be likely to cause offence to another person
• Hate sites (racial or other)
• Gambling
• Criminal skills (including software hacking)
• Advertisement or the conduct of any personal trade, service or profession.

You are also strictly prohibited from sending any emails that are: 

• threatening or aggressive
• abusive, anti-social or sexually biased
• obscene or offensive
• in breach of Company policy or government regulations/legislation
• from someone else’s account, except under proper “delegate” arrangements, which retain individual accountability.

Should you mistakenly locate an Internet site containing any prohibited material (as above) you should notify the IT department so that steps can be taken to avoid other people making the same mistake.

Unauthorised use of email and/or the Internet may expose both you personally and/or the Company to Court proceedings attracting both criminal and civil liability.  You will be held responsible for any claims brought against the Company for any legal action to which the Company is, or might be, exposed as a result of your unauthorised use of email and/or the Internet.

2.3  Software

The Company licenses computer software from a variety of outside sources.  The Companydoes not own this software or related documentation and, unless authorised by the software developer, does not have the right to reproduce it.  The software used on the local area network or multiple/individual machines should have the appropriate licence(s).

You should notify your departmental manager or the IT manager of any misuse of software or associated documentation.

The use of software packages other than those licenced by the Company requires the approval of the IT department and the purchase of appropriate licences. Installation of software and modification of PC’s must be performed by a member of the IT department, unless otherwise authorised by IT management.  The installation and use of unauthorised software such as personal screen savers, wallpapers and games is strictly forbidden.

2.4  Third Parties

Do not give information to third parties unless authorised to do so and do not disclose security information or other details relating to the Company’s computing resources, data, information or processes unless it is necessary for the third party to fulfil its role and the third party has entered into a confidentiality agreement.  Any contract entered into by the Company that contracts a third party for services (e.g. contactors, partners, customers) should contain clear and comprehensive security conditions in respect of the access by the third party to and protection of the Company’s information and IT services. The department responsible for the contract must regularly monitor compliance with such security conditions and liaise with the IT department where necessary.
 
Equally, any similar security and licencing requirements associated with the use of third party information by the Company must be followed.

2.5  Security and Viruses

The accessibility of the Internet is both an advantage and disadvantage of the system.  Whilst you can access a huge amount of information via the Internet, information and emails sent across the Internet may be read by persons unknown to the sender.  Potentially anyone could read private and confidential information transmitted on the Internet. Even if some information has been deleted from your screen it may not necessarily be deleted from the Internet system which provides back-up saving mechanisms. Any message or information requiring security or confidentiality should be distributed by an alternative means of communication.

It is your responsibility to log off from email or close down active sessions when away from the office or from your computer to avoid inadvertent security breaches.  You should update your security password regularly, not store it with your workstation and not disclose this detail unless your job requires it.  You must not forward to third parties emails that contain information which is confidential or commercially sensitive and should not include anything sensitive or private in email messages unless protected with approved encryption software, which can be obtained from the IT department.  Also, be aware that email messages may be forwarded, distributed or read by others without your knowledge.

You must not send via or put on the Internet any material, which incites or encourages or enables others to gain unauthorised access to the Company’s computer system.  It is vital that all staff take all necessary steps to safeguard the Company’s computer system from viruses.  Accordingly, employees must not exchange executable programs using Internet email and must discard any documents or attachments which employees receive unsolicited.  You must not introduce new software onto the Company’s system without written authorisation from the IT department and you must always ensure that the appropriate virus checking procedures have been followed.  If in doubt, take all floppy disks, CD-ROMs or other media originating from external sources to the IT department for virus scanning before inserting into your PC.

Sensitive documents should not be saved to public file shares and you should also physically protect floppy disks, laptops etc. by e.g., locking them up when leaving them unattended and protect sensitive information on documents by, e.g., disposing of sensitive documents in a secure manner.

2.6  Intellectual Property

The Company’s intellectual property represents one of its most valuable assets.  Any invention that has been disclosed to the public may not be patented.  Information is deemed to have been disclosed to the public if anyone is free to disclose it without breaking obligations of confidentiality.  You should not, therefore, send potentially patentable information in unencrypted emails, which may be accessed by unauthorised individuals.

Further, patents will not be granted for inventions that are deemed obvious to a person skilled in the area that has access to all the information available on the subject.  You should not, therefore, make careless publications in the Internet or send careless unencrypted emails that might lead someone to deduce the Company’s ideas.

2.7  Courtesy

As emails can easily be misconstrued you must therefore consider very carefully whether email is the appropriate form of communication in particular circumstances.  If you decide that it is, you should carefully consider the content of all emails and who the appropriate recipients should be.  It is inappropriate to send emails and/or attachments to people (whether they are other employees of the Company or third parties) if the email does not relate to them or if the attachment should not be read by them.  Pay particular attention to style and content of all emails when sending mails externally, treating them in the same way as letters on the Company’s headed notepaper.

2.8  Defamation

Emails and the Internet are considered to be a form of publication and therefore the use of the Internet and email may result in communication constituting a libel contrary to the provisions of the Defamation Act.  Both words and pictures produced on the Internet are capable of being libellous if they are untrue, ridicule a person and as a result damage that person’s reputation.  For these purposes, as well as any individuals, a “person” may include the Company or another company.  You must not put any defamatory statement onto the Internet or on the Company’s computer system whether in emails or otherwise.  As well as you being personally exposed to potential legal action for defamation, the Company can also be exposed both for the actions of you as its employee and also as an on-line provider.

2.9  Obscenity

It is a criminal offence to publish or distribute obscene material or to display indecent material in public.  The Internet or any computer ‘message boards’ qualify as a public place.  The accessing or sending of obscene or indecent material using the Company’s system is strictly forbidden.

2.10  Discrimination and Harassment

The Company does not tolerate discrimination or harassment in any form whatsoever.  This principle extends to any information distributed on the Company’s system or via the Internet. You may not put on

either system any material which discriminates or encourages discrimination or harassment on racial or ethnic grounds or on grounds of gender, sexual orientation, marital status, age, ethnic origin, colour, nationality, race, religion, belief or disability.  Please also bear in mind the Company’s policy on discrimination and harassment.
Breaches of this policy will lead to disciplinary action.  In the event you receive or become aware of obscene, indecent, offensive, inflammatory, discriminatory or socially offensive material you should notify your manager immediately so that appropriate action may be taken.

2.11  Data Protection

Only designated employees within the HR and IT departments may place staff information (including photographs) onto the Company’s system. In all cases the individual to whom the personal data relates should have been made aware that this information would be placed on the system. Photographs should not be placed on the system without an individual’s consent. If you are in any doubt you should check with a member of the HR Department/your Manager.

2.12  Monitoring

In accordance with the Company’s data protection policy, the Company reserves the right, at any time and without notice, to monitor, keep a record of, access, listen to or read any communication madeor received by you on its computers or telephone system for the following purposes:

• to establish the existence of business related facts
• to ascertain compliance with regulatory or self regulatory practices and procedures
• for quality control and staff training purposes
• to prevent or detect crime (including ‘hacking’)
• to intercept for operational purposes, such as protecting against viruses and making routine interceptions such as forwarding e mails to correct destinations
• to detect or investigate unauthorised use of the IT resources
• tocheck voice mail systems when you are on holiday or on sick leave.

The Company also logs all Internet activity and reserves the right to monitor time spent by employees accessing the Internet for browsing.  The Company may monitor sites visited, the content viewed or information downloaded where necessary.

The Company also reserves the right to make and keep copies of telephone calls or emails and data documenting use of the telephone, email and/or the Internet systems, for the purposes set out above.  The Company may bypass any password you set.

Hemant Mardia
Chief Executive Officer
Filtronic plc
May 2010