I.T. Department

Policy restricting personal use of employer’s computer and/or employer’s network

SECTION ONE.

PURPOSE

A. To remain competitive, better serve our customers and provide our employees with the best tools to do their jobs, Grand Capital L.L.C. - I.T. Department makes available to our workforce access to one or more forms of electronic media and services, including computers, e-mail, telephones, voicemail, fax machines, external electronic bulletin boards, wire services, online services, intranet, Internet and the World Wide Web.

B. Grand Capital L.L.C. - I.T. Department encourages the use of these media and associated services because they can make communication more efficient and effective and because they are valuable sources of information about vendors, customers, technology, and new products and services. However, all employees and everyone connected with the organization should remember that electronic media and services provided by the company are company property and their purpose is to facilitate and support company business. All computer users have the responsibility to use these resources in a professional, ethical, and lawful manner.

C. To ensure that all employees are responsible, the following guidelines have been established for using e-mail and the Internet. No policy can lay down rules to cover every possible situation. Instead, it is designed to express Grand Capital L.L.C. - I.T. Department’s philosophy and set forth general principles when using electronic media and services.

SECTION TWO.

PROHIBITED COMMUNICATIONS

Electronic media cannot be used for knowingly transmitting, retrieving, or storing any communication that is:

1. Discriminatory or harassing;

2. Derogatory to any individual or group;

3. Obscene, sexually explicit or pornographic;

4. Defamatory or threatening;

5. In violation of any license governing the use of software; or

6. Engaged in for any purpose that is illegal or contrary to Grand Capital L.L.C. - I.T. Department policy or business interests.

SECTION THREE.

PERSONAL USE

The computers, electronic media and services provided by Grand Capital L.L.C. - I.T. Department are primarily for business use to assist employees in the performance of their jobs. Limited, occasional, or incidental use of electronic media (sending or receiving) for personal, nonbusiness purposes is understandable and acceptable, and all such use should be done in a manner that does not negatively affect the systems' use for their business purposes. However, employees are expected to demonstrate a sense of responsibility and not abuse this privilege.

SECTION FOUR.

PRIVACY AND CONFIDENTIALITY

A. Generally, electronic information created and/or communicated by an employee using e-mail, word processing, utility programs, spreadsheets, voicemail, telephones, Internet and bulletin board system access, and similar electronic media is not reviewed by the company. However, the following conditions should be noted:

Grand Capital L.L.C. - I.T. Department does routinely gather logs for most electronic activities or monitor employee communications directly, e.g., telephone numbers dialed, sites accessed, call length, and time at which calls are made, for the following purposes:

1. Cost analysis;

2. Resource allocation;

3. Optimum technical management of information resources; and

4. Detecting patterns of use that indicate employees are violating company policies or engaging in illegal activity.

B. Grand Capital L.L.C. - I.T. Department reserves the right, at its discretion, to review any employee's electronic files and messages to the extent necessary to ensure electronic media and services are being used in compliance with the law, this policy and other company policies.

C. Employees should not assume electronic communications are completely private. Accordingly, if they have sensitive information to transmit, they should use other means.

SECTION FIVE.

SOFTWARE

To prevent computer viruses from being transmitted through the company's computer system, unauthorized downloading of any unauthorized software is strictly prohibited. Employees should contact the I.T. Department (the system administrator) if they have any questions.

SECTION SIX.

SECURITY/APPROPRIATE USE

A. Employees must respect the confidentiality of other individuals' electronic communications. Except in cases in which explicit authorization has been granted by company management, employees are prohibited from engaging in, or attempting to engage in:

1. Monitoring or intercepting the files or electronic communications of other employees or third parties;

2. Hacking or obtaining access to systems or accounts they are not authorized to use;

3. Using other people's log-ins or passwords; and

4. Breaching, testing, or monitoring computer or network security measures.

B. No e-mail or other electronic communications can be sent that attempt to hide the identity of the sender or represent the sender as someone else.

C. Electronic media and services should not be used in a manner that is likely to cause network congestion or significantly hamper the ability of other people to access and use the system.

D. Anyone obtaining electronic access to other companies' or individuals' materials must respect all copyrights and cannot copy, retrieve, modify or forward copyrighted materials except as permitted by the copyright owner.

SECTION SEVEN.

REMOTE ACCESS AND ONLINE SUPPORT

Grand Capital L.L.C. – I.T. Department has license to softwares that allow remotely accessing all computers (on demand and after the user himself grants access to us) and provide help and support for our employees. Therefore, employees should note that the use of such software is restricted to solely providing access to members of the I.T. Department only to their computers. Allowing users from outside Grand Capital L.L.C. to access our computers is not allowed. Exceptions are made upon approval from the members of the I.T. department only.

SECTION EIGHT.

COMPUTERS USED FOR GOVERNMENT ACCESS

Certain rules and policies apply when using softwares provided by the government or even accessing governmental websites that are not generally available to the public. In such cases employees must contact the I.T. department and get all the details on how these systems can and should be used. Then, it is the employee’s responsibility to comply with these policies. Any violation gives the department the right to investigate and take corrective actions.

SECTION NINE.

CUSTODY OF ELECTRONIC EQUIPMENTS AND COPMTUERS

Any electronic equipment or computers including laptops handed to employees are to remain in the premises of Grand Capital L.L.C.. Taking such equipment home is not allowed. Depending on the nature of the employee’s work, exceptions are made upon approval from the I.T. Department and the Higher Management.

SECTION TEN.

VIOLATIONS

For further clarifications, send an email to IT [at] GrandCapital.me or contact the I.T. department.

IT & Development Department

Grand Capital