SOCIAL MEDIA POLICY
CCP Technologies Ltd. (CCP Technologies Ltd./the Company) has the following Social Media Policy to regulate the use of social media by people associated with CCP Technologies Ltd. The CCP Technologies Ltd. Social Media Policy covers the use of electronic media for engagement within and between the company and the market by directors and employees of CCP Technologies Ltd., and directors and key management personnel of each of the Company’s wholly owned subsidiaries (Restricted Persons).
To preserve the reputation and integrity of CCP Technologies Ltd., this policy will apply to the wide range of technologies commonly referred to as ‘social media’ which fundamentally are no different to other forms of communication, but do represent a risk as well as an opportunity because they can connect large numbers of people with relative ease.
The rationale for the policy is to manage the risks associated with the use of technology platforms and tools of this nature.
Social media means online social networking or Web 2.0 technologies services and tools used for publishing, sharing and discussing information, including without limitation blogs or web logs, electronic forums or message boards, micro-blogs (eg: Twitter™), photo sharing sites (eg: Flickr®), social bookmarking sites (eg: Delicious™, Digg™, Reddit™) social networking websites (eg: MySpace™, Facebook®, LinkedIn®, Google+™, Bebo™, Friendster™) video sharing sites (eg: YouTube™), virtual worlds (eg: Second Life®) and wikis (eg: Wikipedia®) and any other electronic media that allow individual users to upload and share content regardless of format.
The Policy outlines requirements for compliance with confidentiality, governance,
legal, privacy and regulatory parameters when using social media to conduct CCP Technologies Ltd.
business. This policy aims to:
- inform appropriate use of social media tools for CCP Technologies Ltd.
- promote useful market engagement through the use of social media
- minimise problematic communications
- manage the inherent challenges of speed and immediacy
This Policy should be read in conjunction with other relevant policies and procedures of CCP Technologies Ltd.and is not intended to cover personal use of social media where the author publishes information in their personal capacity and not on behalf of, or in association with CCP Technologies Ltd. and no reference is made to CCP Technologies Ltd. its directors, employees, policies and products, suppliers, shareholders, other stakeholders or CCP Technologies Ltd. related issues.
Legislative & Policy Framework
CCP Technologies Ltd. Restricted Persons are expected to demonstrate standards of conduct and behaviour that are consistent with relevant legislation, regulations and policies, including the following non-exhaustive list:
- Corporations Act;
- ASX Listing and Market Rules;
- CCP Technologies Ltd. employment contracts; and
- CCP Technologies Ltd. Securities Trading Policy.
Social Media Policy
When using social media CCP Technologies Ltd. Restricted Persons are expected to:
- seek prior authorisation from the Chief Executive Officer;
- adhere to CCP Technologies Ltd. policies and procedures;
- behave with caution, courtesy, honesty and respect;
- comply with relevant laws and regulations;
- only disclose information that has already been released to the market;
- reinforce the integrity, reputation and values CCP Technologies Ltd. seeks to foster.
The following content is not permitted under any circumstances:
- content that has not been released to the market;
- abusive, profane or language of a sexual nature;
- content not relating to the subject matter of that blog, board, forum or site;
- content which is false or misleading;
- confidential information about CCP Technologies Ltd. or third parties;
- copyright or trade mark protected materials;
- discriminatory material in relation to a person or group based on age, colour, creed, disability, family status, gender, nationality, marital status, parental status, political opinion or affiliation, pregnancy or potential pregnancy, race or social origin, religious beliefs or activity, responsibilities, sex or sexual orientation;
- illegal material or materials designed to encourage law breaking;
- materials that could compromise the safety of any employee;
- materials which would breach applicable laws (Corporations law and regulations, ASX Listing and Market Rules, defamation, privacy, consumer and competition law, fair use, copyright, trade marks);
- material that would offend contemporary standards of taste and decency;
- material which would bring the Company into disrepute;
- personal details of Company directors, employees or third parties;
- spam, meaning the distribution of unsolicited bulk electronic messages; and
- statements which may be considered to be bullying or harassment.
If you have any doubt about applying the provisions of this policy, the CCP Technologies Ltd. Chief Executive Officer is the correct person to check with prior to using social media to communicate on behalf of the Company. Depending upon the nature of the issue and potential risk, it may also be appropriate to consider seeking legal advice prior to publication.
Appropriate authorisation must be obtained before a Restricted Person can use social media including but not limited to uploading content or speaking on behalf of CCP Technologies Ltd.
Statements or announcements cannot be made through social media channels unless authorised by the Chief Executive Officer. No Restricted Person may respond directly if approached by media for comment through social media and must refer the inquiry to the Chief Executive Officer.
No Restricted Person may comment outside his or her area of expertise.
Restricted Persons may only discuss publicly available information. Restricted Persons must not disclose confidential information, internal discussions or decisions of the board, employees, consultants or other third parties.
Information published should be accurate, constructive, helpful and informative. Restricted Persons must correct any errors as soon as practicable and not publish information or make statements which are known to be false or may reasonably be taken to be misleading or deceptive.
Restricted Persons must clear about professional identity, or any vested interests and must not use fictitious names or identities that deliberately intend to deceive, mislead or lie or participate in social media anonymously or covertly or via a third party or agency.
Restricted Persons should not express or publish a personal opinion on CCP Technologies Ltd. generally or about CCP Technologies Ltd. business via social media and should be mindful of market disclosure rules when discussing or commenting on Company matters. Generally, Restricted Persons should not express personal opinions on Company decisions or
CCP Technologies Ltd. business nor be critical of CCP Technologies Ltd. and its personnel. If it is not possible to separate official CCP Technologies Ltd. positions from personal opinions, Restricted Persons should consider using a formal disclaimer to separate interests.
Restricted Persons should be sensitive to the privacy of others. However, CCP Technologies Ltd. is not required to seek permission from anyone who appears in any photographs, video or other footage before sharing these via any form of social media if it is the copyright owner of the relevant image or footage.
CCP Technologies Ltd. will use its own intellectual property where possible and shall obtain prior consent where it is not the creator or copyright owner, to use or reproduce copyright material including applications, sound recordings (speeches, music), footage (cinematographic vision), graphics (graphs, charts, logos, clip-art), images, artwork, photographs, publications or musical notation. CCP Technologies Ltd.will also typically seek permission before publishing or uploading the intellectual property of a third party or before linking to another site or social media application.
Restricted Persons will not comment, contribute, create, forward, post, upload or share content that is scurrilous, malicious or defamatory.
Restricted Persons will endeavour to be courteous, patient and respectful of the opinions of others, including detractors and the discourteous.
Restricted Persons will be conscious of anti-discrimination laws and must not publish statements or information which may be discriminatory in a human rights sense.
Restricted Persons will remain mindful of language and expression and not lapse into excessive use of colloquialisms, having regard to an international audience.
State of Mind
Restricted Persons must not use social media when irritated, upset or tired.
Restricted Persons will should protect their personal privacy and guard against identity theft.
Modification and moderation
Restricted Persons will should ensure that any social media sites created or contributed to can be readily edited, improved or removed and appropriately moderated.
CCP Technologies Ltd. will endeavour to specify the type of comments and feedback that will receive a response and clearly communicate a target response time. Restricted Persons are required to make it easy for audiences to reach CCP Technologies Ltd. by publishing CCP Technologies Ltd. telephone number, generic email, LinkedIn, Twitter and Facebook accounts.
CCP Technologies Ltd. reserves the right, for legal compliance purposes, to monitor social media usage on its systems without advance notice and consistent with any applicable state, federal or international laws. CCP Technologies Ltd. may be legally required to produce logs, diaries and archives of social media use to judicial, law enforcement and regulatory agencies and will comply with any relevant requests. Restricted Persons and other users should govern themselves accordingly.
The Chief Executive Officer has responsibility for enforcing the Policy and may delegate those responsibilities to the Company Secretary from time to time. Restricted Persons will should seek advice or authorisation from the Chief Executive Officer, on using social media or if unsure about applying the provisions of this policy, should register social media accounts with the Company Secretary, understand and comply with the provisions in this policy and any End User Licence Agreements, seek training and development for using social media and maintain records of email addresses, comments, ‘friends’, followers and printed copies or electronic ‘screen grabs’ when using externally hosted sites to the extent practicable. Each Restricted Person is responsible for adhering to the CCP Technologies Ltd. Social Media Policy.
All content published or communicated by or on behalf of CCP Technologies Ltd. using social media must be recorded (including the author’s name, date, time and media site location) and kept on record. CCP Technologies Ltd. will actively monitor social media for relevant contributions that impact on the company, its officers, operations and reputation.
CCP Technologies Ltd. employees breaching this policy may be the subject of disciplinary action, performance management or review. Serious breaches may result in suspension or termination of employment or association. CCP Technologies Ltd. reserves the right to remove, where possible, content that violates this policy or any associated policies.
The requirements imposed by this Policy are separate from, and additional to, the legal prohibitions in the Corporations Act .
Directors, officers and employees should be aware that they can be charged with criminal offences under the rules and regulations associated with the prevention of market manipulation, false trading, market rigging and misleading and deceptive conduct, all of which apply at law regardless of this Policy.
Failure to comply with this Policy is considered cause for termination of employment.
This policy will be published and promoted to CCP Technologies Ltd. personnel through www.ccp-technologies.com and the CCP Technologies Ltd. Policy Manual.