INTENT
Carraway Inc. requires all employees to handle any and all sensitive business information regarding confidential materials, pending business transactions, partnerships, sales, and acquisitions gained through the course of their regular job duties in a confidential and appropriate manner.
Employees agree that if confidential information is not effectively protected, the operations and reputation of Carraway Inc. may be threatened, and the company may suffer irreparably.
Employees of Carraway Inc. must keep all confidential information and relevant knowledge regarding the company confidential both during and after their term of employment. These practices have been adopted as they have been deemed essential to the protection of Carraway Inc.
DEFINITION
Confidential information means all information, whether reduced or not reduced to written or recorded form, whether marked as confidential or not, whether furnished by, received by, or accessible through Carraway Inc. or compiled, contributed, or developed by an employee, that is related to actual or anticipated business, research, development, and manufacturing of Carraway Inc., and that is not generally known to competitors of Carraway Inc., nor intended for general dissemination, and includes, but is not limited to:
Information relating or pertaining to computer software and documentation, products, inventions, prototypes, research and development, files, client and customer lists, client information, working papers, reports, mailing lists, procedures, manuals, pricing and billing information, budgets, projections, forecasts, employment records and data, terms of contracts and agreements to which Carraway Inc. is a party;
Business and strategic plans, investment policies, or business policies or practices, and trade know-how and secrets, whether disclosed to an employee by plans, drawings, reports, sketches, photographs, graphs, or other written materials or documents, by a conversation with Carraway Inc. employees or agents, by third parties to whom Carraway Inc. owes a duty of confidentiality, by observation or inspection of physical objects or displays, or by any other method; and
All objects, documents, and other materials which contain or otherwise reflect such information, and all analyses, compilations, studies, data, or other records or documents prepared by or for employees which contain or otherwise reflect such information, and any information, whether marked confidential or not, derived by examination, testing, or analysis of any such information.
GUIDELINES
In working for Carraway Inc., employees shall not divulge, disclose, provide, or disseminate confidential information to any third party not employed by Carraway Inc. at any time, unless Carraway Inc. gives written authorization. Furthermore, confidential information shall not be used for any purpose other than its reasonable use in the normal performance of employment duties for Carraway Inc.
Reasonable efforts will be made to limit access to confidential information to only those who need to know the information, and those persons will be advised that the information is to be kept confidential until it has been publicly disclosed by a Carraway Inc. spokesperson.
Insiders and employees having knowledge of undisclosed confidential information regarding Carraway Inc. or any third parties currently engaged in negotiations with Carraway Inc. to whom undisclosed confidential information may need to be disclosed are prohibited from trading securities of Carraway Inc. or of any such third party until the information has been fully disclosed and widely disseminated.
Employees who are neither official spokespersons nor permanently or temporarily designated spokespersons cannot, under any circumstances (including on a “no-names” or “off the record” basis), respond to inquiries from the investment community, the media, or securities regulators or stock exchanges, unless specifically asked to do so by an official spokesperson.