Social Media Policy

Scope

This Global Policy on Social Media (Policy) is a Corporate Compliance Policy and applies to all Falcon Safety Products employees, employees of any Falcon Safety Products subsidiary, assigned workers, as well as to third parties performing services on Falcon Safety Products’ behalf (hereinafter collectively referred to as “You”). For employees, compliance with this Policy is an expectation of employment (subject to local legal requirements). For assigned workers and third parties, compliance with this Policy is a condition of access to Falcon Safety Products facilities and resources, and of being permitted to perform services for Falcon Safety Products.

Definitions for capitalized terms used in this Policy may be found at the end of the Policy.

Purpose

Falcon Safety Products recognizes that Social Media tools such as blogs, micro-blogs, online forums, content-sharing websites and other digital channels established for online interaction and connection are increasingly used to:

  • Promote Falcon Safety Products to colleagues, customers, the media and other Falcon Safety Products stakeholders; and/or
  • Share personal opinions and participate in online dialogue as individuals.

The purpose of this Policy is to establish standards and expectations regarding any Falcon Safety Products-related use of Social Media. Falcon Safety Products’ commitment to being direct supports open communications provided such communications adhere to this Policy.

Policy Statement

You must adhere to the following when engaging in Social Media:

Appropriate Use of Information Technology Resources. Falcon Safety Products’ Information Technology (IT) resources are company property dedicated to achieving Falcon Safety Products’ business objectives. Inappropriate use is not acceptable. This includes, but is not limited to, using Falcon Safety Products’ IT assets to post offensive material on content-sharing websites, publish defamatory remarks about colleagues or customers on web forums or blogs, and leaking Confidential Information.

Speaking On Behalf of Falcon Safety Products. Blogging and other online dialogue are far-reaching forms of communication; distribution is meant for a vast public audience. Information purported to be published by Falcon Safety Products contained within blogs and other websites could have a negative impact to Falcon Safety Products  and our stakeholders, with potential legal implications. Unless You have successfully completed Falcon Safety Products’ Social Media training courses and have been certified to speak on behalf of the company via Social Media, You shall never claim to be speaking on behalf of Falcon Safety Products or expressing an official company position in such communications.

Ethical Conduct. You shall not conduct activities that are illegal or contrary to Falcon Safety Products’ Code of Conduct, Privacy Statement Regarding Customer and Online User Information, or other Falcon Safety Products policies. Always respect the dignity and privacy of colleagues, customers, other Falcon Safety Products stakeholders, and Falcon Safety Products competitors. Harassing, intimidating, offensive, abusive, threatening, menacing or hostile content communicated through blogs and other online communications is prohibited. Data related to others, including, but not limited to, personal details and pictures, shall only be posted with that party’s consent.

Transparency of Origin. You shall disclose Your connection to Falcon Safety Products in all communications with customers, the media or other Falcon Safety Products stakeholders when speaking on behalf of Falcon Safety Products (if authorized to do so) or discussing or recommending Falcon Safety Products or its products or services (even when doing so in Your personal capacity). You must also provide Your Falcon Safety Products contact information upon request. Unless you are certified to speak on behalf of Falcon Safety Products, You should make it clear that the opinions are Yours alone and do not necessarily reflect Falcon Safety Products’ views or positions.

Accurate Information. Never knowingly communicate information that is untrue or deceptive. Communications shall be based on current, accurate, complete and relevant data. Falcon Safety Products will take all reasonable steps to assure the validity of information communicated via any channel but it is Your responsibility to assure accuracy in the first instance. Anecdotes and opinions shall be identified as such.

Protection of Confidential Information. You shall protect Confidential Information as such information represents one of Falcon Safety Products’ most important assets. It is never appropriate to share, post, publish, or otherwise disclose Confidential Information unless You are explicitly authorized to do so. You must respect securities and financial disclosure laws, and must not post or otherwise comment in any capacity on Confidential Information that may be considered financial information (such as earnings, future business performance, business plans or prospects).

Accountability. You will be held accountable for the information You share in online activities. Be careful what You share, publish, post, or otherwise disclose. You are personally responsible for what You share and should remember that anything You post may be public for an indefinite period of time (even if You attempt to modify or delete). Try to ensure Your online communications reflect Falcon Safety Products’ brand attributes of openness, responsiveness, integrity and optimism.

Procedures and Training

Falcon Safety Products has adopted training guideline materials to assist You in complying with this Policy. Falcon Safety Products’ Marketing Team will deliver role-appropriate guidelines.

Asking Questions

You are encouraged to ask any questions You may have about this Policy. To learn more about how to use Social Media in accordance with this Policy, contact Falcon Safety Products’ Social Media & Communities Team. You may also ask Your leader, or Human Resources representative, or contact the Marketing Communications Department.

Reporting and Investigation

It is very important that You immediately report any suspicious behavior regarding Falcon Safety Products employees or Falcon Safety Products third parties. To report known or suspected violations of this Policy, contact your leader or another member of management, or your Human Resources representative. Reports made via the telephone or the web-based forms may be made anonymously where permitted by local law. Anyone reporting a suspected or actual violation of this Policy is protected from retaliation under Falcon Safety Products’ Code of Conduct. All good faith allegations of violations of this Policy will be fully and confidentially investigated pursuant to Falcon Safety Products’ Global Policy on Raising and Investigating Potential Ethics & Compliance Violations. You are required to cooperate with all investigations of alleged Policy violations.

Discipline and Other Consequences

Employees who violate this Policy will be subject to appropriate disciplinary action or other remedial measures up to and including termination of employment if warranted under the circumstances and permissible under applicable law. Assigned workers and third parties who violate this Policy are subject to being denied access to Falcon Safety Products facilities, personnel and assets, and permission to perform services on Falcon Safety Products’ behalf.

Waivers

The provisions of this policy cannot be waived. Falcon Safety Products management does not have the authority to approve waivers to this Policy.

Revision and Revocation

This Policy is not a contract between Falcon Safety Products and any employee, assigned worker, or third party. This Policy may be revised or revoked by Falcon Safety Products at any time, without advance notice or cause.

Local Policies and Procedures

Falcon Safety Products operates in many countries and it is Falcon Safety Products’ intention to comply with all applicable legal requirements. Accordingly, if a provision of this Policy conflicts with applicable local legal requirements, Falcon Safety Products will follow the local legal requirement (provided the local requirement does not conflict with U.S. law). In addition, Falcon Safety Products may adopt regional or country-specific policies on this subject to accommodate local conditions or legal requirements, and will inform employees in the applicable region or country of the terms of any such policy.

Definitions

Confidential Information – Important or valuable business information that is not available to the public. It includes trade secrets and other intellectual property that has been developed, licensed or acquired by Falcon Safety Products. It can also include information of customers, business partners or others that has been disclosed to Falcon Safety Products under obligations of confidentiality. Examples include unannounced financial information, strategic business plans, unannounced product or services and solutions offerings, planned or contemplated mergers or acquisitions, lawsuits and other legal proceedings, product design and technical knowledge, customer and team member personal information.

Social Media – Web-based technologies used to broadcast messages and participate in dialogues. Examples of Social Media software applications on the Internet include social networking applications such as Facebook; video-sharing applications such as YouTube; micro-blogging applications such as Twitter; collaboration applications such as Wikipedia; and other Falcon Safety Products’ official brand  blogs. No examples of Social Media applications used within Falcon Safety Products are used at this time.

Global Policy on Social Media Effective Date: November 30, 2010