PROTECTING GS GROUP ASSETS

A. Intellectual property
B. Responsible use of company IT
C. Confidentiality and data protection
D. ControllershipTHE

Proper protection and use of company resources/assets is the responsibility of each employee. While personal use of certain resources is sometimes permissible, we should never abuse this privilege or assume that we have a right to privacy when using these resources.

6A. Intellectual property
Intellectual property (IP) includes all patents, trademarks, design rights, copyrights or other know-how owned by GS Group. By protecting our IP and the IP rights of others, we ensure that the brands, designs and overall value of our company remain safe.

What does it mean for me?

DO

DON’T

  • identify and protect GS Group’s IP
  • ensure that the ownership of new IP is
    agreed on upfront when working with
    another company or asking a third party
    to work on our behalf
  • respect valid patents, copyrighted
    materials and the protected IP of others
  • comply with the guidelines for use of GS
    Group’s primary trademarks and trade
    names
  • use or copy the IP rights of others
  • disclose GS Group proprietary
    information to others
  • allow third parties to use our brands or
    any other IP without consulting your local
    legal department or group lega
  • introduce a new product or service, or
    new product or service name, before
    checking for patent or trademark
    infringement
  • threaten anyone suspected of infringing
    any GS Group IP without first consulting
    with the company’s chief compliance
    officer
 

6B. Responsible use of company IT
Company computers are intended for company use and limited personal use, not for work outside the office. GS Group reserves all legal rights to access, review and use all communications, records and information created at work or with company resources, including things such as intranet or Internet activities, email, voicemail and telephone conversations and computer files.

What does it mean for me?

DO

DON'T

  • use company resources appropriately
  • protect company assets from misuse,
    theft and waste
  • ensure that hardware such as laptops,
    phones and other handheld devices are
    never left in public or unsecured locations
  • provide personal employee information
    to anyone outside of GS Group without
    proper authorization
  • misuse company resources, including
    telephone, email or Internet access for
    personal activities
  • share user IDs or passwords
  • install any non-GS Group approved or
    unlicensed software on your computer or
    download, store or pass on inappropriate
    material
  • connect any non-GS Group or
    unauthorized device to your computer or
    to the network
 

6C. Confidentiality and data protection
GS Group respects the confidentiality of our employees’ personal information - we ensure it is protected and handled responsibly. This means that access to personal records should be limited to company personnel who have authorization and a clear business need for such information. Employees who have access to personal information must treat it confidentially.

 

DO

DON'T

  • ensure that data is securely stored and
    disposed of properly
  • keep customer and employee information
    secure and use them only for the purpose
    for which they were obtained.
  • collect only relevant, accurate and
    updated customer or staff information
  • release information without ensuring
    that the person you are providing it to
    is authorized to receive it and, where
    necessary, that it has been encrypted in
    accordance with GS Group policy


6D. Controllership
Robust controllership processes are needed to allow our management to make well-informed decisions regarding our operations and to ensure integrity in disclosures to government agencies and the public.

What does it mean for me?

DO

DON'T

  • comply with applicable internal
    and external accounting principles,
    standards and regulations affecting
    accounting and financial reporting
  • make certain that financial and nonfinancial
    information and operating
    metrics are reported accurately
  • keep complete and factual records
    reflecting all business transactions,
    expenditures and expenses
  • protect company assets (physical,
    financial and IP) from unauthorized
    access, use or loss
  • comply with the company’s delegation
    of authority with respect to the approval
    and execution of transactions and
    documents
  • cooperate and openly communicate with
    independent auditors by responding
    to requests for information in a
    timely manner. Avoid any action that
    may fraudulently influence, coerce,
    manipulate or mislead auditors in their
    work
  • safeguard documents that may be
    relevant to pending or reasonably
    foreseeable litigation, audits or
    investigations, as directed by the
    company’s chief compliance officer
  • provide/produce financial results that
    lack transparency or do not appear to
    reflect underlying business performance
  • provide/produce distorted financial
    records such as inflated travel expense
    reports, inaccurate overtime reports or
    invoices
  • disclose to individuals outside the
    company financial information or other
    information concerning the company’s
    past or anticipated results of operations
    unless such information has previously
    been disclosed in an authorized press
    release or public report
  • discourage suggestions to improve
    processes and controls to protect assets
    from risk of loss
  • attempt to bypass internal authorization
    controls
  • allow a third party vendor to begin work
    before an authorized purchase order has
    been issued
  • use alternate accounting treatments
    without specific justification
  • destroy documents (including e-mail)
    without determining whether the
    documents are subject to legal
    preservation requirements

 

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