Social Media Policy – Page 2

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E. Disclosure and Transparency

1. Since reputations are built on trust, employees are strongly requested to disclose their identity and affiliation to our organization whenever discussing company or company -related topics via social media channels, so long as they can do so without forfeiting their legal rights to bargain collectively or engage in concerted or protected activities under the NLRA.

a. Be aware of your relationship to our organization in all social media disclosures. Nothing gains more notice in social media channels than honesty — or dishonesty. If you have a vested interest in something you are discussing, be the first to acknowledge that relationship and point it out, so long as you can do so without forfeiting your legal rights to engage in concerted or protected activities related to their employment .

b. Comply with all laws and regulations regarding disclosure of your identity.

c. Our organization believes in transparency and honesty. Employees are encouraged to use their real name and identify that they work for in any social media disclosure that involves company or company -related topics. The use of pseudonyms and aliases are strongly discouraged.

d. Never represent yourself to be anyone other than who you really are, so long as you can do so without forfeiting your legal rights to engage in concerted or protected activities under the NLRA.

e. Be consistent on all the profile pages of your social media accounts. Conflicting information damages your credibility, and could also adversely impact ’s reputation. New employees who intend to use social media to discuss our organization or organization -related topics are encouraged to update their profile pages to reflect these guidelines.

f. Employees are responsible for making sure that any agencies, contractors or vendors they are managing disclose their relationship with our organization in their social media disclosures. Agency personnel, contractors and vendors are prohibited from representing themselves as employees.

2. Whenever commenting on company or company -related topics via social media channels, employees are requested to:

a. Use a method of disclosure that makes it easy for the average reader to understand their position, avoid jargon or ambiguous language and always provide a functional means by which you can be contacted in a timely manner based on the nature of your social media disclosure. Misinformation has the potential to spread quickly online and it is our intention to limit the use of technical or ambiguous language that could be misinterpreted by others. The failure to reply to legitimate questions which arise from comments made by company employees in social media channels, particularly by employees who instigated a conversation, could also result in a negative impressions of our company, products or services. Employees who choose to engage in social media channels about our company or company-related topics are required to monitor their feedback and use their best judgment to respond appropriately when warranted.

b. Employees may only mention our organization's official corporate policies in their social media disclosures when those policies are publicly available on the Internet, and may only do so if they include a link to that policy in their disclosure, so long as they can do so without forfeiting their legal rights to bargain collectively or engage in concerted or protected activities under the NLRA.

c. If an employee chooses to share an opinion on company policy, they may do so only if they precede their social media disclosure with a disclaimer acknowledging that their personal opinion does not necessarily reflect the opinion of their employer. (See section K. Disclaimers) This requirement is not meant to interfere with their legal rights to legal right to bargain collectively or engage in concerted or protected activities under the NLRA, but rather to ensure that others can easily distinguish the official position of organization or our organization's management from those of our employees.

3. When engaging in discussion with others on company or company -related topics via social media channels, and so long as they can do so without forfeiting their legal right to bargain collectively or engage in concerted or protected activities under the NLRA, employees should:

a. Disclose their relationship to our organization , and ask those they are engaging with to disclose their relationships and affiliations as well.

b. Never ask someone else to make anonymous social media disclosures.

c. Never use their relationship to our organization exclusively for personal gain.

d. Never use services or technologies for bulk-posting social media disclosures. Bulk posting of comments to blogs and social networking services is an unethical practice known as comment spam, is disrespectful of our community's attention and strictly prohibited.

e. Employees are discouraged from engaging directly with minors via social media channels, and must always use extreme care if creating content intended to be consumed by minors.

4. When engaging external agencies, contractor or vendors, employees should:

a. Ask agencies, contractors and vendors to acknowledge their contractor relationship with in all their social media disclosures.

b. Publicly acknowledge when agencies, contractors or vendors fail to comply with these policies, and if necessary, take immediate corrective action.

c. Require agencies, contractors and vendors to enforce these requirements on their subcontractors as well.

d. Always discuss and secure formal agreement to these social media policies before entering into a business relationship with an agency, contractor or vendor.

e. Distribute this social media policy to all agencies, contractors and vendors whose business relationship with predates this policy and secure their formal agreement to abide by these guidelines.

5. Compensation and Incentives

a. Never pay bloggers or anyone else outside the organization to write endorsements of our company, product or services, or to create fake social media disclosures. Paying or compensating bloggers to generate endorsements without disclosing compensation is considered unethical by our company and a violation of the US Federal Trade Commission Guides Concerning the Use of Endorsements and Testimonials in Advertising .

b. Employees are restricted from distributing rewards, incentives, promotional items, gifts, samples or any other items exceeding $50 in value each without clearly disclosing the terms and conditions by which that compensation or incentive was distributed in a publicly accessible location on our organization's website.

c. Distributions of items, compensation or incentives worth more than $50 each should include a clear request that as a condition of acceptance, the recipient shall mention the terms and conditions by which they received the item, compensation or incentive in any social media disclosures they may choose to release.

d. Never purchase inbound links, never participate in link bartering exchanges and never use the promise of inbound links to try and convince individuals to create positive social media disclosures about or on behalf of our company .

F. Respectfulness

1. Employees should always be respectful of every individual’s legal right to express their opinions, whether those opinions are complimentary or critical. Our company recognizes and appreciates the rights of individuals to free speech. By respectfulness, we mean tolerance and consideration for the opinions and positions of others, whether they are in alignment or conflict with your own.

2. Whether officially authorized to speak on behalf of the company or not, employees may be seen by people outside of our company as representatives of our brand. Employees are encouraged to represent the core values of our organization whenever they make social media disclosures about our organization or organization-related topics.

3. Employees should always strive to add value to online conversations by advancing the dialogue in a constructive, meaningful way. By adding value, employees can effectively demonstrate respectfulness to those they engage via social media channels.

4. Harassment, threats, intimidation, ethnic slurs, personal insults, obscenity , racial or religious intolerance and any other form of behavior prohibited in the workplace is also prohibited via social media channels.

5. Employees who choose to make social media disclosures about topics relevant to our organization should always be aware that their disclosures are not private or temporary. Social media disclosures live online indefinitely, and employees should remember that they will be visible to a broad audience and possible even read out of context.

6. Always show proper consideration when discussing religion, politics or any other controversial issues that may provoke a charged, emotional response by demonstrating tolerance and patience and always strive to show compassion for alternate points of view.

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Learn Social Media Policy Development

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You are free to use this social media policy template as a starting point for the development of your own corporate social media policy, as long as you attribute include the following language with anchor text where ever you may publish it and as long as you share your policy, be it an exact copy of this policy or a derivative work, with who ever you share it with as well.

Attribution Text with Anchor Text Hyperlinks: This social media policy was developed using a social media policy template by Eric Schwartzman, a digital strategist specializing in online marketing, online communications and social media governance.