Page 4

M. Regulatory Matters

1. For regulatory reasons,  employees are prohibited from distributing social media disclosures or engaging in online discussion that could be seen by regulators as advancing the interests of the  to benefit their  . Employees are prohibited from leveraging  , its regulated business, to advance the business interests of its unregulated business and employees are expected to comply with this regulation in all their social media disclosures.

2. Employees are responsible for knowing and following the  , which was created to help employees adhere to all laws, regulations, and other legal requirements that apply to our business. Employees should become familiar with the legal and regulatory requirements that apply to their job and to the jobs of any employees that report them. Employees are expected to seek appropriate legal guidance and training as necessary in matters that relate to their responsibilities. 

3. If you believe any of the guidance in this policy conflicts with  let the guidance in the  be the prevailing policy that guides your behavior.

N. During Emergencies

1. As evidenced by FEMA's adoption, social media tools are becoming increasingly important in local and incidental crisis and emergency management communications. Nevertheless, even in times of crisis, disaster or emergency, only  Employees with the authority to speak on behalf of  are permitted to do so.

2. If a employee who is not authorized to speak on behalf of the company has valuable information that could benefit those affected by a crisis, disaster or emergency, they may share that information via social media channels, so long as they include a disclaimer and do so in accordance with the guidelines of this policy.

3. All employees may use social media channels to extend the reach of official  communications. While only those officially designated by  are authorized to speak on behalf of the company, all employees are encouraged to share official  content via social media channels, particularly during a crisis, disaster or emergency, so as long they take the time to verify that the information they are sharing is, in fact, official  content. For example, before sharing a link,  employees should always verify that (1) the source of the information is legitimate and (2) that the link they are sharing transits to information hosted at  domain. 

4. If an  employees decides to endorse or republish someone else’s social media disclosure about  ,  -related topics or emergency relief information,  employees must first verify that the social media disclosure they are republishing was distributed by the designated source. For example, before retweeting someone else’s tweet, verify that the Twitter user cited did, in fact, distribute that tweet. There have been numerous cases where false tweets attributed to news sources were redistributed by other Twitter users, promoting misinformation and confusion.

O. Penalties

1. Failure to comply with these social media policies may result in:

a. Withdrawal, without notice, of access to information and/or information resources.

b. Disciplinary action, up to and including termination.

c. Civil or criminal penalties as provided by law.

2. Penalties against violating contractors and agencies may, at the company’s discretion, be enforced against the contractor or agency's primary point of contact at  and/or the  employee to which the primary point of contact reports.

P. References

1. IBM Social Computing Guidelines

2. AP Stylebook 2009, Briefing on Media Law

3. Conduct on the Pentagon Reservation, Title 32, Code of Federal Regulations, Part 234 [PDF]

4. Use of Social Media at FEMA

5. Social Media Business Council, Disclosure Best Practices Toolkit

# # # 

The recommendations and information provided herein or available through these recommendations may include inaccuracies or typographical errors. Changes are periodically made to the many of the sites/services and to the information cited therein. Advice received via these recommendations should not be relied upon for personal, legal or financial decisions and you should consult the Company representative for appropriate professional service for specific advice tailored to your situation. 

Schwartzman & Associates, Inc. (Consultant) and/or its respective partners, agent, suppliers, etc, make no representations about the suitability, reliability, availability, timeliness, lack of viruses or other harmful components and accuracy of the information, software, products, services and related information provided in these recommendations. All such information, recommendations, software, products, services and related graphics are provided “as is” without warranty of any kind. Consultant and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, software, products, services and related graphics, including all implied warranties and conditions of merchantability, fitness for a particular purpose, workmanlike effort, title and non-infringement. Consultant has, to the best of his knowledge, taken appropriate measures and precautions for such. 

These recommendations may contain links to other websites operated by third parties (“Linked sites”). User acknowledges that when they click on any such link to visit a linked site, Consultant cannot be held liable for any unintended consequence, malicious or otherwise, that may or may not occur. User acknowledges that Consultant neither endorses nor is affiliated with the linked sites and is not responsible for any content of any linked site or any link contained in a link site, or any changes or updates to such sites. User acknowledges that Consultant is providing information only as recommendations, and assumes full responsibility for verifying the appropriateness on any of these recommendations.

In no event shall Consultant and/or its suppliers be liable for any direct, indirect, punitive, incidental, special, consequential damages or any damages whatsoever including without limitation, damages for loss of use, data or profits, arising out of or in any way connected with the use or performance of these recommendations. 

Learn Social Media Policy Development

 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. Follow him @ericschwartzman

Social Media Policy Template by Eric Schwartzman is licensed under a Creative Commons Attribution-ShareAlike 3.0 Unported License.
Based on a work at www.socialmediapolicytemplate.com.