Social Media in the Workplace AUSTRALIA 1 POLICY STATEMENT William Demant Holding Pacific Region hereafter referred to as The Company recognises that the use of social media is increasingly widespread and has significant implications on the way that information is disseminated. This policy sets out the requirements for all Company employees in the use of Social Media, and is underpinned by two common values of our society - Respect and Integrity. 2 APPLICABLE TO This policy applies to all individuals employed with the Company or contractors engaged directly with the Company, including consultants and third parties whom have access to the Company s electronic communication systems and equipment. The employment entities are as listed: Oticon Australia, Sonic Innovations, Audmet Australia and Interacoustics. The policy also applies to the use of social media for both business and personal purposes, whether during office hours or otherwise. The policy applies regardless of whether the social media is accessed using the Company s IT facilities and equipment or equipment belonging to employees. Term Social Media LinkedIn Definition Refers to any type of interactive media that allows parties to communicate instantly with each other or to share data in a public forum. It includes social networks such as, but not limited to Facebook, LinkedIn, Instagram, Twitter, video/photo sharing, chat rooms, online forms and discussion groups, wikis, blogs and micro-blogging tools and other websites facilitating the publishing of user- generated content Is considered to be social media however it is permissible to use this site as a business networking and recruitment tool 3 ROLES AND RESPONSIBILITIES Employees Employees of, and contractors engaged directly or indirectly to, the Company have the obligation to: Comply with this policy at all times Take full responsibility for their use of social media for personal activities at the office or using the Company s computers, networks or other IT resources or communications systems All employees are required to conduct themselves in a manner which respects the rights and welfare of other members of the Company and to show competence, care, good faith and compliance with instructions, policies and procedures in relation to accessing Social Media Page 1 of 5
Seek clarity from their manager regarding any statement or posting where there is a cause for concern or uncertainty about the appropriateness of the message. Respect copyright laws and fair use of copyrighted material. All employees are expected to attribute work to the original author or source wherever possible Employees must not at any time: Disclose, post, share or otherwise divulge information belonging to the Company which is not otherwise publicly available. This includes but is not limited to commercially sensitive information, information regarding our customers, and any confidential information which you may have access to in your position Comment on, post, store or share information about business-related matters which may cause damage to the Company and/or our reputation in any way Criticising or arguing with customers, employees or rivals Disparage or otherwise adversely comment or speak about the Company, our customers, our employees, contractors or others connected with the Company. This also includes supporting others making such comments Post images that are inappropriate or links to inappropriate content Breach confidentiality or data protection laws, or infringe any contractual obligations Breach copyright, or other laws or ethical standards Do anything that could be considered discriminatory against, or bullying or harassment of, any individual Employees should also be mindful that making comments or statements about others may result in further legal consequences outside of the employment relationship for which the Company bears no responsibility. Manager Advise the People & Culture team of any breaches to policy People & Culture Team Advise the General Manager / Managing Director if a breach has occurred that results in legal action or is a significant risk to the Company Assist Managers to address any breaches of policy Managing Director(s) and Marketing Manager Are the only authorised spokesperson(s) to make comment on social media in response to any content or otherwise Company The Company seeks to protect its commercial interests, reputation and brand in the marketplace, team members, and customers within the social media environment that may pose risks to the Company s confidential and proprietary information and may jeopardise the Company s compliance with its legal obligations. The Company does not seek to impinge on the rights of employees to use Social Media in a private capacity in their own time but requests that the Company s reputation is respected during online transactions. Page 2 of 5
The Company reserves the right to review, vary, add to, substitute or withdraw this policy from time to time in its absolute discretion. It will also be reviewed regularly to ensure compliance with legal and/or regulatory requirements. 4 GUIDELINES FOR ACCESSING SOCIAL MEDIA Accessing social media at work Whether using Company resources or their own computers or devices to access social media websites while they are at work, employees must limit this to their official rest breaks such as their lunch break or times when they are not on duty, and ensure that it does not interfere with their work responsibilities or productivity. Such use of social media must not involve unprofessional or inappropriate content. Specifically, the circulation of chain letters or other spam is never permitted, nor is the circulation or posting of commercial, personal, religious or political solicitations, or promotion of external organisations unrelated to the Company s business. When disclosing or discussing information about the Company, please ensure that it is limited to publicly available information only. Use of Social Media for Business Purposes If, as part of their duties, an employee is required to speak on behalf of the Company in a social media environment, prior approval for such communication must be obtained from their line Manager, who may require them to undergo training before such activity and may impose certain requirements and restrictions with regard to these activities. Similarly, if any employee is contacted for comments about the Company for publication anywhere, including in any social media outlet, the inquiry must be directed to the Company s Managing Director or Marketing Manager. Employees must NOT respond without prior written approval. The use of social media for business purposes is subject to the remainder of this policy. Inappropriate Use of Social Media Employees are legally responsible for their social media postings and may be liable if these are found to be defamatory, constitute harassment, or be in violation of any laws. Social media must never be used in a way that breaches any other Company policies or contractual obligation. If an internet post would breach any Company policies or contractual obligation in another forum, it will also breach them in an online forum. If there is any uncertainty or concern about the appropriateness of any statement or posting, employees should refrain from making the communication until they have discussed it with their line Manager, Managing Director or Marketing Manager. Page 3 of 5
5 COMPANY SPOKESPERSON The Company will have dedicated authorised spokespersons to comment in any public forum or social media such as Managing Directors or Marketing Manager. Authorised spokespersons must: disclose that they are an employee of the applicable employment entity, and use only their own identity, unless authorised to use an approved official account or avatar ensure that all content published is accurate and not misleading and complies with all relevant Company policies and other relevant requirements comment only on their area of expertise and authority ensure comments are respectful and lawful adhere to the terms of use for using the social media platform or website, and adhere to legislation including copyright, privacy, defamation, contempt of court, discrimination, harassment and any other applicable laws, and the Company s Privacy Policy. respect copyright laws and fair use of copyrighted material. All employees are expected to attribute work to the original author or source wherever possible Authorised spokespersons must not: post or respond to material that is disrespectful, defamatory or otherwise unlawful use or disclose any confidential or secure information comment or post any material that might otherwise cause damage to the Company s reputation or bring it into disrepute. 6 BREACH OF POLICY All employees are required to adhere to this policy, and any breaches of this policy may result in disciplinary action up to and including termination of employment. Disciplinary action may be taken regardless of whether the breach is committed during working hours or in a private capacity, and regardless of whether Company equipment or facilities are used for the purpose of committing the breach. Any employee suspected of committing a breach of this policy will be required to co-operate with any investigation. Employees may be required to remove internet postings which are deemed to constitute a breach of this policy. Failure to comply with such a request may in itself result in disciplinary action. Serious breaches of this policy, such as incidents of bullying of employees or damage to the Company as a result of social media activity may constitute gross misconduct and lead to summary dismissal. Page 4 of 5
7 RELATED RESOURCES, TOOLS AND LINKS Computer, Email and Internet Use Policy Diverse and Respectful Workplace Policy Policy History The Company may vary the policy or procedure at its discretion and advise the appropriate employee(s) of the changes. Date Introduced: 31 August 2015 Version number: Version 1.1 Functional Owner: DGS People & Culture Policy Approval: Pacific Management Group Date of Next Review: August 2016 Page 5 of 5