ovantellc.com

Confidentiality

No employee may use Confidential Information (as defined below) of the Company (or its suppliers, customers or vendors) to personally benefit himself/herself or others besides the Company. In addition, employees must not disclose such information to anyone, inside or outside the Company (including to family members), except on a strict need-to-know basis and under circumstances that make it reasonable to believe that the information will not be used or misused or improperly disclosed by the recipient. Employees may disclose Confidential Information if obligated to do so by federal, state, or local law.

Confidential Information includes, but is not limited to, Proprietary Information (as defined in the subsection titled “Protection and Proper Use of Company Assets”), any documents, knowledge, data or other information relating to the business, organization, management, employees, operations, financial condition, results of operations, sales, marketing, customers, contracts, bidding information or analysis, suppliers, or plans, strategies and prospects of the Company, or any other person or company with which the Company is transacting business, which the Company has not intentionally made or consented to being made publicly available.

Employees should assume that all documents, knowledge, data, or other information of the type described above is Confidential Information, unless the employee has specific knowledge or instructions that it is not. All Confidential Information is the property of the Company and may not be removed from the premises of the Company without authorization. If an employee leaves the Company for any reason, he/she must return all Confidential Information, both originals and copies, in his or her possession or under his/her control. The obligation to preserve Confidential Information continues even after employment ends.

Nothing in this Code is intended to interfere with or restrain any non-management employee’s right to share information regarding his/her wages, hours, or other terms and conditions of employment in the exercise of any rights provided by the National Labor Relations Act. Further, this Agreement shall not interfere with or restrain any employee’s right to report unlawful actions to any law enforcement or administrative agency or to participate in any such agency’s investigation.

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