Chickasaw Capital Management, LLC

Chickasaw Securities, LLC

Acceptable Use Policy

 

Overview

This Acceptable Use Policy is in place to assist in protecting from illegal or damaging actions by individuals, either knowingly or unknowingly.

 

Internet/Intranet/Extranet-related systems, including but not limited to computer equipment, software, operating systems, storage media, network accounts providing electronic mail, Internet browsing, and FTP, are the property of Chickasaw Capital Management, LLC and Chickasaw Securities, LLC (together, “Chickasaw”). These systems are to be used primarily for business purposes.

 

This policy outlines the acceptable use of computer equipment at Chickasaw. These rules are in place to protect the employee and Chickasaw. Inappropriate use exposes Chickasaw to risks including virus attacks, compromise of network systems and services, and legal issues.

 

It is the responsibility of all employees, contractors, consultants, temporary, and other workers at Chickasaw and its subsidiaries (collectively known as “Staff”), to know these policies and guidelines, and to conduct their activities accordingly.

 

Scope

This policy applies to the use of information, electronic and computing devices, and network resources to conduct Chickasaw business or interact with internal or external networks and business systems, whether owned or leased by Chickasaw, the employee, or a third party. All Staff are responsible for exercising good judgment regarding appropriate use of information, electronic devices, and network resources in accordance with Chickasaw policies, standards, local laws, and regulations.

 

General Use

 

·       Chickasaw proprietary information stored on electronic, computing, and storage devices, whether owned or leased by Chickasaw, the employee or a third party, remains the sole property of Chickasaw. Staff must ensure, through legal or technical means, that proprietary information is protected.

·       Staff have a responsibility to promptly report the theft, loss or unauthorized disclosure of Chickasaw proprietary information or equipment, including but not limited to mobile devices, laptops, and storage devices.

·       Staff may access, use or share Chickasaw proprietary information only to the extent it is authorized and necessary to fulfill assigned job duties.

·       Staff are responsible for exercising good judgment regarding the reasonableness of personal use.     

·       Staff should have no right to expect privacy when using Chickasaw systems or devices. Chickasaw may monitor equipment, systems and network traffic at any time.

·       Chickasaw reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.

Unacceptable Use

 

Under no circumstances are Staff authorized to engage in any activity that is illegal under local, state, federal or international law while utilizing Chickasaw-owned resources.

 

The following activities are strictly prohibited, with no exceptions:

 

·       Violations of the rights of any person or company protected by copyright, trade secret, patent or other intellectual property, or similar laws or regulations, including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by Chickasaw.

·       Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books or other copyrighted sources, copyrighted music, and the installation of any copyrighted software for which Chickasaw or the end user does not have an active license is strictly prohibited.

·       Accessing data, a server or an account for any purpose other than conducting Chickasaw business, even if you have authorized access, is prohibited.

·       Exporting software, technical information, encryption software or technology, in violation of international or regional export control laws, is illegal. The appropriate management team should be consulted prior to export of any material that is in question.

·       Introduction of malicious programs into the network or server (e.g., viruses, worms, Trojan horses, e-mail bombs, etc.).

·       Revealing your account credentials to others or allowing use of your account by others.

·       Using a Chickasaw computing asset to actively engage in procuring or transmitting material that is in violation of sexual harassment or hostile workplace laws in the user's local jurisdiction.

·       Making fraudulent offers of products, items, or services originating from any Chickasaw account.

·       Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient or logging into a server or account that the employee is not expressly authorized to access, unless these duties are within the scope of regular duties. For purposes of this section, "disruption" includes, but is not limited to, network sniffing, pinged floods, packet spoofing, denial of service, and forged routing information for malicious purposes.

·       Circumventing user authentication or security of any host, network or account.

·       Introducing honeypots, honeynets, or similar technology on the Chickasaw network.

 

Email and Electronic Communications

 

Chickasaw provides email primarily for business purposes.  The following prohibitions apply to all Staff with a Chickasaw email account.

 

·       Sending unsolicited email messages, including the sending of "junk mail" or other advertising material to individuals who did not specifically request such material (email spam).

·       Any form of harassment via email, telephone or paging, whether through language, frequency, or size of messages.

·       Unauthorized use, or forging, of email header information.

·       Solicitation of email for any other email address, other than that of the poster's account, with the intent to harass or to collect replies.

·       Creating or forwarding "chain letters", "Ponzi" or other "pyramid" schemes of any type.

·       Use of unsolicited email originating from within Chickasaw' networks of other Internet/Intranet/Extranet service providers on behalf of, or to advertise, any service hosted by Chickasaw or connected via Chickasaw's network.

 

 

Blogging and Social Media

 

When using company resources to access and use blogs and social media, Staff must realize they represent Chickasaw.  Chickasaw has adopted social media policies in the Supervisory Procedure Manual for Chickasaw Capital Management, LLC and the Supervisory Procedure Memorandum for Chickasaw Securities, LLC.  Staff are required to comply with these policies whether using Chickasaw’s property and systems or personal computer systems.

 

Exceptions

 

Any exception to the policy must be approved by the CCO.

 

Non-Compliance

 

Any Staff found to have violated this policy may be subject to disciplinary action, up to and including termination of employment or contract.

 

Acknowledgement

 

By using this network, you acknowledge having thoroughly read and understood the foregoing policy and pledges to abide by and comply with the foregoing policy.