CONFIDENTIALITY
POLICY SCOPE
To establish the importance of confidentiality and discretion with respect to the
disclosure of confidential information.
POLICY AND POLICY DEFINITIONS
Employees need to make sure they do not disclose or share confidential
information.
“Confidential information” means any information that concerns ICES, Inc., its
affiliates, and/or its employees, clients, or any information considered to be
proprietary and treated as confidential, or that is under an obligation to keep
confidential.
Such Information, regardless of how transmitted or maintained, includes
but is not limited to:
Employee Information: including former, existing, or potential employees’
information
Client Information: including pricing, trade secrets, confidential knowledge,
data, or other proprietary information relating to products, processes, know-
how, designs, formulas, developmental or experimental work
Statements/reports regarding ICES, Inc. and/or any affiliated entity’s financial
condition
Payments made to or expenses incurred by ICES, Inc., its affiliates, and/or any
of its employees
Discounts given by ICES, Inc., and/or its affiliates, to clients
Business strategies, plans, proposals, marketing, or advertising plans
Other information or materials marked as being confidential, whether
constituting a trade secret or not, and whether proprietary or not, which is of
value to ICES, Inc. and/or its affiliates
DISCIPLINARY CONSEQUENCES
Any violation of this policy may result in disciplinary action up to and including
termination of employment. It should be noted that nothing in this policy should
be construed as prohibiting discussions regarding wages between and among non-
managerial personnel.