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SOCIAL MEDIA POLICY

Office of the General Counsel


Starr Companies

I.

INTRODUCTION

Starr International Company, Inc. and C. V. Starr & Co., Inc. along with their subsidiaries and affiliates
(collectively, the Company or Starr Companies) recognize that Internet based social media and
networking websites and online or electronic forums (Social Media) are increasingly used by individuals
to share personal opinions and participate in online dialogue. For this reason, we have created the Starr
Companies Social Media Policy (this Policy) to guide employee participation in Social Media, both
personally as well as when employees are acting in an official capacity on behalf of the Company. The
purpose of this Policy is to establish clear and reasonable guidelines and expectations regarding the
responsible use of Social Media by the Companys employees.
The term Social Media, as used herein, includes online content created by individuals or organizations to
broadly distribute news, information, images, video and other material, as well as websites designed to
connect people with common interests. Examples of Social Media sites include, but are not limited to, blog
sites, Facebook, LinkedIn, YouTube, Twitter, Flickr, Instagram, Yammer, Tumblr, Pinterest, Vine, Google Plus
and similar websites.

II.

SCOPE

This Policy applies to all employees of the Company without regard to (i) the time of day during which any
Social Media related activity is conducted; (ii) the location where any Social Media related activity is
conducted; or (iii) the equipment utilized to conduct any Social Media related activity.

III.

PERSONAL USE OF SOCIAL MEDIA AND UNAUTHORIZED REPRESENTATIONS

The Company respects the right of employees to use Social Media platforms for self-publishing and selfexpression related to personal matters (i.e., matters unrelated to work, the Company or the Companys
clients, business partners or employees) during personal time, while using their own technology resources,
and nothing in this Policy is intended or designed to infringe or restrict an employees right to do so under
applicable law. Moreover, employees shall be held personally responsible, and shall not be indemnified by
the Company, for any information they may share, post, publish or otherwise disclose on any Social Media
platform.
However, unless specifically authorized as part of an employees role at the Company, employees are not
permitted to state or claim they are speaking on behalf of or otherwise representing the Company. In
addition, when sharing, posting or publishing any information on a Social Media platform, an employee
must:

Make it clear that he or she is expressing his or her own views and opinions and not those of the
Company if such employee is identified as an employee of the Company;
Not disclose proprietary or sensitive information regarding the Company, which may include,
private, confidential or proprietary financial information unannounced planned or contemplated
mergers or acquisitions or other business transactions, lawsuits or legal proceedings, trade secrets,
corporate logos, trademarks and other intellectual property, or other private, confidential or
proprietary documents and information prepared or distributed by or relating to the Company, its
current and former employees, policyholders, customers, clients, vendors or business partners;

IV.

Not use the Companys logo or branding without prior authorization from the Companys
Communications and Marketing Department and Office of General Counsel;
Not make any statement or include any material that would directly or indirectly defame, harass,
discriminate against, threaten or intimidate any current or former employee, policyholder,
customer, client, vendor or business partner of the Company;
Respect copyrights, trademarks, and other third party intellectual property rights; and
Comply with applicable policies set forth in the Code of Business Ethics and Conduct, Records
Retention Policy, Privacy Guide, Information Systems Security Policy, Employee Handbook and
other applicable laws, rules and regulations.

PROFESSIONAL REFERENCES

Employees shall not provide professional references or recommendations for other individuals on Social
Media sites, including any professional networking sites, as such references, positive or negative, can
potentially be attributed to the Company and create potential legal liability for both the author of the
reference and the Company.

V.

AUTHORIZED REPRESENTATION OF THE COMPANY ON SOCIAL MEDIA

When specifically authorized to represent the Company on Social Media, you are required to:
Be transparent in every Social Media engagement;
Protect the private, confidential or proprietary information of the Companys current and former
employees, policyholders, customers, clients, vendors or business partners in compliance with the
Companys Code of Business Ethics and Conduct, Records Retention Policy, Privacy Guide,
Information Systems Security Policy, Employee Handbook and other applicable laws, rules and
regulations; and
Be polite and courteous to others.
Authorized employees are encouraged to add value to the Companys business when representing the
Company on Social Media platforms. When in doubt about posting anything related to the Company,
authorized employees must obtain prior written authorization from the Companys Communications and
Marketing Department and Office of General Counsel.

VI.

CONSEQUENCES OF POSTING ON SOCIAL MEDIA PLATFORMS

This Policy is not intended to provide legal advice to employees of the Company. However, employees can
be held personally liable for commentary or other information that is considered defamatory, obscene,
private, confidential, proprietary or libelous by any offended party, including the Company, or is otherwise
proscribed by applicable laws, rules and regulations.
In addition, employees should be aware that it may be a criminal and/or regulatory offense to post insider
information about the Companys publicly-traded policyholders, customers, clients, vendors or business
partners, or publicly-traded entities whose securities are held by the Company. Breach of this Policy may
result in certain disciplinary action taken by the Company, including termination of employment and,
depending on the severity of the breach, reporting such employee to appropriate law enforcement
authorities or regulators.

Accordingly, employees should carefully consider the type of information they share, post, publish or
otherwise disclose on Social Media platforms and understand that information becomes public the
moment it is shared or posted online and may remain public for an indefinite period of time.

VII.

MEDIA CONTACT

In the event any member of the media or press contacts an employee regarding any Social Media content
relating to the Company, that such employee shared, posted, published or otherwise disclosed such
content, such employee shall immediately contact, and shall only act at the direction of, the Companys
Communications and Marketing Department in coordination with the Office of General Counsel.

VIII.

USE OF COMPANY TIME AND EQUIPMENT

In conducting any Social Media related activity, employees must comply with existing Company policies,
including, policies set forth in the Companys Code of Business Ethics and Conduct, Records Retention
Policy, Privacy Guide, Information Systems Security Policy, Employee Handbook governing Internet and
email usage by employees. In particular, Social Media related activities should not interfere with
employees work commitments. Further, as set forth in the Companys Code of Business Ethics and
Conduct, Records Retention Policy, Privacy Guide, Information Systems Security Policy, Employee
Handbook, the Companys technology resources and equipment are the property of the Company and
should be used to provide service to clients and for other business purposes. Accordingly, within the
limits of applicable law, employees should have no expectation of privacy when using any of the
Companys technology resources and equipment.

IX.

USE OF EMPLOYEE NETWORKS

Yammer is the private and secure enterprise social network through which the Company employees
connect, collaborate and innovate.
In accordance with this Policy, the Companys Code of Business Ethics and Conduct, Records Retention
Policy, Privacy Guide, Information Systems Security Policy, Employee Handbook and other applicable laws,
rules and regulations, employees using Yammer must:

Not disclose proprietary or sensitive information about the Company. Such information may
include, private, confidential or proprietary financial information unannounced planned or
contemplated mergers or acquisitions or other business transactions, lawsuits or legal proceedings,
trade secrets, or other private, confidential or proprietary documents and information prepared or
distributed by or relating to the Company, its current and former employees, policyholders,
customers, clients, vendors or business partners;
Not make any statement or include any material that would directly or indirectly defame, harass,
discriminate against, threaten or intimidate any current or former employee, policyholder,
customer, client, vendor or business partner of the Company;
Respect copyrights, trademarks, and other third party rights.

X.

EMPLOYER MONITORING

As set forth in the Companys Code of Business Ethics and Conduct, Records Retention Policy, Privacy
Guide, Information Systems Security Policy, Employee Handbook and within the limits of applicable
privacy and labor laws, the Company reserves the right to examine, copy or disclose all information
stored on its technology resources and equipment without notice to employees for the purpose of
ensuring that employees are complying with the Companys policies, including this Policy, and for
legitimate business purposes. Notwithstanding the foregoing, in jurisdictions where required by
applicable law, emails and files marked personal may only be examined, copied or disclosed by the
Company if the Company has obtained an appropriate court order or upon the consent of the employee.
Employees consent to such monitoring by their use of the Companys technology resources and
equipment. Employees should not use the Companys technology resources and equipment for matters
which employees wish to be confidential from the Company.
Further, the Company reserves the right to monitor Social Media platforms for any comments or
discussions, or any other content, regarding the Company, its current and former employees, policyholders,
customers, clients, vendors or business partners and the insurance and financial services industry, including
any products and competitors, that may be shared, posted or published by anyone, for the purpose of
ensuring that employees are complying with the Companys policies, including this Policy, and for legitimate
business purposes. The Company reserves the right to utilize content management tools to monitor or
review content on Social Media sites that may violate or breach the terms of this Policy. Although the
Company attempts to monitor online commentary about the Company, it is impossible to capture and
review all online commentary in a timely manner. Accordingly, employees should not assume that the
Company approves of Social Media content shared, posted or published by employees simply because the
Company has not confronted an employee about it.

XI.

REPORTING VIOLATIONS OF THIS POLICY

The Company requests employees to promptly report any questions or violations or breaches of this Policy
to their supervisor, a management member of the Human Resources Department, the Companys
Compliance Director or their local compliance contact in accordance with local law, as applicable. The
Compliance Director is located at:
Compliance Director
Francesca Lulgjuraj
399 Park Avenue, 8th Floor
New York, New York 10022
If, however, reporting violations or breaches of this Policy makes employees uncomfortable, employees
may instead anonymously report any violations or breaches of this Policy by calling the toll-free Starr
Hotline Program. For office locations within the European Union countries, the telephone number is 866318-7452. For all other locations, the telephone number is 866-318-7446.

XII.

DISCIPLINE AND OTHER CONSEQUENCES FOR VIOLATION OF THIS POLICY

Depending upon the circumstances, any employee found to have violated or breached the terms of this
Policy will be subject to appropriate disciplinary action, which may range from a verbal or written

disciplinary warning up to and including termination of employment, except where the conduct at issue is
protected by applicable law.
In addition, employees may be required to remove postings on Social Media platforms which violate or
breach the terms of this Policy or any other Company policy, except where the conduct at issue is
protected by applicable law. Failure to comply with such a request from the Company will be subject to
appropriate disciplinary action, which may range from a verbal or written disciplinary warning up to and
including termination of employment, except where the conduct at issue is protected by applicable law.

VIII.

REVISION AND REVOCATION

This Policy may be revised or revoked by the Company at any time, without advance notice or cause.

IX.

LOCAL POLICIES AND PROCEDURES

If a provision of this Policy conflicts with applicable local legal requirements, the Company will follow the
applicable local legal requirements to the extent it is required to do so.

Policy effective date: February 20, 2015