Overview

Company property includes not only tangible property, like desks and computers, but also intangible property such as data, intellectual property, and confidential, proprietary information. The Company’s proprietary, trade secret, and confidential information is particularly important. “Confidential Information” refers to a piece of information, or a compilation of information, in any form (on paper, in an electronic file, or otherwise), related to the Company’s business that the Company has not made public or authorized to be made public, and that is not generally known to the public through proper means. By way of example, confidential or proprietary information includes, but is not limited to, nonpublic information regarding the Company’s business methods and plans, customer lists, products, materials, designs, plans, ideas, data, business plans, research, development, inventions, financial statements, financial projections, financing methods, pricing strategies, customer sources, employee health/medical records, methods of competing, marketing data, formulas, and trade secrets are examples of confidential information.

Employees may not disclose, transfer or use proprietary or confidential information, without proper authorization or purpose. Each employee should use all reasonable care to protect or otherwise prevent the unauthorized disclosure of such information. Any employee who violates this guideline will be subject to disciplinary action, up to and including termination. Confidential Information does not include information lawfully acquired by non-management employees about wages, hours or other terms and conditions of employment, if used by them for purposes protected by §7 of the National Labor Relations Act such as joining or forming a union, engaging in collective bargaining, or engaging in other concerted activity for their mutual aid or protection. Confidential Information also does not include: conduct that was, or that an employee reasonable believes to be, illegal; conduct that is recognized as against a clear mandate of public policy; or the existence of a non-confidential settlement involving any such conduct.

Nothing in this policy prohibits an employee from communicating with any governmental authority or making a report in good faith and with a reasonable belief of any violations of law or regulation to a governmental authority, or disclosing Confidential Information which the employee acquired through lawful means in the course of employment to a governmental authority in connection with any communication or report, or from filing, testifying or participating in a legal proceeding relating to any violations, including making other disclosures protected or required by any whistleblower law or regulation to the Securities and Exchange Commission, the Department of Labor, or any other appropriate government authority.

Further, employees are hereby notified that under the 2016 Defend Trade Secrets Act (DTSA): (1) no individual will be held criminally or civilly liable under Federal or State trade secret law for the disclosure of a trade secret (as defined in the Economic Espionage Act) that: (A) is made in confidence to a Federal, State, or local government official, either directly or indirectly, or to an attorney; and made solely for the purpose of reporting or investigating a suspected violation of law; or, (B) is made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal so that it is not made public; and, (2) an individual who pursues a lawsuit for retaliation by an employer for reporting a suspected violation of the law may disclose the trade secret to the attorney of the individual and use the trade secret information in the court or arbitration proceeding, if the individual files any document containing the trade secret under seal, and does not disclose the trade secret, except as permitted by order in that proceeding.

Connecticut: Electronic Monitoring

The Company monitors employee use of company computer networks, electronic mail (email) systems and other company communication resources in its sole discretion. Specifically, the Company monitors email, instant messages, internet access and other electronic communications and also conducts video monitoring. Accordingly, employees should not expect that these communications are private.

No audio or video recording occurs in restrooms or areas where employees change clothing.

Connecticut: Privacy Protection Policy for Social Security Numbers

The Company has established the following procedures to protect the confidentiality and security of Social Security numbers (SSNs) received by the Company. This policy applies to SSNs received for any employment-related purpose, including, but not limited to, pre- employment background screening; payroll, benefits, and human resources administration; and employment-related investigations.

Access to, and Use of, Information or Documents That Contain SSNs

Only authorized employees of the Company may access information and documents containing SSNs. Authorized employees may access information or documents containing SSNs only on a need-to-know basis and may use such information and documents only for the purpose for which access is permitted.

Disclosures of Information or Documents That Contain SSNs

The Company will disclose documents containing SSNs outside the Company only as permitted or required by law or court order. If the recipient of the document does not have a need to know the SSN, the SSN should be redacted before disclosure. If the recipient of the document does have a need to know the SSN, then the Company, whenever feasible, should obtain the recipient’s written agreement to provide adequate protections for the documents containing the SSN. SSNs may not be disclosed to a third-party without the prior approval of the Legal Department or of the Chief People Officer.

Additional Safeguards for SSNs

SSNs and documents containing SSNs should receive the following additional protections:

• SSNs should not be publicly displayed, for example, by including them in electronic documents posted on internal web sites or in paper documents posted on employee bulletin boards;

• SSNs should not be printed on cards, such as insurance identification cards, that must be presented for an employee to obtain goods or services;

• SSNs generally should not be printed on paper documents that are mailed to an employee unless the document, by law, is required to include an SSN (such as a W-2 Form) or in certain other limited circumstances. Employees should consult with the Legal Department before including SSNs in a mailing;

• Employees authorized to access SSNs should take steps to prevent casual viewing of SSNs by unauthorized persons, such as activating a password- protected screen saver when leaving an assigned computer unattended;

• Employees authorized to access SSNs should not download SSNs or documents containing SSNs to any portable storage medium unless it is encrypted or remotely access files containing SSNs other than through an encrypted connection.

• SSNs should not be transmitted over the internet unless encrypted pursuant to the Company’s Information Security Policy.

Enforcement

Any employee who becomes aware of, or suspects, a violation of this policy should inform the Chief People Officer or the Legal Department immediately, so that the Company may conduct an investigation where appropriate. No employee may retaliate against an employee who reports a violation of this policy. Violation of this policy will result in disciplinary action up to and including termination of employment.

Michigan: Social Security Number Privacy

Employees must provide the Company with their social security number in order for the Company to satisfy payroll, state and federal tax and insurance coverage requirements. Consistent with Michigan law, the Company takes reasonable steps to maintain the confidentiality of social security numbers.

All documents and records containing social security numbers and information are kept in a secure environment. Only authorized personnel with a legitimate business need may access records and documents (both internal and external) that contain an employee’s social security number and identification information.

In addition to the Company’s policy protecting against the disclosure of confidential information, employees are prohibited from accessing, viewing, or using other employee’s social security information maintained by the Company.

When necessary, documents containing employee social security numbers will be properly destroyed through shredding or other means before disposal.

Any employee who accesses social security data without authorization and/or for unlawful purposes will be disciplined up to and including termination of employment and may be referred to authorities for possible prosecution.