CSS-002

Edition: 1.0

Internet Usage Policy Effective Date:

24 January 2012

Global Compliance Policy Approved By:

Edmond d’Arvieu Chief Security Officer

Functional Owner: Corporate Security

of 4 Alcatel-Lucent – Internal

Proprietary – Use pursuant to Company instruction

INTERNET USAGE POLICY

The Internet Usage Policy is intended to protect Alcatel-Lucent’s business, its network, computing resources and information assets. This includes protecting the confidentiality of company information as well as the productivity of employees and non-employee contract workers.

Authorized Use

Network and computing resources are defined as:

All IT equipment and services provided by the company to employees and non-employee contract workers.

All equipment privately owned by employees or non-employee contract workers and used to connect to the Alcatel-Lucent network (as stipulated in the Personally Owned Devices Terms of Use).

All electronic mail and Internet communications.

Equipment is meant to be used by employees and non-employee contract workers for legitimate business use in a manner that is consistent with the Alcatel-Lucent Code of Conduct, Internet Usage Policy and Social Media Policy and compliant with all applicable laws.

Employees and non-employee contract workers are responsible for professional and personal use of the Internet at all times when it involves:

The obligation to protect company information. Situations in which the employee can be considered a representative of the company. Respecting the Code of Conduct.

Illegitimate use of Alcatel-Lucent’s network and computing resources can make the company liable to criminal prosecution. As a result, Alcatel-Lucent has a legal duty to ensure that these resources are not used for unauthorized activities and all Alcatel-Lucent employees have an ethical responsibility not to participate in such activities using Alcatel-Lucent resources.

Subject to management approval or local practices and work agreements, employees and non-employee contract workers may use company network and computing resources to access the Internet for occasional non-business purposes. Such use must be governed by good judgment and restraint to ensure that it does not interfere with the work responsibilities of employees or non-employee contract workers. Such use must not violate Alcatel-Lucent’s Code of Conduct or Social Media Policy.

Internet Usage Policy Edition 1.0, 24 January 2012



Unauthorized Use

The company network (including remote access), computing resources and the Internet will not be used in any way that interferes with job requirements, undermines productivity, or creates unnecessary business risk.

Employees and non-employee contract workers are prohibited from engaging in any unprofessional behavior when using company networks and computing resources, including (but not limited to) the following:

Soliciting or advocating commercial ventures, religious or political causes, outside organizations, or other non-business-related organizations.

Accessing sites that are not consistent with Alcatel-Lucent’s values, its Code of Conduct and its ethics standards, or unauthorized by law, such as those related to extremist groups, hate groups, violence, pedophilia, gambling, cracking and hacking, sexually explicit materials and/or nudity, unauthorized classified materials, or any other illegal activity.

Taking part in cracking and hacking activities.

Taking part in any form of cyber bullying.

Using the company's name or conducting Alcatel-Lucent business without authorization including creating a Web site, Web page, domain on the Internet, an application, or social media/network presence.

Using computing resources to perpetrate any form of software, film or music piracy or to download unauthorized peer-to-peer, remote administration or other software that could bypass Alcatel-Lucent network controls.

Intentionally uploading any form of malicious software to the corporate network and/or jeopardizing the security of the company’s network and computing resources.

If an employee or non-employee contract worker is unsure about what constitutes acceptable Internet usage, then he or she should ask his or her supervisor for further guidance and clarification.

To ensure the confidentiality and integrity of company information assets, the employee or non-employee contract worker must:

Not disclose confidential information (even partial) and/or names of project or clients on social networks and web sites (refer to Alcatel-Lucent’s Social Media Policy).

Not post any Alcatel-Lucent document, confidential or not, on social networks and web sites without prior approval from the supervisor or the appropriate corporate department (for example, Communications).

Not steal, use or disclose someone else's password.




Not share his or her personal password, or otherwise communicate the password to anyone for accountability purposes, since the owner of the password will be held accountable for any non-compliant activity occurring on the account. Employees and non-employee contract workers are responsible for keeping their passwords safe and never disclosing them to anyone.

Never store information that could be harmful if released to the public on Internet-based programs (such as Google Documents, Dropbox and others). If Alcatel-Lucent employees need to exchange confidential or internal information, the following Alcatel-Lucent compliant solution is available: SAFE Storage Solution (Secure Ad Hoc File Exchange). Use of public storage solutions for our customers or suppliers requires the prior approval of Information Security.

Subject to applicable local laws in force, Alcatel-Lucent reserves the right to limit non-business use of company network and computing resources at any time and may do so in the event such use, for example, results in increased financial costs, interferes with the productivity of individual employees and non-employee contract workers, or negatively impacts the overall performance, integrity and availability of network and computing resources.

Privacy and Monitoring

Alcatel-Lucent reserves the right at any time to monitor, access, retrieve, read and/or disclose any content generated on its IT resources. The use of the company network and computing resources constitutes an individual's express consent to Alcatel-Lucent's monitoring, recording and auditing of all system activities as permitted by law.

In some countries, the use of these resources for any purpose, regardless of whether utilized in the office, home or elsewhere, is not private. Except where prohibited by applicable local laws such as data privacy requirements, Alcatel-Lucent can and will monitor individual use of company network and computing resources - including the use of equipment, visits to specific web sites, instant messaging and e-mail.

All Internet data that is composed, transmitted and/or received by the company network or its computing resources are considered to belong to Alcatel-Lucent and are recognized as part of its corporate data, except for data covered by local privacy and intellectual property laws. Therefore, this data is subject to disclosure for legal reasons to other appropriate third parties.

Compliance Accountability

All employees and non-employee contract workers are responsible for ensuring compliance with the company’s Internet Usage Policy, applicable laws, and the policies and procedures mentioned above.

Any employee or non-employee contract worker who violates these policies can be subject to disciplinary action deemed appropriate by Alcatel-Lucent.




Reporting All employees and non-employee contract workers may report suspected or observed violations of law or company policies by contacting the appropriate manager or by using the company’s approved Compliance Issues Reporting Methods/Compliance Hotline. Alcatel-Lucent will not retaliate against anyone who reports, in good faith, suspected violations of law or company policies.

This Policy is subject to change. Therefore, always refer to the most current version for guidance.

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