PDCA

INTERNAL REGULATIONS

UNLESS SPECIFIED IN ANY PDCA DOCUMENTATION, THESE REGULATIONS APPLY TO ALL RESOURCES, PRODUCTS, SERVICES, ACTIVITIES, ETC.

DIRECT EMPLOYEE and INDEPENDENT CONTRACTORS
Personnel Administration: The task of handling any personnel records and personnel related functions has been assigned to the Administration. Questions regarding benefits, wages and the interpretation of policies and procedures should be directed to the Administration.

Workers Files: Keeping the online personal profile up-to-date is essential and critical at the same time!. If the personnel experience a change in any data/information, they must notify the Administration as soon as possible or modify it themselves online (if applicable). Workers have the right to see information kept in their personnel files, and they may request and receive copies of all personally signed documents.

Employment Classification: candidates who have successfully completed the probation period of employment and who work normal office hours are considered full-time employee (FT).

Job assignments, work schedule and duration within a specific position/rank/grade will be determined on an individual basis. Temporary part-time workers (PT) and Independent Contractors (IC) hired for specific projects are not eligible for the benefits given to Full-Time (FT) workers.

The first day on which the FT employee reports to work is his/her official anniversary date. This date is used to record the various conditions and benefits available to the employee at the time of hire.

EQUAL EMPLOYMENT OPPORTUNITY (EEO) : PDCA is an equal employer opportunity for all. PDCA prohibits discrimination against, or harassment of any person employed, seeking employment, or works with PDCA on the basis of race, color, national origin, religion, sex, gender identity, pregnancy ( includes pregnancy, childbirth, and medical conditions related to pregnancy or childbirth) , physical or medical disability, mental condition (cancer-related or genetic characteristics), ancestry, marital status, age, sexual orientation, citizenship, or service in the uniformed services (veterans), etc. Information provided by workers will remain confidential and will not be used for any discriminatory purpose.

PDCA policy also prohibits retaliation against any worker, person seeking employment or works with PDCA for bringing a complaint of discrimination or harassment pursuant to this policy, or against a person who assists someone with a complaint of discrimination, harassment, or participates in any manner in an investigation or resolution of a complaint of discrimination or harassment.

PDCA policy is intended to be consistent with the provisions of applicable State and Federal laws, regulations and PDCA policies. Inquiries regarding PDCA´s equal employment opportunity and affirmative action policies may be directed to the Administration

Medical Coverage: All FT workers have options to be insured as part of the PDCA benefit package offered at the time of hire.

Service Termination: Although PDCA employment is “at will”; s hould the FT employee or PDCA wish to terminate the employment, with or without cause, at any time, they must give the other party a notice of:
·                   One (1) month, if the employee has been working for less than three (3),
·                   Two (2) months, if the employee has been working more than three (3) and less than six (6) years,
·                   Three (3) months, if the employee has been working more than six (6) years and less than twelve (12) years, or
·                   Four (4) month, if the employee has been working for more than twelve (12) years.

All leaving workers must sign a Final Clearance Form (F-AD-FCF-01), and are subject to an Exit Interview.

Job Description: PDCA maintains job descriptions (F-AD-JDS-01) for each position.
New workers will get a copy of their job description and other documents (Policies, agreement, MOU, ICA, DPA, ect.) upon joining PDCA and will sign a copy for the HR files, and should refer any inquiries or questions to their direct line manager/supervisor. If the duties or responsibilities of any employee are changed, their job description will be updated accordingly, and an amended copy will be provided to the employee (either by hard copy and/or on the system/tool).

Also refer to the JHA/JSA related to your job, tasks, activities risk analysis.

Probation: Newly hired workers will be placed on probation for the first three (3) months of employment during which the employee´s performance will be evaluated.

If an employee fails to perform satisfactorily during the probation period, his/her employment may be terminated. Termination during probation may be done by either party without notice or severance pay.

Monitoring and Performance Review
·                   To ensure that all workers are aware of their job and of the nature of the results to be given to help them meet expectations/objectives, workers and files will be monitored on annually basis by the Administration
·                   To ensure that all workers are aware of the quality of procedures and are implementing them a quality monitoring will be performed on a yearly basis by the QM in conjunction with HR
·                   Workers’ performance will be reviewed once a year, to determine appraisals and identify training needs and set individual objectives
·                   Annual monitoring will affect the Personnel Performance Review (D-AD-PPR-01) that will determine the appraisals and the end of year Bonus (if any)
·                   Personal objectives will be set on a case-by-case basis according to Job requirements and group objectives and will be defined and reviewed during the yearly Personnel Performance Review (D-AD-PPR-01)

Transfers: If a job opening (posting) becomes available within any department, and an employee is interested in applying (bidding) for the new position, the employee must inform and await for PDCA Management decision.

PDCA Management also reserves the right to transfer workers from their current positions to other ones.

Outside Employment: If a person is employed by PDCA on a full-time basis (FT), he/she is expected not to have any other job, and/or participate in any activity that may interfere with their work responsibilities, productivity or that might create a conflict.

Work Schedule: The normal workweek for PDCA FT workers is five days, Monday through Friday. The regular office operating hours are from 8:30 to 17:30 Monday through Friday. Managers/Supervisors will determine the particular hours of work and the lunch period schedule for workers in order to maintain adequate duty coverage at all times. Workers are entitled to thirty (30) minutes lunch break, daily, between 12:30 - 14:30.

Occasionally and based on the Client location and time zone, these schedules may be alternated to always maintain work continuity.

Occasionally PDCA Management may decide to have shifts for Saturdays, but such a privilege can only be granted by the PDCA Management and for the amount of time deemed adequate to maintain work continuity.

Workers must advise the Administration immediately if they are going to be late, absent or on leave. The reason must also be provided for the Administration or HR for retaining personnel records.

1 Attendance: All workers are expected to be at their workstation with their uniform (if any) on and ready to work at 8:30 they are expected to remain at their workstation until 17:30 or until the end of their assigned work hours, with the exception of approved breaks. When employee´s work tasks keep them away from their workstation, they are required to inform their Line Manager/supervisor. Their absence will be considered "unauthorized" when the HOD has not been informed. Arriving 15 minutes after the beginning of work, or leaving 15 minutes prior to the end of work hours, is considered excessive (as per the Standard of Conduct).

2 Absence: If an employee knows in advance that they will need to be absent, they are required to request this leave directly from the Administration who in accordance with the HOD will approve/disapprove the absence and determine the timing when the absence would be most suitable.

When workers call in with an unexpected absence, they should inform the HOD. If the HOD is not available, information must be directed to the Administration or any other Manager/Supervisor available. Notifying the receptionist, secretaries or a fellow employee is not sufficient.

If a worker is unable or incapable to call in due to illness, emergency or other reason, someone else may call on his/her behalf.

For any leave of 1 day and more the employee must fill a Leave/Time Out Request (F-AD-LTR-01) at the Administration and await approval.

3 Time out during working hours/Lateness: It is not a company policy to allow time out during working hours except for emergencies.
The formalities requested to be completed, in case of time out during working hours are:
·                   Workers are requested to obtain official permission before leaving the company premises for personal reasons
·                   A Leave/Time Out Request (F-AD-LTR-01) will be completed by the worker, and given to the HOD, who will approve it. Workers cannot leave unless the Administration informs them that their request was approved
·                   If an employee needs to miss the beginning of the work day (after 8:30) or to leave earlier (before 17:30), permission must be granted at least 24 hours prior to the absence by the Administration. Only emergencies are the exception to this rule, when justified.

4 Excessive absenteeism or lateness: Workers must be aware that excessive absenteeism, lateness, or leaving work early will lead to disciplinary action (as per the Standard of Conduct), including possible Termination. Unexcused tardiness or leaving work early is considered absences by PDCA.

The Administration will follow up on absences, time outs using the Absenteeism Sheet and will follow up on the lateness using the Workers Attendance Sheet (if applicable) and/or any other method.

5 Overtime: Only authorized over time will be paid/rewarded according to the overtime regulations set by PDCA Management.

6 Weekly holidays: Sunday of every week shall be the weekly holiday unless the nature of work requires otherwise.

7 Annual holidays: Depending on the applicable regulations, but as a minimum FT workers are entitled to the following number of days as his/her annual holiday leave, with full pay, for every year of service:
·                   15 days, if the employee has been working for less than five (5) years,
·                   17 days, if the employee has been working for more than five (5) years and less than ten (10) years,
·                   19 days, if the employee has been working for more than ten (10) years and less then fifteen (15) years, or
·                   21 days, if the employee has been working for more than twenty-one (21) years.

The annual leave must be given to the Administration, two (2) weeks prior to its actual beginning date for approval. The employee could also take his/her leave one day at a time; however, it should be taken entirely during their year and will not be postponed to the next year, unless PDCA Management approves that.

If the employee´s service is terminated, for any reason, prior to the utilization of their annual leave, they shall be paid for the unused days of leave after calculating them over the worked period.

8 Official holidays: Official holidays, religious feasts, and weekly holidays shall not be calculated as part of an employee’s annual leave. The Administration will advise every year´s schedule of “Official Holidays” in the country where PDCA operates, through an Internal Memorandum (F-AD-MEM-01). As for International holidays, each case will be separately notified to the concerned personnel.

9 Sick leaves: Depending on the applicable regulations, but as a minimum workers are entitled to sick leaves with full pay in accordance with the following:
·                   ½ month fully paid and half (0.5) month ½ pay, if the employee has been working for less than two (2) years,
·                   1 month fully paid and 1-month ½ pay, if the employee has been working for more than two (2) years and less than four (4) years,
·                   2 months fully paid and 2.5 months ½ pay, if the employee has been working for more than four (4) years and less than ten (10) years, or
·                   2.5 months fully paid and 2.5 months ½ pay, if the employee has been working for more than ten (10) years.

Sick leaves exceeding 1 day must be accompanied by a doctor or physician’s report that will be placed in the employee file.

10 Marriage leaves: Depending on the applicable regulations, but as a minimum w orker is entitled to 7 working days off with full pay for marriage.

11 Maternity leave: Depending on the applicable regulations, but as a minimum female worker have the right to a total of 7 weeks maternity leave, with full pay, prior to and after delivery. It is prohibited to ask a female employee to go back to work prior to the expiry of such period.

12 Paternity leave: Depending on the applicable regulations, but as a minimum male worker have the right to a total of 2 weeks paternity leave, with full pay, prior to and after delivery.

13 Mourning (Death) Leaves: Depending on the applicable regulations, but as a minimum:
·                   A worker who has lost a mother, father, wife, husband, sons, grandsons, grandparents, sisters, brothers has the right to a total of three (3) days leave with full pay,
·                   A worker who has lost an Aunt, uncle or first degree cousins has the right to two (2) days leave with full pay, or
·                   A worker who has lost any relative not mentioned above has the right to one (1) day leave with full pay.
Mourning leaves must be accompanied by a death notice that will be placed in the employer file.

Purchasing and Maintenance of Office Materials: It is the responsibility of the Administration to cover the maintenance requirements for all office equipment/devices/assets.

It is the responsibility of the Administration to handle the office purchases and minimize waste and the consumption of resources, according but not limited to the followings:
·                   By printing on both sides of the papers (except formal ones) and reduce the indirect overhead by printing in grayscale and in draft,
·                   It is very important to turn off all devices, equipment, lighting and materials before leaving the office, even if one plans to come back later to the office,
·                   Also, before leaving the office, the mobile devices should be plugged into the power (and diverted to the MD mobile or else if required)
·                   Also, before leaving the office, remove all types of trash or disposed items (such as foods, search paper, personal things,…) and organize the office equipment, devices and materials.

UPDATES AND MODIFICATIONS OF THESE INTERNAL REGULATIONS
Any modification that occurs in the applicable laws and regulation due to environment changes, whether national or International, will affect these regulations, and all workers should consider and abide by the new updates. PDCA Management could at any time change these regulations, without prior notification; personnel must, on a regular base, check the last updated document and consider the changes made.

CODE OF ETHICS

In order to maintain PDCA positive reputation in the marketplace and an ethical interpersonal relationship, PDCA workers must continually exercise care and good judgment. By accepting employment at or with PDCA, a worker has accepted a responsibility towards the company, its clients, stakeholders and to his/her fellow workers to maintain the highest levels of personal conduct.

PDCA is committed to conducting business in accordance with the highest ethical and legal standards. The standards and principles of conduct set forth in this document, which we refer to as the “Code,” are an extension of our core values. This Code applies to all workers, officers, and directors of PDCA and its subsidiaries. This Code covers a wide range of business practices and procedures. It does not cover every issue that may arise, but sets out basic policies to guide you in your business conduct. These policies reflect our core values and serve as a foundation for all that we do in working to achieve PDCA’s mission of providing the evolving workforce effective and engaging learning experiences that maximize the potential of a better life. In particular, this Code covers policies designed to deter wrongdoing and to promote: honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; full, fair, accurate, timely, and understandable public disclosures, including those we file with the Administration; compliance with applicable laws, rules and regulations; the prompt internal reporting of violations of the Code; and accountability for adherence to this Code. Principal officers of PDCA must also adhere to the same Code of Ethics.

Misrepresentation of Information
All PDCA workers and workers of third-party vendors that have direct contact with prospective customers and the public must respect and obey the final Title IV program integrity rule on misrepresentation of institutional information. Consistent with this document, all PDCA workers and workers of certain third-party vendors are required to complete annual training on Misrepresentation of Institutional Information and acknowledge their understanding of their obligations under this rule. Violations of this rule are taken seriously and can result in disciplinary action or in the termination of an employee found to have provided substantial false, misleading, or erroneous information about PDCA to customers, prospective customers, or the public.

Discrimination
PDCA is committed to providing a work environment that is free of all forms of unlawful harassment and discrimination. In keeping with this commitment, PDCA maintains a strict policy prohibiting all forms of unlawful harassment and discrimination in employment. This document requirements apply to harassment and discrimination committed by and/or against all workers, including such conduct between workers, and such conduct between workers and “non-employee” consultants, contractors, and workers from temporary service agencies and other third parties, including vendors, visitors, and guests of PDCA whose relationship to PDCA is through PDCA’s facilities, programs, or activities, and between workers and PDCA customers. In addition to the policy in this document or any other document, workers must observe all other applicable PDCA policies, including the Policy against Harassment, Discrimination, and Retaliation in the PDCA documentation. In the case of discrimination or harassment between an employee and a customer, PDCA policies concerning customers will be coordinated with this policy to address the matter.

All workers shall adhere to a strict non-discrimination and anti-harassment policy. Every person is to be recognized as a unique individual and is to be treated with respect in all interactions. PDCA does not discriminate on the basis of race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, genetic information, status as a covered veteran, or other protected characteristic in accordance with applicable federal, state, and local laws. PDCA complies with all state and local laws to the extent that they provide broader protections.

Harassment can occur in a variety of circumstances. Unwelcome conduct may occur (i) on PDCA premises; (ii) during business travel or otherwise in connection with PDCA-related business; or (iii) online. The harasser can be the victim’s supervisor, a supervisor in another department, a subordinate, a co-worker, or a non-employee such as a vendor. Harassment can occur between two members of the same group (e.g., two individuals of the same sex) or of different groups.

1.      Sexual Harassment in Employment: Sexual harassment, including unwelcome sexual advances, requests for sexual favors, and other verbal, physical or visual conduct of a sexual or harassing nature, constitutes unlawful sexual harassment when:
•        Submission to such conduct is made an explicit or implicit term or condition of employment; Submission to or rejection of such conduct is used as the basis for employment decisions affecting an individual;
•        Such conduct has the purpose or effect of either unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.
·        Examples of such conduct include, but are not limited to:
•        Offensive or unwelcome sexual flirtations, advances or propositions
•        Verbal abuse of a sexual nature
•        Graphic or verbal commentaries about an individual’s body
•        Sexually degrading words used to describe an individual
•        Sexually oriented jokes or offensive literature
•        Unwelcome physical touching of others
•        Unwelcome conduct such as standing too close, leering or sexually suggestive gestures or physical movements

Notwithstanding the foregoing, any instance of sexual harassment involving an employee and a customer that denies or limits on the basis of sex, an employee’s ability to provide aid, benefits, or services to customers, or a customer’s ability to participate in or benefit from PDCA’s programs and activities, shall be addressed under PDCA’s guidelines and rules.

In any case, under any circumstances and during work period, outside or at PDCA premises, all types of sexual harassment are unacceptable and will be considered as serious crime. All parties involved in any way in such action will be severely punished (as per the Standard of Conduct)

Notice of Non-discrimination – Discrimination on the Basis of Sex: PDCA does not discriminate on the basis of sex in its activities/events, and it is required not to discriminate in such a manner. Questions regarding any PDCA requirement may be referred to the PDCA Management. PDCA’s Code of Ethics Coordinator may be contacted by e-mail at: personnel@pdca-co.net . For more information please see PDCA’s Compliance Policy and Grievance Policy in this document.

2.      Harassment Other than Sexual Harassment: Harassment is verbal or physical conduct that denigrates or shows hostility or aversion to an individual because of race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, genetic information, status as a covered veteran, or other protected characteristic in accordance with applicable federal, state, and local laws, when such conduct has the purpose or effect of: unreasonably interfering with an individual’s work performance; creating an intimidating, hostile, or offensive work environment; or otherwise adversely affecting an individual’s employment opportunities. Harassment may include, but is not limited to: verbal abuse or ridicule, including slurs, epithets, and stereotyping; offensive jokes and comments; threatening, intimidating, or hostile acts; and displaying or distributing offensive materials, writings, graffiti, or pictures.

Harassment or discrimination by an employee in violation of this policy will result in disciplinary action up to and including Termination. For more information on disciplinary actions that may result from harassment or discrimination of a sexual nature between an employee and a customer please see PDCA’s Compliance Policy and Grievance Policy in this document.

Procedure: If workers experience, observe or become aware of behavior which they believe to be harassing or discriminatory in nature, which is inappropriate or offensive, or which makes them or others uncomfortable, they should report the behavior immediately to their line manager or the HR Department. Reports may be made in person to the line Manager or to the HR department. Reports can also be made by calling PDCA MD or e-mailing AD@PDCA-co.net . Providing information of this type will enable PDCA to take appropriate action to ensure that workers enjoy a work environment free from harassment and discrimination. Managers who become aware of a violation or potential violation of this policy must report it to the relevant person under the procedure stated above. Information gathered under this policy will be kept as discreet as possible while allowing PDCA to fully investigate the matter.

Procedure for Customer Related Incidents: If workers or staff experience, observe, or become aware of behavior which they believe to be harassing or discriminatory in nature, which is inappropriate or offensive, or which makes them or others uncomfortable and a customer is involved, they should report the behavior immediately to PDCA Management by calling PDCA MD or e-mailing AD@PDCA-co.net . Providing this information will enable PDCA to take appropriate action to ensure that workers enjoy a work environment free from harassment. Information gathered under this policy will be kept as discreet as possible while allowing PDCA to fully investigate the matter.

It is PDCA policy and practice to promptly and equitably investigate any grievance of harassment, discrimination, or retaliation. Some reports of harassment may properly be addressed through informal inquiry and resolution measures. In cases where more formal investigative steps are required, appropriate procedures for formal resolution will be followed.

PDCA will take whatever corrective action is deemed appropriate, including disciplinary action up to termination of any employee who violates this policy, to prevent the recurrence of harassment and remedy any discriminatory effects on the complainant and others, if appropriate.

Workers will be protected from retaliation for making a report or participating in an investigation under this policy. All grievances of retaliation should be reported in accordance with the procedure outlined above. Any person that retaliates against any individual who seeks a review under this policy will be considered in violation of this policy, which will result in corrective action up to and including termination.

Workers living and working in certain states may have the right to file a charge of discrimination or other complaint with a state-specific agency, such as the West Virginia Human Rights Commission, the Virginia Division of Human Rights, the California Department of Fair Employment and Housing, and the Illinois Department of Human Rights.

3.      Cyber-Harassment: PDCA is committed to providing a safe, positive working environment for staff and workers. PDCA believes that preventing cyber-stalking and cyber-harassment is critical to creating and maintaining a safe and secure culture. Cyber-harassment can create an atmosphere of fear and intimidation, which may lead to more serious violence. Cyber-stalking and cyber-harassment are prohibited at PDCA.

Cyber-stalking is threatening behavior or unwanted advances directed at another using the Internet and other forms of online and computer communications.

Cyber-harassment is the willful and repeated use of cell phones, computers, and other electronic communication devices to harass and threaten one or more staff members or workers, which occurs in the work or any location or with technology with an effect of doing any of the following:
·        Substantial interference with an employee’s work
·        Creation of a threatening environment
·        Substantial disruption of the orderly operation of PDCA

Examples of cyber-harassment include but are not limited to:
·        Using the Internet, cell phone, e-mail or any other form of electronic communication to intimidate someone
·        Online personal verbal or written attacks
·        Offensive harassing messages
·        Publicly disclosing someone’s personal information
·        Breaking into an account and sending damaging messages
·        Creating a fictitious online account using legitimate personal information and then placing damaging or harassing information in the account

Cyber-stalking and cyber-harassment are prohibited, whether in the office, online, through the use of social networking sites, e-mail or any other form of electronic communication. The use of the PDCA e-mail server to send harassing messages to individuals outside of PDCA is also prohibited. Cyber-stalking and cyber-harassment are criminal offenses. Cyber-stalking and cyber-harassment based on protected characteristics may also implicate federal, state, and local non-discrimination laws. PDCA reserves the right to report an incident to the appropriate law enforcement agencies, and it will participate in any investigation by law enforcement of an alleged cyber-stalking or cyber-harassment offense.

Compliance Policy
It is PDCA’s policy to take prompt and appropriate steps when it is made aware of possible sexual misconduct, which may include, but is not limited to, sexual discrimination, sexual harassment, or sexual violence, as those terms may be further defined in this Compliance Policy, that denies or limits on the basis of sex an employee’s ability to provide aid, benefits, or services to customers, or a customer’s ability to participate in or benefit from PDCA’s programs and activities. Inappropriate conduct that may constitute or otherwise be construed as an offense committed against any member of the PDCA community is prohibited. All grievances involving one or more customers shall be processed in accordance with the Grievance Policy available in this document, the implementation of which may include processing under other company policies as PDCA may determine in its sole discretion. Grievances involving only workers shall be processed through the HR Department in accordance with the Discrimination and Harassment; Investigation of Complaints Policy described in this document.

PDCA’s goal is to resolve grievances promptly and equitably and provide a safe and nondiscriminatory environment for all customers and workers, free from discrimination, harassment and violence of a sexual nature. For more information see PDCA’s Compliance Policy and Grievance Policy in this document.

Staff Grievance Policy Applicable to Shared Services:
PDCA entered into a contractual arrangement with third party company, pursuant to which these companies/organization provide certain non-work related, business-related services for the benefit of PDCA, subject to PDCA oversight and authority. The services that are performed under this arrangement relate to human resources, facilities, information technology, marketing, finance, institutional research/analytics, and legal. If a staff member has concerns regarding the performance of such services, the staff member may e-mail personnel@PDCA-co.net , outlining the grievance or concern and what steps have been taken toward resolution. The time it takes to resolve individual grievances may vary, but staff can expect an initial response, outlining next steps and timelines, within 3-5 business days.

Whistle Blower/HotLine:
PDCA is proud of its reputation for employing ethical business practices throughout the organization. PDCA promotes an open door policy that encourages workers to discuss issues or problems related to their job, their line managers, their coworkers or others within the company. The company strives to provide an effective way for workers to bring problems or concerns to the attention of management. PDCA Management is always open to listening to workers’ concerns.

The HotLine is for all workers to report concerns about the possibility of questionable accounting, operational reporting, auditing procedures, other types of fraud, management practices, policy issues, interpersonal concerns, threats or violence, ethics and governance policy violations, etc. by workers at every level. Workers have the option of reporting concerns anonymously.

In any organization, problems or differences of opinion over work-related matters may occasionally arise between an employee and manager, fellow workers, or PDCA in general. If this should occur, please follow the procedure outlined below.
·        Workers are encouraged to bring any concerns they might have to their immediate line manager or HR if the workers believe it would be inappropriate to discuss the matter with their line manager;
·        If workers are not satisfied with their line manager´s resolution of the problem, they should discuss it with the next level of management or HR;
·        If the concern is unresolved, workers must communicate to their department head or HR;
·        If the concern is unresolved, contact HR so the situation can be elevated to the appropriate levels for further action.

PDCA Leadership encourages workers to bring their problems and questions to our attention. The company will thoroughly discuss and evaluate each issue and take the necessary actions to reach a solution.

The HotLine was established to assure the highest ethical standards and provide a system/tool for reporting violations of the code of ethics and business conduct. This system/tool is operated by a third party organization, and provides workers an avenue to share their concerns relative to management practices, policy issues, interpersonal concerns, threats or violence, etc. This system/tool offers anonymous reporting opportunities and 24/7 access. Workers can utilize this resource by calling PDCA MD or e-mailing AD@PDCA-co.net . Messages and/or Voice Message left on the HotLine are completely confidential – once recorded, the message will be transcribed into text to protect the privacy of the user. The confidential text message will be sent to PDCA’s Management for investigation.

Miscellaneous
1.      Gifts: It is important that each employee declines any gift or gratuity from any source as it insinuates an inappropriate business relationship between the donor and the employee, it is strictly forbidden for any employee to accept any kind of gift without written management approval, otherwise this offence will be considered as a bribe and will be act upon. Prior written management approval is required at all times and for any kind of gifts, even for advertisings or promotional products (T-shirts, coffee mugs, pens, key chains, etc.).

2.      Alcohol and Substance Abuse: PDCA prohibits the unlawful manufacture, possession, distribution, sale, purchase or transfer of alcohol, illegal drugs or unauthorized controlled substances in the premises or while conducting company business off the premises.

PDCA also prohibits the unauthorized use of alcoholic beverages on company premises or in company property (such as Vehicles) and considers it a violation of company Quality Policy (I-QA-POL-01) for anyone to work or report to work while under the influence of alcohol, drugs or illegal substances.

3.      The Law and Illegal Conduct: All workers are expected to adhere to and abide by the laws and regulations of the Country they reside in. The company will ensure that all workers are obligated to the rules set forth by that Country’s Government.

If there is even the slightest question as to the legality of any action to be taken in the name of, or on behalf of, the company, such action should not be taken before consulting with the QM.

If any employee becomes aware of any illegal conduct on the part of any person related to PDCA the employee must inform the Administration with full assurance of confidentiality.

4.      Illegal Compensation: Workers are prohibited from offering, promising, giving or receiving anything of value to/from any person or entity, in any manner, in the course of seeking or retaining business for the company, or for directing company business to such people or accepting business from such people on behalf of the company.

Secret or illegal payments, favors, kickbacks, bribes or any other payment in any form whatsoever, to obtain benefits for the company will be severely punished (as per the Standard of Conduct).

ALL WORKERS ARE, AT ALL TIME, FULLY RESPONSIBLE AND ACCOUNTABLE TO ABIDE BY AND IMPLEMENT THIS CODE OF ETHICS

SAFETY MANUAL

It is quite very important to take the necessary action for the prevention of injury, illness and/or damage to all PDCA personnel and public, to the environment, to protect PDCA properties from any loss or damage… in compliance with client requirements, applicable laws, national and international regulations.

PDCA shall throughout the execution and completion of the work and the remedying of any defects therein:
·                   Have full regards for the safety of all persons on and off site and keep the site and the works in an orderly state appropriate to the avoidance of danger to any person
·                   Know and understand all laws governing the operation along with any requirements and work hazards
·                   Take all necessary measures to protect personnel, the employers personnel, other persons, the general public and the environment
·                   Avoid damage or nuisance to person or to property of the public or others resulting from pollution, noise or other causes arising as a consequence of the operations

PDCA shall adopt a positive approach, awareness and responsibility towards safety, health and the environment, and take appropriate action by:
·                   Ensuring the regulations enforcement
·                   Paying attention to possible injury to unauthorized persons entering the site, particularly children and women
·                   All equipment, materials, devices, chemicals are fit and safe for use
·                   All personnel have the required level of competency (through training and development)
·                   Identify hazards and implementing effective controls to eliminate the risks (operational, engineering, system and administrative, etc.)

Safety and Reporting Accidents
Safety involves protecting public from injuries caused by work-related accidents; safety is everybody’s responsibility and is to be given primary importance in every aspect of planning and performing PDCA activities. Workers are required to report any work related accident, equipment needing repair or safety hazards to the Administration.

Safe, pleasant, and efficient working conditions are our goals. PDCA´s policy is to provide and maintain safe and healthy working conditions and to follow only those operating practices that will result in safe and efficient working conditions. PDCA makes every effort to reduce the possibility of accidents, comply with all safety laws and ordinances and provide complete instructions covering safe working methods. Each employee has the obligation to observe general safety principles and to practice safety at all times. Any injury or illness, no matter how slight that arises from your employment must be reported immediately to a line manager or HR.

Workers must report all incidents to their line manager, the HR Department at ad@PDCA-co.net, and complete an “Incident Report” from the system/tool within 24 hours of the incident. Workers’ compensation insurance is provided according to state laws governing industrial injuries or disease.

Any equipment that needs to be repaired should be reported to a line manager as soon as possible. No PDCA employee, contractor, or visitor shall be permitted to make use of any device which produces an open flame. This shall include, but is not limited to, candles, oil-burning or kerosene lamps or incense. It shall be the responsibility of the manager hiring the contractor or the employee hosting any visitor to enforce the policy with the non-PDCA personnel.

Please refrain from using space heaters in the buildings as they are against fire code. Contact your immediate line manager if there is an issue with the heating or cooling system. PDCA strives to provide a comfortable and ergonomic working environment for workers.

Other Safety tips and best practices:
Below are a few general safety rules, tips and best practices that every worker must abide by. HOD may post other safety procedures within their departments or work areas:
·                   Avoid overloading electrical outlets
·                   View Signs, and consider them seriously
·                   Use flammable items, such as cleaning fluids, with caution
·                   Walk - don’t run
·                   Climb and descend stairs one at a time
·                   Report to the HOD if one or a co-worker is ill or injured
·                   Ask for assistance when lifting heavy objects or moving heavy furniture
·                   Smoke only in designated smoking areas, and be sure to turn off the cigarette before throwing it into garbage or ashtray
·                   Sit firmly and squarely in chairs that roll or tilt
·                   Do not operate any equipment until after safety requirements have been explained and are understood
·                   Wear appropriate personal protective equipment in designated areas or when doing an activity which requires their use
·                   Keep work areas and aisles clean and orderly
·                   Stack materials to a safe height
·                   Watch out for the safety of fellow workers
·                   Use the right tool for the job, and use it correctly
·                   Check that the electrical devices as AC, lamps, PC, scanners, printers, radios, TV, calculator, copying machines, shredders… are off before leaving the workplace
·                   Better to sterilize the work area after meals

Workers shall be provided, when necessary, with:
·                   Non metallic hard hats and shall be worn, when required, at the work site
·                   Safety glasses meeting international standards are available for use in specified worksite areas such as: hammering, chipping, welding, grinding, electrically powered equipments spray painting, solvents, etc…
·                   Chemical resistant aprons and gloves when handling acids, caustics, and chemicals with corrosive or toxic properties in order to prevent accidental contract with the material
·                   Safety shoes with reinforced toes to be worn by all personnel (if required at the site)
·                   Hearing protection when operating in noisy areas exceeding 90 decibels
·                   Workers will be provided with JHA/JSA for assessing the risks (existing or potential) related to their work, job, tasks, activities, etc.

Security
Security and Health refers to public’s freedom from physical or emotional illness. Below are some general security guidelines which every employee is responsible for. HOD may post other security procedures within their departments or work areas.

PDCA is committed to a safe and secure environment for all customers, workers, and visitors within both its online system/tool and the physical locations. All Systems/Tools are located on the worldwide web. PDCA also has an administrative physical location.

As a vital part of the PDCA security system, each employee is issued an identification badge on the first day of employment that includes the employee’s name and photo. The ID badge is required to enter the buildings and other secured areas as needed. Workers are encouraged to wear the ID badge in plain view while on PDCA property. Workers must be able to produce their ID badge if asked. If an employee’s identification badge is lost or stolen, he or she must obtain a replacement. Workers must report lost or stolen cards to their line manager and the Administration immediately. Upon suspension or termination, workers will be required to return ID badges to HR.

Other Security tips and best practices:
·                   Cash should be securely locked away. When an employee is aware that cash is insecurely stored, the person in charge must be informed immediately
·                   The location of all alarms, fire extinguishers and emergency exits should be known to all workers. Staff should also know how to use them should the need arise
·                   When leaving PDCA premises, desks, cabinet doors, PCs and file desk drawers must be locked with confidential documents secured and all entrances and windows properly locked and secured
·                   In case of an Emergency one should directly contact the emergency hotline and give real info. In case of fire, please review the fire extinguisher (Safety Manual). In case of an earth quaver use only the stairs, sit under a table or at a door step, make sure that nothing that might fall is over the head. In case of emergency evacuation, top priority to save the Company legal file, the Hard Disk/Server and any other critical tool are the responsibility of each person who is originally in charge (in case that person in not available, any person is responsible for such action)
·                   Respect of others privacy and work ambiance (no disturbing is allowed, comments and claims are subject of discussions).

Inclement Weather
The decision to close the offices due to weather conditions will be made by PDCA Management and communicated via e-mail and on the weather line by 6:30 a.m. A separate decision may be made for each location. Please call in using the support numbers provided on www.pdca-co.net under “Contact US”.

If workers are on vacation or sick leave during the inclement weather, they will still be charged their planned vacation time or sick leave even if the offices are closed or there is a delayed opening/early closing. If workers come into the office when it is closed, they are not permitted to bank time for later use. Office closings and delays are a safety precaution.

Remote capability means that workers have access to the Internet and VPN. There are some workers whose work does not require access to a computer to conduct the essential functions of their job (i.e., Facilities). In these situations, workers will not be required to utilize their vacation time or take leave without pay if the offices are closed. All workers should have the capability to work remotely, with the exception of positions in the Facilities department . All other workers are expected to work.

• If PDCA offices are open, but workers decide they are unable to make it into the office safely, they must contact their line manager and must utilize their vacation time if they are unable to work. If workers do not have a vacation balance, the time is considered leave without pay.
• If PDCA announces a delayed opening, the offices will open at 10:00 am., unless otherwise notified. Workers are expected to work remotely during this time. If they do not have remote capability, they will not be charged vacation time for the work time missed. Workers are permitted to follow the “Friday” dress code for delayed openings due to inclement weather.
• If PDCA offices are closed, workers are expected to work remotely for the entirety of their shift. If they choose not to work, they must take vacation time if available. If there is no vacation balance, it will be recorded as leave without pay.
All workers that conduct the breadth of their work on a computer are encouraged to take their laptops home during the winter months.

Control of Substances Hazardous to Health
Hazardous materials are stored in approved safety container and handled in a manner as specified by the manufacturer or prescribed by relevant authorities.
Only properly trained and equipped personnel will handle hazardous materials.

Workers shall be informed of potential hazards and appropriate steps will be taken to reduce hazards and be prepared for emergency situations.

An assessment shall be made for every operation involving hazardous substances, and will be recorded a hazardous and inflammable substances assessment method statement for which shall be submitted to the QM prior to the delivery and use of the substance.

All safety, health and environmental and other notices and signs will be clearly displayed and written in both local and English languages.

First Aid and Medical Attention
Comprehensive first aid kits are available (on site) at all times and will be placed in clearly identified places. The first aid kit contains the necessary medication for minor headaches, stomachaches, slight injuries, etc. A trained employee in first aid is available with appropriate identification.

Workers are required to report immediately after any accident which occurs during working hours on the premises, while on the road, or at work sites. Particular arrangements for calling a doctor and transporting injured person to hospital (when necessary) and relevant information are prominently displayed in the office.

Fire Protection and Prevention
Fire protection shall be in complying with regulations by specialized authorities. When on site, personnel will be provided with fire prevention and evacuation plan and this will be updated from time to time and when needed.

All temporary accommodation and stores will be provided with smoke detectors and fire alarms,
·                   Fuel storage will not be permitted in work areas,
·                   Fire extinguishers are placed close to areas working in equipment with open flame,
·                   Fuel burning engines must be shut off while being refueled,
·                   Flammable substances and materials will be stored in proper containers and rooms.

Using of Ladders
Manufactured ladders shall meet the applicable safety regulations for wood or metal ladders. Straight ladders will be equipped with non-skid safety feet. Ladders rungs and steps will be kept clean free of grease and oil.

Electrical Safety
All temporary electrical installations, tools and equipment shall comply with current regulations dealing with on-site electrical installations. A permit to work system shall be established for work on energized circuits of any voltage. Only authorized personnel are allowed to work or repair electrical installations and equipment.

·                   When portable are semi-mobile equipment operates at voltages in excess of 110 volts, the supply shall be protected by a residual current device (RCD)
·                   All static electrically powered equipment, including motors, transformers, generators, welders, and other machinery will be properly earthed, insulated and protected by a ground fault interruption device
·                   Lamp holders on festoon lighting will be molded to flexible cable and be of the screw type
·                   Clip on guards will be fitted to each lamp unit. All tungsten halogen lamps will be fitted with a glass guard to the element. These lamps will be fixed permanently at high level
·                   The safe design capacity of any piece of equipment shall not be exceeded nor shall the equipment be modified in any manner that alters the original factor of safety or capacity
·                   Mobile equipment will be fitted with suitable alarm and motion sensing devices, including backup alarm when required

Environmental and Health Requirements
As per our knowledge, it is required to comply with all environmental laws, rules, and regulations for materials, including hazardous substances, any such materials shall not be dumped, released or otherwise discharged or disposed without the authorization of the QM.

All necessary measures will be taken to limit pollution from dust and any windblown materials during the works, including damping down with water on a regular basis during dry climate conditions.

Waste solvents, petroleum products, toxic chemicals or solutions shall not be disposed in the city drainage system or watercourses. These types of waste shall be taken to an approved disposal facility regularly.

The site and any ancillary areas used and occupied for performance of the works shall be maintained clean, tidy and rubbish free condition at all times.

PDCA shall comply with statutory and municipal regulations and requirements for the disposal of rubbish and waste, and shall provide suitable metal containers for the temporary storage of waste. The rubbish containers shall be removed from site as soon as they are full.

PDCA shall ensure that the work is conducted in a manner so as to comply with all restrictions of the authorities having jurisdiction as they related to noise. In all cases, PDCA will adopt the best practicable means of minimizing noise.

Compressors, percussion tools and vehicles shall be fitted with effective silencers of a type recommended by the manufacturers of the equipment. Noisy appliances shall not be used during days of rest or after normal working hours without the consent of the QM.

All work in public areas shall be carried out to minimize disturbance and avoid dangers to the public.

If applicable, Provide details of measures and temporary works to minimize disturbance and safeguard and public which will include temporary diversions, safety barriers, screens, signs, lighting, watchmen and arrangements for control of traffic and pedestrians and advance warning to be given to the public, details of the availability of necessary resources.

For works, involving long lengths of trencher to be carried out at one time. Personnel are notified and the location and duration of work for trenches and excavation with the issuance of an excavation permit signed by QM.

Obtain permission from relevant authorities including the police when required.

Erect all temporary works such as barriers, warning signs, lighting, etc…

Other Health and Safety Regulations:
Ergonomics: is the study of human interaction with tasks, equipments, tools, and the physical environment. Ergonomics should be considered when assigning new task and hiring new people.

Light: it should be considered when working in dark places and when working at night or when the light is excessive. Any measures could be taken to provide a good and healthy lighting environment.

Sound: it should be considered when working in noisy areas exceeding 90 decibels. Any measures could be taken to provide a good and healthy sound environment.

Unsafe Personnel Actions and Workplace Violence: anyone who will break these Safety, Security and Health rules in this Safety Manual will be considered as a threat and his/her job will be terminated (as per the Standard of Conduct).

PDCA will provide a clean, safe, secure and healthy work place and will provide the best equipment/tools possible. Workers are expected to work safely, to observe all safety and security rules and to keep the premises clean and neat.

Workers must remember that failure to adhere to these rules and any other safety and security rules posted by management will be considered serious offenses. Carelessness and endangering oneself or others may lead to disciplinary action including possible dismissal.

“SAFETY FIRST”

STANDARDS OF CONDUCT

By accepting employment at or with PDCA, a worker has accepted a responsibility towards the company, its clients, stakeholders and to his/her fellow workers to adhere to certain rules of behavior and conduct. The purpose of these rules is not to restrict the employee´s rights, but to ensure they understand the level conduct that is expected of them. When each person can fully depend upon fellow workers to follow the rules of conduct, PDCA will be a better place for everyone to work.

REPORTING PROCEDURES/ENFORCEMENT
In any situation, workers are expected to report immediately to their line manager or the HR Department. Reports can be made anonymously, and all reported incidents will be investigated. Reports or incidents warranting confidentiality will be handled appropriately and information will be disclosed to others only on a need-to-know basis. All parties involved in a situation will be counseled and the results of investigations will be discussed with them. PDCA will actively intervene at any indication of a possibly hostile or violent situation.

Threats, threatening conduct, or any other acts of aggression or violence in the workplace will not be tolerated. Any employee determined to have committed such acts will be subject to disciplinary action, up to and including termination. Non-workers engaged in violent acts on PDCA premises will be reported to the proper authorities and may be fully prosecuted.

CODE OF CONDUCT
PDCA management has established a set of rules and regulations to help everyone work together efficiently, effectively, safely and harmoniously. PDCA Management believes that when these rules and regulations are understood and abided by, all workers can maintain the highest standards of quality service to the company and its stakeholders.

Welcomed and expected conduct:
•        Act professionally, accurately and in an unbiased manner,
•        Do not represent conflicting or competing interests, or disclose to any client or employer any relationships that may influence their judgment,
•        Do not discuss or disclose any information unless required by law or authorized in writing by the client,
•        Do not intentionally communicate false or misleading information that may compromise the integrity of work, and
•        WORKERS SHOULD RESPECT AND ABIDE BY:
1.      The hierarchy: communication line, coordinating, delegating, assigning, etc.
2.      The position: delegation, duties, job description and specifications, JHA/JSA, etc.
3.      The MS: forms, databases and templates, processes, etc.
4.      The reporting system/tool, documentation, etc.

Prohibited Conduct: PDCA does not tolerate any type of workplace violence (physical, emotional, or mental) committed by or against workers, vendors, or customers. Workers are prohibited from making threats or engaging in violent activities. This list of behaviors, while not inclusive, provides examples of conduct that is prohibited:
•        Causing physical injury to another person;
•        Making threatening remarks;
•        Aggressive or hostile behavior that creates a reasonable fear of injury to another person or subjects another individual to emotional distress;
•        Intentionally damaging employer property or property of another employee;
•        Possession of a weapon while on company property or while on company business, except as permitted by law;
•        Committing acts motivated by, or related to, sexual harassment or domestic violence; or
•        In addition to any of the conducts/behaviors listed in this document.

Workplace Violence: PDCA provides a safe workplace for all workers. To ensure a safe workplace and to reduce the risk of violence (including but not limited to harassment, retaliation, insults, unprofessional acts, illegal behaviors, aggressiveness, threats, etc.), all workers should review and understand all provisions of this workplace violence policy.

Dangerous/Emergency Situations: Workers who confront or encounter an armed or dangerous person should not attempt to challenge or disarm the individual. Workers should remain calm, make constant eye contact and talk to the individual. If a line manager can be safely notified of the need for assistance without endangering the safety of the employee or others, such notice should be given. Otherwise, cooperate and follow the instructions given.

Dress Code: In an effort to provide an atmosphere of professionalism, PDCA will adhere to a formal dress policy. All workers should dress in a manner that is in keeping with the business and professional contact that PDCA subscribers expect.

Housekeeping: Workers are expected to keep their work areas, restrooms, vehicles and kitchenettes clean, neat and organized at all times.

Personal phone calls: To avoid work interference, workers are expected to keep personal phone calls to a minimum, and mobiles kept as silent as possible. Emergency calls may be made at any time.

Smoking: Smoking is prohibited at all PDCA premises and property and while working at the client premises.

Theft: Property theft is the unauthorized use of company services, facilities, or property for personal use. PDCA considers stealing a serious offense, and any type of theft will not be tolerated.

No item purchased or supplied by PDCA should ever be removed from company premises, its retail outlets or branches without expressed written authorization from the QM. This applies to all company properties and funds.

All workers are expected to look out for theft and to report any suspected activities to the Administration. Any information about theft in the workplace will be kept confidential.

The penalty for any incidence of unauthorized possession or removal of company property, regardless of the employee´s past record, seniority, or value of the item, will be severe. Workers found stealing from the company will be subject to disciplinary action including possible dismissal and prosecution (as per the Standard of Conduct).

Property equipment/MATERIAL and care: It is the employee´s responsibility to understand the operation of equipment/material needed to perform their duties, and to take good care of them.

If any employee finds equipment/material not working properly or is unsafe, they must notify the Administration to make immediate arrangements for its repair.

It is the employee’s responsibility not to damage or destroy PDCA property issued to them for use during their work. Workers must keep the equipment/material in proper working order.

It is also the employee’s responsibility to cover the cost of any lost or damaged items. The value of any property issued and not returned may be deducted from their paychecks (as per the Standard of Conduct). Workers may be required to sign a Reception Note (F-AD-RNT-01) for this purpose.

Personal Use of Company Property: The personal use of company equipment, materials, tools, resources and premises is not allowed including but not limited to the followings:
·                   Excessive Internet Use (Chat, online games, facebook …)
·                   Printers, Faxes, Photocopy machine(s), Scanner(s), Shredder, Binders, Laminating…
·                   To remain in the office after hours with no official assignment (overtime)
·                   Uniform (if exist)
·                   Consumables as paper, CD, envelops, pens, business cards, folders…
·                   Etc.

Workers with urgent or exceptional cases must obtain permission from the Administration.

UNACCEPTABLE ACTIVITIES
Discipline is the state of personnel self-control and orderly conduct that indicates the extent of genuine teamwork within PDCA. Disciplinary Actions involves a penalty against a worker who fails to meet the requirements in this or any other document.

It is expected of each worker to always act responsibly. However, to avoid any possible confusion, the list below includes activities PDCA considers unacceptable. Avoidance of these activities is beneficial to everyone. Questions concerning unacceptable activities should be directed to the HOD or to the Administration

Nevertheless, PDCA reserves the right to determine, in its sole and exclusive discretion, whether an employee has committed one of the offenses identified in this list or another offense that warrants discipline, and to determine the degree of discipline that may be appropriate. Occurrences of any of the below violations, due to their seriousness, may result in serious disciplinary actions or possible termination

All employment (including contractual) at PDCA is "at will" and may be separated by the employee or the company at any time, with or without cause, with or without prior notice or warning.

The following is a list of specific examples of conduct that may result in disciplinary action, up to and including termination (this list is not all inclusive or exclusive):
·                   Failure to fulfill the job description
·                   Violating PDCA Internal regulations or its client requirements
·                   Failure to protect “proprietary information” that could compromise PDCA or its workers or be considered harmful to PDCA´s client relations or reputation;
·                   Absenteeism from work without legitimate reason or Unauthorized or inexplicable departure from job location (training venue or client site) or PDCA premises
·                   Leaving work before the end of a working day, not being ready to work at the start of a working day, or cessation of work before the time specified without the written approval of the HOD, temporarily leaving work during working hours without the permission of the HOD, or failure to report an absence or late arrival and excessive absenteeism, tardiness or lateness
·                   Dishonesty. Willful falsification or misrepresentation on an application for employment or other work records; lying about sick or personal leaves, falsifying reasons for a leave of absence or falsifying personal data requested by PDCA for company records or other documents
·                   Disclosing confidential information and giving confidential or proprietary internal information. Breach of confidentiality of personnel information or conducting work for another business
·                   The employee will be considered to have breached PDCA internal regulations when he/she award contracts/deals, or interfere by any mean such as releasing information to award a contract to a contractor/supplier. The penalty of this violation is dismissal from the company. The company reserves the right to claim compensation for damage incurred from such a violation
·                   Impersonating the identity of another person and/or submitting forged certificates or documents for the purpose of bringing personal benefit or determent to others
·                   Insubordination. Refusing to obey instructions properly issued by PDCA management pertaining to his/her work. Refusing to assist on any special assignment. Refusal to do the work assigned.
·                   A final conviction by a court of a felony or misdemeanor touching on honor and public morality
·                   Unauthorized possession of dangerous or illegal firearms, weapons or explosives on company property or while on duty
·                   Found drunk or under the influence of narcotics (drugs and/or alcohol), mentally influencing factors or committing an act which is improper to public morals on the premises of PDCA work time
·                   Using, possessing and/or selling controlled substance drugs or alcohol, in any quantity while on the company premises
·                   Assaulting the employer, the HOD, one of the employee’s superiors, any employee or any other person during work or due thereto by beating or humiliating
·                   Obscene or abusive language and sexual harassing manager, employee or client; indifference or rudeness toward a client or fellow employee; and any disorderly/antagonistic is forbidden in the company premises otherwise it is considered a workplace violence
·                   Engaging in criminal conduct, acts of violence, assault, threats to any person during work or when representing PDCA. These include but are not limited to beating, humiliating, fighting or provoking a fight on company property, committing an error resulting in serious material loss to PDCA
·                   Negligence or any careless action which endangers the life or safety of another person
·                   Engaging in an act of sabotage, willfully or with gross negligence, causing the destruction or damage to company property or the property of fellow workers, clients, suppliers or visitors in any manner, or any error which results in serious material loss to the company
·                   Theft of company property or the property of fellow workers. These include the unauthorized possession of any company property, including documents and records, from the premises without prior written permission from the management. Unauthorized use of company equipment or property for personal use and/or using company equipment for profit
·                   Excessive use of the company´s property for personal manners especially the phone for personal calls (incoming or outgoing). Personal phone conversation is preferred to be kept to the minimum (especially the internal ones and the one done from a cell/hot line)
·                   Disrespecting the law by driving the company vehicles in speed, careless and/or all other regulations or without valid driving license
·                   Malicious gossip and/or spreading rumors which interfere with another workers´ job; willfully restricting work output or encouraging others to do the same
·                   Secret or illegal payments, favors, kickbacks, bribes or any other payment in any form whatsoever, to obtain benefits for the company or a third party
·                   Failure to report receiving gifts from clients or receiving gift without written approval
·                   Unsatisfactory or careless work. Failure to meet PDCA standards and making mistakes due to carelessness or failure to get necessary instructions. Inefficient or careless performance of duties and failure to maintain high standards of operation and service.
·                   Failure to maintain a neat and clean appearance as established by PDCA dress code; any departure from accepted conventional modes of dress or wearing improper clothing
·                   Creating or contributing to unsanitary conditions
·                   Smoking in restricted areas or taking excessive smoking breaks
·                   Buying company merchandise for re-sale
·                   Covering and not reporting fault of a fellow coworker which affect PDCA
·                   Chewing gum is forbidden on and off premises during work
·                   People who get any tickets (due to law violation of the operation country) while being in PDCA vehicle will pay the ticket or it will be deducted from their monthly paycheck or commission
·                   Hands in the pockets or unprofessional body position or improper act is strictly forbidden while being with a Customer or Supplier or fellow employee, subordinate or supervisor

DISCIPLINARY ACTIONS
While PDCA may separate an employee or IC “at will”, the company reserves the right to take any or all of the following disciplinary actions against the worker in the event of violating applicable laws and regulations and/ or any PDCA rule, policy, procedure, expectation, or guideline. PDCA may deem appropriate in its sole discretion to add Other action(s) such as Persecution and/or Legal action.

Progressive Disciplinary actions resulting of unacceptable behavior will be dealt with in the following manners, depending on the type of violation:

Agreement Termination (AT)

Probation Work Suspension with or without pay – PT or FT will be suspended in term of days (DS)

Probation or Work Suspension with or without pay –IC will be suspended in term of number of jobs or for a duration of time (JS)

Informal warning – Verbal Warning or Counseling (WW)

Causes and Reasons (Offences and Disciplinary Action)	A	B	C	D
Failure to maintain a neat and clean appearance	WN	1 DS/JS	2 DS/JS	WW
Creating or contributing to unsanitary conditions	WN	1 DS/JS	2 DS/JS	WW
Chewing gum	WN	1 DS/JS	2 DS/JS	WW
Hands in the pockets or unprofessional body position or improper act	WN	1 DS/JS	2 DS/JS	WW
Smoking in restricted areas or taking excessive smoking breaks	WN	1 DS/JS	2 DS/JS	WW
Absenteeism from work without legitimate or false reason/ Excessive absenteeism	WN	1 DS/JS	3 DS/JS	WW
People who get any tickets (due to law violation of the operation country) while being in PDCA vehicle	DS/JS	DS/JS	DS/JS	WW
Found drunk or under the influence of narcotics	WN	1 DS/JS	WW	AT
Assaulting anyone related to work	WN	1 DS/JS	WW	AT
Failure to report receiving gifts from clients or receiving gift without written approval	WN	1 DS/JS	WW	AT
Excessive use of the company´s property for personal manners	WN	3 DS/JS	WW	AT
Unsatisfactory or careless work	WN	3 DS/JS	WW	AT
Engaging in an act of sabotage causing the destruction or damage to company workers, clients, suppliers or visitors property	WN	3 DS/JS	AT
Failure to fulfill the job description	WN	WW	WW	AT
Award contracts/deals, or interfere by any mean in such action	WN	WW	WW	AT
Driving the company vehicles in speed, careless or without valid driving license	WN	WW	WW	AT
Covering and not reporting fault of a fellow coworker which affect the Company	WN	WW	WW	AT
Using, possessing and/or selling controlled substance	WN	WW	AT
Malicious gossip and/or spreading rumors	WN	WW	AT
Insubordination	1 DS/JS	2 DS/JS	3 DS/JS	AT
Obscene or abusive language and sexual harassing and workplace violence	3 DS/JS	WW	AT
Violating PDCA Internal Regulations and/or client requirements	WW	WW	AT
Impersonating the identity of another person and/or submitting forged certificates	WW	WW	AT
Engaging in criminal conduct, acts of violence, assault, threats to any person	WW	WW	AT
Negligence or any careless action which endangers the life or safety of another person	WW	WW	AT
Buying company merchandise for re-sale	WW	WW	AT
Secret or illegal payments to obtain benefits for the company or a third party	WW	AT
A final conviction by a court of a felony or misdemeanor	AT
Possession of dangerous or illegal firearms, weapons or explosives	AT
Failure to follow or abide by safety and environmental requirements, policies, guidelines	AT
Was directly or indirectly involved or subject to cause an injury, incident, accident, etc.	AT
Theft of company property or the property of fellow workers	AT
Disclosing confidential information for any other party or Failure to protect “Proprietary Information”	AT

·        • Formal warnings – Verbal Written, Written Notice, Final Written Warnings/Counseling Forms- (WN)

Although one or more of these steps may be taken in connection with a particular employee, PDCA may separate the employment relationship without following any particular series of steps whenever it determines, in its sole discretion, that such action is appropriate.

Disciplinary actions can also include fines, suspension from work and other procedures that would be appropriate according to the situation. A written warning will include the reasons for the dissatisfaction and the support evidence and will be registered at the Ministry of Labor and/or any other body. The employee will have the opportunity to defend their actions and rebut the manager’s charge.

Note:
As shown in the following table, the Causes and Reasons (Offences and Disciplinary Action) are reset each year for the first 3 categories, unless one has attended in the previous year the stage “C”, his/her work will be terminated (AT).

If a person got 3 Offences and Penalties of the same category (eg “A”), any additional Offences and Penalties of the same category, then the additional Offences and Penalties that he/she will get is the highest of the next category (eg “B”).

Three written warnings (WW) within a 12-month period will lead to termination (AT).

ACCEPTED STANDARDS OF PROPER BEHAVIOR INCLUDE PUNCTUALITY, MAKING A DEDICATED EFFORT TO THE JOB TASKS, RESPECTFUL TREATMENT OF CO-WORKERS AND COOPERATING WITH OTHERS.

CONFIDENTIALITY POLICY

Confidential Information
The nature of PDCA business requires all workers to be custodians of confidential information. In order for PDCA to maintain the trust and respect it has earned from its clients, suppliers and staff, every PDCA employee must keep all information regarding all business conducted within the office or related to any office activity to them.

Workers are required to keep all office related information especially system/tool PASSWORD confidential and protected at all times, they should not be disclosed to non-PDCA personnel or to PDCA colleagues who have no reasonable need to know (check the “Password Rules” in this document).

Employment with PDCA assumes an obligation to maintain confidentiality, even after leaving the company. As mentioned in the confidentiality statement.

Any disclosure of confidential information to any unauthorized parties could result in dismissal without prejudice to PDCA right to claim compensation for damages incurred because of such disclosure (as per the Standard of Conduct).

No one is permitted to remove or make copies of any of PDCA or its client’s records, reports, or documents without prior written management approval.

ELECTRONIC RESOURCES & PAPER DOCUMENTS
1- Computer Use for Business Purposes
PDCA IT infrastructure, including personal productivity Systems/Tools such as laptops, desktops, software packages, etc., is critical to PDCA ability to serve its customers and is provided to workers (IC, Trainer, employees, etc.) at PDCA expense to assist them in carrying out PDCA’s business. These Systems/Tools permit PDCA workers to perform their jobs, share data and information, and communicate with each other internally and with selected outside companies and individuals that the company, in its sole discretion, decides should be communicated with or connected to the company network.

PDCA treats all information transmitted through or stored in the system/tool, including e-mail messages, as business information.

PDCA has the capability to access, review, copy, and delete any information transmitted through or stored in the system/tool, including e-mail messages. PDCA reserves the right to access, review, copy, or delete all such information for any purpose and to disclose it to any party (inside or outside the company) it deems appropriate.

Those files containing the personal information of an employee as a result of the employee making incidental use of the computer for personal purposes, including transmission of personal e-mail messages, will be treated no differently than other files. PDCA reserves the right to access, review, copy, or disclose them for any purpose. Accordingly, workers should not use the computer system/tool to send, receive, or store any information that they wish to keep private. Workers must exercise a greater degree of caution in transmitting confidential PDCA information on the computer system/tool than they take with other means of communicating information (e.g., written memoranda, letters, or phone calls, etc.) because of the reduced human effort required to redistribute information electronically.

Passwords
Workers must use passwords as made available by the company computer system/tool to protect against unauthorized access to files on which they are working. Passwords must conform to the policies described in the “Password Rules” in this document. Never disclose personal or system/tool passwords to anyone other than an authorized company representative.

Disks and Back-up Tapes
If Applicable, do not leave disks or backup tapes that contain confidential information out in the open. Keep them locked in drawers or file cabinets.

Laptop Computers
As a general rule, confidential information should never be stored on a laptop or notebook. PDCA information should always be stored on a file server, SharePoint, or other provided storage location that is within the company network and is being backed up regularly by IT. If a valid reason to temporarily store confidential information on a laptop exists, which should be approved by management (in written), extra precautions and care is required.

must be exercised when taking that confidential information out of the office on a notebook or laptop computer. Never leave a company laptop computer unattended while offsite.
All workers are expected to bring the PDCA laptop computer home after their shift, as part of PDCA Business Continuity Plan.

Copyrighted Information
Use of PDCA equipment to copy and/or transmit any software programs, documents, or other information protected by the copyright laws is prohibited by federal law and may subject you and PDCA to civil and criminal penalties. Never copy software programs of any kind without express authorization from company representatives. Never accept copies of any software program from other workers without approval from authorized company representatives.

Installation of Software
The installation of personal software on any company issued device is prohibited.

Viruses
Workers should ensure that PDCA approved virus checking software is installed and always running on the PDCA issued computer. Workers must never disable this software and must never insert any disks or other external hard drive into the company issued computer. Further, workers must not download any files from outside sources without first checking them for viruses. Workers may use thumb drives, but should exercise the utmost caution and discretion in doing so.

Other Prohibited Uses
PDCA’ computers, networks, communications systems/tools, and other IT resources are intended for business purposes only (except for limited personal use as described below) during working time and at all other times. Each user is responsible for using these resources and systems/tools in a productive, ethical, and lawful manner.

PDCA’ policies prohibiting harassment apply to the use of the company´s IT resources and communications systems/tools. No one may use any communications or computer system/tool in a manner that may be construed by others as harassing or offensive based on race, color, national origin, sex, sexual orientation, age, disability, religion, genetic information, status as a covered veteran, or any other characteristic protected by federal, state or local law.

The use of company IT resources and communications system/tool by a worker shall signify his/her/it understanding of, and agreement to the terms and conditions of this document and PDCA’s Management System as a condition of employment.

To ensure that workers comply with these policies, PDCA may conduct periodic audits of the computer system/tool, including individual personal computers, disks or backup tapes. An worker´s failure to comply with these policies may lead to disciplinary action.

2- Electronic Resources
Due to the significant risk of harm to the company´s electronic resources, or loss of data, from any unauthorized access that causes data loss or disruption, workers should not bring personal computers or data storage devices (such as CDs/DVDs, external hard drives, USB / flash drives, "smart" phones, iPods/iPads/iTouch or similar devices, laptops or other mobile computing devices, or other data storage media) to the workplace and connect them to PDCA electronic system/tool unless expressly permitted to do so by IT.

To minimize the risk of unauthorized copying of confidential company business records, customer records, and proprietary information that is not available to the general public, any employee connecting a personal computing device, data storage device, or image-recording device to the company networks or information systems thereby gives permission to PDCA to inspect the personal computer, data storage device, or image-recording device at any time with personnel and/or electronic resources of the Company´s choosing and to analyze any files, other data, or data storage devices or media that may be within or connectable to the data-storage device in question in order to ensure that confidential company business records, customer records and proprietary information have not been taken without authorization. Workers who do not wish such inspections to be done on their personal computers, data storage devices, or imaging devices should not connect them to company computers or networks.
Violation of this policy, or failure to permit an inspection of any device under the circumstances covered by this policy, shall result in disciplinary action, up to and possibly including immediate termination of employment, depending upon the severity and repeat nature of the offense. In addition, the employee may face both civil and criminal liability from the Company, from law enforcement officials, or from individuals whose rights are harmed by the violation.

3-E-mail
Electronic mail (e-mail) is an important tool that greatly enhances productivity and communication with and within PDCA. The use of e-mail shall be generally limited in scope to support business needs and should be used in an ethical and legal manner.

User Accountability
Each employee e-mail account is associated with one individual in order to ensure that unique identities can be maintained and that communications can be effectively monitored. All workers are held accountable for their communications via PDCA communication systems/tools, including e-mail. No messages will be transmitted under an assumed name, and users must not attempt to obscure the origin of any message. Passwords to e-mail accounts must not be disclosed or shared (Check the “Password Rules” in this document).

Mail Systems
Communications systems/tools, including e-mail, are to be used for the purpose of conducting PDCA business. The current acceptable e-mail systems are PDCA MS-Exchange server. Limited personal use of the communications systems/tools is permitted, as long as such use does not interfere with business objectives.

Business and Personal E-mail System Usage
The company e-mail systems should not be used in a manner that will cause degradation of performance or hamper the ability of others to access and use such systems (e.g., distributing chain letters and large attachments).

Message Content and Public Representations
Workers must comply with the following guidelines while using company e-mail systems:
• PDCA has a zero-tolerance policy concerning obscene communications. E-mail should be free of obscene, harassing, defamatory language or attachments.
• E-mail must not include rumors or unwarranted speculation. Avoid incomplete, unbalanced, and unprofessional e-mail content.
• E-mail is primarily for business use. Personal communications should be limited.

The following uses are not permissible:
• Derogatory, obscene, defamatory, and harassing communications (including but not limited to the transmission and viewing of sexually explicit material, humor that is off-color or contains racial or ethnic slurs, and abusive, or profane language).
• Fraudulent communications.
• E-mail used for commercial, charitable, religious, or partisan political purposes.
• Transmission of trade secrets, or privileged communications.
• Unauthorized copying and distribution of copyrighted material.
• Communications that violate or infringe the rights of others.
• Automatic forwarding of e-mail outside of the company.

It is the responsibility of every employee to refer to PDCA IT and other Policies for additional details on acceptable use of company computing facilities.

The following guidelines should be followed for using e-mail signatures in an appropriate, ethical, and professional manner.
• E-mail and signatures should be professional and strictly relate to company business.
• E-mail signatures must be consistent with the standards and format set forth by PDCA.
• Refrain from including other slogans, quotes, or other statements in the signature portion of your e-mail messages.

This policy is not intended to restrict communications or actions protected or required by state or federal law.

Harassing or Offensive Material
PDCA systems/tools may not be used for transmittal, retrieval, or storage of any communication which is of a discriminatory, harassing, defamatory, or threatening nature, or which is derogatory to any individual or group. In addition, PDCA systems/tools may not be used for transmittal, retrieval, or storage of any obscene or offensive communications or for any other purpose that is illegal or against company policy or contrary to the company’s interest. Offensive and/or unprofessional communications and any other violations of the policies and/or internal controls may result in disciplinary action, including letters of reprimand, fines, notification to appropriate law enforcement officials, and termination of employment.

Monitoring and Privacy
E-mails and computer files are the property of PDCA. Workers should not expect their messages to be kept private. At any time, management may access information and files, including e-mails, and reserves the right to monitor and review employee usage of the company’s systems/tools to ensure that they are being used in compliance with company policies. The company reserves the right to review or inspect e-mail and files on company computer systems periodically, as deemed necessary and appropriate and to disclose the contents thereof to law enforcement or other third parties with or without notice to the sender or the recipient.

PDCA normally uses software for e-mail supervision, unless extraordinary circumstances warrant other types of supervision, as determined on a case-by-case basis by PDCA Management.

4- E-mail Management
The E-mail Management Policy provides workers with guidelines and procedures that enable the company to have:
• An accurate accounting of the important records that the company maintains,
• An understanding of how and by whom records are managed, and
• A means for appropriate handling of record retention, hold and disposal.

Compliance with this policy is very crucial. Non-compliance may result in disciplinary action for workers who do not comply, including potential termination for violators, and can lead to legal, regulatory, and cost-control issues for PDCA. Additionally, violation of federal and state statutes regarding improper document destruction and obstruction of justice may result in the imposition of significant fines and terms of imprisonment for individuals who engage in such activity.

Information Systems/Tools and e-mails
All computers and related equipment (information and the e-mail systems) are the exclusive property of PDCA. As such, the following rules and guidelines apply to all workers:
·                   All such systems/tools are to be used for Company business only. They are not to be used for personal matters, for any non-Company purpose, or in any way that may be disruptive to PDCA business.
·                   Personal e-mail is not permitted
·                   E-mail is not private. Authorized Company personnel have unrestricted access to any and all information stored on the Company’s information system, including e-mail.
·                   One may not attempt to gain access to another person file or e-mail messages without the workers’ express permission. However, authorized Company personnel have unrestricted access to any and all information stored on the Company’s information system including e-mail.
·                   Displaying, sending, or receiving sexually explicit images, messages or content is not allowed. Displaying, sending, or receiving ethnic slurs, racial epithets or anything that may be construed as harassment or disparagement of others based on their race, national origin, sex, age, disability, religious beliefs, citizenship, marital status, veteran status or sexual orientation is not allowed.

5-Internet Usage
Access to the Internet through PDCA is for company business use. Users granted this access must adhere to strict guidelines concerning the appropriate use of the web. Users who violate the provisions outlined in this document are subject to disciplinary action up to and including termination. In addition, any inappropriate use that involves a criminal offense will result in legal reporting.

Acceptable Use of Internet Access
Access to the Internet is specifically limited to activities in direct support of official PDCA business. In addition to access in support of specific work related duties, the PDCA Internet connection may be used for related purposes (research).

If any user has a question of what constitutes acceptable use he/she should check with his/her line manager for additional guidance. Management or supervisory personnel shall consult with the IT for clarification of these guidelines.

Inappropriate Use of Internet Access
Internet access shall not be used for any illegal or unlawful purposes. Examples of this would be the transmission of violent, threatening, defrauding, pornographic, obscene or otherwise illegal or unlawful materials.
·        Use of company e-mail or messaging services shall be for the conduct of PDCA business only. These services shall not be used to harass, intimidate or otherwise annoy another person. Please see the E-mail policies regarding the use of e-mail.
·        Internet access shall not be used for private, recreational, or other non-company related activity.
·        PDCA Internet connections shall not be used for commercial charitable, religious, or partisan political purposes.
·        Use of the company Internet access shall not be for personal gain such as selling access of an PDCA user login.
·        Internet access shall not be used for or by performing work for profit with PDCA resources in a manner not authorized by PDCA.
·        Users shall not attempt to circumvent or subvert security measures on PDCA network resources or any other system/tool connected to or accessible through the Internet.
·        PDCA users shall not use Internet access for interception of network traffic for any purpose unless engaged in authorized network administration.
·        PDCA users shall not make or use illegal copies of copyrighted material, store such copies on company equipment, or transmit these copies over the company’s network.
·        PDCA users shall not use Internet access for streaming video or audio for personal entertainment.

Security
• Users who identify or perceive an actual or suspected security problem shall immediately contact Information Security at ad@pdca-co.net .
• Users shall not reveal account password (Check the “Password Rules” in this document) or allow another person to use their account. Similarly, users shall not use the account of another user.
• Access to PDCA network resources shall be revoked for any user identified as a security risk or who has a demonstrated history of security problems.
• User awareness is a critical part of the cyber security program at PDCA; as such, users will be required to take part in training as an expectation to perform a critical role in protecting our customers, workers, and the organization from cyber threats.

Penalties
Any user violating this document or applicable state or federal laws is subject to disciplinary action including but not limited to termination and/or notification to the appropriate law enforcement agencies. The company reserves the right to review and monitor Internet usage periodically or as deemed necessary and reserves the right to disclose the results of this monitoring to law enforcement or other third parties with or without notice to the employee.

User Compliance
All terms and conditions as stated in this document are applicable to all users of the network and the Internet connection. These reflect an agreement of all parties and should be governed and interpreted in accordance with the laws of the state where the employee is located

6-Password Rules
Everyone who has a password on any file should send the list of work related passwords to the Administration. PDCA management do not accept any secured file hidden or with restricted access to the Administration (Business Continuity).

Setting up passwords
·        All systems/tools require a personalized or customized password for access.
·        Passwords are case sensitive.
·        The password must be at least 8 characters long AND must consist of a mixture of Uppercase, Lower Case, Number, and Special Character (limited to:!,@,#,&,$,%).
·        When setting up the password, its strength (Strong, Moderate, Weak) will be determined by the system/tool.
·        Both Passwords entered in “New Password” and “Re-enter New Password” should be identical - in this case a green checkmark icon will appear next to both fields (if not, an error red icon will appear. In such case, it is better to re-enter both fields prior to saving).
·        It would be better not to use an obvious or easily guessed password. Avoid anything resembling your name, email, company, job, hobbies, address, birthday, phone number, Social Security number, or other personal attributes. Also do not use a word that can be found in the dictionary, consist of date or keyboard sequences, e.g., QWERTY.
·        To safeguard password: either commit it to memory, do not post it, do not keep it in an obvious place or an unsecured area (such as writing it on sticky notes, desk blotters, calendars, or storing it online where others can access it). Never share passwords or access credentials. It is also recommended to track your passwords and keep them secure and retrievable.
·        At a minimum, passwords must be changed every year, yet it is recommended to do so every sixty (60) days.
·        Automated mechanisms are in place for password-based authentication to ensure that the system:
1.      Protects passwords from unauthorized disclosure and modification when stored and transmitted;
2.      Prohibits passwords from being displayed when entered (the password characters are shown as bullet points; to view the password, one must click on the view icon next to the field);
3.      Enforces automatic passwords expiration such as periodic password changes (the system will push an annual password change request for account users);
4.      Prohibits password reuse for a specified number of generations; after 3 unsuccessful attempts, the password will reset automatically.
·        For additional security:
1.      Reusing a Password cannot be identical to the last 3 passwords.
2.      Passwords cannot be copied and pasted.
3.      Do not use the “Remember Password” feature in any application.
4.      It is recommended to use a password that can be typed quickly, without having to look at the keyboard. This makes it harder for someone to memorize your password if they observe you while you are typing it on the keyboard (also known as “Shoulder Surfing”).

Password Protection Policies
·        DO use a password that contains alphanumeric characters and include punctuation, where supported by the operating system.
·        DO use a password with mixed-case letters. Do not just capitalize the first letter, but add uppercase letters throughout the password.
·        DO use at least eight characters.
·        DO use a seemingly random selection of letters and numbers.
·        DO use a password that can be typed quickly, without having to look at the keyboard. This makes it harder for someone to steal your password by looking at your keyboard (also known as "shoulder surfing").
·        DO change passwords regularly. The more critical an account to network integrity (such as root on a UNIX host or Administrator on Windows NT), the more frequently the password should be changed. This change stops someone who has already compromised an account from continued access.
·        DO NOT use a network login ID in any form (reversed, capitalized, or doubled as a password).
·        DO NOT use your first, middle or last name or anyone else’s in any form. Do not use your initials or any nicknames you may have or anyone else’s.
·        DO NOT use a word contained in English or foreign dictionaries, spelling lists, or other word lists and abbreviations.
·        DO NOT use other information easily obtained about you. This includes pet names, license plate numbers, telephone numbers, identification numbers, the brand of your automobile, the name of the street you live on, and so on. Someone who knows the user very easily guesses such passwords.
·        DO NOT use a password of all numbers, or a password composed of alphabet characters. Mix numbers and letters.
·        DO NOT use dates e.g., September, SEPT2020 or any combination thereof.
·        DO NOT use keyboard sequences, e.g., QWERTY.
·        DO NOT use a sample password, no matter how good, that you’ve gotten from a book that discusses information and computer security.
·        DO NOT use any of the above things spelled backwards, or in caps, or otherwise disguised.
·        DO NOT write a password on sticky notes, desk blotters, calendars, or store it online where others can access it.
·        DO NOT use shared accounts. Accountability for group access is extremely difficult.
·        DO NOT use passwords that are less than eight characters.
·        DO NOT reveal a password to ANYONE, including co-workers, family members or the boss.
·        DO NOT reveal a password in an email message.
·        DO NOT talk about or recite a password in front of others.

Password Sharing and Exposure
·        DO NOT use the ‘Remember Password" feature of applications (Internet Explorer, Windows requests, etc.)
·        DO NOT reveal a password on questionnaires or security forms.
·        DO NOT reveal a password to co-workers while on vacation.