Table of Contents

  1. Purpose
  2. General
  3. Policy
  4. Security Program Guidelines
  5. Responsibilities
  6. Procedure
  7. Deviations
  8. Flowchart
  9. References

1. Purpose

This procedure defines Company policies and responsibilities as they relate to mitigating theft, malicious damage to or misuse of company property. This procedure defines the means available for reporting such activities and establishes processes for conducting appropriate and prompt investigations of such activities.

2. General

Definitions

a. Assets - Tangible assets are buildings, plants and facilities including new facilities and those under construction, equipment, materials, products or other physical property. In tangible assets include company or client information and/or trade secrets including inventions, technology and information developed or acquired by the company, processes and techniques, marketing plans, pricing data, and other data covered by restrictive company and/or client designations.

b. Facility - A construction site, engineering office, manufacturing plant, laboratory, or office building used by Company or its contractors or subcontractors for performing work under the jurisdiction of Company.

c. Physical Security - The use of physical measures including, but not limited to, barriers, locks, alarms, badges, guards and receptionists to control ingress to and egress from facilities where company property is located.

d. Pilferage - To steal in small amounts in a repetitious manner.

e. Sensitive Information/Material (Company and/or Client) - Company and/or client sensitive data that is company private, competition sensitive and/or company confidential.

f. Sensitive Property - Those items which are considered susceptible to being appropriated by employees for personal use or which can be readily converted to cash.

g. Theft - The felonious taking and removing of property with the intent to deprive the rightful owner of its use; an unlawful taking such as burglary of those items belonging to another.

3. Policy

It is the policy of Company to regard the security and protection of its assets, tangible and intangible, to be of primary importance to its continued growth, profitability and success. Thus, the company’s objectives must ensure that employees work together to prevent theft, embezzlement and disclosure of company information. Essential to meeting this goal is establishing internal and external controls to guard against the loss of company assets and provide this information to all employees. The Company objectives for asset protection and control include, but are not limited to, controlling the following:

h. Losses resulting from burglary, robbery or theft of property including, but not limited to, local business facility inventories of furniture, fixtures, machinery, tools, equipment, computers and other office accessories. An unexplained loss or the mere disappearance of property may not be considered a wrongful act until such time as the loss is satisfactorily established.

i. Unauthorized disclosure of company or client sensitive data (including company private, competition sensitive and/or company confidential information) by transferring, publishing, using or disclosing such data other than is necessary in the ordinary course of business or as directed or authorized by Company.

j. Inappropriate or unauthorized personal use or appropriation of Company assets, data or resources, including computer equipment and software.

4. Security Program Guidelines

The scope or extent of a location security program will vary depending on facility size, vulnerability, nature and sensitivity of operations or processes, security risks involved and geographic, economic, client/customer and political factors. The Physical Security or security essential to maintain control of the premises of a company will be provided to a degree sufficient to ensure only authorized individuals are allowed access to the premises. Therefore casual or systematic pilferage of company assets is prevented. Computers and Telecommunications Systems Security will be maintained sufficiently to ensure only authorized individuals are provided access to sensitive company and/or client information stored or communicated electronically on computers, networks, file servers or over telephone or modem lines.

5. Responsibilities

k. The General Manager is tasked with overall responsibility for the Security Program.

l. The Manager Facilities & Services acts for the General Manager and is responsible for establishing control programs involving accountability, security, and audits which preclude the loss of assets such as are implemented by those management personnel ultimately responsible for preserving the assets of the company.

m. All employees are responsible for preserving and protecting the company assets and for reporting actual or suspected violations to their supervisors and to the Company Facilities & Services Department, Ext. 4110 or 4108.

6. Procedure

n. Reporting

  1. This person(s) who suspects or discovers a theft should immediately notify his/her supervisor and Manager Facilities & Services.
  2. The investigation is initiated by ensuring that the required form (ref. 6.6) is filled out in its entirety by the on-site person handling the situation. The Form is faxed and subsequently forwarded to the Manager Facilities & Services.
  3. All real or suspected thefts or acts are investigated. The Manager Facilities & Services or designee determines the extent of the investigation.
  4. Identification of alleged suspects is withheld unless such release is approved by the Manager Human Resources and the General Manager.

o. Conduct of the Investigation

  1. The Manager Facilities & Services conducts, assists or coordinates any necessary investigation of irregularities noted on the Corporate Security Investigation Form.
  2. The investigations may be conducted at the location of the alleged activity or may be coordinated from The Hague office.
  3. All liaison with local authorities is coordinated with the Manager Facilities & Services

7. Deviations

There shall be no deviations from this procedure without the explicit written permission from the General Manager.

8. Flowchart

N/A.

9. References

Document Number

Title

Level

CM-CS-018

Company Security Program

2