Customers, vendors, and others disclose confidential information to ePlus for business purposes. Each employee has a responsibility to protect and maintain the confidentiality of this information. Failure to properly protect customer and third-party information may damage our relationships with these important business partners, and may result in legal liability.
ePlus owns all information, in any form (including electronic information), that is created or used in support of its activities. This information is a valuable asset and ePlus expects you to protect it from unauthorized disclosure. This information includes ePlus customer, vendor, business partner and employee data. Federal, state and foreign laws may restrict the use of this information and may penalize you if you use or disclose it. You should protect information pertaining to ePlus’ competitive position, business strategies and information relating to negotiations with employees or third parties and share it only with employees who need to know it in order to perform his or her job. Nothing in this policy shall be deemed to interfere with employee disclosure rights protected by law.
Intellectual Property and Proprietary Information
You should carefully maintain and manage the intellectual property rights of ePlus to which you have access, including patents, trademarks, copyrights, licenses and trade secrets, to preserve and protect their value. In addition, you should respect the intellectual property rights of others. If you violate other’s intellectual property rights, you and ePlus could face substantial liability, including criminal penalties. Intellectual property that you create during the course of your employment belongs to ePlus. You must share any innovations or inventions you create with your supervisor so that ePlus can take steps to protect these valuable assets.
Federal and state securities laws and ePlus’ policies prohibit you from:
- Purchasing or selling ePlus securities while you know material, nonpublic information about ePlus; and
- Disclosing material, nonpublic information, except as permitted by law.
In order to better protect non-public information, all confidential Company business information and information of our customers, vendors and business partners, should be disseminated internally only on a “need-to-know” basis. For more information, employees should refer to the ePlus Insider Trading Policy which is posted on the Corporate Intranet and is included as an Appendix to the ePlus Employee Handbook.
Because of the complexity of insider information and insider trading, and the severity of the punishments involved, which can include criminal prosecution, you should seek the advice of ePlus’ General Counsel on any questions regarding this subject. In some cases, you may want to retain an attorney on your own to advise you.
Requests for information from the media, analysts, attorneys, law enforcement officers and others.
What may appear to be an innocent request for information could result in serious harm to our company. Be alert to requests for information from outside of ePlus.
You should not initiate contact with the media, analysts, attorneys or others.
If you receive a request for information from these sources, you must direct the caller to the Company’s main telephone number (703) 984-8400 or 888-482-1122. The call will then be directed to the General Counsel, the Chief Financial Officer, or the Investor Relations Department.
To avoid inadvertent disclosure, never discuss with any unauthorized person confidential information. Furthermore, you should not discuss such information even with authorized ePlus employees if you are in the presence of others who are not authorized, for example, at a trade show reception or in a public area. You should also not discuss such information with family members or with friends, who might innocently or unintentionally pass the information on to someone else.
If you ever suspect or know that you or someone else has inadvertently disclosed information that is confidential or non-public, you must contact the General Counsel immediately.