Confidential Information
Employees have access to a variety of confidential information while employed at the Company. Confidential information includes all non-public information that might be of use to competitors or, if disclosed, harmful or disadvantageous to the Company or its customers, suppliers or joint venture partners. Employees have a duty to safeguard and protect all confidential information of the Company or third parties with which the Company conducts business, except when disclosure is authorized or legally mandated. An employee’s duty to safeguard and protect confidential information continues after he or she leaves the Company. Unauthorized disclosure of confidential information could cause competitive harm to the Company or its customers, suppliers or joint venture partners and could result in legal liability to you and the Company.
Any questions or concerns regarding whether disclosure of Company information is legally mandated should be promptly referred to the Compliance Officer.
Confidential Information
Safeguarding Confidential Information
Care must be taken to safeguard confidential information. Accordingly, the following measures should be adhered to:
Employees should conduct their business and social activities so as not to risk inadvertent disclosure of confidential information. For example, when not in use, confidential information should be secretly stored. Also, review of confidential documents or discussion of confidential subjects in public places (e.g., airplanes, trains and taxis)should be conducted so as to prevent overhearing or other access by unauthorized persons.
Within the Company’s offices, confidential matters should not be discussed within hearing range of visitors or others not working on such matters.
Confidential matters should not be discussed with other employees not working on such matters or with friends or relatives, including those living in the same household as a Company employee.
The Company’s files, personal computers, networks, software, internet access, internet browser programs, e-mail, voicemail, and other business equipment (e.g., desks and cabinets) and resources are provided for business use, and they are the exclusive property of the Company. Misuse of Company property will not be tolerated.
Company Records
Accurate and reliable records are crucial to our business. Our records are the basis of our earnings statements, financial reports, and other disclosures to the public and guide our business decision-making and strategic planning. Company records include booking information, payroll, time cards, travel and expense reports, e-mails, accounting and financial data, measurement and performance records, electronic data files and all other records maintained in the ordinary course of our business.
All Company records must be complete, accurate and reliable in all material respects. Undisclosed or unrecorded funds, payments or receipts are inconsistent with our business practices and are prohibited. You are responsible for understanding and complying with our record keeping policy. Ask your supervisor if you have any questions.
Protection and Use of Company Assets
Employees should protect the Company’s assets and ensure their efficient use for legitimate business purposes only. Theft, carelessness and waste have a direct impact on the Company’s profitability. The use of Company funds or assets, whether or not for personal gain, for any unlawful or improper purpose is prohibited. To ensure the protection and proper use of the Company’s assets, each employee should:
Exercise reasonable care to prevent theft, damage or misuse of Company property.
Report the actual or suspected theft, damage or misuse of Company property to a supervisor.
Safeguard all electronic programs, data, communications and written materials from inadvertent access by others.
Use Company property only for legitimate business purposes, as authorized in connection with your job responsibilities.
Use the Company’s telephone system, other electronic communication services, written materials and other property primarily for business-related purposes.
Employees should be aware that Company property includes all data and communications transmitted to, received by or contained in the Company’s electronic or telephonic systems. Company property also includes all written communications. Employees and other users of Company property should have no expectation of privacy with respect to these communications and data. To the extent permitted bylaw, the Company has the ability, and reserves the right, to monitor all electronic and telephonic communication. These communications may also be subject to disclosure to law enforcement or government officials.
Frequently Asked Questions
No. All software, source code, and documentation generated or provided by Teammates, consultants, or contractors for Canadian Solar EMEA MSS belongs to Canadian Solar EMEA MSS. Canadian Solar EMEA MSS's code, data, and other property must remain as a Canadian Solar EMEA MSS asset. Here, an “asset” is a computer, storage account, or other device or application belonging to Canadian Solar EMEA MSS, which means Teammates must not store Canadian Solar EMEA MSS code, or data, on a home computer or personal storage account.
Leave the event and make sure you document the situation to the Ethics & Compliance Office via the Speak-Up Helpline. Talking about price, territories, or strategic alliances with competitors is illegal and could get Canadian Solar EMEA MSS into a lot of trouble.
The Company places a high value on its credibility and reputation in the community. What is written or said about the Company in the news media and investment community directly impacts our reputation, positively or negatively. Our policy is to provide timely, accurate and complete information in response to public requests (eg, media and analysts), consistent with our obligations to maintain the confidentiality of competitive and proprietary information and to prevent selective disclosure of market-sensitive financial data. To ensure compliance with this policy, all news media or other public requests for information regarding the Company should be directed to the Company’s Investor Relations Department. The Investor Relations Department will work with you and the appropriate personnel to evaluate and coordinate a response to the request.
If you are an employee, customer, job applicant, or marketing recipient of Canadian Solar EMEA MSS, you can fill out a data subject access request (DSARs) <<<here>>>, and we will provide you with that information.
You should immediately report this security incident to our Security Team. Contact Torsten Dobroschke or Ken Land immediately. Reporting this can help protect Canadian Solar EMEA MSS against a possible cyber-attack.