TECHNOLOGY RESSOURCES USE POLICY

Policy restricting personal use of employer’s computers and systems

1. PURPOSE

a) To remain competitive, better serve our customers and provide our employees with the best
tools to do their jobs, Win Thein & Sons Co., Ltd (“the Company”) makes available to our
workforce access to one or more forms of electronic media and services, including but not
limited to: computers, software, printers, copiers, files, databases, cellular phone, pager,
email, telephones, voicemail, fax machines, external electronic bulletin boards, wire services,
online services, intranet, Internet and the World Wide Web.

b) Win Thein & Sons Co., Ltd encourages the use of these media and associated services
because they can make communication more efficient and effective and because they are
valuable sources of information about vendors, customers, technology, and new products and
services. However, all employees and everyone connected with the organization should
remember that electronic media and services provided by the company are company property
and their purpose is to facilitate and support company business. All computer users have the
responsibility to use these resources in a professional, ethical, and lawful manner.

c) To ensure that all employees are responsible, the following guidelines have been established
for using email and the Internet. No policy can lay down rules to cover every possible
situation. Instead, it is designed to express Win Thein & Sons Co., Ltd philosophy and set
forth general principles when using electronic media and services.

1. AUTHORIZATION

Access to the Win Thein & Sons Co., Ltd technology resources is within the sole discretion of the
Company. Generally, employees are given access to the Company's various technologies based on their
job functions. Only employees whose job performance will benefit from the use of the Company's
technology resources will be given access to the necessary technology. Additionally, employees must
successfully complete company-approved training before being given access to the Win Thein & Sons
Co., Ltd technology resources.

2. PROHIBITED COMMUNICATIONS

Electronic media cannot be used for knowingly copying, transmitting, retrieving, or storing any
communication that is:

 Discriminatory or harassing;
 Derogatory to any individual or group;
 Obscene, sexually explicit, pornographic, defamatory or threatening;
 In violation of any license governing the use of software;
 Engaged in for any purpose that is illegal or contrary to Win Thein & Sons Co., Ltd policy or in a
manner contrary to the best interests of the Company, in any way that discloses confidential or
proprietary information of the Company or third parties, or for personal or pecuniary gain; or
 Protected by copyrights laws unless the employee has the author's permission or is accessing a
single copy only for the employee's reference.

3. PROFESSIONAL CONSIDERATIONS

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It is important to maintain a proper spirit and tone to your communications over the system. The following
guidelines are suggested:

 Make your communications positive, constructive, complete, factual.

 Don’t write when angry and edit before sending.
 Be careful with humor – they can’t see you wink.
 Always avoid sarcastic humor.
 Never use all caps – that is perceived as “SHOUTING!”
 Avoid belaboring disagreements in email – there is a time for face-to-face meetings.
 Always guide your recipient in responding by stating what you need and by when.
 Pay attention to grammar and spelling, both to protect your own reputation and intelligence, and
to avoid irritating your recipients who are distracted by careless mistakes.

4. PERSONAL USE

The computers, electronic media and services provided by Win Thein & Sons Co., Ltd are primarily for
business use to assist employees in the performance of their jobs. As long as personal use does not
interfere with the employee's duties, is not done for pecuniary gain, does not conflict with the Company's
business, and does not violate any Company policy, occasional, or incidental use of electronic media
(sending or receiving) for personal, non-business purposes is understandable and acceptable, and all
such use should be done in a manner that does not negatively affect the systems' use for their business
purposes. However, employees are expected to demonstrate a sense of responsibility and not abuse this
privilege.

The Company assumes no liability for loss, damage, destruction, alteration, disclosure, or misuse of any
personal data or communications transmitted over or stored on the Company's technology resources. The
Company accepts no responsibility or liability for the loss or non-delivery of any personal electronic mail
or voicemail communications or any personal data stored on any Company property. The Company
strongly discourages employees from storing any personal data on any of the Company's technology
resources.

5. ACCESS TO EMPLOYEE COMMUNICATIONS

a) Generally, electronic information created and/or communicated by an employee using email,

word processing, utility programs, spreadsheets, voicemail, telephones, Internet and bulletin
board system access, and similar electronic media is not reviewed by the company. However,
the following conditions should be noted:

Win Thein & Sons Co., Ltd does routinely gather logs for most electronic activities or monitor
employee communications directly, be it:

i) Telephone Use and Voicemail: Records are kept of all calls made from and to
a given telephone extension. Although voicemail is password protected, an
authorized administrator can reset the password and listen to voicemail
messages.

ii) Electronic Mail: Electronic mail is backed-up and archived. Although electronic
mail is password protected, an authorized administrator can reset the password
and read electronic mail.

iii) Desktop Facsimile Use: Copies of all facsimile transmissions sent and received
are maintained in the facsimile server.

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 iv) Document Use: Each document stored on Company computers has a history,
which shows which users have accessed the document for any purpose.

v) Internet Use: Internet sites visited, the number of times visited, and the total
time connected to each site is recorded and periodically monitored.

Win Thein & Sons Co., Ltd reserves the right, at its discretion and without notice, to review
any employee's electronic files and messages to the extent necessary to ensure electronic
media and services are being used in compliance with the law, this policy and other company
policies, or to investigate misconduct, to locate information, or for any other business
purpose.

b) Employees should understand, therefore, that they have no right of privacy with respect to
any messages or information created or maintained on the Company's technology resources,
including personal information or messages. Accordingly, if they have sensitive information to
transmit, they should use other means.

All messages sent and received, including personal messages, and all data and information
stored on the Company's electronic-mail system, voicemail system, or computer systems are
Company property regardless of the content. As such, the Company reserves the right to
access all of its technology resources including its computers, voicemail, and electronic-mail
systems, at any time, in its sole discretion.

Passwords do not confer any right of privacy upon any employee of the Company.
Employees are expected to maintain their passwords as confidential. Employees must not
share passwords and must not access coworkers' systems without express authorization.

Deleting or erasing information, documents, or messages maintained on the Company's

technology resources is, in most cases, ineffective. All employees should understand that
any information kept on the Company's technology resources may be electronically recalled
or recreated regardless of whether it may have been "deleted" or "erased" by an employee.
Because the Company periodically backs-up all files and messages, and because of the way
in which computers re-use file storage space, files and messages may exist that are thought
to have been deleted or erased. Therefore, employees who delete or erase information or
messages should not assume that such information or messages are confidential.

7. THE INTERNET AND ON-LINE SERVICES

The Company provides authorized employees access to on-line services such as the Internet. The
Company expects that employees will use these services in a responsible way and for business-related
purposes only. Under no circumstances are employees permitted to use the Company's Technology
Resources to access, download, or contribute to the following:

 gross, indecent, or sexually-oriented materials;

 sports sites;
 job-search sites;
 entertainment sites;
 gambling sites;
 games, humor;
 illegal drug-oriented sites;
 personal pages of individuals; and
 politically-oriented sites or sites devoted to influencing the course of legislation or public policy.

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Additionally, employees must not sign "guest books" at Websites or post messages to Internet news
groups or discussion groups at Websites. These actions will generate junk electronic mail and may
expose the Company to liability or unwanted attention because of comments that employees may make.
The Company strongly encourages employees who wish to access the Internet for non-work-related
activities to get their own personal Internet access accounts.

7. PARTICIPATION IN ONLINE FORUMS

a) Employees should remember that any messages or information sent on company-provided

facilities to one or more individuals via an electronic network – for example, Internet mailing
lists, bulletin boards, and online services – are statements identifiable and attributable to Win
Thein & Sons Co., Ltd.

b) Win Thein & Sons Co., Ltd recognizes that participation in some forums might be important to
the performance of an employee's job. For instance, an employee might find the answer to a
technical problem by consulting members of a news group devoted to the technical area.

8. SOFTWARE

To prevent computer viruses from being transmitted through the company's computer system,
unauthorized downloading of any unauthorized software is strictly prohibited. Only software registered
through Win Thein & Sons Co., Ltd may be downloaded. No employee may load any software on the
Company's computers, by any means of transmission, unless authorized in advance by Win Thein &
Sons Co., Ltd’s system administrator.

9. SECURITY/APPROPRIATE USE

a) Employees must respect the confidentiality of other individuals' electronic communications.

Except in cases in which explicit authorization has been granted by company management,
employees are prohibited from engaging in, or attempting to engage in:

 Monitoring or intercepting the files or electronic communications of other employees

or third parties;
 Hacking or obtaining access to systems or accounts they are not authorized to use;

 Using other people's log-ins or passwords; and

 Breaching, testing, or monitoring computer or network security measures.

b) No email or other electronic communications can be sent that attempt to hide the identity of
the sender or represent the sender as someone else.

c) Electronic media and services should not be used in a manner that is likely to cause network
congestion or significantly hamper the ability of other people to access and use the system.

d) Anyone obtaining electronic assess to other companies' or individuals' materials must respect
all copyrights and cannot copy, retrieve, modify or forward copyrighted materials except as
permitted by the copyright owner.

a) The Company has installed a variety of programs and devices to ensure the safety and
security of the Company's technology resources. Any employee found tampering or disabling
any of the Company's security devices will be subject to discipline up to and including
termination.

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10. ENCRYPTION

Employees can use encryption software supplied to them by the systems administrator for purposes of
safeguarding sensitive or confidential business information. Employees who use encryption on files stored
on a company computer must provide their supervisor with a sealed hard copy record (to be retained in a
secure location) of all of the passwords and/or encryption keys necessary to access the files.

8. CONFIDENTIAL INFORMATION

The Company is very sensitive to the issue of protection of trade secrets and other confidential and
proprietary information of both the Company and third parties ("Confidential Information"). Therefore,
employees are expected to use good judgment and to adhere to the highest ethical standards when using
or transmitting Confidential Information on the Company's technology resources.

Confidential Information should not be accessed through the Company's technology resources in the
presence of unauthorized individuals. Similarly, Confidential Information should not be left visible or
unattended. Moreover, any Confidential Information transmitted via technology resources should be
marked with the following confidentiality legend:

"This message contains confidential information. Unless you are the addressee (or
authorized to receive for the addressee), you may not copy, use, or distribute this
information. If you have received this message in error, please advise [EMPLOYEE'S
NAME] immediately at [EMPLOYEE'S TELEPHONE NUMBER] or return it promptly by
mail."

11. VIOLATIONS

Any employee who abuses the privilege of their access to email or the Internet in violation of this policy
will be subject to corrective action, including possible termination of employment, legal action, and
criminal liability.

12. PROCEDURES

Procedures for accessing the Voicemail, Email and Internet system, as well as the guidelines for how to
properly send and retain information, may be obtained by contacting Administrative Department.

The Voicemail/Email/Internet policies and procedures should be reviewed by each employee on a semi-
annual basis.

Questions concerning the use of the Voicemail/Email/Internet system should be directed to the systems
administrator. Questions concerning the improper use of the system should be directed to the employee’s
immediate supervisor, and if not satisfied with the response, to the systems administrator.

13. EMPLOYEE AGREEMENT ON USE OF EMAIL AND THE INTERNET

I have read, understand, and agree to comply with the foregoing policies, rules, and conditions governing
the use of the Company's computer and telecommunications equipment and services. I understand that I
have no expectation of privacy when I use any of the telecommunication equipment or services. I am
aware that violations of this guideline on appropriate use of the email and Internet systems may subject
me to disciplinary action, including termination from employment, legal action and criminal liability. I
further understand that my use of the email and Internet may reflect on the image of Win Thein & Sons

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Co., Ltd to our customers, competitors and suppliers and that I have responsibility to maintain a positive
representation of the company. Furthermore, I understand that this policy can be amended at any time.

DATED:

EMPLOYEE COMPANY

Authorized Signature Authorized Signature

Print Name and Title Print Name and Title

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