BLD BRANDS RESOURCES AND ELECTRONIC COMMUNICATIONS POLICY

1. PURPOSE

The purpose of this policy is to set out the conditions by which each individual who is employed by BLD Brands may use the Company's computers, networks, telephones, cell phones, voicemail, email, instant messaging, blackberries, PDAs, internet and internet access and resources, facsimile and scanning equipment, and all other similar Company provided electronic systems and equipment ("Electronic Equipment"). Offices, facilities, desks, lockers, vehicles, and Electronic Equipment are Company property and must be maintained according to Company rules and regulations. They must be kept clean and are to be used only for work-related purposes. Company reserves the right to inspect and gain access to all Company property to ensure compliance with its rules and regulations, without notice to the employee and/or in the employee's absence.

2. OVERVIEW

While electronic communication tools are tremendous assets to the Company when used appropriately, abuse of these resources can put both the individual and the Company at risk. Therefore it is important for every team member and manager to read and understand this policy. This will help minimize the risk, both to the individual and to the Company, inherent in the abuse or misuse of these systems. Abuse and misuse of these systems will result in disciplinary action, up to and including termination. The use of Company electronic resources implies an understanding of, and agreement to, this policy.

3. GUIDELINES

A. BLD Brands team members and managers may use the Company's electronic communications systems for performing lawful Company business. The Company's electronic communication systems are provided for the individual's business use during Company time. Limited, occasional or incidental use of electronic communication systems (sending or receiving) for personal, non-business purposes may be permitted under the following conditions:

· All use is subject to the Guidelines herein, and must be consistent with the Policy Regarding Use of Social Media by Employees. Personal use may not involve any prohibited activity described elsewhere in this policy

· Personal use may not interfere with the productivity of the individual or his/her co-workers.

· Personal use may not disrupt or delay the performance of Company business

· Personal use may not consume Company resources or otherwise deplete system resources available for business purposes.

B. All information and communications created, received, saved or sent on the Company's system are the property of the Company

C. E-mail sent and received through Company computers, including personal e-mail or Internet search activity using third-party Internet Service Providers, are subject to search and monitoring with or without notice, regardless of whether the Company's systems are accessed in or out of the office. Use of the words "private" or "confidential" on an email message will not exempt it from possible review by the Company. Use of passwords, encryptions, or other means of preventing the Company from viewing the emails is prohibited. The Company will periodically and randomly perform such monitoring of individual usage.

D. Except as prohibited by law, anything that is created, sent, received or stored on Company's Computer, IT Network, or Electronic Equipment is the property of BLD Brands, and subject to investigation, review and search at any time without prior notice, if BLD Brands, in its discretion, should determine such review is necessary. Thus, the individual team member or manager has no personal privacy right in any material created, received, saved or sent using the Company's e-mail or computer systems, and should have no expectation of privacy in such communications.

E. Employees should also be aware that all electronic records are subject to discovery and may be used in conjunction with litigation between the Company and third parties .

F. BLD Brands electronic communications systems may not be used in any way that violates any law, regulation, ordinance, the Policy Regarding Use of Social Media by Employees or other Company policy or procedure, or that is offensive or harmful to any individual within the Company. Examples of forbidden communications and use include, but are not limited to:

· Viewing, posting or distributing material that is sexually explicit, pornographic, racist, sexist, or that is offensive based on race, national origin, sex, sexual orientation, religion, age, disability, religion or political beliefs

· Viewing, sending or posting messages intended to harass, intimidate, threaten, embarrass, humiliate or degrade another Company team member or manager, or that contain defamatory references

· Conducting illegal activity, including gambling

· Using electronic communications resources for commercial uses not intended to benefit the company

· Downloading or distributing pirated software or data, entertainment software, music or games

· Sending chain letters

· to engage in copyright or trademark infringement, misappropriation of trade secrets, or discrimination

· Propagating viruses, worms, Trojan horse or trap door program codes

· Attempting to access or accessing another individual's computer, computer account, e-mail or voice mail messages, files or other data without that person's consent or the consent of an authorized supervisor

· Using resources for personal use that interferes with business operation, business productivity or distracts others from their responsibilities

G. Employees may not install personal software on Company computers or systems, and any and all installation shall be performed by the Company IT department, and in compliance with PCI standards.

H. Use of Passwords: To prevent unauthorized parties from obtaining access to Electronic Communications, Customer Information, and Company confidential data users should choose passwords that are difficult to guess. Each user should have their own individual password. Individual passwords MUST NEVER be shared or revealed to anyone. To do otherwise exposes the authorized user to liability for actions taken by the other party using the password.

Again, any abuse or misuse of Company systems will result in disciplinary action, up to and including termination.