Information Technology and Communications policy statement

Information Technology and Communications policy statement This policy is designed to: – Help employees and other users (e.g. visitors, contractors) understand the ways in which they are and are not allowed to use the Keltbray IT systems – Help maintain the security, data governance, integrity and performance of the Keltbray IT systems – Minimise both Keltbray and other user’s exposure to possible legal action arising from unauthorised use of the Keltbray IT and communications systems – Help ensure that Keltbray can demonstrate effective and appropriate use of resources This policy covers use of systems and facilities provided by Keltbray, in particular: – – – – – – –

Cyber security Data management and Information handling Systems, Cloud services and collaboration platforms Internet Email Digital bulletin boards Social media / messaging and video conferencing

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Computers, laptops, tablets and servers Telephones (landline and mobile) and faxes

Policy The Keltbray IT, communications systems and facilities are provided to enable employees and other users to perform their jobs effectively and efficiently. All normal use of these systems in pursuit of Keltbray business objectives within an employee’s authority to act is allowed. Some limited personal use of the Keltbray IT and communications system by employees is allowed provided that it is not excessive, does not interfere with their normal work or the work of others, does not involve Keltbray in significant expense, does not expose Keltbray to legal action, does not expose Keltbray to cyber security or risk bringing Keltbray into disrepute, and does not relate to running a private business.

The following issues are not permitted. Any contravention will be treated as gross misconduct and will result in disciplinary action being taken by the company.

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Accessing or viewing email, phone texts, or other social media channels etc containing pornography or other offensive material regarded as gross misconduct The system (email, phone texts, or other social media channels etc) is not to be used for the creation or distribution of any offensive, disruptive messages including messages containing offensive comments about race, gender, age, sexual orientation, pornography, religious or political beliefs, national origin or disability Downloading any product software, music or videos that have copyright and licensing restrictions is not permitted Accessing pornography, indecent websites or social media of any form is NOT permitted and will result in instant dismissal

All use by non-employees is subject to the same restrictions as for employees. More information on acceptable use, restrictions on use and penalties that can be applied is available in the guidelines for implementation of the Keltbray IT and Communications policy.

Keltbray reserves the right to monitor, log, and review the use of its information technology and communications systems to protect the confidentiality, integrity, and availability of corporate information.

This monitoring may include, but is not limited to: –

Detection and review of large or unusual data upload and download activity

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Monitoring of file transfers across internal systems, cloud platforms, and external services

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Monitoring of email usage, including bulk attachments

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Monitoring of use of removable storage devices, including USB media

Monitoring activities are undertaken in accordance with applicable legislation and internal governance procedures and are designed to: –

Prevent unauthorised data exfiltration and misuse of systems

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Detect potential security incidents or breaches

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Support regulatory, legal, and contractual obligations

KEL-CRP-POL-007 - Information Technology and Communications policy statement

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There should be no expectation of privacy in the use of Keltbray IT and communications systems. Any misuse, unauthorised data movement, or circumvention of monitoring controls may be treated as gross misconduct and will result in disciplinary action.

Keltbray and its management team fully support this policy and are committed to provide competent personnel and financial resources to implement it. This policy statement shall be reviewed annually by all interested parties. All Keltbray policies are available on the Keltbray Business Management System. New employees are briefed on the use of the Business Management System and locations of the Keltbray policies and any reviews or key changes in the policies are advised to employees.

Karl Goose Chief Executive Officer

KEL-CRP-POL-007 - Information Technology and Communications policy statement

Last review date: January 2026 Next review date: January 2027

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