ABOUT THIS POLICY
This document provides guidelines for all employees regarding the use of social media and is an addendum to Chapter 12 of the Employee Handbook. The Company appreciates that many people enjoy using Social media sites such as Facebook, Twitter, LinkedIn and social media applications (‘apps’) such as Snapchat.
While we do not wish to interfere with employees’ activities outside work (or permitted activities in work), the Company has a right to protect its reputation, intellectual property, trade secrets, and confidential and sensitive information, as well as ensuring our policies are complied with. To strike a fair balance between the interests of all parties, the guidelines below should be observed when using social media sites, social media ‘apps’, blogging and making any other postings on the internet.
Purpose
This policy is in place to minimise the risks to the Company’s business through use of social media.
Scope
This policy applies to all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers.
Responsibilities
All employees are responsible for complying with this policy, including being aware of how to use social media safely. This policy applies to use of social media for business purposes as well as personal use that may affect the Company’s business in any way. If you are in any doubt as to whether you need authorisation to post an item on social media, or whether a post will breach this policy, you should check with your line manager.
USING SOCIAL MEDIA
Social networking in every form provides the Company with a tremendous opportunity to spread the good word about what it does, what its clients and partners are doing and the Company’s work.
However, employees’ use of social media can pose risks to the Company’s confidential information and reputation and can jeopardise its compliance with legal and regulatory obligations.
Online social networks blur the lines between public and private information. By virtue of you identifying yourself as an employee of the Company within a social network, you should ensure that content associated with you is consistent with your work and the Company’s brand.
COMPLIANCE WITH RELATED POLICIES AND PROHIBITED USE
Social media should never be used in a way that breaches any of the Company’s other policies. If an internet post would breach any of the Company’s other policies in another forum, it will also breach them in an online forum. For example, you are prohibited from using social media to:
The same principles and guidelines that apply to the Company’s activities in general apply to all online activities. This includes all forms of online publishing and discussion (whether for personal use or on behalf of the Company) including blogs, wikis, user-generated video and audio, virtual worlds and social networks.
When providing references or recommendations for other individuals on social or professional networking sites, (whether positive or negative), you are to ensure that it is made clear that the views are yours only and are not attributable to the Company as they could create legal liability for both the author of the reference and the Company.
You must avoid making any social media communications that could damage the Company’s business interests or reputation, even indirectly.
You must not use social media to:
You must not post comments about sensitive business-related topics, such as the Company’s performance, or do anything to jeopardise the Company’s trade secrets, confidential information or intellectual property.
You must not make any reference, directly or indirectly, to business-related topics that are in the course of negotiation, such as potential contract or client wins.
You must not post comments about sensitive business-related topics, such as the Company’s performance, or do anything to jeopardise the Company’s trade secrets, confidential information or intellectual property.
You must not make any reference, directly or indirectly, to business-related topics that are in the course of negotiation, such as potential contract or client wins.
You must also be conscious that you work within a group of companies which is listed on the Stock Exchange and that, as a result, we may become aware of information which may be “price sensitive”, that is, information which, if made public, would be likely to have a significant effect on the price of shares in the Company. Our policy prohibits the disclosure of price sensitive information on social media. Disclosure of price sensitive information may also constitute a criminal offence.
Any employees that act in breach of any of the above (whether while posting in a personal capacity or on behalf of the Company or whether or not the breach takes place during or outside working hours and whether or not you used company systems or devices) may be subject to disciplinary action up to and including the termination of their employment and any other staff or contractors that do likewise may have their contracts terminated immediately.
PERSONAL USE OF SOCIAL MEDIA
In general, what you do in your own time is your business. However, activities in or outside of work that adversely affect: (1) your job performance; (2) the performance of others; or (3) the Company’s legitimate business interests, are a proper focus for this policy.
The Company allows you occasional personal use of social media during your working hours so long as it does not involve unprofessional or inappropriate content, does not interfere with your responsibilities or productivity and complies with this policy.
You should be respectful to others when making any statement on social media and be aware that you will be personally responsible for all communications published on the internet for anyone to see.
You must not express opinions on the Company’s behalf or include the Company’s logos, brand names or other trademarks via social media, unless expressly authorised to do so by your line manager. You may be required to undergo training in order to obtain such authorisation.
You must not make any statements or postings using social media that damages the reputation of this Company or which puts our reputation at risk. In particular, you should not make any defamatory or adverse statements about this Company, our clients or suppliers or make any statements that could be interpreted as doing so.
You must not reveal or jeopardise the Company’s trade secrets, confidential or sensitive information when using social media. You have the same duty to maintain confidentiality when using social media as you do in any other forum.
If you do disclose your affiliation with the Company on your profile or in any social media postings, you should make it clear in the social media post, or in your personal profile, that you are speaking on your own behalf. You should write in the first person and use a personal e-mail address. You must:
You should always remember that personal posts, even if sent outside of work hours or premises and regardless of whether the social media is accessed using the Company’s IT and communications facilities and equipment, may still defame or disparage the Company (or its
staff or any third party), either directly or by way of association and may lead to disciplinary action being taken against employees up to and including dismissal or contracts of contractors being terminated.
BUSINESS USE OF SOCIAL MEDIA BY EMPLOYEES
You may only speak or post on behalf of the Company in a social media environment when specifically authorised to do so by the Company.
If you are required for business purposes to speak on behalf of the Company in a social media environment, you must still seek prior approval for such communication from your line manager and must act in accordance with the guidelines in this policy.
Care must be taken to ensure that any social media posts do not reveal or jeopardise the Company’s trade secrets, confidential or sensitive information related to the Company or any of its clients. Any proposed posts which could be considered to contain this type of information (i.e. make reference to the business performance of the Company, its contracts or any of its clients) must be approved in advance by a Director of the Company.
Any proposed posts which could be considered to contain sensitive information or make reference to the business performance of the Company, its contracts or any of its clients must be approved in advanced by your line manager and a director of the Company.
In general, reposting of news which has already been notified by the Company under a regulatory information service is permitted.
You must not misuse the Company’s logos or trademarks and must only use them if you have the authority to do so. For example, you should not use “Grosvenor Technology” in your screen name or other social media ID.
USE OF SOCIAL MEDIA BY DIRECTORS AND PERSONS DISCHARGING MANAGERIAL RESPONSIBILITIES (PDMRs)
Directors and PDMRs who have access to inside information must be mindful of the Company’s obligations under the Market Abuse Regime (MAR) and the AIM Rules for Companies.
You must not use social media to disseminate information which could constitute inside information as defined under Article 19 of MAR.
All posts made by Directors and PDMRs related to the Company will require prior approval from both the Chief Executive Officer and Chief Financial Officer who will review Social media posts in advance of release and consult with Allenby Capital as appropriate.
BUSINESS USE OF SOCIAL MEDIA ON BEHALF OF THE COMPANY BY THIRD PARTIES
No third party may be engaged to undertake social media activities on behalf of the Company without the prior approval of the Board.
MONITORING
The Company reserves the right to monitor, intercept and review, without further notice, your online social media postings and activities related to the Company, to ensure that the Company’s rules are being adhered to and for legitimate business purposes and you consent to such monitoring.
For further information on monitoring, please refer to the Company’s Use of Computers, Internet and Email Policy.
RECRUITMENT
The Company may use internet searches to perform due diligence on candidates in the course of recruitment.
Where the Company does this, it will act in accordance with its Data Protection Policy, Policy of Equal Opportunity and its Harassment and Bullying Policy.
BREACH OF POLICY
Any breach of this policy by employees may result in disciplinary action up to and including their dismissal, and any other member of staff or contractor may have their contracts terminated immediately where such a breach has occurred. If you are suspected of committing a breach of this policy you will be required to co-operate with the Company’s investigation, which may involve handing over relevant passwords and login details.
You may be required to remove any social media content that the Company considers a breach of this policy. Failure to comply with such a request may in itself result in disciplinary action being taken or contracts being terminated.
AIM rules dictate how information regarding AIM companies is disclosed, this should be without delay and via a Regulatory Information Service (“RIS”) such as the RNS system, before it can be disclosed elsewhere (such as the Company’s website or via the media or social media).
If found in breach of the AIM Rules, The Stock Exchange could commence disciplinary proceedings and subsequently issue both a disciplinary notice and a substantial fine to the Group’s parent company, Newmark Technology plc.
In a case in December 2016, the Exchange issued a disciplinary notice in which it announced that an AIM company had been privately censured and fined £75,000 by the Exchange for a breach of AIM Rule 31.