The protection of confidential Company and customer data and trade secrets is vital to our interests and success. Confidential data is any nonpublic information including, but not limited to, trade secrets involving the Company and/or its customers, products, or employees, as more fully outlined below. The classification of confidential data also includes personal identifiable information (PII), with respect to customer names and addresses provided to us directly, and indirectly by automatic upload to our business applications, for use in order fulfillment. All Company and personal identifiable information should be held in strict confidence, and not relayed to anyone outside the Company, except in the usual course of business and with Company permission. The relay of any personal identifiable information is limited to the exchange with shipping companies for fulfillment purposes and is subject to be disposed of within the Company’s 3-year disposition policy in compliance with regulations. Disclosure of Company confidential information to Company competitors or others could cause egregious and irreparable harm. Confidential information includes, but is not limited to, the following examples:


• Product development plans
• Business records of the Company
• Company manuals, policies and procedures
• Information relating to confidential or proprietary processes and technologies
• Customer or supplier lists and related information
• Agreements between customers/clients and the Company
• Customer financial information
• Contracts with Company vendors or suppliers or independent contractors
• Financial information of the Company
• Company strategic and development plans
• Market analysis information
• Company billing rates to customers/clients
• Any confidential information maintained regarding customers/clients
• Project records
• Employee records and compensation data (see Policies on Confidentiality of Employees’
Personal Information and Confidentiality of Payroll)
• Employee agreements (see Policy on Confidentiality of Employees’ Personal Information)


Company employees are in a position of trust and have an obligation to the Company and to its customers/clients to see that the confidentiality of this information is strictly maintained and protected on our business systems. Unauthorized use or disclosure of confidential information, even if inadvertent, compromises both you and the Company and seriously erodes customer confidence. Furthermore, any unauthorized use or disclosure of confidential information is documented within the auditing functions of our business applications. Employees may be required to sign a nondisclosure agreement as a condition of employment. However, regardless of whether a formal agreement is signed, any employee who discloses Dynarex’s trade secrets or confidential and proprietary business information to anyone other than a person known to be authorized to receive such information will be subject to disciplinary action up to and including termination of employment, and may also be subject to legal action, including but not limited to actions under the Defend Trade Secrets Act of 2016 (“DTSA”). However, an employee will have immunity from an action asserting a trade secret misappropriation if the disclosure the employee makes was made in confidence to a Federal, State, or local government official, either directly or indirectly, or to an attorney; and that disclosure of the Company’s confidences was made solely for the purpose of reporting or investigating a suspected violation of law. Similar immunity is available if the disclosure of confidences is made in a complaint or other document filed in a lawsuit or other proceeding, provided such filing is made under seal. Such immunity extends to both criminal and civil liability under any Federal or State trade secret law.


Further, each employee has a continuing obligation to safeguard and not disclose or use Company confidential proprietary information, even after employment with the Company ends for any reason. Such restriction on disclosure of our confidential information includes a restriction on posting or relaying it on the internet in any forum, blog or electronic communication of any sort. Upon termination of employment, all confidential information in the employee’s possession must be promptly returned to the Company. As the Company expects its confidential information to be respected, it is also our policy to respect the confidential information of others. Employees who possess confidential business information from a former employer, or relating to customers, clients or employees of a former employer, must keep that information confidential and not disclose or use that information in performing job duties for the Company. Questions about what constitutes confidential data or whether it can be released should be directed to your immediate supervisor or to Human Resources. Consent to the above requirements is acknowledged by signature of the Handbook that this policy is part thereto.