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Model Company Policy Relating to the Use of the Internet Internet Access Services The Company provides access to the Internet from the desk-top and various other locations. This policy statement sets forth the Company’s policies with respect to acceptable use of any Company-provided Internet access resources (personal computers, browser software and communications lines to the Internet). To the extent that Internet access is used to send or receive e-mail, this policy should be read with the Company’s Policy Relating to Use of E-Mail. Appropriate Use of Internet Access Business Use The Company’s Internet access resources are, like other resources of the Company, first and foremost made available for Company-related business. They can be used for work on client matters, practice and business development, associated research and other Company matters. Personal Use The Company recognizes that use of the Company’s Internet access resources for personal use may be necessary, just as personal telephone calls from the office may be necessary, and may be more efficient than using the telephone or leaving the office to conduct personal business. Personal use of the Company’s Internet access resources is permitted subject to this policy. The capacity of the Company’s communications lines to the Internet is not unlimited and, therefore, Company-related uses have priority at all times. Permitted Uses Downloading of Text and Other Non-Executable Files For Company-related business, users, in their discretion, may download text and other non-executable files. Users are encouraged, where possible, to download large files (whether for Company-uses and always for personal uses) during off-peak periods (e.g., evening hours), when there is likely to be less congestion on the Company’s communications lines to the Internet. For personal use, users should  Attempt, where possible, to determine the size of a file before downloading and avoid downloading audio, video or graphics files, or any other files that are in excess of twenty pages. 40050488v1  Only print out a downloaded file when, having checked with other users, there are no other competing Company-related needs for the printer.  Not print out very large files Interactive Sites Users of the Internet may need to access Web sites or other Internet locations that require user registration or for which a charge is imposed. Users also may need to access or upload information to other interactive sites, such as bulletin boards or private or public chat rooms. Subject to the Company’s Policy Relating to Use of E-Mail (which prohibits subscribing to personal listservs at the Company, limits personal use to short messages and asks that users try to limit the receipt of lengthy personal messages from correspondents), access to such sites and locations is permitted in accordance with the following:  Registration using a Company e-mail address is permitted.  Whenever the user registers using a Company e-mail address, participates in a listserv, enters a chat room, sends or otherwise uploads information, the inclusion of the domain name “Company.com” indicates that the user is affiliated with the Company. Users should be sensitive to any such affiliation (whether implicit or express) and, for uses that are obviously Company-related, they must be authorized to engage in interactions or upload information that identifies their relationship to the Company.  If a Web site or other Internet location charges for access or to obtain relevant information, users should charge, or authorize another to charge, such fees to their Company-issued or personal credit cards. Where such charges are required for access in connection with Company-related matters, they are reimbursable in accordance with usual Company policies and procedures.  Participation in interactive games or in other similar interactive sites is not permitted for personal use. Prohibited Uses Internet access from the Company is prohibited for objectionable activity and the following activities are expressly prohibited:  Accessing (including browsing) any sexually-oriented or other similar “adult” Web sites, news groups or other Internet locations. Users are forbidden from undertaking any other activity that is intended to cause sexually-oriented or other “adult” materials to be downloaded to, or to be otherwise associated with, the Company.  Accessing (including browsing) any other Web sites, news groups or other Internet locations for purposes of gambling or engaging in any illegal activity.  Downloading executable programs (e.g., self-extracting zip files) or program modules (i.e., software applications or applets), or installing executable attachments to e-mail, except as authorized by the Information Services Department, to protect the Company’s computer systems from viruses and to prevent incompatibility with Company-provided software.  Conducting any ongoing non-Company business activity. Confidentiality Considerations Disclosure of user information is inherent in Internet usage. Users should be aware that they may be inadvertently disclosing confidential information about themselves and the Company to Web site operators or third parties.  Particularly when Internet usage is undertaken in connection with client-related matters, users should be aware that Web sites and other Internet locations are capable of monitoring and tracking user-specific and Company usage, the frequency and length of user visits, any items searched and any information that was retrieved and downloaded.  When Web sites and other Internet locations require information about the Company or its resources as a condition of registration or access, users should not disclose sensitive or proprietary information. Providing public information about the Company is permissible, but users should clear any disclosure of proprietary information with the Information Services Department.  Many Web sites use “cookies,” which are files that are sent to a user’s hard drive and allow Internet servers to keep track of specific user information. In the interests of maintaining user privacy and the confidentiality of information about the Company, its users and their usage patterns, the Company’s Internet browser has been modified to require the express consent of the user before a Web site is allowed to install a cookie on a user’s personal computer. In most cases, Web sites remain fully accessible even when a user declines to permit the cookie to be installed. Privacy Consistent with the tradition of the Company, we respect the privacy of all users of the Company’s Internet access resources. Personnel at the Company do not routinely monitor users in their Internet-related activities. Nevertheless, all users are put on notice that the Company tracks Internet usage and is aware of which sites (including the Web, news groups and other Internet locations) are visited by which users. It uses computer programs to check for and log patterns of activity, routing information and length of Internet access to particular sites and locations, and has the capability to monitor the contents of uploads and downloads. Accordingly, no user of the Company’s Internet access resources has (or should expect to have) any expectation of privacy. (The Company will, of course, respect its professional and legal obligations not to disclose client confidences.) Whether for the purposes of managing those resources and traffic flow, assuring system security, verifying and ensuring compliance of all persons with Company policies or applicable law, or for any other reason, the Company specifically reserves the right (from time-to- time or at any time), to intercept, divert, discard, access or review any Internet communication, other electronic communications or file, or any contents of such communication, or any other information created on, transmitted over or stored in Company or service provider facilities, whether incoming or outbound, and whether at the time of transit or thereafter. The Company also reserves the right to disclose to other persons or otherwise use the contents of any Internet communication or any other electronic communications or file for any of the foregoing purposes, as well as for the purposes of complying with or assisting law enforcement officials or legal authorities who may, by subpoena, search warrant or otherwise, seek review of such communications, or for the purposes of litigation or other legal proceedings. The only persons authorized by the Company to intercept, divert, access, disclose or review any Internet communication, other electronic communications or file, or any contents of such communication, without the consent of the sender or recipient, is the Director of the Company’s Information Services Department.