Panalyt Cyber Security Policy
1. Policy brief & purpose
Our company cyber security policy outlines our guidelines and provisions for preserving the security of our data andtechnology infrastructure.
The more we rely on technology to collect, store and manage information, the more vulnerable we become to severe
security breaches. Human errors, hacker attacks and system malfunctions could cause great financial damage andmay jeopardize our company’s reputation.
For this reason, we have implemented a number of security measures. We have also prepared instructions that mayhelp mitigate security risks. We have outlined both provisions in this policy.

2. Scope
This policy applies to all our employees, contractors, volunteers and anyone who has permanent or temporary accessto our systems and hardware.

3. Policy elements
3.1 Confidential data
Confidential data is secret and valuable. Common examples are:●●●●Unpublished financial information
Data of customers/partners/vendors
Patents, formulas or new technologies
Customer lists (existing and prospective)

All employees are obliged to protect this data. In this policy, we will give our employees instructions on how to avoid
security breaches.

3.2 Protect personal and company devices
When employees use their digital devices to access company emails or accounts, they introduce security risk to ourdata. We advise our employees to keep both their personal and company-issued computer, tablet and cell phone
secure. They can do this if they:●●

Keep all devices password protected.
Choose and upgrade a complete antivirus software. The Panalyt Data Security Officer is responsible for
installing the latest version of AVG Antivirus ( https://www.avg.com/en-ww/avg-antivirus-for-mac) on every●●●Panalyt terminal before handing over to a new employee and ensuring it is constantly updated onemployee terminals.
Ensure they do not leave their devices exposed or unattended.
Install security updates of browsers and systems monthly or as soon as updates are available.
Log into company accounts and systems through secure and private networks only.

We also advise our employees to avoid accessing internal systems and accounts from other people’s devices orlending their own devices to others.
When new hires receive company-issued equipment they will receive instructions for:●●●Password management for all company accounts across different system
Secure file transfer practices
Maintenance of antivirus/ anti-malware software setup by line manager before item handover

They should follow instructions to protect their devices and refer to the Panalyt Data Security Officer if they haveany questions.

3.3 Keep Emails safe
Emails often host scams and malicious software (e.g. worms.) To avoid virus infection or data theft, we instructemployees to:●●●●Avoid opening attachments and clicking on links when the content is not adequately explained (e.g.
“watch this video, it’s amazing.”)
Be suspicious of clickbait titles (e.g. offering prizes, advice.)
Check email and names of people they received a message from to ensure they are legitimate.
Look for inconsistencies or give-aways (e.g. grammar mistakes, capital letters, excessive number ofexclamation marks.)

If an employee isn’t sure that an email they received is safe, they can refer to the Panalyt Data Security Officer.

3.4 Manage passwords properly
Password leaks are dangerous since they can compromise our entire infrastructure. Not only should passwords besecure so they won’t be easily hacked, but they should also remain secret. For this reason, we advise our employees
to:
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Choose passwords with at least ten characters (including capital and lower-case letters, numbers andsymbols) and avoid information that can be easily guessed (e.g. birthdays.)
Remember passwords instead of writing them down. If employees need to write their passwords, they areobliged to keep the paper or digital document confidential and destroy it when their work is done.
Under no circumstances are Panalyt employees allowed to share their credentials for access to anysystem.

Remembering a large number of passwords can be daunting. We will purchase the services of a password
management tool which generates and stores passwords. Employees are obliged to create a secure password for thetool itself, following the above mentioned advice.

3.5 Transfer data securely
Transferring data introduces security risk. Employees must:●●●●●

Avoid transferring sensitive data (e.g. customer information, employee records) to other devices oraccounts unless absolutely necessary. When mass transfer of such data is needed, we request
employees to ask our Panalyt Data Security Officer for help.
Share confidential data over the company network/ system and not over public Wi-Fi or privateconnection.
Ensure that the recipients of the data are properly authorized people or organizations and have adequate
security policies.
Report scams, privacy breaches and hacking attempts
All communication channels used for communicating client’s data must be encrypted using standard
encryption methods.

Our IT team needs to know about scams, breaches and malware so they can better protect our infrastructure. For thisreason, we advise our employees to report perceived attacks, suspicious emails or phishing attempts as soon as
possible to our specialists. Our IT team must investigate promptly, resolve the issue and send a companywide alert
when necessary.
Our IT team is responsible for advising employees on how to detect scam emails. We encourage our employees toreach out to them with any questions or concerns.

3.6 Additional measures
To reduce the likelihood of security breaches, we also instruct our employees to:
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Turn off their screens and lock their devices when leaving their desks. All Panalyt terminals must beconfigured with an automatic screen lock after 5 minutes of inactivity.
Report stolen or damaged equipment as soon as possible to the IT Department and HR.
Change all account passwords at once when a device is stolen.
Report a perceived threat or possible security weakness in company systems.
Refrain from downloading suspicious, unauthorized or illegal software on their company equipment.
Avoid accessing suspicious websites.

We also expect our employees to comply with our social media and internet usage policy.
Our IT team should:
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Install firewalls, anti malware software and access authentication systems.
Arrange for security training for all employees.
Inform employees regularly about new scam emails or viruses and ways to combat them.
Investigate security breaches thoroughly.
Follow these policies’ provisions as other employees do.

Our company will have all physical and digital shields to protect information.

3.7 Remote employees
Remote employees must follow this policy’s instructions too. Since they will be accessing our company’s accounts
and systems from a distance, they are obliged to follow all data encryption, protection standards and settings, andensure their private network is secure.
We encourage them to seek advice from our IT team.

4. Disciplinary Action
We expect all our employees to always follow this policy and those who cause security breaches may facedisciplinary action:●●

First-time, unintentional, small-scale security breach: We may issue a verbal warning and train theemployee on security.
Intentional, repeated or large scale breaches (which cause severe financial or other damage): We will
invoke more severe disciplinary action up to and including termination.
We will examine each incident on a case-by-case basis.

Additionally, employees who are observed to disregard our security instructions will face progressive discipline, even
if their behavior hasn’t resulted in a security breach.

5. Revision
The Panalyt Data Security Policy is reviewed and updated on a regular basis in line with new loopholes to prevent
potential security-related incidents from occurring.

Daniel J WestFounder and CEO
Panalyt