Information Security Policy

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Overview

This Information Security Policy is intended to protect ecoPortal’s employees, partners, and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.

Internet/Intranet/Extranet-related systems, including but not limited to computer equipment, software, operating systems, storage media, network accounts providing electronic mail, web browsing, and file transfers, are the property of ecoPortal. These systems are to be used for business purposes in serving the interests of the company, and of our clients and customers during normal operations.

Effective security is a team effort involving the participation and support of every ecoPortal employee or contractor who deals with information and/or information systems. It is the responsibility of every team member to read and understand this policy and to conduct their activities accordingly.

Purpose

The purpose of this policy is to communicate our information security policies and outline the acceptable use and protection of ecoPortal’s information and assets. These rules are in place to protect customers, employees, and ecoPortal. Inappropriate use exposes ecoPortal to risks including virus attacks, compromise of network systems and services, financial and reputational risk, and legal and compliance issues.

The ecoPortal “Information Security Policy” is comprised of this policy and all ecoPortal policies referenced and/or linked within this document.

Scope

This policy applies to the use of information, electronic and computing devices, and network resources to conduct ecoPortal business or interact with internal networks and business systems, whether owned or leased by ecoPortal, the employee, or a third party. All employees, contractors, consultants, temporary, and other workers at ecoPortal and its subsidiaries are responsible for exercising good judgment regarding the appropriate use of information, electronic devices, and network resources in accordance with ecoPortal policies and standards, and local laws and regulations.

This policy applies to employees, contractors, consultants, temporaries, and other workers at ecoPortal, including all personnel affiliated with third parties. This policy applies to all ecoPortal-controlled company and customer data as well as all equipment, systems, networks, and software owned or leased by ecoPortal.

Security Incident Reporting

All users are required to report known or suspected security events or incidents, including policy violations, and observed security weaknesses. Incidents shall be reported immediately or as soon as possible by sending an email to: issues@ecoportal.com.

In your email please describe the incident or observation along with any relevant details.

Whistleblower Anonymous Fraud Reporting

Our Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that we can address and correct inappropriate conduct and actions. It is the responsibility of all employees to report concerns about violations of our code of ethics or suspected violations of law or regulations that govern our operations.

It is contrary to our values for anyone to retaliate against any employee or who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Anonymous reports may be submitted via Google Forms.

Mobile Device Policy

All end-user devices (e.g., mobile phones, tablets, laptops, desktops) must comply with this policy. Employees must use extreme caution when opening email attachments received from unknown senders, which may contain malware.

System level and user level passwords must comply with the Access Control Policy.  Providing access to another individual, either deliberately or through failure to secure a device is prohibited.

All end-user, personal (BYOD), or company-owned devices used to access ecoPortal information systems (i.e. email) must adhere to the following rules and requirements:

• Devices must be locked with a password (or equivalent control such as biometric) protected screensaver or screen lock after 5 minutes of non-use

• Devices must be locked whenever left unattended

• Users must report any suspected misuse or theft of a mobile device immediately to  ecoPortal’s Tech Team

• Confidential information must not be stored on mobile devices or USB drives (this does not apply to business contact information, e.g., names, phone numbers, and email addresses)

• Any mobile device used to access company resources (such as file shares and email) must not be shared with any other person

• Upon termination, users agree to return all company-owned devices and delete all company information and accounts from any personal devices

Clear Screen Clear Desk Policy

Users shall not leave confidential materials unsecured on their desk or workspace and will ensure that screens are locked when not in use.

Remote Access Policy

Laptops and other computer resources that are used to access the ecoPortal network must conform to the security requirements outlined in ecoPortal’s Information Security Policies and adhere to the following standards:

• To ensure mobile devices do not connect a compromised device to the company network, Antivirus policies require the use and enforcement of client-side antivirus software

• Antivirus software must be configured to detect and prevent or quarantine malicious software, perform periodic system scans, and have automatic updates enabled

• Users must not connect to any outside network without a secure, up-to-date software firewall configured on the mobile computer

• Users are prohibited from changing or disabling any organizational security controls such as personal firewalls, antivirus software on systems used to access ecoPortal resources

• Use of remote access software and/or services (e.g., VPN client) is allowable as long as it is provided by the company and configured for multifactor authentication (MFA)

• Unauthorized remote access technologies may not be used or installed on any ecoPortal system

• If you access it from a public computer (e.g., from a business center, hotel, etc.), log out of the session and don’t save anything. Don’t check “remember me”, collect all printed materials, and do not download files to a non-ecoPortal controlled system

Acceptable Use Policy

ecoPortal proprietary and customer information stored on electronic and computing devices, whether owned or leased by ecoPortal, the employee, or a third party, remains the sole property of ecoPortal for the purposes of this policy.  Employees and contractors must ensure through legal or technical means that proprietary information is protected in accordance with the Data Management Policy. The use of Google Drive for business file storage is required for users of laptops or company-issued devices. Storing important documents on the file share is how you “backup” your laptop.

You have a responsibility to promptly report the theft, loss, or unauthorized disclosure of ecoPortal proprietary information or equipment. You may access, use or share ecoPortal proprietary information only to the extent it is authorized and necessary to fulfill your assigned job duties. Employees are responsible for exercising good judgment regarding the reasonableness of personal use of company-provided devices.

For security and network maintenance purposes, authorized individuals within ecoPortal may monitor equipment, systems, and network traffic at any time.

ecoPortal reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.

Unacceptable Use

The following activities are, in general, prohibited. Employees may be exempted from these restrictions during the course of their legitimate job responsibilities with properly documented Management approval. Under no circumstances is an employee of ecoPortal authorized to engage in any activity that is illegal under local, state, federal, or international law while utilizing ecoPortal-owned resources or while representing ecoPortal in any capacity. The list below is not exhaustive but attempts to provide a framework for activities that fall into the category of unacceptable use.

The following activities are strictly prohibited, with no exceptions:

1. Violations of the rights of any person or company protected by copyright, trade secret, patent, or other intellectual property, or similar laws or regulations, including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by ecoPortal

2. Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books, or other copyrighted sources, copyrighted music, and the installation of any copyrighted software for which ecoPortal or the end user does not have an active license

3. Accessing data, a server, or an account for any purpose other than conducting ecoPortal business, even if you have authorized access, is prohibited

4. Exporting software, technical information, encryption software, or technology, in violation of international or regional export control laws, is illegal. The appropriate management shall be consulted prior to the export of any material that is in question

5. Introduction of malicious programs into the network or systems (e.g., viruses, worms, Trojan horses, email bombs, etc.)

6. Revealing your account password to others or allowing use of your account by others. This includes family and other household members when work is being done at home

7. Using a ecoPortal computing asset to actively engage in procuring or transmitting material that is in violation of sexual harassment or hostile workplace laws

8. Making fraudulent offers of products, items, or services originating from any ecoPortal account

9. Making statements about warranty, expressly or implied, unless it is a part of normal job duties

10.  Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient, or logging into a server or account that the employee is not expressly authorized to access, unless these duties are within the scope of regular duties. For purposes of this section, "disruption" includes, but is not limited to, network sniffing, pinged floods, packet spoofing, denial of service, and forged routing information for malicious purposes

11.  Port scanning or security scanning is expressly prohibited unless prior notification to the ecoPortal engineering team is made

12.  Executing any form of network monitoring which will intercept data not intended for the employee's host, unless this activity is a part of the employee's normal job/duty

13.  Circumventing user authentication or security of any host, network, or account

14.  Introducing honeypots, honeynets, or similar technology on the ecoPortal network.

15.  Interfering with or denying service to any user other than the employee's host (for example, denial of service attack)

16.  Using any program/script/command, or sending messages of any kind, with the intent to interfere with, or disable, a user's session, via any means

17.  Providing information about, or lists of: ecoPortal employees, contractors, partners, or customers to parties outside ecoPortal without authorization

Email and Communication Activities

When using company resources to access and use the Internet, users must realize they represent the company and act accordingly.

The following activities are strictly prohibited, with no exceptions:

1. Sending unsolicited email messages, including the sending of "junk mail", or other advertising material to individuals who did not specifically request such material (email spam)

2. Any form of harassment via email, telephone, or texting, whether through language, frequency, or size of messages

3. Unauthorized use, or forging, of email header information

4. Solicitation of email for any other email address, other than that of the poster's account, with the intent to harass or to collect replies

5. Creating or forwarding "chain letters", "Ponzi", or other "pyramid" schemes of any type

6. Use of unsolicited email originating from within ecoPortal networks or other service providers on behalf of, or to advertise, any service hosted by ecoPortal or connected via ecoPortal’s network

Additional Policies and Procedures Incorporated by Reference

Personnel is responsible for reading and complying with all policies relevant to their roles and responsibilities.

Policy Compliance

ecoPortal will measure and verify compliance with this policy through various methods, including but not limited to ongoing monitoring and both internal and external audits.

Exceptions

Requests for an exception to this policy must be submitted to the CTO for approval.

Violations & Enforcement

Any known violations of this policy should be reported to the CTO. Violations of this policy can result in immediate withdrawal or suspension of the system and network privileges and/or disciplinary action in accordance with company procedures up to and including termination of employment.