Below is Gibraltar Associates’ newly-crafted social media policy. With it, we hope to establish a set of  best practices or guiding principles that will help our employees manage their online presence smartly. As employees, we must constantly remind ourselves that in the world of Web 2.0, we are a representational image of our employers, whether or not we intend to be.

We encourage other companies — particularly those currently without such a policy — to use the below as a guide in crafting their own best practices, but also to remember that in order to be effective a social media policy has to be tailored to your company and the type of business your company is in.

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Gibraltar Associates Social Media Policy

Facebook, Twitter, YouTube and You

Online Rules of Engagement

The following set of social media guidelines were developed for employees of Gibraltar
Associates. This policy will be updated as needed to reflect changes in emerging social media
networks, technologies and usage trends.

The social media policy (“SMP”) closely follows the Gibraltar Ethics Policy outlined in the
official employee handbook and will be included as an addendum to the existing handbook.
Gibraltar’s Ethics Policy states, “Gibraltar requires all employees to observe high standards of
business and personal ethics in the conduct of their duties and responsibilities. Employees may at
any time raise concerns in this regard or any other company policy with any member of
management. Employee complaints will be promptly and thoroughly investigated.”

Given the generally open access to social networks and blogs, Gibraltar requires that company
employees maintain these “high standards of business and personal ethics” when engaging across
online platforms as well. Adherence to this basic policy will ensure the image of Gibraltar and its
employees will be responsibly maintained.

The SMP applies to any Gibraltar employee at any level of employment (including part time and
hourly), who creates, contributes to or otherwise engages with blogs, wikis, social networks,
virtual worlds or any other kind of social media, whether or not the individual expressly
represents Gibraltar Associates in their engagement.

Please learn and follow Gibraltar’s guiding values as outlined below if you participate in social
media or produce online content. Failure to do so may limit or preclude your participation with
Gibraltar Associates in any capacity, whether currently or in the future.

1) Respect. Be respectful at all times. This includes using the appropriate tone and avoiding
offensive remarks/language.

2) Transparency. Always be open and transparent when communicating online. Not being
fully transparent is unethical and does not follow the Gibraltar Ethics Policy – this
includes refraining from creating anonymous comments or posts or using a false
pseudonym.

3) Prohibited / Confidential Content. Unless preapproved, work-related topics,
particularly those relating specifically to client work, are prohibited from discussion in
your personal social media networks.

4) Image. The image you portray online is a representation of and reflection on Gibraltar.
Remember this and keep it in mind when posting / tagging pictures or other content that
reflect on you or others, and use the Gibraltar Ethics Policy to help inform your
understanding of what is appropriate.

Further Discussion and SMP Rationale

In general, a good rule of thumb is that if you are about to post content that gives you pause – or
you think might make others at Gibraltar (or Gibraltar’s clients) uncomfortable – think twice
before hitting “send.”

In today’s world, the prevalence of social media has diluted any real notion of “privacy.” The
lines between professional life at work and personal life at home or on the weekends have
become blurred by the ubiquitous connectivity that social media affords its users. Therefore,
users of social media who are also Gibraltar employees need to continuously be aware of how
their actions or statements on social networks or blogs – even when at home and “off the clock”
– affect both their personal image and the image and reputation of Gibraltar and Gibraltar’s
clients.

Because social connectivity also blurs the lines between internal and external communications,
employees should be thoughtful about the content they publish, especially on external platforms.
It is equally important to ensure that employees do not disclose or otherwise reveal any
confidential or propriety information relating to Gibraltar or any of its clients.

It is also important not to discuss any of Gibraltar’s or Gibraltar’s clients’ proprietary financial or
other inside information, including private knowledge regarding business performance, business
plans or privileged financial statements. This applies to conversations of any kind, but especially
when talking to members of the press or other third party organizations, and includes
conversations with friends, whether written, spoken or electronic.

Accordingly, Gibraltar’s clients, partners and other third-party individuals or organizations with
whom Gibraltar works should not be cited or obviously referenced without prior approval of both
the individual or group in question as well as consent from Gibraltar management. Employees
should never reveal a client or partner by name without permission – excluding “agency of
record” situations – and should never discuss any confidential or proprietary details surrounding
client engagement, online or in person.

Gibraltar does, however, permit general discussion about kinds of projects the company is
engaged in, so long as the information provided does not make it easy for someone to identify
the client or violate any non-disclosure or intellectual property agreements that may be in place.

Additionally, no employee should conduct client business via their personal blog or other
personal social network.

Employees should also constantly keep in mind that there could be professional consequences to
the posting of personal content, even when this content does not directly relate to Gibraltar or
Gibraltar’s client work. It is also important to remember – particularly if the content in question
does relate to Gibraltar – that management is open to discussing any questions an employee may
have as to what is appropriate or inappropriate. Ultimately, though, the content, whether aural,
visual, written or electronic, is the sole responsibility of the employee regardless of the location
this content is posted – blog, social network, YouTube, etc.

Finally, employees should ensure that their online activities do not interfere with their
professionalism, commitment to Gibraltar or their ability to provide excellent client service.