NOTICE: Paper copies of this Procedure should NOT be used for decision making purposes.

Only use the electronic LAN based copy at

u:\common\Policies and Procedures\Assoc Relations\.

Subaru of Indiana Automotive, Inc.

Policy

Policy No.
40-04

Effective Date:
01/01/09 E-MAIL AND INTERNET POLICY
Supercedes: 3/26/98

I. PURPOSE:

To establish an SIA compliance regulation with regard to (1) access, use, retention,
and disclosure of electronic mail messages sent or received on SIAs electronic mail
systems (E-mail) and (2) access and use of the Internet. This policy applies to all SIA
Associates and Temporary Workers.

II. GENERAL PROVISIONS:

(1) Use of E-mail and Internet access services provided to Associates by SIA is limited to
SIA approved and business related purposes only. An Associates use of SIA
provided E-mail and Internet access constitutes the Associates agreement to abide by
SIA policies and legal restrictions applicable to such use. The excessive use of E-mail
and the Internet for personal business is strictly prohibited, and E-mail and the
Internet may not be used for any solicitation of any kind between or among
Associates. All use of SIA provided E-mail and Internet access is subject to audits
and monitoring by SIA to ensure compliance with this policy and applicable law, and
to protect SIA and its Associates. SIA reserves the right to access, monitor and
disclose, with or without advance notice, the contents of any correspondence or data
sent, received or stored by Associates on E-mail or the Internet to determine whether
there have been any breaches of security, violations of SIA policies or law or other
misuse. Any Associate who violates this policy or applicable law shall forfeit his/her
Internet privilege, and shall be subject to corrective action under SIAs policies and
possible civil and criminal liability. Information Systems (IS) is responsible for the
administration of this policy. Section Managers are responsible for explaining this
policy to all Associates under their supervision and monitoring its administration.

(2) E-mail and Internet communications are the property of SIA and constitute SIA
records. Associates should be aware that these communications are not private but are
business records that can be subpoenaed by a court of law. Do not send or download
E-mail or Internet communications, internally or externally, that contain material that
could be considered libelous or defamatory about any individual or company or
NOTICE: Paper copies of this Procedure should NOT be used for decision making purposes. Only use the electronic LAN based copy at
u:\common\Policies and Procedures\Assoc Relations\.

messages that disparage another companys products or services. Do not send or

knowingly download materials, messages, internally or externally, that might be
considered offensive, including materials or messages with sexually explicit content,
racial slurs, religious content or other materials that may be interpreted as demeaning
or ridiculing any individual or group. Any such offensive or demeaning material may
not be downloaded, copied or printed from the Internet. Libelous, defamatory and
offensive communications may result in corrective action, up to and including
termination of employment, and personal civil liability for the Associate, as well as
liability for SIA. Questions about whether your anticipated communications may
violate SIA policy or applicable law should be referred to the SIA Legal Department.

(3) Confidential and proprietary SIA information is not to be transmitted or received over
the Internet, nor is such information to be communicated to any third party by
unsecured E-mail without the prior approval of the Section Manager. Information
transmitted or received by these methods may be accessed by unauthorized
individuals.

(4) Access to the E-mail and Internet systems creates issues with regard to ownership and
use of information, the copying and distribution of materials and the potential
presence of viruses. Therefore, all Associates should be aware of the following:

a) Information created by an Associate as part of the Associates work is

owned by SIA, which reserves all rights. An Associate may not copy,
upload or distribute externally any such information, except as expressly
permitted by SIA.

b) Some of the materials on the Internet are protected by copyright law in the
United States and other countries. Associates may not download, copy,
print and distribute, or create derivative works from copyrighted materials
without obtaining permission from the author to do so. In order to protect
SIA from unintended liability for infringement, requests to use such
materials should be forwarded to the SIA Legal Department.

c) Do not send messages about SIA products, services, policies or positions

that might tend to harm SIAs image. Internal SIA business sensitive
messages or documents should not be sent or forwarded to an Associates
external email accounts, or to any outside network, unless covered by other
SIA Company Business Communications Policies or confidentiality
agreements or having prior approval from the responsible section
Management.

d) Downloading files or programs from the Internet creates the possibility of

importing a virus, worm, Trojan horse or E-mail bomb that can
infect the entire system and destroy valuable information or take down the
NOTICE: Paper copies of this Procedure should NOT be used for decision making purposes. Only use the electronic LAN based copy at
u:\common\Policies and Procedures\Assoc Relations\.

computer system. Therefore, no files should be downloaded onto or

executed in an environment where the risk of spreading a virus, worm,
Trojan horse or E-mail bomb exists, such as LAN, WAN, client server or
mainframe system. If software must be downloaded, it should be done
under the supervision of IS. Do not execute the program until a virus
detection program has been run to determine whether a virus or bomb exists
within the program. Associates should be cautious of unsolicited E-Mail
received via the Internet as such E-Mail may contain the above mentioned
threats. Contact IS for details on this issue.

(5) All E-mail and Internet accounts are granted on a per user basis. Section Manager
approval for Internet access is required. Sharing User IDs and passwords, or using
another User ID, with any other Associate or person is prohibited. Associates are
responsible for all use of their account. The dissemination and use of passwords does
not mean that E-Mail and Internet communication by Associates is private and
confidential; the communication is still subject to audits and monitoring by SIA and
may be accessed by unauthorized individuals.

(6) System statistics will be generated on a regular basis. Any user exceeding SIA
guidelines on space utilization or message retention will be notified by IS to purge
data. Associates will then have one week to rectify the situation or IS will
automatically purge messages beginning with the oldest messages until the current IS
guideline on utilization is achieved.

The intent of this policy is to identify certain uses of E-Mail and the Internet which are not
appropriate, not to exhaustively enumerate all such possible uses. SIA reserves the right from
time to time to replace, modify or expand upon this policy and to make determinations that
particular uses are not appropriate.