Confidentiality

GENERAL CONFIDENTIALITY POLICY

Following are some guidelines that will help individuals (Spear’s employees, consultants, suppliers, etc.) involved in any of Translation Projects in dealing with confidential information while working on the Translation Project. Please read this entire document very carefully.

The objective of maintaining confidentiality is to ensure the integrity of the translation project management process, prevent any personnel from obtaining an advantage, as well as to avoid protests. It is crucial to understand that the disclosure of particular confidential or sensitive information could jeopardize the service Spear provides. Individuals involved in the Translation Project must be careful to avoid breaching of confidentiality both inside and outside of the workplace. Each individual is personally responsible for maintaining confidentiality in all verbal and written communications, as well as in the handling of information through electronic means such as email, communication applications or any software. The disclosure of any sensitive information that may jeopardize the Translation Project may result in civil or criminal penalties and/or disciplinary actions.

If you have any questions,please contact SPEAR Group Ltd., at info@spear.com.hk. (https://www.spear.com.hk)

SIGNING CONFIDENTIALITY AGREEMENTS

Individuals working on the Translation Project will be required to sign a confidentiality agreement prior to entering into discussions or planning of the Project. Individuals who are currently working in any Project Management activities and who have yet signed a confidentiality agreement should ask for an agreement, sign and submit it back to one’s immadiate manager.

Please read the confidentiality agreement carefully. It also includes a conflict of interest statement. Any individual who believes that they may have a personal or financial interest that would be inappropriate rto participate in any Translation and Management Project activities must disclose that information to Spear Group Ltd. prior to signing the confidentiality agreement.

In some cases, support staff may be required to handle confidential information. Those situations should be reviewed and may require such support staff to sign also a confidentiality agreement. Support staff will be instructed on how to handle such confidential information.

WHAT INFORMATION IS CONFIDENTIAL?

• Any information related to the Translation Project Management.

• Any document, hard-copy and materials labelled with “Confidential”.

• Any materials not to be released to any supplier.

• Any feedback, proposal or evaluation materials related to certain Translation Management Project

• Any discussions and Decisions related to the Translation Project

CHOCIE OF LAW

All Confidentiality Agreement, Terms, Conditions and Statements shall be governed by the substantive law of Hong Kong SAR.