Records Management Policy

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  11.11.2008    Mario Rieger   

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RECORDS MANAGEMENT POLICY In any company, corporate executives are ultimately responsible for ensuring that corporate records are properly managed. That responsibility lies with the President at each operating company. Records Management Policy requires that: A qualified individual is assigned the responsibility of developing, implementing and administering a comprehensive records management program Senior company management approves the RMP Record retention schedules are developed based upon legal and regulatory requirements and include descriptions of record titles and citations that document the logic and source(s) of retention periods Record retention schedules approved at two levels:

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1) Senior company management 2) Company Board Attorney Companies identify their vital records and execute a program that provides for their protection. Policies and procedures are developed and implemented to assure that: Unnecessary records are removed and destroyed no less than annually (Cleanouts) Records required for litigation or governmental inquiries are maintained and held until formally released by the Law Department

Mario Rieger

Digitally signed by Mario Rieger DN: cn=Mario Rieger, o, ou, email=mario_rieger@we b.de, c=US Reason: I am the author of this document Date: 2009.07.24 11:42:12 +02'00'

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Departments are audited for compliance with records management policies All records management standards are maintained A controlled program for secondary storage is implemented that includes policies and procedures for protection, retrieval, and destruction of inactive records Training is conducted to assure that records management policies are fully communicated to all employees of the company A program is in place to ensure the continuity of the business in the event of a disaster An annual report is submitted to the company’s Board of Directors and ILMW regarding the status of records management programs

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