During the course of their work, many individuals working within or for Rauch Education will often handle or be exposed to information which is deemed personal, sensitive or confidential, which may include but is not limited to; commercial, private investor, program or project development, national or Education security. It is a requirement that any individual, company and firm to which this Policy applies shall not at any time during the period they work for or provide services to Rauch Education nor at any time after its termination, disclose confidential Information that is held or processed by Rauch Education. Further, information designated as confidential may not be discussed with anyone outside the organization and may be discussed within the organization only on a “need to know” basis. In addition, employees have a responsibility to avoid unnecessary disclosure of non-confidential internal information about the Company, its customers and suppliers. Individuals, Subsidiaries, Affiliates or Companies working for or with Rauch Education authorised to have access to confidential information may be required to sign special nondisclosure agreements and must treat the information as proprietary Company property for which they are personally responsible. Individuals, Subsidiaries, Affiliates or Companies working for or with Rauch Education are prohibited from attempting to obtain confidential information for which they have not received authorization. Individuals, Subsidiaries, Affiliates or Companies working for or with Rauch Education should not discuss with the officers, directors or employees of competing organisations any topic that might give the impression of an illegal agreement in restraint of trade. These prohibited topics include pricing agreements, customer allocation and division of sales territories. Individuals, Subsidiaries, Affiliates or Companies working for or with Rauch Education often learn confidential or proprietary information about the Company or its customers. Company policy prohibits Directors, Employees and Legal Agents from disclosing or using confidential or proprietary information outside the Company or for personal gain, either during or after employment, without proper written Company authorisation to do so. An unauthorised disclosure could be harmful to the Company or a customer or helpful to a competitor. The Company also works with proprietary data of customers, suppliers and joint venture partners. This is an important trust and must be discharged with the greatest care for the Company to merit the continued confidence of its customers, suppliers and joint venture partners. No Director, Employee or Legal Agent shall disclose or use confidential or proprietary information outside the Company without Company authorization, nor shall any Director, Employee or Legal Agent disclose such information to other Employees except on a need-to-know basis. Confidentiality should only be breached in exceptional circumstances and with appropriate justification and be fully documented. All staff, any individual, company or firm working within or for Rauch Education should ensure that the following principles are adhered to:

• When you are responsible for confidential information you must ensure that the information is effectively protected against improper disclosure when it is received, stored, transmitted or disposed of;
• Access to confidential information should be on a need-to-know basis
• Every effort should be made to inform individuals how their information is going to be used and who it will be shared with and why it may be shared
• When an individual consents to disclosure of information about them, they must be made aware of what is being disclosed, the reason it is being disclosed and the likely consequences of that disclosure
• If an individual withholds consent, or if consent cannot be obtained, disclosures may be made only where: They can be justified in the public interest (usually where disclosure is essential to protect someone from the risk of significant harm)

Individuals or companies working for or with Rauch Education violating this policy will be subject to disciplinary action, up to and including termination and may be subject to legal action.