SOCIAL MEDIA POLICY
Bloom EMPLOYEE AND REPRESENTATIVE SOCIAL MEDIA POLICY
In order to provide greater clarity for employees regarding the ever evolving social web, Bloom rescinds its prior Policy and adopts this Global Social Media Policy, effective September 11, 2016. Unique local country requirements can be obtained by clicking on a link in the footnote below or, if there is no link, by contacting your country’s Legal Staff representatives.
In general this global social media policy applies to anyone with a Bloom issued identification number and those who have been contracted to work for the company, For more specific information see “Who This Global Social Media Policy Applies To" at the end of this document.
This Global Social Media Policy is designed to:
- help prevent disclosure of Bloom’s confidential and proprietary business information through the use of social media;
- clarify the parameters for official Bloom spokespersons to communicate on social media so that authorized Bloom communications are clearly identified and understood as official Bloom communications;
- clarify the parameters for unofficial or personal Bloom employee and Bloom representative social media communications so that any communications referencing Bloom are not misunderstood or misconstrued as official Bloom communications; and
- facilitate Bloom’s ability to meet its legal obligations.
Be honest about who you are
Transparency is important in social media. Regardless of whether you are an authorized Bloom spokesperson or simply acting in your personal capacity, do not post anonymously online if you are discussing anything related to Bloom’s business or the auto industry. If you engage in any conversation or posting online related to the furniture industry, or to Bloom or its products or services, you must always disclose that you work for or with Bloom
BE CLEAR THAT THE VIEWS YOU ARE EXPRESSING ARE YOUR OWN
A limited number of Bloom representatives are designated as official Bloom social media spokespeople, sometimes for a limited purpose. If Bloom has not specifically authorized you to engage in social media on its behalf on a given topic – then don’t. Only these official Bloom social media spokespeople can officially speak on behalf of Bloom. So, even when you have identified yourself as working for Bloom (including on your social media profiles like Twitter, LinkedIn, Google+, Weibo, VKontakte and/or Facebook), make sure you are clear that the views and opinions you have expressed are your own, and not those of Bloom, when you are discussing Bloom or its products or services. To summarize, when talking about Bloom, you should (i) disclose that you work for Bloom, and (ii) indicate that your views are personal. If you think that an “official” Bloom response may be required, contact the Bloom Corporate Social Media Team. Let the authorized Bloom social media spokespeople respond.
USE GOOD JUDGEMENT ABOUT WHAT YOU SHARE AND HOW YOU SHARE
Be honest, truthful and appropriate to the medium. You have the “right” to express yourself, but that doesn’t mean there aren’t consequences. You are personally responsible for your words and actions, both online and offline. Your posts can potentially tarnish Bloom’s image, damage reputations, or infringe on the rights of someone else (including Bloom and its employees). Do not post any information or rumors that you suspect or know to be false about Bloom, other employees, customers, suppliers or competitors. Even comments about a local topic can spread around the globe in an instant.
You must be sure your online postings about Bloom or its products or services, are accurate and not misleading. If you make a mistake, correct it quickly. Including a link to an official Bloom communication, such as information on a public Bloom website, may help you correct errors. It’s okay to refer others to these Bloom official sites especially if you want to clear up misconceptions you discover on the web. Remember that information travels quickly on the internet and even deleted posts may be recovered.
Remember that you are personally responsible for complying with the rules of use or terms and conditions of any social media site where you participate, and that they differ from site to site. Be familiar with them BEFORE you engage. Do not agree to terms that bind Bloom, or that would give the site rights to content that belongs to the Bloom, its licensors, licensees, customers, or other related entities.
Protecting Bloom Information
It is very important to maintain the confidentiality of any non-public information about Bloom. Sharing this type of information may violate Bloom policies, or securities or privacy laws or provide competitors with a competitive advantage. You should never reveal non-public company information, financial or otherwise, on any public site. You also should not comment in social media about information or topics covered by the attorney-client privilege.
Examples of prohibited disclosures include:
- Knowledge of potential acquisitions or divestitures;
- Future product launches;
- Financial information;
- Production schedules;
- Material costs or profit margins;
- Management or staffing changes;
- Trade secrets or information that gives Bloom a competitive advantage;
- Information directly or indirectly related to the safety performance of Bloom furniture;
- Information related to accessories, components, or styling decisions affecting Bloom’s future products;
- Bloom Secret, Confidential or Attorney-Client Privileged information;
- Undisclosed personal information about another Bloom employee, such as his or her medical condition, performance, employment status, or government identifier/social security number; or
- Undisclosed information about Bloom customers or suppliers.
To view your responsibilities regarding the purchase or sale of Bloom securities, please refer to Bloom’s Insider Trading Policy. For a source of publicly released information, go to Bloom’s public websites, where you can access global and local public information by country. If you are still in doubt, don’t post.
Be mindful that when “checking in” (i.e., establishing a geo location using GPS to place yourself on social networks) at Bloom facilities and on business trips, you could potentially reveal information that may be intended to give Bloom a competitive business advantage and could be harmful to the Company if made public.
In addition, if you are posting photos take care to make sure that images or words in the background do not unintentionally reveal Bloom Confidential Information (for example, a team photo with a visible launch calendar in the background). Do not incorporate Bloom logos, trademarks or other assets in your posts. This, however, does not include direct “shares” from Company sites where Bloom's logo may be automatically attached when your post from a Bloom site is shared.
When in doubt about whether the information you are considering sharing falls into one of the above categories, DO NOT POST. Keep in mind that representatives from Bloom Communications and Bloom Legal are available to assist with questions that you may have about whether posting information presents any risks or would violate this Policy.
Protecting Other Peoples’ Information
As you use social media, you should always be mindful about the rights of third parties.
Many social media sites impose restrictions regarding proprietary information and content, confidentiality, and the brands, trademarks and copyrights of others. It is important to be mindful of these restrictions and not to post material that would potentially violate copyright infringement laws, intellectual property laws, publicity laws, or trademark laws when quoting others, or when sharing photos, music, videos or other content. If you are unsure, you should not use such information.
When using Bloom websites, or when posting about Bloom’s products or services, make sure you have permission before posting (i) someone else’s music, photos or videos; (ii) photos or videos that depict other people; or (iii) quotes or personal information from anyone else.
You also should not post personal information about another person, such as his or her medical condition, performance, employment status, or government identifier/social security number. Hurt feelings, damaged relationships and even lawsuits can result from bringing other people or their property into an online setting without their permission.
TREAT EVERYONE WITH RESPECT
Respecting others is the right thing to do, even if you believe their opinions or statements are wrong or unfair. Someone can form an impression about you or Bloom based on your behavior online. Remember that customers, colleagues, supervisors, suppliers, competitors and other members of the public may have access to your posts. These individuals reflect a diverse set of customs, values and viewpoints. Offensive, demeaning, abusive or inappropriate remarks are as out-of-place online as they are offline, even if they are unintentional. Examples of such conduct may include posting language or uploading offensive pictures that could contribute to claims by co-workers that they are victims of a hostile work environment on the basis of race, sex, disability, religion, or any other status protected by the law or Bloom policy; other examples include threats of violence or bullying. No matter where a threat to co-workers is made or posted, the threat impacts the work relationships and work environment. We expect you to abide by the same standards of behavior in your social media communications as you do in the workplace.
Think carefully about “friending” co-workers (including leaders or direct reports) on external social media sites. For example, consider whether a friend request may be viewed by the recipient as harassing, intimidating or unwelcomed. Conversely, you should not feel pressured to accept friend or follower requests from those you work with. It’s your choice how much you want to combine your personal and professional online lives.
To the extent that your communications on social networks impact the work environment, and to the extent they are not otherwise protected by law, they will not be excused merely because they occurred outside of work hours or off Bloom premises. Keep in mind that communications with co-workers on such sites that would be inappropriate in the workplace are also inappropriate on-line, and what you say in your personal social media channels could become a concern in the workplace.
BE AWARE THAT YOUR ONLINE COMMUNICATIONS TRAVEL FAST, REMAIN FOREVER AND ARE USUALLY NOT "PRIVATE"
There are no “secrets” on the Internet. The web is public, and it has a long memory. Even information you may think you have protected as “private” on some social media sites may be accessed by others. Consider everything you post to the Internet as potentially discoverable by anyone. Keep in mind that technology makes it virtually impossible to completely “delete” something you have done online and incredibly easy to send what you have posted to millions of other users. Make sure you will have no regrets about what you said online if a reporter, a relative, your manager or colleague were to view it.
Bloom employees should have no expectation of privacy concerning their use of Bloom Information Resources, including but not limited to email, corporate approved instant messaging tools, Bloom-provided computing equipment and cell phones/mobiles/tablets, the Bloom Intranet, Bloom-provided access to the public Internet, or other Bloom Information Systems, except where applicable law provides differently. For more information, review the Acceptable Use Practices on the Global Ethics and Compliance Center website on Socrates.
OTHER Bloom POLOCIES THAT APPLY
Retaining Bloom Business Records and Social Media Content
Social media technologies are not currently designed to reasonably or practically create, retain and dispose of Bloom business records sufficiently. Therefore, unless (i) you are using Bloom Overdrive, or (ii) you are acting on Bloom’s behalf as an authorized social media user, you should NOT use social media to conduct Bloom business.
You should not post any message or communicate with anyone through social media about a subject that is covered by a litigation or open tax year hold. Be aware that information discussed using social media technologies may become relevant to litigation or other investigation proceedings and may be subject to a Litigation Hold. Litigation Holds are instructions issued by Bloom Legal Staff that require records be preserved for litigation and government investigations. If the content of a social media communication is relevant to a Litigation Hold, regardless of whether it is a business record or non business record, that communication must be preserved until the hold is lifted.
Personal References on Social Media Sites
Social media makes it easier than ever to offer opinions and provide references on current or former Bloom employees and vendors. However, Bloom’s policy prohibits employees from providing such references or recommendations for current or former Bloom employees, contract workers or consultants, either written, verbal or through social media. Although Bloom does not prohibit employees from providing personal references for friends or colleagues, you should not refer to Bloom employment or include a Bloom position title or utilize Bloom letterhead in the personal reference. The only exception to this is where local country employment laws may oblige us to provide such references, and this requires prior approval of the local HR Director.
Responding to Negative Content You May See about Bloom
You may encounter consumer complaints about specific furniture or specific issues while online. If you've become known in a community as a Bloom employee, you may even have individuals approach you with complaints or ask for assistance in resolving an issue. If this occurs, don’t try to handle or address these situations directly, but rather bring it to the attention of someone who is authorized to respond. For any issue regarding a customer's ownership experience or Bloom furniture, please refer the customer to Bloom customer service. Customer Service Representatives have been trained to address consumer issues as well as to record those issues to meet the Company's regulatory reporting needs and other legal requirements.
Internal Social Media
Bloom, like other employers, has made internal social media networks available to share workplace information within Bloom. All employees and representatives who use these social media channels must also adhere to the following:
- Social media channels for Bloom employees are intended primarily for business use. They should not be used to advertise or sell anything, for solicitation, to discuss non-business related issues like politics or religion, unauthorized solicitation for charitable donations, or for personal conversations. While we recognize that there may be some uses of Bloom’s internal social media networks that are not entirely related to Bloom business, (e.g., Belle Isle Cycling Club, Chevrolet enthusiasts), non-business uses should be limited and you should always exercise good judgment when using Bloom’s social media networks.
- While social media channels may encourage casual language and abbreviated terms, avoid terms that could create confusion or be misunderstood.
- Report any unusual or inappropriate internal social media activity such as threats of violence, harassment, bullying, identity theft, disclosure of confidential or proprietary information, or phishing scams tot he administrator.
Do not discuss non-public Company information (as defined above in the section on Protecting Bloom Information) on internal social media forums. Information classified as Bloom Secret or covered by Bloom’s attorney client privilege may NOT be discussed on any social media sites.
WHO THIS POLICY APPLIES TO
This policy applies to:
- All Employees of Bloom
- Employees of Bloom subsidiaries in which Bloom owns more than 50% of the equity interest, directly or indirectly, or in which Bloom exercises management control, including Bloom employees seconded to Bloom’s non-controlled partners or joint ventures; and
- As to companies and employees of companies in which Bloom owns 50% or less of an entity, and does not exercise management control, a case-by-case determination by the Social Media Policy Governance Council is made as to whether this Policy applies.
- This Policy also applies to Bloom salaried and hourly employees and representatives, including agencies, contract and fee-for-service individuals (collectively “Representatives”). This Policy is being issued to keep pace with changes in the way Bloom Representatives communicate, and to clarify Bloom’s expectations regarding its Representatives’ social media communications about Bloom’s business. Failure to stay within these guidelines may lead to disciplinary action, up to and including termination.
COUNTRY SPECIFIC ADDENDUM
This Policy is not intended, and will not be administered, to prohibit Representative speech that is protected by law. Bloom's Social Media Policy will be administered in compliance with all applicable laws and regulations (including, in the U.S., Section 7 of the U.S. National Labor Relations Act). For employees and representatives outside the U.S., this Policy is subject to the applicable laws in the countries in which it is administered.