FTC Networks, LLC

At FTC Networks we are committed to the highest level of integrity while we build and nurture a culture of trust. Our security efforts are focused on three areas, which are the essence of Network Security:

· Safeguard our customers, our users, our staff, our property, our information and our assets.

· Preserve our reputation and protect network value by supporting the highest standards of ethical conduct.

· Protect Company facilities, physical and intellectual property through a process of managing and mitigating security risks.

· Participate in and support the Company Compliance and Internal Audit programs including integrated support of the Child’s Online Privacy Protection Act (COPA), and other online security initiatives.

· Develop and maintain security-related policies, procedures, standards and guidelines to assist Company decision makers in improving protections and reducing potential security threats.

· Partner with Legal, Audit, and Information Technology support units to ensure compliance with regulatory requirements and adequate protection for FTC Networks' intellectual property and information assets.

· Partner with Health and Safety, Compliance, Human Resources and Operational Support units to provide cost effective solutions for access control, monitoring, protection and surveillance of locations and facilities.

· Provide an effective process for reporting security incidents and violations and for conducting timely investigation of complaints.

· Establish and maintain Emergency Response and Emergency Command Center plans and operation functions.

· Maintain strong liaison with relevant law enforcement, regulatory agencies and professional organizations for assistance, timely information and ongoing business improvement strategies in the security field.

· Provide support to local Crime Stoppers organizations and other community outreach programs

· Implement and maintain effective, Company-wide pre-and post-employment background screening and drug screening programs for our workforce.

· Establish and operate a Life Safety Control Center to provide cost-effective around-the-clock monitoring of alarms, access controls and security surveillance at designated sites.

· Conduct and manage a site security survey and assessment program to provide security recommendations and advice to site managers.

· Establish an Information Safeguards Program to recommend security protections for our information assets and for our Information Technology resources.

· Establish and maintain an internal investigation capability to respond to security incidents and reported violations of law, regulatory compliance, policy, ethics, and other directives.

· Develop and maintain formal Crisis Management and Emergency Response plans and support Business Continuity Planning and implementation.

· Provide and maintain strike response capability that ensures safe conduct of our business in conformance with the NLRA.

· Partner with local community, national law enforcement and emergency management organizations for emergency response plans.

· Participate in and support infrastructure protection planning and security initiatives with organizations such as InfraGard and API.

The FTC Networks Security Organization is unique in the network operations industry. Security has built a core team of highly qualified professionals devoted exclusively to enhancing security services for the Company, customer and for the members of our online communities. This team is tasked with developing effective security programs that integrate with and support our Company business operations to both ensure acceptance and to produce a positive impact on all aspects of our business. Providing a safe and secure work environment for employees, and for our customers and visitors, is more than just a concept and it does not happen by itself. It requires a responsible, unwavering effort and a complete commitment to act with integrity, to support and fairly enforce our policies and to maintain workers in our communities who are themselves good citizens.

Reporting Abuse - To report abuse appearing to come from a user on our network please Contact Us. We take abuse matters very seriously. Please send any logs complete with timestamps of the9 abuse incident you are reporting to our Abuse Department.

Network Security Services Division