The present document presents Five Star Innovations’ Privacy and Data Protection policy which applies to all personal and operational information and data held on Five Star Innovations employees, sub-contractors and clients. All Five Star Innovations employees must read, understand and apply it.

Purpose:

While exercising its right to collect, use and disclose personal information or data for legitimate business purposes, Five Star Innovations is committed to protect, in all countries where it does business, the personal and operational information and data concerning.

• Our employees
• Our sub-contractors
• Our clients and their operations

in order to maintain strict rules of conduct to lower the likelihood of:

• Confidentiality breaches;
• Loss of privacy;
• Loss of trust; and/or
• Legal liability.

Position and Etiquette:

Five Star Innovations is committed to protect the personal information of its employees as required for staffing, employee management, compensation and benefits administration purposes.

Five Star Innovations may also collect personal and operational information and data on client and client personnel, for example, in Outsourcing contracts. All client personal and operational information and data collected by Five Star Innovations will comply with the policies and procedures established by the client and/or Five Star Innovations. As well, Five Star Innovations will always respect and act in compliance with all applicable legislation.

Five Star Innovations respects the privacy of any visitors to www.fivestarinnovations.biz and does not share any personal information with third parties.

Five Star Innovations’ principles for information handling practices are the following:

Accountability:

The Vice Presidents responsible for a Business Unit oversee the application of this policy and take corrective action on violations and on non-compliance. Five Star Innovations employees who have concerns regarding the privacy of their own, sub-contractor or client personal information should report their concerns as well as any weakness in the measures protecting such information to their manager (for client and sub-contractor personal information) or to their local Human Resources representative (for employee personal information). All employees must respect this Global Privacy and Data Protection Policy as well as the privacy of other Five Star Innovations employees and the client's privacy policies when working at a client site.

Business Units who hold and manage client personal or operational information and data, as a result of providing services to these clients, must protect such information and data. Any violation of client personal or operational information or data, in the context of providing services to these clients, should be reported directly to the Vice-President responsible for the Business Unit safeguarding such information or data.

Identifying Purpose of Collection:

Advise employees, sub-contractors and clients when collecting personal information of the reason for collection, how the information will be used and any new purpose for the collection.

Consent for Collection:

Obtain the employee's sub-contractor's or client's written or electronic consent to the collection of information and whenever a new use of the information is identified.

Limit Collection, Use, Disclosure, and Retention Collect:

only the information necessary for the identified purpose. Use and disclose information only for the purpose for which it was collected or when required by legislation and in the manner prescribed by the legislation in the jurisdiction where Five Star Innovations does business. Retain information only as long as necessary and dispose of all sensitive information in a secure manner.

Accuracy:

Ensure the accuracy of the information collected by verifying with the individual and updating it periodically. Five Star Innovations employees must notify their local Human Resources of any changes or updates that will affect their personal records.

Safeguards:

Protect personal and operational information or data according to its sensitivity and as required by any applicable legislation. Sensitive personal or operational information or data is to be protected from unauthorized use, disclosure, access and modification. These safeguards apply to sensitive personal and operational information or data irrespective of the storage medium.

Such safeguards may take the form of locked filing cabinets, restricted access to information (physical and on a need-to-know basis, alarm systems or other electronic control devices, technological tools such as passwords, encryption, firewalls, anonymizing software, etc. The selection of safeguards will be done considering the sensitivity, amount and format of the information or data needing protection.

Security measures around data protection are reviewed regularly to follow the company evolution or changes in the organization.

Openness:

In distributing this document, advise the employees, sub-contractors and clients about Five Star Innovations’ practices and the application of this policy.

Individual Access:

Provide employees, sub-contractors and clients access to their information held by Five Star Innovations so that they may know what information is retained. Provide the employees, sub-contractors and clients an opportunity to verify the accuracy of their information and to correct any inaccuracies. Inform in writing, if access is refused, of the reasons why and of the appeal process.

No Expectation of Privacy:

Subject to the applicable legislation, Five Star Innovations has the right to monitor any and all aspects of its information systems and infrastructures including, but not limited to:

• Visited Internet sites;
• Instant messaging systems;
• Chat groups;
• News groups;
• and E-mail sent and/or received.

Such monitoring may occur at any time, without notice, and without obtaining the user's permission.

Sanctions Violations of this policy may result in a disciplinary action which will be proportional to the seriousness of the behaviour concerned. Vice Presidents responsible for business units or corporate functions are responsible to decide on the proper course of action in case of a breach to this policy. The Executive Vice-President and Chief Corporate Officer is the designated Five Star Innovations Privacy and Data Protection Officer.