Securities Policy Statement
INCLUDED ON THS WEBSITE AND REFERENCED HEREIN ARE FORWARD-LOOKING STATEMENTS, INFERENCES AND PROJECTIONS OF THE MEDIA GLOBO CORPORATION WITHIN THE MEANING OF SECTION 27A OF THE SECURITIES ACT OF 1933, AS AMENDED, AND SECTION 21E OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED. ALTHOUGH THE COMPANY BELIEVES THAT THE EXPECTATIONS REFLECTED IN SUCH FORWARD-LOOKING STATEMENTS, INFERENCES AND PROJECTIONS ARE REASONABLE, IT CAN GIVE NO ASSURANCE THAT SUCH EXPECTATIONS REFLECTED IN SUCH FORWARD-LOOKING STATEMENTS, INFERENCES AND PROJECTIONS WILL PROVE TO BE CORRECT; NOR SHOULD SUCH FORWARD-LOOKING STATEMENTS, INFERENCES AND PROJECTIONS BE RELIED UPON FOR INVESTMENT OR OTHER MANNER OF RELIANCE PURPOSES.
HR Information Policy Statement
MEDIA GLOBO CORPORATION recognizes and acknowledges current data protection laws in the European Union (“EU”), and has therefore adopted this Policy governing Human Resource Data (as defined below) transferred to or from MEDIA GLOBO Corporation business units in the EU to or from MEDIA GLOBO Corporation operations in the U.S. Due to its operations, MEDIA GLOBO Corporation has a need to extract, compile, process, transfer and use the Human Resource Data of its U.S. and EU employees. This Policy allows flexibility for each MEDIA GLOBO Corporation business unit to determine how best to comply with this Policy for its own operations, while addressing protection of its European employees’ Data. MEDIA GLOBO Corporation uses Human Resource Data for, among other things, administration of benefits and compensation and related transactions, IT system administration, global enterprise headcount reporting, statistical analysis, career development and training, staffing, international personal security issues, internal investigations, ethics investigations, law enforcement inquiries, and mergers, acquisitions and divestitures. MEDIA GLOBO Corporation adheres to the Safe Harbor Principles of the Safe Harbor Program administered by the U.S. Department of Commerce with respect to Human Resource Data transferred to or from MEDIA GLOBO Corporation business units in the EU to or from MEDIA GLOBO Corporation operations in the U.S. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce's Website. MEDIA GLOBO Corporation self-certifies, or shall certify, on an annual basis, to the U.S. Department of Commerce its compliance with the Safe Harbor Principles. This Policy applies to all Human Resource Data transfers to or from MEDIA GLOBO Corporation operations in EU Member States to or from MEDIA GLOBO Corporation operations in the United States. “Human Resource Data” or “Data” means, for the purposes of this Policy, any human resource information relating to an employee of any MEDIA GLOBO Corporation business unit located in the U.S. or EU, and who can be identified, directly or indirectly, as a particular person by reference to an identification number or to one or more aspects of an employee’s physical, physiological, mental, economic, cultural or social identity. Human Resource Data includes the transmission of Data over phone lines, computer lines, and in hard copy, of information such as employee contact information, demographic data, financial information, work history and performance data, and any material that identifies a particular individual employee. “MEDIA GLOBO Corporation” means The MEDIA GLOBO Corporation and its majority owned subsidiaries.
Guidelines
MEDIA GLOBO Corporation has adopted the Department of Commerce’s Safe Harbor Principles, as set forth below, with respect to Human Resource Data transferred to or from MEDIA GLOBO Corporation business units in the EU to or from MEDIA GLOBO Corporation operations in the U.S.
Notice – MEDIA GLOBO Corporation notifies its employees covered under this Policy about the types of Human Resource Data it collects about them, the purposes for which it collects such Data, and the types of third parties to which it discloses such Data. Notice is provided in clear and conspicuous language at the time of collection, or as soon as practicable thereafter, and before MEDIA GLOBO Corporation uses or discloses the Data for a purpose other than that for which it was originally collected.
Choice – In the event Human Resource Data is to be used for a new purpose incompatible with the purposes for which the Data was originally collected or subsequently authorized, or is to be transferred to the control of a third party, employees are given, when feasible and appropriate, an opportunity to choose (opt-out) whether to have their Data so used or transferred. In the event that sensitive data (e.g., personal information that pertains to racial or ethnic origin, political or religious beliefs, health condition or sexual orientation) is used for a new purpose or transferred to the control of a third party, the employee’s explicit consent (opt-in) will be obtained prior to the use or transfer of the sensitive data.
Onward transfer (transfer to third parties) – MEDIA GLOBO Corporation will transfer Human Resource Data to a third party consistent with the notice provided to its employees and any consent that they have given. MEDIA GLOBO Corporation will only transfer Human Resource Data to a third party when the third party has provided assurances that it will provide at least the same level of privacy protection as is required by this Policy. When MEDIA GLOBO Corporation has knowledge that a third party is using or sharing Human Resource Data in a way that is contrary to this Policy, MEDIA GLOBO Corporation will take reasonable steps to prevent or stop such processing or use.
Access – Employees covered under this Policy have access to Human Resource Data about them that MEDIA GLOBO Corporation holds and are able to correct, amend or delete information if it is inaccurate (except when the burden or expense of providing access would be disproportionate to the risks to an individual’s privacy in the case in question, or if the rights of persons other than the individual would be violated).
Security – MEDIA GLOBO Corporation takes reasonable precautions to protect Human Resource Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Data Integrity – Human Resource Data collected, processed and maintained by MEDIA GLOBO Corporation shall be kept and used for its intended purpose. MEDIA GLOBO Corporation takes reasonable steps to ensure that the Data is used for its intended purpose, and is accurate, complete and current.
Enforcement – To ensure compliance with these Safe Harbor Principles, MEDIA GLOBO Corporation will: Cooperate with the Data Protection Authorities (“DPAs”) of the U.S. and EU Member States where it has operations in the investigation and resolution of complaints and comply with advice given by DPAs; Periodically review and verify the company’s compliance with the Safe Harbor Principles; Remedy issues arising out of any failure to comply with the Safe Harbor Principles. MEDIA GLOBO Corporation acknowledges that its failure to provide an annual self-certification to the Department of Commerce will remove it from the Department’s list of participants and thereafter the transfers of Human Resource Data will not be allowed unless MEDIA GLOBO Corporation otherwise complies with the U.S. and EU Data Protection Directive(s).
Dispute Resolution
In the event of disputes arising under this Policy, covered employees should contact their local Human Resources representative. MEDIA GLOBO Corporation agrees to cooperate with the U.S. and European DPAs for the purpose of handling any unresolved complaints.
Limitation on Scope of Policy
Adherence by MEDIA GLOBO Corporation to this Policy may be limited to the extent required to meet legal, governmental, or national security obligations. Questions regarding this Policy or transfers of Human Resource Data should be referred to the Office of the President of MEDIA GLOBO Corporation.
Changes to this Policy
This Policy may be amended from time to time consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such amendments.
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