The Law and Ethical Considerations
The Law and Ethical Considerations
Social Media Policy
This sample policy was ruled lawful by the NLRB in a May 2012 Operations Management Memo
At [Employer], we understand that social media can be a fun and rewarding way to share your
life and opinions with family, friends and co-workers around the world. However, use of social
media also presents certain risks and carries with it certain responsibilities. To assist you in
making responsible decisions about your use of social media, we have established these
guidelines for appropriate use of social media.
This policy applies to all associates who work for [Employer], or one of its subsidiary companies
in the United States ([Employer]).
Managers and supervisors should use the supplemental Social Media Management Guidelines
for additional guidance in administering the policy.
Guidelines
In the rapidly expanding world of electronic communication, social media can mean many
things. Social media includes all means of communicating or posting information or content of
any sort on the Internet, including to your own or someone else’s web log or blog, journal or
diary, personal web site, social networking or affinity web site, web bulletin board or a chat
room, whether or not associated or affiliated with [Employer], as well as any other form of
electronic communication.
The same principles and guidelines found in [Employer] policies and three basic beliefs apply to
your activities online. Ultimately, you are solely responsible for what you post online. Before
creating online content, consider some of the risks and rewards that are involved. Keep in mind
that any of your conduct that adversely affects your job performance, the performance of fellow
associates or otherwise adversely affects members, customers, suppliers, people who work on
behalf of [Employer] or [Employer’s] legitimate business interests may result in disciplinary
action up to and including termination.
Know and follow the rules
Carefully read these guidelines, the [Employer] Statement of Ethics Policy, the [Employer]
Information Policy and the Discrimination & Harassment Prevention Policy, and ensure your
postings are consistent with these policies. Inappropriate postings that may include
discriminatory remarks, harassment, and threats of violence or similar inappropriate or unlawful
conduct will not be tolerated and may subject you to disciplinary action up to and including
termination.
Be respectful
Always be fair and courteous to fellow associates, customers, members, suppliers or people
who work on behalf of [Employer]. Also, keep in mind that you are more likely to resolved workrelated complaints by speaking directly with your co-workers or by utilizing our Open Door
Policy than by posting complaints to a social media outlet. Nevertheless, if you decide to post
complaints or criticism, avoid using statements, photographs, video or audio that reasonably
could be viewed as malicious, obscene, threatening or intimidating, that disparage customers,
members, associates or suppliers, or that might constitute harassment or bullying. Examples of
such conduct might include offensive posts meant to intentionally harm someone’s reputation or
posts that could contribute to a hostile work environment on the basis of race, sex, disability,
religion or any other status protected by law or company policy.
Be honest and accurate
Make sure you are always honest and accurate when posting information or news, and if you
make a mistake, correct it quickly. Be open about any previous posts you have
altered. Remember that the Internet archives almost everything; therefore, even deleted
postings can be searched. Never post any information or rumors that you know to be false
about [Employer], fellow associates, members, customers, suppliers, people working on behalf
of [Employer] or competitors.
Post only appropriate and respectful content
• Maintain the confidentiality of [Employer] trade secrets and private or confidential
information. Trades secrets may include information regarding the development of
systems, processes, products, know-how and technology. Do not post internal reports,
policies, procedures or other internal business-related confidential communications.
• Respect financial disclosure laws. It is illegal to communicate or give a “tip” on inside
information to others so that they may buy or sell stocks or securities. Such online
conduct may also violate the Insider Trading Policy.
• Do not create a link from your blog, website or other social networking site to a
[Employer] website without identifying yourself as a [Employer] associate.
• Express only your personal opinions. Never represent yourself as a spokesperson for
[Employer]. If [Employer] is a subject of the content you are creating, be clear and open
about the fact that you are an associate and make it clear that your views do not
represent those of [Employer], fellow associates, members, customers, suppliers or
people working on behalf of [Employer]. If you do publish a blog or post online related to
the work you do or subjects associated with [Employer], make it clear that you are not
speaking on behalf of [Employer]. It is best to include a disclaimer such as “The postings
on this site are my own and do not necessarily reflect the views of [Employer].”
Using social media at work
Refrain from using social media while on work time or on equipment we provide, unless it is
work-related as authorized by your manager or consistent with the Company Equipment
Policy. Do not use [Employer] email addresses to register on social networks, blogs or other
online tools utilized for personal use.
Retaliation is prohibited
[Employer] prohibits taking negative action against any associate for reporting a possible
deviation from this policy or for cooperating in an investigation. Any associate who retaliates
against another associate for reporting a possible deviation from this policy or for cooperating in
an investigation will be subject to disciplinary action, up to and including termination.
Media contacts
Associates should not speak to the media on [Employer’s] behalf without contacting the
Corporate Affairs Department. All media inquiries should be directed to them.
For more information
If you have questions or need further guidance, please contact your HR representative.
