Policy

FUNCTIONAL RESPONSIBIILITY: Information Systems NUMBER: CO1-5

PROCEDURE NUMBER: TITLE: Electronic Communication
Systems
SUPERSEDES: New DATE: August 20, 1998

Scope of Policy
This document sets forth the policy of Cooper Tire & Rubber Company (“Company”) regarding the use of its Electronic
Communication Systems (“e-Systems”) which include but are not limited to telephones, voice mail, electronic mail,
facsimile machines, video conferencing, Internet & Intranet usage, and all the computers and related equipment used to
access and utilize the aforementioned services. All employees who use the Company’s e-Systems agree by such use to
comply with the intention for reasonable use as outlined in this policy.

Ownership of Messages
The Company’s e-Systems and all information stored on them are Company property. All information and messages
that are created, sent, received, accessed, or stored on these systems constitute Company records. As Company records,
they are subject to disclosure to law enforcement or government officials, or to other third parties through subpoena or
other legal processes.

Business Use Only

The Company's e-Systems are provided at Company expense and are to be used for Company benefit. The policy on
Business Ethics and Standards of Conduct (C04-9 issued April 1, 1993) contains the following paragraph, which should
guide employees in their e-Systems usage:

“Unauthorized Use of Company Property or Services

No employee may use any Company property or service for the employee's personal benefit or the personal benefit
of anyone else. The Company realizes that sometimes the line between personal and Company benefits is difficult
to draw, and sometimes there are both personal and Company benefits in certain activities. The only prudent
course of conduct is to make sure any use of Company property or services which may not be solely for the benefit
of the Company is approved beforehand by your immediate supervisor.”

No Presumption of Privacy
By their very nature, communications on e-Systems are only reasonably secure and complete privacy cannot be
guaranteed. User ID’s and passwords are designed to inhibit information loss to unwanted third parties, not to provide
total personal privacy in message storage and transmittal. Employees should assume that any communication created,
sent, received, or stored on Company e-Systems could be seen or heard by someone other than the intended recipient.
Employees should not use the Company e-Systems to send highly confidential or sensitive information. In using the
Internet, employees should remember that all communications and traces of sites visited could be recorded at either end
of the connection.

Company’s Right to Monitor Messages

The Company reserves the right to monitor, access, retrieve, read, and disclose for law enforcement officials or other
third parties all messages created, sent, received, or stored on the Company’s e-Systems without prior notice to the
originators and recipients of such messages. Authorized personnel may monitor the electronic communications of
employees to determine whether there have been any violations of law, breaches of confidentiality or security,
communications harmful to the business interests of the Company, or any violations of this Policy or any other
Company policy.

Message Restrictions
Communications on Company e-Systems may not contain content that a reasonable person would consider offensive,
harassing, disruptive, derogatory, defamatory, disparaging, or disrespectful to any person or group.

Prohibited Activities
Employees are expressly prohibited from using the Company’s e-Systems in the following way:
- in a manner that would reflect badly on the Company, such as pirating software, stealing passwords, disrupting
other machines on the Internet, participating in the creation, viewing or exchange of pornography or obscene
materials, sending discriminating, intimidating, or harassing E-mail, or engaging in any illegal or tortious
activities.
- to upload, download, or otherwise transmit copyrighted, trademarked, or patented material in violation of the
owner’s restrictions to do such.
- to upload, download, or otherwise transmit Company trade secrets or other confidential, private, or proprietary
information or materials without Company authorization.
- to upload, download, or otherwise transmit any illegal information or materials.
- to upload, download, access, create, distribute, or otherwise transmit sexually explicit materials.
- to post information, opinions, or comments to Internet discussion groups (or similar forums) which are not
business related without your supervisor’s approval.
- to include “push” technology (e.g., PointCast, Castanet, or stock trading ticker tapes) on a Company
Internet machine without Information Systems management approval.
- to gain unauthorized access to Company or non-Company e-Systems or to damage, alter, or disrupt such
e-Systems in any way.
- to utilize someone else’s user ID and password without their knowledge or disclose anyone’s user ID and
password, including one’s own user ID and password.
- to enable unauthorized third parties to have access to or use the Company’s computers to jeopardize the
security of the Company’s e-Systems.
- to send anonymous E-mail or facsimile messages.

Message Creation
Employees must exercise good judgment when creating messages on the Company’s e-Systems. Even when a message
has been deleted, it may still exist on a backup media, be printed on paper, or may have been forwarded to someone else
without the creator’s knowledge. As with paper records, proper care should be taken in creating electronic records
which can affect the Company’s reputation and which the Company may some day have to produce in connection with
a lawsuit.

Record Retention
As with paper documents created and received by an employee, it is each employee’s responsibility to ensure that those
electronic messages that should be retained are in fact saved and backed-up. Those messages that need not be retained
should be deleted in compliance with the Company’s record retention policies.

Viruses and Tampering

As stated in the Company Procedure on Microcomputers (C01-4.1 dated November 15, 1993), any files or E-mail
received from non-Company sources must be scanned with virus detection software prior to installation and execution.
The introduction of viruses, malicious tampering, or attempts to breach system security of any Company e-Systems is
expressly prohibited. Employees should report the discovery of viruses, tampering, or other security breaches to an
Information System representative as soon as it is known.

Selling and Purchasing

The Company’s standard purchase and sales policies apply to all purchasing and sales-related activities conducted via
the Company’s e-Systems.

Posting Information on the Internet and Intranet

Employees must not place Company or customer material, such as copyrighted software or other materials, internal
memos, Company trademarks, etc. on the Company Web site or any other publicly accessible Internet computer, unless
the head of Information Systems has approved the posting or the person doing the posting. Placing confidential
Company information on the Company Web site or any publicly accessible Internet computer is prohibited. Placing
confidential information on the Company Intranet is permitted if security measures are used to grant access by
individual. All placements on the Company Web site, the Company Intranet, and any publicly accessible Internet
computer must comply with all applicable laws.

Policy Violations
Violations of this Policy, including breaches of confidentiality or security, may result in suspension of system privileges,
disciplinary action, and in severe cases, termination. The Company reserves the right to hold the employee personally
liable for any violations of this Policy.