1. Purpose

At EASTWIND , we recognize the critical importance of maintaining the confidentiality of sensitive information across all jurisdictions where we conduct business. This Confidentiality Policy outlines our commitment to safeguarding confidential information and ensuring its protection from unauthorized disclosure or use, in compliance with applicable laws and regulations worldwide.

2. Scope

This policy applies to all employees, contractors, consultants, and third parties who have access to confidential information in the course of their work with EASTWIND , regardless of location.

3. Definition of Confidential Information

Confidential information includes, but is not limited to, trade secrets, client information, financial data, intellectual property, business strategies and plans, employee information, and any other proprietary or sensitive information related to the operations of EASTWIND .

4. Responsibilities

All employees, contractors, consultants, and third parties are responsible for:

• Understanding the importance of confidentiality and adhering to this policy, as well as any additional confidentiality requirements specified by applicable laws and regulations in their respective jurisdictions.

• Safeguarding confidential information from unauthorized access, use, or disclosure.

• Using confidential information only for legitimate business purposes and with proper authorization.

• Reporting any suspected breaches of confidentiality to the appropriate authorities, in compliance with relevant laws and regulations.

5. Protection Measures

To ensure the protection of confidential information, EASTWIND will implement appropriate security measures, taking into account the requirements of applicable laws and regulations worldwide. These measures may include access controls and restrictions, encryption, secure storage and transmission protocols, and employee training and awareness programs.

6. Non-Disclosure Agreements

Where necessary, EASTWIND may require employees, contractors, consultants, and third parties to sign non-disclosure agreements (NDAs) to formalize their commitment to confidentiality, in compliance with applicable laws and regulations.

7. Consequences of Breach

Any breach of this Confidentiality Policy may result in disciplinary action, up to and including termination of employment or contract, and legal consequences in accordance with applicable laws and regulations worldwide.

8. Review and Updates

This Confidentiality Policy will be reviewed periodically and updated as necessary to ensure its effectiveness and compliance with relevant laws and regulations in all jurisdictions where EASTWIND operates.

9. Contact Information

If you have any questions or concerns about this Confidentiality Policy or the handling of confidential information at EASTWIND , please contact [Designated Contact Person/Department].