We take confidentiality very seriously, and our employees, contractors, suppliers, and affiliates sign confidentiality agreements protecting Millennium and its clientele.
Employees and others acting on Millennium Management’s behalf are responsible for protecting the confidential information of Millennium Management’s clientele, and confidential information of Millennium, including trade secrets, from unauthorized disclosure whether internal or external, deliberate or accidental. Employees and others acting on Millennium Management’s behalf must know:
• The information classification of the Millennium Management information they create or have access to (Public, Internal, Confidential or Regulated). Any of these classifications other than Public may represent a Millennium Management trade secret. • The security precautions that apply to Millennium Management information, and • How long to retain Millennium Management information, and how to properly dispose of it. Just as we expect others to respect our company’s confidential information, Millennium Management respects the confidential information of other parties. It is Millennium Management policy to use only legal and ethical means to collect and use business and market information in order to better understand our markets, customers and competitors. Millennium Management will not collect or use another party’s confidential information without that party’s permission.
What it means for Millennium Management confidential information • Protect Millennium Management confidential information regardless of the media in which the information is conveyed (e.g., printed, electronic files, e-mail, verbal conversation). • Protect Millennium Management confidential information for the entire life cycle of the information–from creation, storage, use, transmittal, retention through disposal. • Contact your assigned Millennium Management legal counsel if you need help determining whether certain information is confidential. • Share confidential information inside Millennium Management only with those who have a business need to know the information. • Have a written, signed confidential disclosure agreement before disclosing confidential information to a party outside Millennium Management. Confidential disclosure agreements must be signed by a general manager or technical director, or higher level. • The duty to protect Millennium Management confidential information includes trade secrets. Although some information may be designated trade secret, special designation is not required. Any information that falls within the definition of trade secret is a trade secret for as long as it fits the definition. The life of a trade secret can be indefinite and depends, to some degree, on the efforts to maintain secrecy. Keeping trade secrets secure maintains their viability as intellectual property giving Millennium Management a competitive advantage.
Wear your Millennium Management identification badge while at Millennium Management facilities and ensure that others are authorized to be in your area and are authorized to have access to Millennium Management business information.
Retain all Millennium Management information in accordance with Millennium Management’s Records Retention Schedule. If you have received a Preservation Notice, immediately take steps to preserve all potentially pertinent records and files.
Promptly report any actual or suspected unauthorized access or use of Millennium Management systems or information to: Your manager, Corporate Security at 800-791-6962 (available 24 hours) IT Security and Integrity.
What it means for confidential information of others • As we do not disclose Millennium Management confidential information without a proper confidential disclosure agreement, do not accept another party’s confidential information without a written, signed confidential disclosure agreement. These confidential disclosure agreements must be signed by a technical director or higher level executive. • Unless you have another party’s permission to use the party’s information, make sure you can answer “no” to each of these questions before using the information: o Is the information actually confidential information? o Was the information obtained illegally or unethically? o Would using the information violate any other business conduct policy? • Contact your assigned Millennium Management legal counsel before hiring or using a consultant or agent to obtain information for Millennium Management or if you learn that an improper disclosure or improper use of another party’s confidential information may have occurred. • Do not interview or hire employees or consultants of competitors without first contacting your assigned legal counsel.
What to avoid • Sharing Millennium Management confidential information with friends or family. • Talking about Millennium Management confidential information in public places, such as elevators, airplanes or restaurants, where you can be overheard. • Leaving Millennium Management confidential information unattended on your desk, within Millennium Management facilities, in public areas, etc. • Copying Millennium Management confidential information onto non-Millennium Management computers or systems, or accessing Millennium Management confidential information through non-Millennium Management computers or systems. • Disclosing Millennium Management confidential information to anyone outside Millennium Management who does not have a confidential disclosure agreement protecting that information, or to anyone inside Millennium Management who does not have a need to know the information. • Divulging information about a new product or service before any necessary patent applications have been filed. • Receiving confidential information from an employee about his or her former employer. • Using third party confidential information that has been obtained illegally or unethically.