USE OF ELECTRONIC SYSTEMS

I. Purpose

INTERLATAM respects the individual privacy of its associates, but must also protect its interests in the electronic systems it provides associates to facilitate Company business and business-related communications. This policy sets out the Company’s rules governing the use of these Company systems. This policy covers INTERLATAM, LLC., and all of its subsidiary companies around the world (collectively “INTERLATAM” or “Company”).

II. Scope

This policy governs the use of all of the Company’s electronic systems. The “electronic systems” covered by this policy include:

1. Electronic equipment, including telecommunication equipment, facsimile devices, personal computers and laptops, computer network devices and all related components and equipment.

2. Electronic services, including voice mail, internal and external electronic mail (e- mail), Lotus Notes access and internet access.

3. Software, covering all software programs, including operating systems, object code and source code stored on or operating on the Company’s electronic equipment.

4. Electronic information, including all information or data stored on or transmitted across the Company’s electronic equipment.

III. Policy

INTERLATAM's policy regarding the use of the Company’s electronic systems is as follows:

1. Compliance with this Policy is Required. Any associate who violates this policy may be subject to corrective action up to and including discharge. Enforcement of this policy will be handled according to the disciplinary procedures of the associate’s business unit.

2. This Policy Supplements INTERLATAM’s other Company Policies. This policy requires associates to act consistently with general rules of ethical behavior, relevant laws and regulations, the Company's Code of Business Ethics, if applicable, and other workplace policies. No associate may use the Company’s electronic systems in a manner that would violate such laws, regulations, Code of Business Ethics, if applicable, or other workplace policies. Communications containing sexually explicit images, messages, jokes or cartoons, and communications containing ethnic slurs, racial epithets, or anything that may be considered to harass or disparage others based on race, national origin, gender, sexual orientation, age, disability, or religious beliefs are strictly prohibited.

3. The Company’s Electronic Systems are to be used for Company Business. An INTERLATAM associate may employ Company-supplied electronic systems in any manner directly associated with the lawful and ethical conduct of the business duties assigned by the Company. They may not be used to support any other business or commercial activity.

4. Permitted Incidental Personal Use. An associate also may use these resources responsibly for incidental personal purposes. However, the incidental personal use of these resources is a privilege which may be revoked by INTERLATAM in its sole discretion.

For example, this may be done as part of a disciplinary action, or if in the judgment of the Company this privilege is being abused, or if the Company decides the exercise of this privilege is interfering with the Company’s interests. Under no circumstances does permitted “incidental” personal use include accessing or transmitting pornographic or sexually explicit materials, nor does it include accessing or transmitting materials that advocate hate or include derogatory material pertaining to race, national origin, gender, sexual orientation, age, disability, or religious beliefs.

5. No Expectation of Privacy. The Company’s electronic systems are the property of INTERLATAM, and INTERLATAM associates and other persons using them should have no expectation of privacy regarding them. INTERLATAM may, at its sole discretion and without notice, monitor, examine or audit the use of its property and anything stored on or transmitted across it. While the Company does not intend to routinely monitor the content of associate personal communications or other non-business information on the Company’s systems, monitoring could happen at any time without notice. Associates also should be aware that communications and other information on computers may be preserved indefinitely on one or more computers and/or backup tapes even after they are believed to have been deleted by an associate.

6. Associates are Responsible for Electronic Systems in their Care. Each associate is responsible for the prudent care and handling of all electronic systems placed in his/her care. This includes exercising care to ensure that: a) the electronic systems are not stolen or broken, b) regular backup's of data are made, c) security procedures are followed, including changes to and care of passwords, and d) no unauthorized person is allowed to use the electronic systems. In particular, the costs of the replacement or repair of IT Assets damaged due to an associate's improper handling or care of electronic systems may be borne by the associate. Associates also must return all electronic systems and related documentation the Company issued to them when they leave the Company, or at the Company’s request.

7. No Copying or Downloading of Licensed Software or Data. Under no circumstances may an INTERLATAM associate make an unauthorized copy of INTERLATAM - licensed software or licensed data for use on a personal computer, whether on a workplace computer, on the associate's home computer or on the computer of any third party. Unauthorized copying of copyrighted computer files from or to any of the Company’s electronic systems is unlawful and is strictly prohibited. Whenever feasible, the Company will negotiate its personal computer software license agreements to permit INTERLATAM associates to make use of them on their home computers for business-related purposes. Information regarding the specific software titles for which such home use copies are permitted will be made available by the Information Technology Department.

8. No Unapproved Software, Hardware, or Data may be Downloaded, Installed or Used with the Company’s Electronic Systems. No INTERLATAM associate may install or operate non-INTERLATAM -supplied software or licensed data on any electronic system without authorization from his/her supervisor and from the designated IT representative in his/her business unit. This policy applies to all software, including, for example, commercially-sold software, shareware, and freeware available on the Internet or from other sources, as well as software developed by the associate. This policy applies notwithstanding an associate’s good faith belief that there is a valid business reason to have such software or data. If an associate believes he/she requires additional or alternative electronic systems, such needs should be discussed with the associate's

9. Security Procedures Must be Followed. Associates will, from time to time, be assigned account ID's, passwords and other mechanisms to maintain the security of INTERLATAM's various electronic systems. Each associate is accountable for all actions made with his/ her account ID, password or other security mechanism. Each associate is to exercise prudent judgment in safeguarding these account ID's, passwords and other security mechanisms. In particular, associates may not share or otherwise transfer their access rights to another party, whether that person is another INTERLATAM associate, a trading partner or an outsider. Each associate should take care not to leave his/her computer logged on and unattended with the account ID and password set so that unauthorized parties might access IT Assets and Services using that ID and password. Procedures established for INTERLATAM's IT systems will require associates to change their passwords and other security mechanisms regularly. Associates are to comply with these security change requests.

10. The True Author of All Electronic Communications Must Be Identified. All electronic communications must include the name of the person sending them. Anonymous electronic communications are strictly prohibited. No associate is to use or cause to be used the account ID and password of another associate unless specifically authorized to do so. No associate is to make any attempt to conceal or otherwise disguise his/her own identity in making use of the Company’s electronic systems.

11. Personal Encryption of Information is Prohibited. The use of encryption software not provided directly by the Company on any of the Company’s electronic systems is strictly prohibited. Associates to whom the Company provides encryption software will be assigned their encryption keys by the Company. The use of any other encryption key is strictly prohibited. The Company reserves the right to decrypt, without notice, any encrypted communication made or received using any of the Company’s electronic systems.

12. Unauthorized Passwords are Prohibited. Users may use confidential, individual login passwords for login access to Company networks, personal e-mail boxes or voice mail boxes only. All files and information stored on the Company’s personal, laptop or network computers must be stored without passwords unless specifically authorized in writing by an Information Technology Department representative. Login passwords used to gain access to the Company’s electronic systems are for the protection of the Company, not the associate. Authorized representatives of the Company have access to, and may use at the Company’s sole discretion and without notice, any and all login passwords used to access its electronic systems. The unauthorized use of a password belonging to another associate is strictly prohibited. Even though a private login password is used, e- mail or voice mail messages are not private, and associates should not transmit anything that should not be read or heard by a third party.

13. No Unauthorized Intercepting, Accessing, or Monitoring of Company Electronic Systems is Permitted. No associate shall access, or attempt to access, any non- business related information on a computer assigned to another associate without the express authorization of that associate or the Company. Nor shall any associate access, or attempt to access, any electronic communication not specifically addressed to him/her without the express authorization of the addressee or the Company. Any associate who receives an electronic communication that clearly was not intended for him/her shall promptly return such misdirected communication to the sender. No associate who receives a misdirected electronic communication shall use or disclose the communication to anyone other than the sender except where it appears that the communication violates Company policy, such as the prohibition on discrimination or harassment. In that event, the associate receiving it shall retain the communication and promptly inform management, without further use or disclosure other than as may be directed by management.

14. Company Confidential Information Must be Protected. Confidential information should not be forwarded via electronic systems either outside of the Company or to associates within the Company unless the recipients are authorized by the Company to receive such information, and unless reasonable precautions are taken to protect and ensure confidentiality. Care must be exercised whenever it is necessary to use internal e-mail for communicating the Company’s confidential information to individuals who are authorized to receive it. Any internal e-mail message containing such confidential information should bear the legend “CONFIDENTIAL” in the subject heading. No such confidential information should be left visible or accessible on your computer screen while you are away from your computer or while any person not authorized to view it is present.

15. Associates Have a Duty to Report Breaches of this Policy. If an associate becomes aware of a situation in which he/she believes there has been a significant breach of this policy, the associate is to notify his/her supervisor of the perceived problem. All such reports are to be referred to his/her supervisor or other manager in the business unit in which the associate works for prompt investigation and resolution. If the associate believes that reporting the matter to his/her supervisor would cause him/her a problem, then the report should be made to the senior Human Resources or IT manager for the associate's business unit, or to the INTERLATAM Legal Department.

16. Supervisory Personnel must be Familiar with this Policy. All supervisory personnel are to become fully familiar with this policy, related training materials and the related operational procedures so as to advise associates on their application and to oversee compliance with them..