II. Association Policies
A. Workplace Behavior
1. Safety Policy
The safe operation of Port Terminal Railroad
operations is always a primary goal. All PTRA officers and employees are
responsible for compliance with all applicable rules and regulations related to
the safety of our employees, our customers and the communities we serve. All
operating officers and employees are expected to regularly assess PTRA’s safety
rules, practices and operations and should report to the appropriate supervisor
any perceived problems or areas for improvement.
2. Employee Privacy
The Association is committed to complying with all
applicable laws regarding the collection, protection and dissemination of
personal identification information collected from employees. The
Association will limit the personal information it requires employees to
provide to that which is required for the Association to carry out its business
and provide access to such personal information only to those persons and entities
that need the information for the Association to carry out its business.
Employee use of Association Electronic Mail, or
Internet or use of any other Association asset is not private. The Association
has the right to access and review usage and contents of any computer system or
message going across the Association’s network or on any Association computing
3. Equal Employment Opportunity
The Association, through its policy and practice,
provides equal opportunity to all employees and applicants for employment
without regard to race, color, gender, national origin, age, disability,
religion, veteran status, sexual orientation, or any other ground prohibited by
law. This policy applies to all terms and conditions of employment, including
hiring, placement, promotion, demotion, termination, transfer, leaves of
absence, compensation, and training.
4. Respectful Work Environment
The Association is committed to ensuring work
environments free from all forms of discrimination, including harassment/sexual
harassment. All employees should be treated with dignity and respect. The
Association is committed to providing a work environment free from offensive
behavior or statements directed at a person’s race, gender or any other
protected status. In addition, the Association requires its employees to
refrain from threats of harm and violent behavior directed against other
employees and those outside the Association with whom they have dealings.
Violence in the workplace (both verbal and
physical) will not be tolerated.
5. Employee Time
Employees are responsible for the appropriate use
of time that should be allocated to the Association and the Association’s
resources. Limited personal use of Internet, Electronic Mail, and phones (as
discussed previously in Section II), is permitted. Employees may not use other
Association assets, or labor or information for personal use, unless prior
appropriate management approval is given for other limited purposes (such as
charitable contributions and activities).
There will be no unlawful retaliation against any
employee for making a good faith report of alleged violations of our policies
against discrimination, harassment or offensive behavior; opposing any practice
believed in good faith to be unlawfully discriminatory; or participating in an
internal or government investigation of possible discrimination.
Protection of Association Assets
Employees are expected to maintain the
confidentiality of information entrusted to them by the Association and any
other confidential, proprietary (i.e. trade secrets) or other nonpublic
information that comes to them, from whatever source, in the course of their
work for the Association, except when disclosure is authorized or legally
mandated. Confidential information includes:
Information about the
Association, including information concerning pricing, products, and services
and information about contracts, finances, operations, customers, business or
transportation plans, strategies, measures, metrics, legal proceedings,
unreported or anticipated earnings, or acquisitions; and
b. Information received
from or relating to third parties with which the Association has or is
contemplating a relationship, such as customers or suppliers.
Information given to for received from
attorneys representing the PTRA. Attorney – client privilege.
Employees may not use confidential information for
the benefit of anyone other than the Association.
Reasonable prudence and care should be exercised
in dealing with confidential information in order to avoid inadvertent
2. Dealing with the Media
The General Manager is the spokesperson for the
Port Terminal Railroad Association, and as such will answer all media
inquiries. The General Manager may appoint one of his direct reports to handle
this as necessary. All inquiries for information, comments, or interviews from
any media source must be directed to the General Manager. Employees are prohibited from giving
information, statements, or interviews that involve the PTRA.
3. Integrity of Records and Financial Reporting
Accurate and reliable preparation and maintenance
of all Association records is of critical importance to proper management
decisions and fulfillment of the Association's financial, legal and reporting
obligations. Diligence in accurately preparing and maintaining the Association's
financial records allows the Association to fulfill its financial reporting
obligations and to provide shareholders with information that is complete,
accurate and understandable. All transactions must be properly documented and
accounted for on the books and records of the Association. No off-book funds or
transactions are allowed. All reports, vouchers, bills, invoices, payroll and
service records, business measurement and performance records, and other
essential data are to be prepared and maintained with care and honesty. Such
data must not be falsified or altered to conceal or distort assets,
liabilities, revenues, expenses or performance measures. Employees are
responsible for safeguarding Association assets and properties under their
control and for providing an auditable record of transactions relating to the
use or disposition of such assets and properties.
4. Record Retention
The Association is committed to efficient and
economical management of its business records to comply with all legal and
business requirements. Business records are retained in accordance with
the guidelines listed in Exhibit 1 and should be retained for the designated times
listed. Records relevant or related to
an ongoing or anticipated legal proceeding, government investigation or tax
audit should not be destroyed, even if scheduled for destruction, until the GM
or CFO advises such destruction is permissible.
Department heads are responsible for seeing that record retention and
maintenance is handled according to this policy.
5. Data and Information Security
All business information the Association acquires
and produces, in any form, constitutes a corporate asset. The ownership,
usage, dissemination, storage, or formulation of information, as well as all
physical corporate systems used to process, transmit, or store this data,
belong exclusively to the Association. It is the responsibility of every user
to guard against unauthorized use or disclosure of these assets.
Every user of the Association’s computer systems is responsible for reasonable
protection of the Corporation’s data and the systems used to produce the data
6. Software Compliance
Software is generally the property of the software
vendor and duplication of copyrighted software, except for backup purposes, is
a violation of the federal copyright law. Under this law, software that is
loaded on your hard disk or a file server may not be duplicated for use on any
other computer and the making or distributing of copyrighted material without
authorization (except for backup purposes) is illegal. In addition, employees
shall not load any software, including software owned by employees, onto the Association’s
computers without prior appropriate management approval.
7. Association Property
Any employee found to be engaging in or attempting
theft of Association property, facilities or physical resources including
documents, equipment, intellectual property, personal property of other
employees, cash or any other items of value will be subject to dismissal and
possible criminal prosecution. All employees have an obligation to report any
theft or attempted theft to the Association.
An employee may not divert to his or her personal
benefit any invention, know-how, technology or computer program which the
employee has developed or learned of in the course of his or her employment and
which the employee has reason to know may be useful to the Association in its
8. Internet, Electronic Mail and Phone Services
Employees should use the Association’s Internet,
Electronic Mail and phone services primarily for business-related purposes.
Limited personal use of these services is authorized. Employees should be
careful that the use of Internet, Electronic Mail and phone services does not
violate local, state or federal laws, adversely affect Association operations,
violate Association policies, promote personal financial gain, or otherwise
detract from productivity or work responsibilities. The viewing or distribution of pornographic
images, jokes, photographs, or any similar materials can and will be considered
to be in violation of ethical standards and EEOC policies. These images can also be violations of state
and federal laws. The PTRA will not
tolerate violation of this policy.
Employees should not have the expectation of
privacy in relation to Internet or Electronic Mail services. Usage and contents
of all computer systems and messages going across the Association’s network and
computing devices are audited for compliance. Phone usage is also audited for
Specific examples of unauthorized use include:
committing a crime, gambling, viewing pornographic material, defamation of any
person or entity, activities and transactions for profit unrelated to the Association,
dissemination of the Association’s confidential, proprietary or non-public
information, excessive use of social networking and other similar activities
such as “tweeting” etc., or use that detracts from employee productivity.
Specific examples of authorized use include:
communication with personal service providers (e.g. doctors, teachers, day
care, bank), purchase of goods and services (e.g. mail order prescriptions),
use of Electronic Mail and Internet while traveling on Association business as
tools to assist with work/life balance.