Dell's Online Policies

Dell recognizes that online communication tools such as weblogs ("blogs") and other online channels (chat rooms, etc.) increasingly serve as channels for direct interaction with customers, the media and other Dell stakeholders. The company's commitment to being direct supports open communications by employees and other Dell representatives, providing such communications are transparent, ethical and accurate.

All online communication by Dell employees or company representatives on behalf of Dell is subject to Dell's Code of Conduct and applicable Electronic Dialogue policies, laws and regulations. Dell's Code of Conduct sets forth a standard of personal responsibility for employees both inside and in some cases, outside the workplace. Dell's Online Communication Policy adopts the same standard. Dell also recommends that its suppliers to adopt the standards outlined below.

Any Dell employee or representative engaging in online, electronic dialogue as a delegate of the company is required to meet a standard that mandates:

Transparency of Origin. Dell requires that employees and other company representatives disclose their employment or association with Dell (e.g., Richard@Dell) in all communications with customers, the media or other Dell stakeholders when speaking on behalf of Dell. Dell requires that employees, suppliers and other company representatives provide contact information on request. Accurate Information. Dell employees and other company representatives may not knowingly communicate information that is untrue or deceptive. Communications should be based on current, accurate, complete and relevant data. Dell will take all reasonable steps to assure the validity of information communicated via any channel but it is the employee's or other company representative's responsibility to assure accuracy in the first instance. Anecdotes and opinions will be identified as such. Ethical Conduct. Dell employees and other company representatives will not conduct activities that are illegal or contrary to Dell's Corporate Code of Conduct, Privacy Policy and related policies. Protection of Confidential and Proprietary Information. Dell employees and other company representatives must maintain the confidentiality of information considered Dell company confidential, including company data, customer data, partner and/or supplier data, personal employee data, and any information not generally available to the public. Dell employees or company representatives who fail to comply with this policy will be subject to discipline, up to and including termination of employment from Dell. In addition, depending on the nature of the policy violation or the online channel content, participants may also be subject to civil and/or criminal penalties.

Additionally, Dell subscribes to the Code of Ethics established by the Word of Mouth Marketing Association (WOMMA). The WOMMA Code of Ethics is available at http://www.womma.org/ethicscode.htm. Dell's adherence to the WOMMA code means:

Consumer protection and respect are paramount to Dell employees, suppliers and other company representatives. Dell demands honesty of relationship and opinion and identity. Dell respects the rules of the venue. Dell manages relationships with minors responsibly. Dell promotes honest downstream communications. Dell protects consumer privacy and requires specific permission to disclose consumer information to any outside organization for its use in marketing.