RECORD RETENTION AND DESTRUCTION POLICY

1) Purpose
The purpose of this Policy is to ensure that necessary records and documents of are adequately protected and maintained and to ensure that records that are no longer needed by IJK International or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of IJK International in understanding their obligations in retaining electronic documents – including e-mail, Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files.

2) Policy
This Policy represents IJK International’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents.

3) Administration
Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of IJK International and the retention and disposal of electronic documents. The Data Protection Officer(the “Administrator”) is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. The Administrator is also authorized to: make modifications to the Record Retention Schedule from time to time to ensure that it is in compliance with local, state and federal laws and includes the appropriate document and record categories for IJK International; monitor local, state and federal laws affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.

4) Suspension of Record Disposal In Event of Litigation or Claims
In the event IJK International is served with any subpoena or request for documents or any employee becomes aware of a governmental investigation or audit concerning IJK International or the commencement of any litigation against or concerningIJK International, such employee shall inform the Administrator and any further disposal of documents shall be suspended until shall time as the Administrator, with the advice of counsel, determines otherwise. The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.

5) Applicability
This Policy applies to all physical records generated in the course of IJK International’s operation, including both original documents and reproductions. It also applies to the electronic documents described above.

This Policy was approved by the Board of Directors of IJK International on
APPENDIX A – RECORD RETENTION SCHEDULE

The Record Retention Schedule is organized as follows:

SECTION TOPIC
A.Accounting and Finance
B.Contracts
C.Corporate Records
D.Correspondence and Internal Memoranda
E.Electronic Documents
F.Customer Identification Records

 

A.ACCOUNTING AND FINANCE

Record Type                                                                                  Retention Period

Accounts Payable ledgers and schedules                                 7 years

Accounts Receivable ledgers and schedules                           7 years

Annual Audit Reports and Financial Statements                      Permanent

Annual Audit Records, including work papers                          7 years after completion of audit
and other documents that relate to the audit

Annual Plans and Budgets                                                            2 years

Bank Statements and Canceled Checks                                    7 years

Employee Expense Reports                                                          7 years

General Ledgers                                                                              Permanent

Interim Financial Statements                                                        7 years

Notes Receivable ledgers and schedules                                 7 years

Investment Records                                                                        7 years after sale of investment

Credit card records (documents                                                  2 years
showing customer credit card number)

1.Credit card record retention and destructionA credit card may be used to pay for IJK Internationalproducts and services.If it is determined that information on a document, which contains credit card information, is necessaryfor retention beyond 2 years, then the credit card number will be cut out of the document.

 

B.CONTRACTS
Record Type                                                                                    Retention Period

Contracts and Related Correspondence                                     7 years after expiration or termination
(including any proposal that resulted in
the contract and all other supportive documentation)

 

C.CORPORATE RECORDS

Record Type                                                                                    Retention Period

Corporate Records (minute books, signed                                 Permanent
minutes of the Board and all committees,
corporate seals, articles of incorporation,
bylaws, annual corporate reports)
Licenses and Permits                                                                      Permanent

 

D.CORRESPONDENCE AND INTERNAL MEMORANDA
General Principle: Most correspondence and internal memoranda should be retained for the same period asthe document they pertain to or support. For instance, a letter pertaining to a particular contract would beretained as long as the contract (7 years after expiration). It is recommended that records that support aparticular project be kept with the project and take on the retention time of that particular project file.Correspondence or memoranda that do not pertain to documents having a prescribed retention period shouldgenerally be discarded sooner. These may be divided into two general categories:

1.Those pertaining to routine matters and having no significant, lasting consequences should be discardedwithin two years. Some examples include:
•Routine letters and notes that require no acknowledgment or follow-up, such as notes of appreciation,congratulations, letters of transmittal, and plans for meetings.
•Form letters that require no follow-up.
•Letters of general inquiry and replies that complete a cycle of correspondence.
•Letters or complaints requesting specific action that have no further value after changes are made oraction taken (such as name or address change).
•Other letters of inconsequential subject matter or that definitely close correspondence to which nofurther reference will be necessary.
•Chronological correspondence files.
Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability.

2.Those pertaining to non-routine matters or having significant lasting consequences should generally beretained permanently.

E.ELECTRONIC DOCUMENTS
1.Electronic Mail: Not all email needs to be retained, depending on the subject matter.
•All e-mail—from internal or external sources will be deleted no earlier than 6 years after the termination of a client relationship.
•Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.
•IJK International will archive e-mail for six months after the staff has deleted it, afterwhich time thee-mail will be permanently deleted.
•All IJK International business-related email should be downloaded to a service center oruserdirectory on the server.
•Staff will not store or transfer IJK International-related e-mail on non-work-relatedcomputersexcept as necessary or appropriate for IJK International purposes.
•Staff will take care not to send confidential/proprietary IJK International information tooutsidesources.
•Staff with more than 500MB in their e-mail account will be unable to send or receive messages untilthe size of their account is reduced. Staff will be notified by {Insert Responsible Department} as their account size approaches 500 MB.
•Any e-mail staff deems vital to the performance of their job should be copied to the staff’s H: drivefolder, and printed and stored in the employee’s workspace.

2.Electronic Documents: including Microsoft Office Suite and PDF files. Retention also depends on thesubject matter.
•PDF documents– The length of time that a PDF file should be retained should be based upon thecontent of the file and the category under the various sections of this policy. The maximum periodthat a PDF file should be retained is 6 years. PDF files the employee deems vital to the performanceof his or her job should be printed and stored in the employee’s workspace.
•Text/formatted files – Staff will conduct annual reviews of all text/formatted files (e.g., MicrosoftWord documents) and will delete all those they consider unnecessary or outdated. After five years, alltext files will be deleted from the network and the staff’s desktop/laptop. Text/formatted files the staffdeems vital to the performance of their job should be printed and stored in the staff’s workspace.

3.Web Page Files: Internet Cookies
•All workstations: Browsers should be scheduled to delete Internet cookies once per month.
IJK International does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.
Each day IJK International will run a tape backup copy of all electronic files (including email) on {Insert Name of Organization}’s servers, as specified in the IJK International Disaster Recovery Plan. This backup tape is a safeguard to retrieve lost information within a one-year retrieval period should documents on the network experience problems. The tape backup copy is considered a safeguard for the record retention system of IJK International, but is not considered an official repository of IJK International records. All monthly and yearly tapes are stored offsite according to IJK International’s Disaster Recovery Policy. In certain cases a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

F. CUSTOMER IDENTIFICATION RECORDS

Customer Identification Records will be securely stored for 5 years after each relevant transaction in order to comply with any anti-money laundering requirements.