GUARANTY TITLE AND ESCROW CO.
IT SECURITY POLICY

Purpose
The availability, integrity, and confidentiality of computerized information is critical to the success of any company. This document establishes the corporate policy and standards for protecting all computerized communications, data, and information at Guaranty Title and Escrow Co.

Policy
All communications, data, and information created on, received through, or sent over Guaranty Title and Escrow Co.'s information resources (including the internet/intranet, phones, e-mail, and instant messaging (IM) systems) are protected, commensurate with value and sensitivity to disclosure, at all times according to the standards of behaviour defined in this document. Guaranty Title and Escrow Co. reserves the right to determine the appropriate use and suitability of any of this information. All such information is the property of Guaranty Title and Escrow Co.

All non-public information is secured as required by law and according to the Best Practice guidelines of the American Land Title Association.

Monitoring and Examination of Information
Guaranty Title and Escrow Co.'s business systems are considered private and not-for-public forum; therefore, guarantees of free speech under the First Amendment do not apply. At any time and without prior notice, Guaranty Title and Escrow Co. management reserves the right to access and monitor all communications and electronic files and to divulge this ifnormation to law enforcement officials and regulatory agencies as required by the state and federal regulations.

Reporting Incidents and Potential Violations
Guaranty Title and Escrow Co. encourages the reporting of all preceived incidents of misconduct (which includes potential violations of policy), regardless of the offender's identity or position. All reports of suspected incidents are taken seriously and investigated. To the extent practicable, Guaranty Title and Escrow Co. will keep reports confidentials; however, absolute confidentiality is not promised and cannot be assured.

Any employee or other individual who believes he or she has been subjected to, witnessed, or made aware of misconduct should immediately report the incident to management along with violations related to information resources or information technology networks; however, if the routing person is not identified, Guaranty Title and Escrow Co. might not be able to respond appropriately to the reported concern. There is no penalty for reporting an alleged incident in good faith.

Review
Guaranty Title and Escrow Co. has voluntarily adopted this policy for its sole and exclusive use. This policy and all related documents will be reviewed annually or as needed based on prevailing business conditions.