Workplace & Social Media Policy

01 Purpose

Solis Leisure recognises social media as an important professional channel for promoting the company, its people, properties, hospitality and catering operations, real-estate developments, career opportunities and professional reputation.

This policy establishes appropriate standards for employees who use social media in connection with their employment or who publicly identify themselves as employees of Solis Leisure.

The purpose of this policy is to:

• Protect the reputation and professional image of Solis Leisure.
• Ensure that company information is handled appropriately.
• Provide employees with clear guidance on professional social-media activity.
• Encourage employees to positively represent the company where appropriate.
• Protect confidential, commercially sensitive and personal information.
• Ensure compliance with applicable Maltese and EU laws and regulations.

02 Scope

This policy applies to all Solis Leisure employees, directors, managers, consultants, contractors, temporary workers and other individuals representing the company.

It applies to social media activity conducted:

• During working hours.
• Using company equipment or accounts.
• On behalf of Solis Leisure.
• Through an account that identifies the individual as an employee of Solis Leisure.
• When commenting on, sharing or discussing company-related matters publicly.

The policy does not prevent employees from maintaining personal social media profiles or expressing legitimate personal opinions, provided they comply with this policy and do not create the impression that they are speaking on behalf of Solis Leisure without authorisation.

03 Personal Social Media Profiles

Employees are encouraged to maintain accurate and professional social media profiles.

Employees may identify Solis Leisure as their employer and may describe their role, responsibilities and professional experience.

Employees should ensure that information relating to their employment is accurate and does not disclose confidential or commercially sensitive company information.

Employees should not:

• Claim to officially represent Solis Leisure unless authorised to do so.
• Use the Solis Leisure logo or other company branding in a manner that suggests an official company account where this has not been authorised.
• Publish misleading or inaccurate information about the company.
• Disclose confidential company information.
• Publish information about colleagues, clients, suppliers, guests, investors or business partners without appropriate permission.
• Make statements that could reasonably be interpreted as official company positions when they are not authorised to make such statements.

Where appropriate, employees may state:

"Views expressed are my own and do not necessarily represent those of Solis Leisure."

This disclaimer does not permit an employee to disclose confidential information or engage in inappropriate conduct.

04 Official Solis Leisure Social Media Accounts

Only individuals authorised by Solis Leisure management may create, manage or publish content on official Solis Leisure social media pages or accounts.

Authorised administrators are responsible for ensuring that published content is:

• Accurate.
• Professional.
• Consistent with Solis Leisure's brand.
• Appropriate for a public audience.
• Compliant with applicable laws and company policies.

Employees must not create unofficial social media pages, groups or profiles that could reasonably be mistaken for an official Solis Leisure account.

05 Confidential and Commercially Sensitive Information

Employees must not disclose confidential, proprietary or commercially sensitive information through social media.

This includes, but is not limited to:

• Business plans and strategies.
• Financial information that has not been publicly released.
• Property acquisition or disposal plans.
• Real-estate development plans that have not been publicly announced.
• Planning, permitting or construction information that is not public.
• Investment information.
• Negotiations with investors, landlords, tenants, suppliers or business partners.
• Unannounced hospitality or catering projects.
• Pricing, contracts or commercial agreements.
• Internal policies and procedures.
• Passwords, access credentials or security information.
• Internal communications.
• Personal information relating to employees, customers, guests or other individuals.

Employees should assume that information is confidential unless they have been informed that it is approved for public release.

06 Hospitality, Guest and Customer Information

Due to the nature of Solis Leisure's hospitality and catering activities, particular care must be taken when discussing guests, customers and events online.

Employees must not publish:

• Guest names or personal details without appropriate permission.
• Photographs of guests without appropriate consent.
• Private events or functions without authorisation.
• Guest complaints or disputes.
• Booking information.
• Personal information obtained through employment.
• Internal incidents involving guests or customers.

Employees must never use social media to discuss or respond publicly to a guest complaint or customer dispute unless specifically authorised to do so.

07 Real Estate Development and Property Information

Solis Leisure may be involved in property acquisition, development, construction, investment and related activities.

Employees must not publicly disclose information about properties, developments or transactions before the information has been officially released by the company.

This includes:

• New development announcements.
• Property purchases or sales.
• Development concepts.
• Architectural plans and drawings.
• Construction progress.
• Planning applications.
• Investor information.
• Expected launch dates.
• Property pricing.
• Commercial negotiations.

Employees may share official Solis Leisure announcements after they have been published through approved company channels.

08 Photographs and Videos

Employees must exercise care when taking or publishing photographs or videos connected to Solis Leisure.

Photographs or videos must not reveal confidential information, private documents, internal systems, guest information, security arrangements or other sensitive material.

Images taken inside workplaces, hospitality venues, kitchens, offices, construction sites or properties should only be published where appropriate and where the employee has permission to do so.

Employees must not photograph or record guests, colleagues or third parties in circumstances where doing so would be inappropriate or where their privacy would reasonably be expected.

09 Professional Conduct

Employees representing themselves as Solis Leisure employees are expected to maintain professional standards online.

Employees must not use social media to publish content that is:

• Harassing, threatening or abusive.
• Discriminatory.
• Defamatory.
• Sexually inappropriate.
• Intentionally misleading.
• Offensive or hateful.
• Intended to intimidate or embarrass another person.
• Likely to seriously damage the reputation of Solis Leisure.

Employees should remember that social media is a professional platform and that public posts may remain accessible for an extended period even after deletion.

10 Discrimination, Harassment and Bullying

Solis Leisure does not tolerate discrimination, harassment or bullying through any social-media platform.

Employees must not use social media to harass, threaten, discriminate against or target colleagues, customers, applicants, suppliers or business partners.

Conduct outside working hours may still be considered a workplace matter where it has a connection to Solis Leisure, its employees or working relationships.

11 Recruitment and Job Advertising

Solis Leisure may use social media to advertise employment opportunities and identify potential candidates.

Employees involved in recruitment must handle candidate information responsibly and must not disclose personal information about applicants publicly.

Employees must not make discriminatory comments about candidates or applicants.

Recruitment-related communication should be conducted through approved company channels and in accordance with Solis Leisure's recruitment procedures.

12 Sharing Company Content

Employees are encouraged to support Solis Leisure's official social media presence by engaging with and sharing approved company content.

Employees may:

• Like official company posts.
• Share official company announcements.
• Celebrate company achievements.
• Share approved job vacancies.
• Congratulate colleagues on professional achievements.
• Promote publicly announced developments and projects.

When sharing company content, employees should avoid adding comments that could create an inaccurate impression of the company's position.

13 Media and Public Statements

Employees must not provide official statements to journalists, media organisations, influencers or other public channels on behalf of Solis Leisure unless authorised.

Requests for official comments regarding Solis Leisure should be referred to management or the person designated by the company to handle external communications.

14 Political and Personal Opinions

Solis Leisure respects employees' right to express personal opinions in their private capacity.

However, employees should take reasonable care to distinguish personal opinions from official company positions.

Employees must not suggest that Solis Leisure endorses, supports or opposes a political party, candidate, political campaign or public policy position unless expressly authorised by the company.

15 Use of Company Branding

The Solis Leisure name, logo, photographs, graphics and other brand assets are company property and may only be used in accordance with company guidelines.

Employees must not modify or use company branding in a way that could damage the company's reputation or create confusion regarding whether an account or communication is officially authorised.

16 Social Media During Working Hours

Social media may be used during working hours when it is necessary for an employee's role, including recruitment, business development, networking, marketing, hospitality promotion and other legitimate business activities.

Personal social media use should be reasonable and must not interfere with an employee's responsibilities, productivity or customer service.

Managers may establish reasonable restrictions where social media use is affecting work performance.

17 Company Equipment and Systems

Employees must comply with Solis Leisure's IT, cybersecurity and acceptable-use requirements when accessing social media through company devices or networks.

Employees must never share company passwords, access credentials, internal documents or security information through social media.

Employees should use appropriate security measures, including strong passwords and multi-factor authentication where available.

18 Data Protection and Privacy

Employees must handle personal information responsibly and in accordance with applicable data-protection requirements, including the General Data Protection Regulation (GDPR) and applicable Maltese legislation.

Personal information relating to employees, applicants, guests, customers, suppliers and other individuals must not be published on social media without an appropriate lawful basis and, where required, consent or other authorisation.

19 Reporting Concerns

Employees who become aware of inappropriate social media activity involving Solis Leisure should report the matter to their manager, Human Resources or senior management.

Employees should not engage in online arguments or attempt to resolve serious complaints publicly.

Where an employee believes that confidential information has been accidentally published, the matter should be reported immediately so that appropriate action can be taken.

20 Breaches of this Policy

Failure to comply with this policy may result in appropriate action by Solis Leisure.

Depending on the circumstances and seriousness of the matter, this may include:

• Informal guidance or counselling.
• Formal disciplinary action.
• Removal of unauthorised content.
• Restriction of access to company social-media accounts.
• Further action in accordance with the employee's contract and applicable law.

Serious breaches involving confidentiality, harassment, discrimination, data protection, fraud, deliberate misconduct or significant reputational damage may result in more serious disciplinary consequences.

Nothing in this policy limits an employee's statutory rights or their ability to make a lawful protected disclosure or report concerns to an appropriate authority.

21 Policy Review

Solis Leisure may amend this policy from time to time to reflect changes in legislation, technology, social-media platforms, business requirements or company practices.

Employees will be informed of significant changes to the policy.