Definitions Active Record See “Altair Record” below. Historical Record See “Altair Record” below. Custodian of Record The designated Department, as identified in the Record Retention Schedule, responsible for retaining and timely destruction of Altair Records in compliance with this Policy. Department Any and all Altair business, financial, human resources offices including any specific divisions or areas of expertise or responsibility. Electronically Stored Information Any and all information created, manipulated, communicated, stored, and best utilized in digital form, requiring the use of computer hardware and software. Electronically Stored Information resides in many places, including: · Office Equipment – including personal desktop computers, laptops, smart phones, and voicemail systems. · Networked Photocopiers, · Portable Media – including jump drives, portable hard drives, CDs, DVDs, magnetic tapes, diskettes, memory cards. · Servers – including email servers, SPAM filter servers, document management systems servers, instant messaging (IM) servers, file servers, print servers, firewall servers, HR database, servers, payroll database servers, and internal and external web servers. · Proprietary applications (software or other programs licensed expressly to Altair); and · Back-up tapes or other backup systems. Inactive Record See “Altair Record” below. IS Office The Information Services office, and/or, as applicable, any other organizational technology group within Altair (including its subsidiaries and affiliates) that maintains Altair Information or Altair Resources. Litigation Hold Notice A formal directive issued by the Vice President, Legal Services that Altair is under a legal obligation to preserve potentially relevant evidence in connection with a pending or threatened legal action. Record Management Administrator The Department representative responsible for maintaining day-to-day records management practices and procedures. Record Retention Period The length of time for which the Records Custodian is responsible for retaining a specified Altair Record in accordance with the Record Retention Schedule. Record Retention Schedule The table listing the required Record Retention Period and the designated Records Custodian for each identified Altair Record. Altair Altair Global Services, LLC, d/b/a Altair Global including its divisions, subsidiaries, and affiliates (e.g., Altair Global Relocation Ltd., Shanghai, Singapore, EU, etc.) Altair Information All activities and business must be conducted on Altair Resources. All Altair Information must be stored on Altair Resources. Any and all use of Altair Information and Altair Resources must comply with all local, state, and federal laws and regulations as well as company policies and procedures and client contracts. At Altair’s sole discretion and in accordance with this Policy and procedure, any and all Altair Information and Altair Resources are subject to access by designated Altair representatives, with the approval of the Chief Executive Officer, President or EVP, TMXR for preservation, review, monitoring, and seizure, at any time without notice, in order to: 1. Ensure compliance with local, state, and federal laws and regulations as well as any Altair policy, and procedure. 2. Comply with any order by a court, agency, or other governmental entity. 3. Retain information and data. 4. Preserve and produce Evidence in Litigation Discovery. 5. Maintain the integrity and security of Altair Information and Altair Resources. 6. Investigate a suspected violation of law or regulation, or of a suspected infraction of Altair policy; and/or 7. Respond to an emergency of any kind. Because the primary use of Altair Information and Altair Resources is to further Altair’s mission, goals and objectives, Team members should not have an expectation of privacy in their use of such resources and information. In the event Altair activities and business are conducted on non-Altair Resources, or Altair Information is stored on Non-Altair Resources, such non-Altair Resources are subject to this policy. Any violation of this policy and procedure or failure to timely cooperate in complying with its provisions by any Applicable Member may result in disciplinary action up to and including termination. Altair Record Any recorded information (hard copy or electronic) that is created, received or transmitted by a Team member or Department in the ordinary course of Altair business. All Altair Records regardless of their format are subject to this Policy. · Active Record: An Altair Record that is currently being used in the ordinary course of Altair business. · Inactive Record: An Altair Record that is no longer being used in the ordinary course of Altair business that must be retained until the end of its Record Retention Period and is not required to be preserved in accordance with a Litigation Hold Notice. · Expired Record: An Altair Record: · that is no longer being used in the ordinary course of Altair business. · is not listed under the Record Retention Schedule or whose Record Retention Period has ended. · that is not subject to a Litigation Hold Notice; and · that is not a Historical Record. GDPR The General Data Protection Regulation [1] is a legal framework that sets guidelines for the collection and processing of personal information of individuals within the European Union (EU). [ 1] The General Data Protection Regulation (EU) 2016/679 (GDPR) is a regulation in EU law on data protection and privacy in the European Union (EU) and the European Economic Area (EEA) that also addresses the transfer of personal data outside the EU and EEA areas. CCPA The California Consumer Protection Act [1] is a legal framework that sets guidelines for the collection and processing of personal information of individuals within and/or residents of California. Additional states are contemplating legislation similar to the CCPA and for purposes of this document, will be included under CCPA. [1] California Consumer Privacy Act of 2018, Ca Civil Code §1798.185, et. seq. (2020)

The Chief Financial Officer (CFO) is responsible for retention of financial (accounting, tax), statutory and regulatory, and other related records. The Executive Vice President, TMX Resources and Administration (EVP-TMXR) is responsible for retention of all HR records. The Vice President, Infrastructure Services (VP-IS) is responsible for storage of electronic data in line with this procedure. The Chief Technology Officer (CTO) is responsible for ensuring that retained records are included in business continuity and disaster recovery plans.

The purpose of the Record Management Policy is to (1) establish an efficient Altair-wide record management system for maintaining, identifying, retrieving, preserving and destroying records, (2) ensure that records are adequately protected, (3) preserve Altair history, (4) ensure that records that are no longer needed or of no value are destroyed at the appropriate time, and (5) comply with all applicable local, state, and federal laws and regulations.

This policy applies to all records, including all Altair Information and Altair Resources, regardless of format, whether in paper, electronic, microform (e.g., microfilm, microfiche, magnetic tapes, and CD-ROM), or other medium.

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