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Continuity Plan ensures that WEX employees, and the physical and information assets entrusted <br />to us by our clients are protected by viable response and recovery plans. The Corporate BCP takes <br />an all hazards approach to the assessment of risk posed to critical business functions and develops <br />comprehensive plans that provide for effective recovery from a disruption of critical business <br />functions. The plans are tested before implementation and exercised regularly thereafter to <br />ensure their viability and continued improvement. <br />In instances of fraud or card skimming, WEX works in a similar manner to ensure accounts and <br />customer information is shut off and safeguarded. See discussion of WEX's fraud detection <br />system, SaferPayments, in our response to Question 15.4. <br />7.7 Contractor must provide and maintain an appropriate information security program to prevent <br />the unauthorized disclosure, misuse, alteration, or destruction of confidential information. <br />As part of the WEX BCP, WEX has in place an information security program that exists to safeguard <br />both WEX and WEX customers from the unauthorized disclosure of information, especially <br />sensitive information. This includes unauthorized disclosure, misuse, alteration or destruction of <br />confidential information. The WEX Information Security Program outlined below covers the <br />protection of cards, account numbers, passwords, PINS, transaction data, among many other <br />sensitive systems and information. <br />The WEX production data center is a secure facility, accessed by badge readers and monitored by <br />CCTV. The facility is staffed 24x7x365. The WEX data center has a Tier III rating as specified by the <br />uptime institute. WEX visitors and maintenance personnel are only allowed access to data center <br />facilities with an authorized escort and approved business need. <br />WEX has an ISO 27001/27002 based Information Security Program that includes robust access <br />controls, security monitoring controls, governance, risk and compliance, backup and recovery <br />capabilities, regular penetration testing and vulnerability scanning, strong physical and <br />environmental controls, policies and procedures, and security awareness training. Policies and <br />standards are reviewed and updated annually. Procedures are owned by the individual teams and <br />are required to meet the standards and also be approved by their management. <br />WEX also obtains a SSAE16 SOC1, PCI-DSS certification over our WEXOnline° platform, and is <br />subjected to regular reviews and oversight by Internal Audit, External Audit, FDIC Examiners, and <br />various third parties. <br />The SSAE16 SOC1, PCI-DSS certification governs WEX security protocols for how we handle <br />customer information like cards, account numbers, passwords, personal identification numbers <br />and transaction data. <br />Vendor Access <br />WEX has a Vendor program that establishes the following review and oversight areas: <br />Information Security service provider review, Procurement review, and Legal Department review <br />that must be performed prior to a third party being approved. Logical access is then requested by <br />the WEX manager that owns the relationship with the third party and provisioned by a systems <br />access group. <br />System Patches <br />System patches, including service packs and security fixes are reviewed and approved following <br />standard change management processes. Relevant patches are applied as soon as practical given <br />MASTER AGREEMENT No. 00819 — FLEET CARD SERVICES PAGE 106 OF 138 <br />