Records Retention Policy

The corporate records of Majestic Capital, Ltd. and its subsidiaries (collectively, the "Company") are important assets. Corporate records include essentially all records you produce as an employee, whether paper or electronic. A record may be as obvious as a memorandum, an e-mail, a contract or a case study, or something not as obvious, such as an expense record.

The law requires the Company to maintain certain types of corporate records, usually for a specified period of time. Failure to retain those records for those minimum periods could subject you and the Company to penalties and fines, cause the loss of rights, obstruct justice, spoil potential evidence in a lawsuit, place the Company in contempt of court, or seriously disadvantage the Company in litigation.

The Company expects all employees to fully comply with any published records retention or destruction policies and schedules, provided that all employees should note the following general exception to any stated destruction schedule: If you believe, or the Company informs you, that Company records are relevant to litigation, or potential litigation (i.e., a dispute that could result in litigation), then you must preserve those records until the General Counsel determines the records are no longer needed. That exception supersedes any previously or subsequently established destruction schedule for those records. If you believe that exception may apply, or have any question regarding the possible applicability of that exception, please contact the General Counsel.

From time to time the Company establishes retention or destruction policies or schedules for specific categories of records in order to ensure legal compliance, and also to accomplish other objectives, such as preserving intellectual property and cost management. Several categories of documents that bear special consideration are identified below. While minimum retention periods are suggested, the retention of the documents identified below and of documents not included in the identified categories, should be determined primarily by the application of the general guidelines affecting document retention identified above, as well as any other pertinent factors.

TYPE OF RECORD	RETENTION PERIOD
ACCOUNTING
Accounts receivable subsidiary ledgers	7 years
Accounts payable subsidiary ledgers	7 years
Auditor's reports/schedules	Permanently
Bank deposit slips	3 years
Bank statements, reconciliations,check registers, investment statements	7 years
Budgets	3 years
Cancelled checks, generally	7 years
Cancelled checks, important payments	Permanently
Cash disbursements journal	Permanently
Cash receipts journal	Permanently
Depreciation records	Permanently
Employee expense reports	7 years
Annual financial statements	Permanently
Interim/internal financial statements	3 years
General journal/ledger and end-of-year trial balances	Permanently
Inventory lists	7 years
Invoices to customers	5 years
Invoices from vendors	5 years
Internal audit reports	Permanently
Petty cash vouchers	3 years
CORPORATE RECORDS
Annual reports	Permanently
Articles of Incorporation	Permanently
Constitution and bylaws	Permanently
Board and board committee minutes	Permanently in minute book
Contracts and leases (expired)	Permanently
Contracts and leases (active)	Permanently
Deeds, mortgages and bills of sale	Permanently
Legal correspondence	Permanently
Property appraisals	Permanently
Property records	Permanently
Tax-exemption documents	Permanently
EMPLOYMENT/PERSONNEL RECORDS
Employee files (after termination)	7 years
Employment applications	3 years
Payroll records, summaries and tax returns	7 years
Pension/profit sharing retirement plan tax information, returns and correspondence	Permanently
Time cards and daily reports	7 years
FAXES
Should be saved by keeping in the appropriate file.	Retention Period depends upon subject matter of fax.
INSURANCE
Accident reports and claims (settled cases)	7 years
Contracts with brokers	7 years
Expired insurance policies	7 years
Policies (expired)	7 years
Medical Exams	7 years
INTELLECTUAL PROPERTY/TRADE SECRETS
All documents designated as containing trade secret information	Life of the trade secret
LEGAL FILES
General counsel should be consulted to determine retention period of particular documents	10 years
MARKETING AND SALES DOCUMENTS
Final copies of marketing and sales documents	3 years
PRESS RELEASES/PUBLIC FILINGS
All public filings	Permanently
All press releases	Permanently
TAX RECORDS
Income tax returns & cancelled checks	Permanently
Payroll tax returns	7 years
Property tax returns	7 years

The various types of records listed above may be generated from a number of sources including but not limited to faxes, email or instant messaging and word processing functions. It is imperative that each type of record is retained for the appropriate time period listed above and in a manner which best complies with all governing International, Federal and State laws. Below we have outlined procedures to implement when retaining various types of documents. The Company requires that each of our employees strictly adhere to these procedures.

ELECTRONIC RECORDS RETENTION

The term "electronic record" means any record that is created, received, maintained or stored on the Company's local workstations or central servers. Examples include, but are not limited to, electronic mail (e-mail), word processing documents and spreadsheets, and databases. The term "legal custodian" shall mean the originator of an e-mail message or the creator of an electronic document if that person is a Company employee; otherwise it is the Company employee to whom the message is addressed or to whom the electronic document is sent.

1. General Requirements. Maintenance and disposal of electronic records, as determined by the content, is the responsibility of the legal custodian and must be in accordance with this Policy. The retention period depends upon the subject matter of the electronic document and should follow the time-frames set forth above. When an employee leaves the Company, the department head is responsible for designating a new legal custodian and ensuring that any electronic records in the employee's possession are properly transferred to a new legal custodian.



2. Electronic Mail. E-mails are records of the Company and must be treated as such.
   
   The retention period of email depends upon the subject matter of the email, as set forth above, and should be either: (1) printed in hard copy and kept in the appropriate file; or (2) be maintained in the employee's email files. The printed copy of the e-mail should contain the following header information: (a) who sent message; (b) who the message was sent to; (c) date and time message was sent; and (d) subject. The Company uses an electronic email archival system for the migration, archival, storage and retention of emails stored electronically.



3. Instant Messaging. The Company does not support the use of Instant Messaging (IM) for Company business.



4. IT Backup Files. The Information Technology department performs backups on a regular schedule of electronic records. These backups are to be used for system restoration purposes only and will not be maintained indefinitely. The IT system administrator is not the legal custodian of messages or records which may be included in such backups.

LITIGATION HOLDS

When litigation against the Company or its employees is filed or threatened, the law imposes a duty upon the Company to preserve all documents and records that pertain to the issues. As soon as the Company is made aware of pending or threatened litigation, a litigation hold directive will be issued to the legal custodians. The litigation hold directive overrides any records retention schedule that may have otherwise called for the transfer, disposal or destruction of the relevant documents, until the hold has been cleared by the Company's Counsel. E-mail and computer accounts of separated employees that have been placed on a litigation hold by the Company's

Counsel will be maintained by Information Technology department until the hold is released. No employee who has been notified by the Company's Counsel of a litigation hold may alter or delete an electronic record that falls within the scope of that hold. Violation of the hold may subject the individual to disciplinary action, up to and including dismissal, as well as personal liability for civil and/or criminal sanctions by the courts or law enforcement agencies.

POLICY ENFORCEMENT

Failure to comply with this Document Retention Policy may result in punitive action against the employee, including suspension or termination. Questions about this policy should be referred to the General Counsel who is in charge of administering, enforcing and updating this policy.

Revised and Adopted: August 5, 2009

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