Ethics & integrity

We hold ourselves to a high standard of integrity and professional conduct. This allows us to establish trust with our employees, customers, and partners, as well as build an ethical culture throughout our value chain. We understand that a trusted relationship is important for success and that trust is hard to earn and easy to lose. Avaya’s Code of Conduct is a resource our employees use every day to make the right decisions for our company and our customers.

Foundation

The ethics program is built on the principles of prevention, detection and remediation. The compliance team works proactively with the business groups to assess compliance risk and determine if actions need to be taken. We work closely with our business stakeholders to identify issues of misconduct and take the time to thoroughly investigate issues, identify the root cause and take corrective measures when needed.

Avaya’s Code is the foundation of our program and covers a variety of topics including an overview of our guiding principles and information on how to conduct business in a manner that complies with the law. It is a global resource that ensures employees not only comply with the law, but they do the right thing, the right way, for the right reason.

Avaya’s Code applies to anyone that conducts business on behalf of Avaya. We have also developed Codes of Conduct for our Suppliers and Business Partners that are incorporated into agreements to ensure our expectations of ethical behavior are clearly communicated.

Training

Avaya provides a variety of training on legal and compliance related issues. Avaya employees, including management, are required to complete on-line training modules regarding anti-bribery and corruption, data privacy, cyber security and our Code of Conduct.  Successful completion of the modules is monitored and all employees must acknowledge their understanding of the course content.

Reporting 

Making sure that issues can be raised is an important component to our compliance program. While issues are raised to management during the normal course of business, we want our employees, customers, partners and suppliers to know they can raise any concern to us using our Ethics Helpline. Anyone using this service can choose to remain anonymous.  It is available by:

Phone: 1-877-99-ETHIC (1-877-993-8442) or +1 908-953-7276

https://app.convercent.com/en-us/Anonymous/IssueIntake/IdentifyOrganization

In addition, we are pleased to offer the following local reporting options via our independent 3rd Party Provider, Convercent, to all employees and other persons of France, Germany, Hungary, and Ireland who might have work-related concerns regarding compliance with EU law.

First option – Telephone report

Reporting Number for France: 0805-080339

Reporting Number for Germany: 0800 181 2396

Reporting Number for Hungary: 36-212111440

Reporting Number for Ireland:  1800-904-177

Second option – Web based report

Reports can also be made online at www.convercent.com

Alternative option

While we encourage everyone to provide Avaya the opportunity to investigate and resolve a claim first, we want to make clear that there is also the option to report a breach of EU law to an outside party such as a local regulator.

Investigations

Once a report is received, it is reviewed and investigated. At the conclusion of the investigation, the root cause is identified and, if necessary, corrective action is taken.

The investigative process is confidential based on local laws. Confidentiality is applied to all parties, as such, we cannot provide details on the outcome of an investigation other than informing the reporter when the matter is closed.

Non-retaliation

In order to encourage the raising of issues to leadership, Avaya has a non-retaliation policy which prohibits individuals for taking adverse action against individuals that make good faith reports.

Additional information

• Avaya Code of Conduct
• Supplier Code of Conduct