Operating with Integrity is Avaya's worldwide code of ethics and business conduct. It is a guide to help us each resolve ethical issues in an increasingly complex global business environment, and also serves as a public statement of our commitment to the highest standards of integrity. While business practices may change over time, our commitment remains constant.

We believe that conducting business ethically is critical to our success. It means more than just obeying the law; it means that integrity underlies everything we do at Avaya. We can all be proud of our pledge.

Of course, no code of conduct can anticipate and address every situation. In many cases, common sense and good judgment will be your best guide. If you are unsure about any aspect of this Code of Conduct or how it may apply to a situation with which you are faced, you are encouraged to consult with your supervisor. In addition, you may send questions or concerns by email to compliance@avaya.com or call Avaya's Compliance Hotline 1-877-99-ETHIC (1-877-993-8442) for U.S. or 1-908-953-7276 for non-U.S. callers) or by logging in to www.ethicspoint.com.* Whatever you do, keep in mind that when you act on the company's behalf, Avaya's reputation for honesty and integrity is in your hands.

* In EU Member States, www.ethicspoint.com reporting is limited to concerns relating to accounting, internal control and auditing matters (i.e. SOX-related).

Last Updated: February 2011
Code of Conduct – Operating with Integrity (PDF, 3.04MB)  

I. Introduction
II. Our Values
III. Our Customers, Suppliers, Agents and Partners
IV. Our Competitive Practices
V. Our Colleagues
VI. Promoting Avaya's Interests and Protecting Avaya's Assets
VII. Our Internal Controls, Reporting, Records and Communication
VIII. The Broader Community
IX. Managing Compliance and Reporting Violations
X. Consequences of Violating Operating with Integrity
XI. Additional Provisions for Directors and Executive Officers
XII. References

A. What is Operating with Integrity?
Operating with Integrity is Avaya's worldwide code of ethics and business conduct. It provides information about the standards of integrity that Avaya requires Directors, officers and employees of Avaya Inc. and its subsidiaries to follow. Avaya expects that our contractors, consultants, agents, representatives, Business and Channel partners and others conducting business on our behalf will conform to the behaviors required by Operating with Integrity and/or our Supplier Codes of Conduct, as appropriate.

The pages that follow contain information regarding our corporate values; how we interact with one another as well as with our customers, suppliers, partners and other third parties; how we promote Avaya's interests and protect our assets; and how we encourage compliance with applicable laws and Avaya policies. However, keep in mind that Operating with Integrity does not address every situation or set forth every rule, and it is not a substitute for the responsibility of every person to exercise good judgment.

To help resolve issues that may not be addressed specifically by Operating with Integrity, you are encouraged to visit the websites and policies referenced throughout. In addition, you should visit Avaya's Ethics and Compliance website, where you can find helpful links to related corporate policies and answers to frequently asked questions and the Global Ethics & Compliance Blog for guidance and examples of the consequences associated with poor ethics decisions. Specific requests for guidance and questions regarding Operating with Integrity and Avaya's Global Ethics and Compliance Program can be sent to compliance@avaya.com.

B. What is the Scope of Operating with Integrity?
Operating with Integrity requires compliance with laws applicable to Avaya's business. However, because Avaya is a global company, its operations are subject to the laws of many countries, provinces, states, and municipalities. At times there may be situations where laws outside the U.S. seem to conflict with U.S. law. If you have any questions regarding the laws applicable to a particular situation, whether in the U.S. or elsewhere, you should consult Avaya Law. Directories of the members of Avaya Law who can assist you can be found on the Avaya Law website.

C. Important Notice for Directors, Officers, Employees and Others
Unless otherwise provided by local law or a collective bargaining or other labor agreement, Operating with Integrity is not a contract of employment and does not create any contractual rights of any kind between Avaya and its Directors, officers or employees. Moreover, unless prohibited by local law or unless an Avaya employee's terms and conditions of employment are governed by a collective bargaining or other labor agreement or there exist other local law or public policy exceptions, employment at Avaya is on an "at will" basis in the United States and elsewhere, where applicable. (Please note, for most countries outside the US, employment is generally not "at-will".) "At-will" means that an employee may terminate his or her employment at any time and for any reason, and, similarly, Avaya may generally terminate an employee's employment at any time and for any reason, or for no reason at all.