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

V. Our Colleagues

A. We Encourage Diversity and Prohibit Discrimination and Harassment

Avaya is committed to providing a work environment free from discrimination based on race, color, religion, national origin, sex, age, disability, sexual preference or orientation, marital status or any other unlawful factor.  This means that we comply with applicable civil rights and employment legislation at the local, state and national levels, and we do not discriminate unlawfully in any aspect of employment, including recruiting, hiring, compensation, promotion or termination.  It also means that Avaya does not permit conduct that creates an intimidating, hostile or offensive work environment, whether at an Avaya location or at an Avaya-sponsored activity.  Avaya’s Equal Opportunity Policy statements can be found in their entirety in the HR Policy Guide.

If you believe that you are the victim of discriminatory or harassing conduct or you have witnessed that kind of conduct directed at one of your colleagues, please report that conduct to your supervisor or, if that is not appropriate, call the Equal Opportunity/Affirmative Action Hotline at (866) 282-9201 (U.S.) and +1 908-953-7488 (International)*.  All complaints made in good faith will be investigated promptly and without reprisal to the person initiating the investigation.  To the extent possible and consistent with Avaya’s obligations under law and Avaya policy, Avaya will maintain the confidentiality of anyone reporting a complaint.

B. We Respect the Privacy of Employee Records

Avaya recognizes that privacy is important to each of us.  Avaya therefore limits access to and knowledge of employee records to people who need the information for legitimate purposes. If you have access to employee records or personnel information about co-workers, take precautions to ensure it isn't misused or disclosed improperly.  You should not disclose this kind of information without the authorization of a member of the HR or Law teams.  In addition, observe all applicable laws, such as the European Union’s Directive on Data Protection, regarding employee information, including those regarding information gathering, those requiring maintenance of records for a specific time and at a specific location, and those limiting the movement of personnel data across national borders.

C. We Strive to Ensure a Safe Work Environment

It is our policy to comply with all applicable regulations and policies relating to workplace safety, including those of the U.S. Occupational Safety & Health Administration and similar agencies around the world.  Furthermore, it is our policy to report and address dangerous conditions immediately so that workplace accidents are minimized.  You can learn more about Avaya’s commitment to health and safety by visiting Avaya’s Environment, Health & Safety Services website.

To report environmental, health and safety incidents, you can call the Health, Environment, Safety, and Benefits Administration Organization hotline (1-866-888-1118 (U.S.) and 1-239-263-5964 (International))*.  Please note, however, that this hotline should not be used as a replacement for your local facility’s reporting procedures and/or emergency services (e.g., dialing “911” in the U.S.).

D. We are Committed to a Drug-Free Workplace

The misuse of drugs, both legal and illegal, interferes with a safe, healthy and productive work environment and is prohibited.  Specifically, Avaya prohibits the use, possession, distribution or sale of illegal drugs by its directors, officers and employees.  Furthermore, no director, officer or employee may conduct Avaya business while under the influence of drugs or alcohol. Of course, prescribed use of prescription drugs is generally permitted provided that its use does not impair the employee’s ability to safely perform the essential elements of his/her job.

* Except in EU Member States where regular local reporting channels should be used.

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with Avaya
Contact Investor Relations:
phone +1 (908) 953-7504
envelope avirsvcs@avaya.com
Contact Transfer Agent:
phone Bank of New York
+1 (866) 22AVAYA
+1 (212) 815-3700
Must Use Company Code 8267
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