A. We Encourage Charitable Contributions
All charitable contributions on behalf of Avaya, whether in cash or in kind, must be made in accordance with Avaya’s gift giving policies. Also, depending on the amount and nature of the proposed donation, you must ensure that it complies with all applicable guidelines and procedures adopted by your organization. Special care should be taken to ensure that the donation is being made to an organization that is recognized as a charity under the laws of the country in which the donation is being made, that the organization is not controlled or influenced by a government official, and that the donation otherwise complies with U.S. law (e.g., the U.S. Patriot Act) and/or the laws of that country. In addition, if the donation is in any way related to a bid or other Avaya business, or if you or any of your family members are directors of or otherwise act in an official capacity on behalf of the charitable organization you are looking for Avaya to support, you must ensure that the donation does not violate the conflict of interest provisions of Operating with Integrity (see Section VI.A above)
B. We Believe Involvement in Political Activities should be Personal and Voluntary
Directors, officers and employees worldwide are prohibited from using their positions with Avaya or Avaya’s assets in attempting to influence the personal decisions of others to contribute to or otherwise support political parties or candidates. Any involvement in political activities is personal and voluntary, and it should be done on your own time and with your own resources.
With respect to issues affecting Avaya’s business, Avaya has established a Political Action Committee (PAC), supported by voluntary employee contributions, for making political contributions in the U.S. Under Avaya’s policy and the Schedule of Authorizations, no company resources may be used to make political contributions to political parties or candidates for political office in the U.S., except through the PAC. This prohibition applies to contributions at the federal, state, local and municipal levels. Questions involving political contributions in the U.S. should be directed to Avaya Government Affairs.
In other countries, no contributions to political parties or candidates for political office may be made on behalf of Avaya unless the contribution is legal under both U.S. law and the laws of those countries, and you have the prior written approval of your supervisor, with advice from the International and Commercial Law group of Avaya Law
.
|
