A. We Believe in a “Tone at the Top” Approach
Avaya has established a compliance structure that assigns oversight responsibility for Avaya’s Ethics and Compliance Program to the Chief Administrative Officer & General Counsel, as Avaya’s Chief Compliance Officer. With the assistance of the Director, Global Ethics & Compliance and Avaya’s Global Ethics and Compliance Council, made up of leaders in key Avaya roles, Avaya’s Compliance Officer has established a system designed to promote compliance with the provisions of Operating with Integrity throughout the organization. An important aspect of that system involves the commitment of every employee to review the terms of Operating with Integrity and to take training courses that are distributed in connection with the Global Ethics and Compliance Program.
In addition, supervisors have a special responsibility to show, through words and actions, personal commitment to the highest standards of integrity. In particular, supervisors must:
- lead by example, using their own behavior as a model for other employees;
- maintain an environment of open communication in which Operating with Integrity and related policies are shared and discussed;
- ensure that their people understand the Avaya values and the provisions of this Code of Conduct, promote required training, and give them additional training, when appropriate;
- take reasonable steps to ensure that unethical conduct within their areas of responsibility is detected and addressed; and
- consider whether a person lives the Avaya values before placing him or her in a position of responsibility.
If you have any questions regarding the provisions of Operating with Integrity or any of the other corporate policies referenced in Operating with Integrity, you can contact compliance@avaya.com for additional information.
B. We Encourage Reporting of Policy and Other Violations
Ultimately, our conduct is our own responsibility. None of us should ever commit dishonest, destructive or illegal acts even if directed to do so by a supervisor or co-worker, nor should we direct others to act improperly.
You should notify Avaya Security immediately if you suspect, observe or learn of unethical business conduct or the commission of any dishonest, destructive or illegal act. Avaya Security can be reached on a 24-hour basis within the U.S. on 1-877-99-ETHIC (1-877-993-8442) and for non-U.S. calls on 1-908-953-7276.* Alternatively, you can submit good faith reports by logging on to www.ethicspoint.com** or by sending an e-mail to compliance@avaya.com*, and you can direct any questions about this Code of Conduct or any compliance related policy to that email address as well. Under the direction of Avaya Security or Global Ethics & Compliance, Avaya will investigate all reports, including those made anonymously, and provide feedback when appropriate.
Furthermore, the Audit Committee of the Board of Directors has created a process for employees to use to transmit to the Audit Committee complaints relating to suspected violations of Avaya’s Accounting Policy and/or other concerns relating to accounting, internal control and auditing matters. If you have a concern regarding accounting, internal accounting controls or auditing matters relating to Avaya and wish to submit the concern confidentially or anonymously, you may do so through the Avaya Ethics & Compliance hotline at www.ethicspoint.com, or by calling 1-877-99 ETHIC or 1-877-993-8442 (for U.S. callers), or 1-908-953-7276 (for callers from outside the U.S.) or by contacting the Audit Committee of the Board of Directors by email at compliance@avaya.com or by mail at the following address:
Chairman, Audit Committee
Avaya Inc.
Room 3C429
211 Mount Airy Road
Basking Ridge, New Jersey 07920
Please note that Avaya will not tolerate any reprisals by its directors, officers, employees, contractors, subcontractors or agents against those who report in good faith suspected violations of Operating with Integrity or any related Avaya policy. Examples of those types of reprisals include any discharge, demotion, suspension or harassment of, or threats or other discrimination against, an individual who makes a good faith report. Moreover, the identity of each person that makes a good faith report of any violation will be protected to the extent consistent with law and Avaya policy.
* Except in EU Member States where regular local reporting channels should be used.
** In EU Member States, www.ethicspoint.com reporting is limited to concerns relating to accounting, internal control and auditing matters (i.e. SOX-related).
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