Ivanti Vendor Code of Business Conduct
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Ivanti Vendor Code of Business Conduct
1. Introduction
Ivanti has a long-standing reputation for integrity and trustworthiness among its customers
and this reputation depends upon the way in which Ivanti conducts its business and its
commitment to corporate social responsibility. As a well-respected security focusedorganization, Ivanti’s actions must be above reproach to maintain the confidence of its
customers and to avoid damage to its reputation.
Commitment to ethical business practices is a core value for Ivanti and this Vendor Codeof Business Conduct (the “Code”) is designed to ensure that all of Ivanti’s Vendors have aclear understanding of how Ivanti expects to conduct its business with its Vendors.
Ivanti expects all Vendors to fully comply with all of the principles and processes in theCode. All of Ivanti’s Vendors must carefully review the commitments in this Code andagree to abide by the commitments as a condition of doing business with Ivanti.
2. Vendor Code of Business Conduct
This section sets out Ivanti’s specific expectations and requirements regarding theworkplace standards and business practices of its Vendors. These expectations areconsistent with the Ivanti's values, principles and policies regarding ethical businessconduct. Ivanti will seek to identify and engage suppliers who conduct their business basedon a set of ethical standards compatible with its own. Ivanti will not knowingly do businesswith Vendors who do not meet the standards outlined in this Code.
a. Conflicts of Interest
Vendors shall avoid actual or apparent conflicts of interest by disclosing actual or
potential conflicts honestly and promptly prior to making any decision and ensuringthat their employees (nor employee’s family members) do not make personal
investments in companies that have a business connection with Ivanti.
b. Compliance with Laws
Vendors will comply with all applicable laws and regulations, whether domestic or
foreign, which govern the conduct of their businesses.
c. Employment and Wages
Vendors will employ employees who are, in all cases: present voluntarily, not put
at risk of physical harm due to their work environment, fairly compensated andallowed the lawful right of free association. Vendors will, at a minimum, provide
wages and benefits that comply with the laws of their country of operation.
d. Working Hours
Vendors will not exceed prevailing local work hours except where workers areappropriately compensated for overtime. Vendors should use less than sixty-hourwork weeks and allow employees at least one day off in seven days, or equivalent
leave privileges.
e. Anti-Slavery and Human Trafficking

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Ivanti Vendor Code of Business Conduct
Vendors prohibit slavery and human trafficking, this includes, but is not limited to(i) engaging in any form of human trafficking; (ii) using forced labor for any typeof work; (iii) using child labor; (iv) procuring commercial sex acts; (v) denying an
individual access to his/her identity or immigration documents, such as drivers’
licenses, visas, or passports, regardless of issuing authority; denying accessincludes, but is not limited to, destroying, confiscating, and concealing; (vi) using
misleading or fraudulent information when recruiting potential candidates, or in theprocess of an official offer of employment, contract, full-time, or otherwise; thisincludes, but is not limited to, using a language the potential employee is unfamiliar
with, making material misrepresentations regarding key terms and conditions (e.g.,wages, location of work, nature of work), or withholding any information regarding
key terms and conditions; (vii) charging applicants or potential candidates any
application or recruitment fee; (viii) using recruiters that are not compliant with thelabor laws of the country they are recruiting in; (ix) when required by law orcontract, failing to provide or pay for transportation; (x) when required by law orcontract, failing to provide or arrange housing that follows the housing and safety
standards of the correlating country; and (xi) when required by law or contract,
failing to provide in writing a recruitment agreement, employment contract, or othernecessary work documents.
f. Discrimination/Human Rights
Vendors must not discriminate against their employees in hiring practices or any
other term or condition of work (other than legitimate occupational requirementsallowed by law) on the basis of race, ancestry, place of origin, color, ethnic origin,citizenship, religion, faith, political opinion, sex, sexual orientation, genderidentity, age, marital status, same-sex partnership status, family status or disability.
g. Workplace Environment
Vendors will provide their employees with a safe and healthy working environment
consistent with all applicable laws and regulations and shall not use corporalpunishment or other forms of mental or physical coercion.
h. Environmental Protection
Vendors will comply with all applicable environmental laws and regulations in theircountry and all applicable Ivanti environmental policies.
i. Resource Efficiency and Greenhouse Gas Emissions
Throughout their operations, Vendors will seek to reduce greenhouse gas emissions
as well as other resources including raw materials, energy, and water. Further,
Vendors will provide reports relating to energy consumption and sustainability
initiatives as may be requested by Ivanti from time to time.
j. Confidentiality and Privacy
Vendors will not disclose to others or use for their own purposes or the purposes ofothers any trade secrets, confidential information, knowledge, designs, data, skill,or any other information which Ivanti identifies to the Vendor as confidential or ifsuch information by its nature should reasonably be understood by the Vendor toPage 3 of 5

Ivanti Vendor Code of Business Conduct
be confidential. In accordance with the intent of Ivanti’s Privacy Policy(https://www.ivanti.com/company/legal/privacy-policy), Vendors will respect theprivacy of personal data they collect, use or disclose as a consequence of theirbusiness relationship with Ivanti.
k. Protection and Responsible Use of Personal Data
Vendors shall protect the personal and sensitive data of Ivanti’s customers,
employees and other persons obtained during Vendor’s business activities by: (i)processing personal data lawfully, fairly and in a transparent manner; (ii) collecting
personal data for specified, explicit and legitimate purposes and not processing it
in a way that would be unlawful or incompatible with those purposes; (iii) having
adequate security procedures and policies designed to protect personal data fromloss, unauthorized use or disclosure; (iv) collecting accurate personal data and,
where necessary, keeping it up to date; (v) collecting only the type(s) and amountof personal data that is relevant and required for the business relationship andservices being provided; (vi) not keeping personal data longer than is necessary forthe purpose for which the data was collected; (vii) respecting procedures to ensure
prompt responses to enquiries from customers regarding their data; (viii) not selling
customers data; (ix) organizing appropriate data protection training for theiremployees, agents and contractors; and (x) immediately informing Ivanti of any
security breach involving a loss of personal data.
l. Bribery, Corruption and Unlawful Payments
Vendors shall be knowledgeable about and adopt local anti-bribery & corruption
policies. Vendor shall never offer a gift that affects or appears to affect theimpartiality of the person who receives it and shall apply local prior pre-approval
procedures before offering or accepting a gift, entertainment or hospitality. Vendors
shall not give a payment or a gratuity to government officials or employees toexpedite a routine administrative action or make any contributions, whether
financial or in kind, to political parties or organizations, or to individual politicians(where it is legal to do so) on behalf of Ivanti without pre-approval from Ivanti.
m. Insurance
To ensure the protection of Ivanti’s business, Vendors shall maintain appropriate
insurance coverage as required by Ivanti, and as updated from time to time, for theduration of the business relationship with Ivanti.
n. Anti-Money Laundering
Vendors shall take all necessary steps prevent and detect any money laundering andterrorism financing by understanding and complying with all applicable laws andregulations, such as Title III of the Uniting and Strengthening America byProviding Appropriate Tools Required to Intercept and Obstruct Terrorism Act of2001 (the “USA Patriot Act”).
3. Assessment and Monitoring

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Ivanti Vendor Code of Business Conduct
Ivanti reserves the right to assess and monitor on an ongoing basis a Vendor’s practices
regarding this Code. Assessments may include a review of relevant Vendor records as wellas inspection of Vendor facilities for compliance with this Code. Ivanti will determine thefrequency and extent of the assessments and ongoing monitoring. Consistent with standard
industry practice, all costs associated with the assessments and ongoing monitoring will beborne solely by Vendor. Vendor will allow Ivanti and/or any of its representatives
reasonable and timely access to Vendor’s facilities and to Vendor’s relevant records at alltimes.
4. Enforcement
Vendors who do not meet the requirements of this Code may, where considered appropriate
by Ivanti, be provided with the opportunity to bring their business into compliance withthis Code within a reasonable time frame determined by Ivanti. Ivanti reserves the right toterminate its business relationship, including any and all agreements between Ivanti and aVendor, with any Vendor who fails to comply with this Code.
5. Reporting and Addressing Code Violations
Any person who believes that a violation of this Code has occurred, is asked to report therelevant information in confidence to the Ivanti Business Conduct Web Reporting Portalat https://secure.ethicspoint.com/domain/media/en/gui/49468/index.html.
Ivanti will make every effort to investigate all reported violations in a discreet, fair andconfidential manner and will take appropriate action to maintain the integrity of its
business.

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