DocuSign Envelope ID: 56F3D142-54F2-4098-873D-454EDEF0A219

Avaya Responsible Minerals Policy
Background
Virtually all electronic products contain various minerals necessary for functionality including
tantalum, tin, tungsten, and gold (also referred to as 3TG). 3TG are sometimes known as"conflict minerals" because of concerns about their mining and sale contributing to armed
conflict and human rights abuses in the Democratic Republic of Congo (“DRC”) and nineneighboring countries, (defined as “covered countries” by the Dodd-Frank Wall Street
Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act")).
The Dodd-Frank Act requires publicly traded companies to assess their supply chains andreport annually on the source of conflict minerals in the products they manufacture orcontract to manufacture.
Along with governments, NGOs, the investment community, and many other companies
worldwide, we are concerned about human rights violations including forced labor, humantrafficking and child labor occurring anywhere in the world, as well as the role that armed
conflicts play in causing extreme violence across so-called Conflict-Affected and High-RiskAreas. 1

Avaya’s Commitment
Consistent with our commitment to corporate social responsibility, Avaya is committed tothe sourcing of minerals in an ethical and sustainable manner that safeguards the humanrights of everyone in our global supply chain and preserves the environment. Avaya does
not directly procure minerals from mines or the smelters or refiners that process them,rather our suppliers acquire and use minerals from multiple sources worldwide. We influence
the upstream supply chain through our policies and practice and our goal is to work
collaboratively with our supply chain to source minerals consistent with our values aroundhuman rights, business ethics, labor, health and safety practices and environmental
responsibility.
Avaya will:•Require our supply chain to source 3TG from smelters and refiners that conform to•

the Responsible Minerals Assurance Process (“RMAP”)
Conduct due diligence to identify and mitigate risks in our supply chain, following theOECD Due Diligence Guidance

1 See also our Statement on the Prevention of Modern Slavery & Human Trafficking at:https://www.avaya.com/en/documents/avaya-uk-modern-slavery-act-transparency-statement.pdf

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Collaborate with customers, suppliers and industry associations including theResponsible Minerals Initiative (“RMI”) on long terms solutions and best practice toenable responsible sourcing
Commit to transparency in the implementation of this policy by making available
reports on our progress to relevant stakeholders and the public.

Avaya’s Expectations of Suppliers
To support our commitment to the responsible sourcing of minerals, we expect our suppliersto:•Comply with the Avaya Supplier Code of Conduct 2•Source 3TG only from smelters and refiners validated as conformant to the RMAP thirdparty assessment program•Source minerals from non-conflict regions or, if sourced from conflict regions, to verify
that the sourcing is conflict-free (i.e., not used to fund conflicts in Covered Countries)•

through a reasonable due diligence program
Disclose to Avaya via the RMI Conflict Minerals Reporting Template (“CMRT”) therequested information necessary for Avaya to conduct its due diligence and accurately
report to the SEC as required•Respond to Avaya inquiries for due diligence information, and promptly implement
corrective actions identified and requested by Avaya•

Extend all these expectations to their own suppliers.

Where necessary, Avaya works with suppliers to remediate risks and perform additional
due diligence to ensure alignment with our expectations and so that we can continue tosource responsibly, building on established management processes.
Avaya's Responsible Mineral Policy and subsequent updates are communicated to our supply
chain partners and stakeholders via our website and referenced in all new RFPs, contracts,and contract revisions with direct material suppliers. Compliance with this Policy is arequirement for all direct material supplier contracts. Avaya will terminate relationships withsuppliers that pose a risk and that do not make substantive and prompt efforts to comply
with our policy.

_________________________________
Michel Cote, VP Supply Chain

May 30, 2022___________

Date

Please use the Avaya Ethics Helpline to share concerns about the content or execution of this policy:
Phone: 1-877-99-ETHIC (1-877-993-8442) or +1 908-953-7276
https://app.convercent.com/en-us/Anonymous/IssueIntake/IdentifyOrganization2

https://www.avaya.com/en/documents/supplier_code_conduct.pdf