Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Avaya LLC

AVAYA MODERNSLAVERY AND
HUMAN
TRAFFICKINGSTATEMENTMay 2024

Updated July 2024 to incorporate Avaya UK and Avaya Australia Pty. Ltd. approvals.

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Contents

Introduction ..............................................................................................................................2
Our Business ............................................................................................................................3
Activities ................................................................................................................................3
Supply Chain ........................................................................................................................4
Our Policies and Due Diligence Processes ...........................................................................4
Human Rights Statement ...................................................................................................5
Grievance Mechanism .........................................................................................................6
Supplier Code of Conduct...................................................................................................6
Responsible Minerals Policy and Conflict Minerals Reporting.......................................7
Our Risk Context .....................................................................................................................9
Supply Chain Risks ..............................................................................................................9
Operational Risks ...............................................................................................................10
Access to Remedy .................................................................................................................11
Grievance Mechanisms .....................................................................................................11
RBA Remediation Policy....................................................................................................11
Consultation ...........................................................................................................................12
Looking Forward ....................................................................................................................12
Approval and Attestation - Canada ....................................................................................14
Approval ..............................................................................................................................14
Attestation ..........................................................................................................................14
Approval - UK .........................................................................................................................15
Approval ..............................................................................................................................15
Approval - Australia ..............................................................................................................16
Approval ..............................................................................................................................16
Appendix 1: Mapping of Sections to Laws ........................................................................171

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Introduction
This Statement describes the actions taken by Avaya LLC (Avaya, we, or our) to assess andaddress modern slavery and human trafficking risks in our operations and supply chains,pursuant to the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains
Act (the Canadian Act), the United Kingdom (UK) Modern Slavery Act, and the AustralianModern Slavery Act (Cth) 2018. Avaya LLC is submitting this report on behalf of our
Canadian (Avaya Canada Corp., Avaya Cloud Canada, and 3102455 Nova Scotia
Company 1), our UK (Aurix Ltd., Avaya Capital Ireland (UK Inc.), Avaya ECS Ltd., Avaya
International Holdings Ltd., Avaya UK, Avaya UK Holdings Ltd., Esna Technologies Ltd., andUbiquity Software Corp. Ltd.), and our Australian (Avaya Australia Pty. Ltd) entities.
All of the actions by Avaya LLC described throughout this Statement are representative of
the subsidiaries’ management of modern slavery and human trafficking risks, as they utilize
the same corporate policies and processes.
This is Avaya’s first statement under the Canadian and Australian Acts. Avaya has
previously issued UK Modern Slavery Statements. This Statement compiles information toaddress each law’s respective requirements. A mapping of the different sections of thereport to each law’s reporting requirements is available in Annex 1. 2This Statement has been prepared for the financial year 2023 (FY23), ending in
September. 3 It communicates Avaya’s policies and practices to respect human rights andhow we identify, assess, mitigate, and remediate actual and potential impacts. Avaya
upholds and respects human rights as contained in international law and standards,
including the United Nations Universal Declaration of Human Rights (UDHR), the elevenfundamental instruments developed by the International Labour Organization (ILO), and theOrganization for Economic Cooperation and Development (OECD) Guidelines forMultinational Enterprises. Throughout this Statement, we reference “modern slavery andhuman trafficking 4”, of which the former encompasses both child labour 5 and forced labour 6.

1
While this is formally an Avaya entity, it does not own any intellectual property and has no employees, ongoingdeals/transactions, or relevant financial information.
2
We are in the process of gathering the necessary approvals and signatures to adhere to the requirements of the
UK and Australian Acts and intend to submit a revised report when this is completed.
3
Avaya’s FY23 is 1 October 2022 – 30 September 2023.
4“Human trafficking is defined as “the recruitment, transportation, transfer, harbouring or receipt of persons, bymeans of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of
power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent
of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at aminimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour orservices, slavery or practices similar to slavery, servitude or the removal of organs” (ILO.org).
5“Child labour is any work that deprives children of their childhood, their potential and dignity, and that is harmfulto physical and mental development” (ILO.org).
6“Forced labour is defined as “all work or service that is exacted from any person under the menace of penalty andfor which the said person has not offered himself voluntarily”” (ILO.org).

2

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Our Business
Our Structure, Activities and Operations
Avaya is a global digital communications products, solutions, and services provider, leadingin customer experience and communications solutions and helping organizations drive
momentum by creating unmatched customer and employee experiences. We offer ourcustomers software solutions and a suite of electronic hardware products. 7
We are headquartered in Morristown, New Jersey, United States, with operations acrossAsia Pacific (APAC), Central America and Latin America (CALA), Europe, Middle East andAfrica (EMEA), and North America (NAR). Avaya became a private company in May 2023
following restructuring. Previously, Avaya was a publicly listed company trading on the New
York Stock Exchange as (NYSE: AVYA).
At the end of FY23, we had 6,338 direct employees (6,274 full time employes and 64 parttime employees) globally. Of those employees, 246 are in Canada, 56 are in Australia and218 are in the UK. In addition to our direct employee base, we are supported by 3,757
external contractors, which includes consultants, interns, and staff supplementation roles,
among others.

Activities
Avaya is a global leader in digital communications products, solutions, and services forbusinesses of all sizes. We help our customers enhance and simplify collaboration in thecloud, on-premises, or a hybrid of both by creating converged contact center and unified
communications and collaboration (UCC) and contact center (CC) software solutions. We
also offer hardware and gateway solutions which include a range of devices such as
telephones and video conferencing units that enhance collaboration and productivity, andposition organizations to incorporate future technological advancements. The complete listof our hardware products that were imported into Canada includes servers, cameras /videoconferencing units, telephones (including cordless units, conference phones, anddesktop phones), gateways, and Internet Protocol (IP) external expansion modules. In
FY23, we imported a combined total of 98,832 product units into Canada.
Our Avaya Canada Cloud entity is used to sell our regulated products and services in
Canada, including our telecommunications equipment that must comply with CanadianRadio-Television and Telecommunications Commission (CRTC) and Canadian industry
standards. Avaya Canada Corp. is used for anything else that does not fall under the Avaya
Canada Cloud’s purview, including software solutions, customer support services, andbusiness communication services that do not fall under specific regulatory oversight. The

7
Per the requirements of the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act,
reporting requirements are applicable to, “entities producing goods in Canada or elsewhere or importing goods
produced outside Canada.” In accordance with the definition of goods in the Canadian Act’s official guidance, only
Avaya’s hardware fall under the purview of the Canadian Act and are therefore subject to the reporting
requirements. Our software services are not subject to the reporting requirements.

3Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

third entity, 3102455 Nova Scotia Company, does not currently serve any active function in
Canada.
Avaya sells our hardware and software services products directly through a worldwide sales
force and indirectly through our global partner network, including distributors, service
providers, dealers, value-added sellers, system integrators, and business partners thatprovide sales and services support.

Supply Chain
Avaya has a large supply chain that consists of multi-layered networks comprised of directly
contracted suppliers and sub-tier (Tier N+) suppliers. We procure goods and services for
manufacturing our branded hardware products, our daily operations (e.g., employee
computers) and our resale program for goods manufactured by third parties, among otherprocurement categories. In FY23, our key direct hardware vendors manufactured goods
across China, Taiwan, the United States, Singapore, Poland, and Mexico.
Our hardware production relies on our global network of suppliers and partners. Avayabranded products are assembled, tested, and logistically managed by our key contract
manufacturing partners (our partners), who are wholly responsible for the production andsupport the logistics of our branded products. While we provide our partners with a list of
approved vendors determined based on quality specifications for key components of ourbranded products (e.g., displays), the contract manufacturers control the rest of thematerial inputs into our products.
In addition to our key contract manufacturers, we have a supplier network that we use to
procure our products that come from other large-name brands which we then sell as-is orre-brand with our name (e.g., servers), as well as smaller vendors who make small
products specifically for Avaya (e.g., a power adaptor). As with our partners, the suppliers
who we source smaller products or rebranded products control their own supply chain formaterial inputs. The finished products are then sent to our contracted warehouses where
they remain until distribution. We have warehouses in the United States, Germany, andnear Hong Kong.

Our Policies and Due Diligence Processes
Relating to Modern Slavery and Human Trafficking
Avaya has a longstanding commitment to ethical business conduct in our operations andsupply chains and is opposed to all forms of corruption and unethical business conduct. We
are committed to treating everyone who works at or with Avaya with dignity and respect.
We explicitly prohibit human trafficking and the use of any form of modern slavery within
our supply chain including forced, bonded or indentured labour, involuntary or exploitative
prison labour, and child labour.
We are an affiliate member of the Responsible Business Alliance (RBA), a nonprofit coalitionof electronics companies who are committed to supporting the rights and wellbeing ofworkers and communities in the global electronics supply chain. As RBA members, we

4Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

publicly commit to the organization’s Code of Conduct (the Code) and pursue its standards
through our operations and supply chain, including by implementing the Code’s principles
into our policies and processes. In addition to alignment with the Code, we have access to arange of RBA training and assessment tools to support the continuous improvement ofsocial and ethical performance in our supply chain.
Avaya’s policies and processes in relation to modern slavery and human trafficking include
the Human Rights Statement Supplier Code of Conduct (the Supplier Code), Responsible
Minerals Policy, and Conflict Minerals Report. As of May 2024, we are in the final stages ofdrafting and approving a human rights policy that articulates our overarching and ongoingapproach to human rights due diligence in line with the UN Guiding Principles on Businessand Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct.

Human Rights Statement
Our Human Rights Statement expresses our commitment to preventing the use of modern
slavery, and human trafficking in our operations and supply chains. The Human Rights
Statement is aligned with the Universal Declaration of Human Rights and is guided by the
RBA’s Code of Conduct.
Human Rights Due Diligence Processes
Per our Human Rights Statement, Avaya may take the following steps to identify risks andprevent modern slavery in our manufacturing supply chain and business operations:
1. Evaluate and address the risks of modern slavery in our operations and supply chainsby completing a Self-Assessment Questionnaire (SAQ) about our existing company
policies and procedures relative to RBA’s requirements; review Validated Assessment
Program (VAP) results that are available from our suppliers; and participate in the
RBA and Responsible Minerals Initiative (RMI) to obtain country of origin information
about conflict minerals in our supply chain.
2. Leverage the findings from the first step to identify suppliers who demonstrate
higher risks of modern slavery practices.
3. Engage with suppliers and, ultimately, reserve the right to terminate relationships
with suppliers who are non-compliant with the Code and with our own employees
and contractors who fail to comply with the established expectations.
4. Continuously engage with our sourcing and procurement colleagues on key humanrights topics.
Available RBA VAP reports for assessments conducted in 2022 and 2023 on companies
within our supply chain identified indicators of modern slavery (such as the payment of
recruitment fees and excessive working hours). We are engaging with external experts to
conduct additional due diligence of these companies to help us validate the findings andconfirm the existence of these risks at the facilities used by Avaya. We will continue toleverage our participation in the RBA to identify and manage these risks and engage with
our suppliers on their human rights management and compliance with the Supplier Code of
Conduct.

5Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Grievance Mechanism
As part of our ethics program, we operate an Ethics Helpline that reflects and embodies ourhigh standards of integrity and ethical conduct. Our ethics program is built on the principles
of prevention, detection and remediation and is a key component of our ability to identify
risks and take corrective measures when needed. Our Ethics Helpline ensures that ouremployees, customers, business partners, and suppliers can raise any concern – including
concerns relating to unfair labour practices and other indicators of modern slavery andhuman trafficking with us.
Associated Due Diligence Processes
All employees are encouraged to reach out to their managers or our Ethics & Complianceteam to make reports if they feel comfortable to do so. In addition, our Ethics Helpline isavailable to all Avaya stakeholders, including employees, business partners, our suppliers
and their employees, and local community members in which Avaya operates. Reports canbe made 24/7 via phone or online and are multilingual, non-retaliatory, and maintainanonymity for reporters. In addition to the helpline, we also offer local reporting options for
our EU-specific operations. This reporting information is accessible on our website andcommunicated to our suppliers via email when they are onboarded. We provide further
information on how we process reports in the below section on Access to Remedy.

Supplier Code of Conduct
Our modern slavery and human trafficking-related expectations are communicated tosuppliers through our Supplier Code of Conduct and Responsible Minerals Policy (seebelow). The Supplier Code is informed by the RBA’s Code of Conduct and includes provisions
on the prohibition of modern slavery and human trafficking, and other internationallyrecognized human rights and labour frameworks. Our suppliers are required to comply with
the Supplier Code. It is a contractual requirement written into every agreement we enter,and all new suppliers we onboard are required to review and agree to the Supplier Code.
The Supplier Code also requires that our suppliers establish a management system designed
to ensure their compliance with applicable laws and regulations, conformance with the
Supplier Code and the identification and mitigation of risks relating to the Supplier Code.
Associated Due Diligence Processes
Our Procurement team is responsible for managing our suppliers. We require all new
suppliers to complete a compliance questionnaire during onboarding. The questionnaire asks
suppliers about their geographic locations, goods and services, political exposure and antibribery and corruption processes. We use the Corruption Perception Index (CPI) to
determine if the supplier operates in a high-risk country and use a risk-based approach toensure higher risk vendors undergo further due diligence.
We also conduct bi-annual due diligence on a sample of approximately 25 existing suppliers
based on their risk profile (informed by annual spend, CPI, and the type of service
provided). We ask suppliers to complete a detailed compliance risk assessment and use an
external service to rank each supplier and prioritise high risk suppliers. High risk suppliers
complete an additional questionnaire which includes a question about the management and6

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

presence of modern slavery and human trafficking in their operations. High risk suppliers
are flagged to our legal representative in the area where the company operates and areconsistently monitored by the external service.
In general, Avaya only onboards one to two hardware suppliers per year at most. Vetting
and onboarding processes for new suppliers are primarily focused on financial and productquality, data privacy, and compliance risk. We aim to embed human rights and modern
slavery risks in these checks going forward.

Responsible Minerals Policy and Conflict Minerals Reporting
Our Responsible Minerals Policy formulates our commitment to responsible sourcing of“conflict minerals” including tin, tantalum, tungsten and gold (also referred to as 3TG)
among our supply chain and creates a framework for collaboratively working with our supply
chain to source minerals in a way that is consistent with our ethical values. The Responsible
Minerals Policy establishes suppliers’ responsibility to identify the sources of conflictminerals and declare the conflict mineral status of their products.
The Responsible Minerals Policy underpins the inputs into our annual Conflict Minerals
Report, which summarizes our due diligence processes for suppliers beyond Tier 1 who
source conflict minerals.
Associated Due Diligence Processes
While Avaya does not purchase minerals directly from the smelters producing the minerals,
many of our electronic hardgoods rely on 3TG. Our conflict minerals due diligence processaligns with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals
from Conflict-Affected and High-Risk Areas (OECD Guidance) five step framework (seebelow). The work is conducted in collaboration with the Responsible Minerals Initiative(RMI), a leading organization for advancing responsible conflict minerals supply chains. The
RMI’s conflict minerals work is underpinned by the Responsible Minerals Assurance Process(RMAP), which is a framework developed by the RMI to help companies ensure responsible
conflict minerals sourcing, particularly those from conflict-affected and high-risk areas.
To help advance the transparent sourcing of conflict minerals among our supply chain, weleverage three key elements of the program:
1. Determine product applicability
2. Conduct a reasonable country of origin inquiry (RCOI)
3. Initiate due diligence on relevant suppliers (determined by steps one and two)
The first element of the program, determining product applicability, involves generating alist of products and parts that were manufactured for Avaya, sold by us in the previous
year, and contain 3TG. If suppliers fulfill all of the three elements, they are considered inscope.
The list of in-scope suppliers is then sent a Conflict Minerals Reporting Template (CMRT)
which requests information about suppliers’ conflict minerals sourcing, including declarationof minerals in products and the product and smelter list. The RMI provides a list of known
smelters in the CMRT, which allows suppliers to identify their respective smelter supplier

7

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

and the smelter’s associated country of origin. In addition to the CMRT results, we also
leverage the RMI’s RCOI database to determine country of origin, as well as other publicly
available resources that identify origin countries like the London Bullion Market Association(LBMA) and the Responsible Jewelry Council (RJC). These inputs are reviewed to identify
suppliers that require additional information and further due diligence.
Upon identifying the suppliers who require additional information, we then apply the OECD
Guidance’s five-step framework:
1. Establish strong company management systems: Avaya communicates our
Responsible Minerals Policy to in-scope suppliers to ensure they are aware of their
obligations to comply with the full scope of expectations of the Policy and RMAP
procedures.
2. Identify and assess risks in the supply chain: We evaluate the RCOI database toassess whether our suppliers participated in the conflict minerals audit process. The
audit process validates or identifies non-compliance with the responsible minerals
sourcing standards.
3. Design and implement a strategy to respond to identified risks: We leverage
our close collaboration with the RBA and RMI to continue to access RMAP audits andaddress non-conformant supplier recommendations, including dis-engagement orsuspension.
4. Carry out independent third-party audit of supply chain due diligence at
identified points in the supply chain: Avaya utilizes the RMAP’s third-party audits
to identify social compliance risks along the conflict minerals supply chain.
5. Report on supply chain due diligence: We work with an external consultant to
prepare the annual Conflict Minerals report to document and disseminate our supply
chain due diligence activities.
We conduct this due diligence annually on our relevant suppliers, as our responsible
minerals work is our primary human rights due diligence mechanism. Although the RMAP
process does not solely focus on modern slavery in the conflict minerals supply chain, it
does contain multiple provisions for elements of modern slavery (namely, forced labour andchild labour). Below, we have outlined the key standards relating to the prevention of forced
labour and child labour that are reviewed as part of the RMAP process.
The RMAP’s Standards for Forced Labour and Child Labour
Forced Labour

Child Labour

A management system that prevents the use of any forms of forced
labour and participation in acts of human trafficking, including:•Documented policies prohibiting forced, bonded, indentured, andinvoluntary prison labour;•
Zero tolerance for requiring workers to pay employment or
recruitment fees;•
Contracts detailing the conditions of employment are provided in
the employee’s native language;•
Workers are provided a copy of their employment contract prior
to leaving their country of origin;•
The employment agreement is not changed unless changes areto meet local law and provide equal or better terms;•••

Documented policies banning the use ofchild labour;
Implementation of at least one of thefollowing (whichever is more stringent)oNational, subnational, or local legal
requirements for child labour; oroA management system that prevents
the employment of children under 15
and prevents exposure of employees
under the age of 18 to hazardous
working conditions.
Written policies and procedures for
remediation of child laborers that include

8Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

•
•
•
•

All work is voluntary and workers are free to leave at any time
without penalty, given reasonable notice as per the employment
contract;
Government-issued identification and personal documents are
not held by the employer, labor agent, or contractor;
Employers can only hold documentation if required by law, andemployees cannot be denied access to their documents; andThere are no unreasonable restrictions on the movement ofworkers and their access to basic liberties.

•

adequate financial and other support toenable children to attend and remain inschool; andEstablished procedures ensuring young
works are subject to compulsory education
laws and they only work outside of school
hours.

Our Risk Context
Modern Slavery and Human Trafficking Risks
Due to the nature of our work in the technology industry, we recognise that elements of ourdirect operations and supply chain may carry risks of modern slavery and human trafficking,including (1) our extended supply chain, (2) our use of third-party / labour recruitment
agencies and (3) our outsourced labour functions.
We have assessed that our hardware activities carry the greatest risk of modern slavery andhuman trafficking. In particular, the use of conflict minerals in our hardware products is asalient risk. As such, much of our due diligence on these risks relates to our upstream
supply chain.

Supply Chain Risks
Modern slavery and human trafficking are salient issues in the electronic manufacturingsector, particularly in China, a leading electronics exporter to Canada and the United States.
Child labour is a frequent occurrence, particularly in electronics that use raw materials likecobalt and mica. Children are reported to work in hazardous mining conditions in Africa(e.g., cobalt), Asia, and Latin America (e.g., mica). Both raw materials are essential inputs
for most electronic products.
Our Supplier Code of Conduct is the cornerstone of our efforts to mitigate these risks. The
Supplier Code is embedded in our contractual agreements with suppliers, and it prohibits
the use of modern slavery and human trafficking and requires the respect of otherinternationally recognized human rights and labour rights frameworks. Through ourcontractual agreement with suppliers, we reserve the right to make unannounced audits toensure the Code is respected. Similarly, our conflict minerals due diligence aims to identify
and address the known modern slavery hazards in the 3TG supply chain.
Tier N+ Supply Chain
We rely on our two main contract manufacturing partners (our CMs) for the development of
our hardware. Our CMs are charged with the sourcing, assembly, testing, and logistics of
Avaya’s hardware products. We regularly visit our CMs to assess their processes and thequality of the products.
Limited transparency into supply chains beyond Tier 1 suppliers carries risks of modern
slavery and human trafficking. In addition to the previously identified factors withinelectronic manufacturing supply chains, these supply chains are highly competitive, which
can cause companies to seek cheap – often exploitative – labour to fulfill demands or to9Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

outsource labour to unscrupulous third-party manufacturers. Many electronic manufacturing
facilities are also located in regions that have weaker labour laws and inadequate
enforcement mechanisms, which makes it easier for exploitative work to occur.
We acknowledge the importance of understanding the complete supply chain and its
associated risks. To address this, we are working with external expert advisors to expand
our management of human rights risks relating to our contract manufacturing operations
and our wider supply chains.

Operational Risks
We aim to mitigate the risks of labour exploitation to our direct employees by conducting
extensive background checks on every employee we hire in all of our geographies. Our
Ethics Helpline and internal grievance processes also help us identify and address risks oflabour exploitation towards our employees. Although we have a number of mechanisms for
managing the risk of modern slavery and human trafficking in our activities, such as our
Supplier Code of Conduct, we are aware of key inherent risk factors within our operations
which include third-party labour providers, contractors and outsourced labour.
Contracted and Outsourced Labour
We employ contract labourers to fill multiple functions, particularly during major hiring
initiatives or to fill skills or position gaps at Avaya. We currently employ 3,757 contractors in
43 countries which includes both high-risk and lower-risk geographies 8, with the highest
geographic concentration in India (1,164 workers). Our contractors are primarily high-skill
workers, which minimizes the risks of modern slavery and human trafficking. However, welargely rely on third-party labour providers to oversee the workers, meaning that we do nothave control over the contactors’ employment conditions. The lack of oversight, while low
because of the nature of employment, does mean that contract / temporary workers may
still be vulnerable to labour exploitation due to job insecurity, limited legal protections,precarious work arrangements, and limited representation or access to rights.
Similarly, Avaya outsources labour for human resources, call centers, transportation,cleaning and building maintenance, and warehousing functions. The outsourced labor ismanaged entirely by the third-party entities and our reduced oversight of these workers’
contracts and conditions limits our leverage to mitigate risks of modern slavery and humantrafficking. We are actively working with external experts to identify areas for improvementof our management of risks affecting these workers.

8
The complete list of countries that we employ contract labour includes: Argentina, Australia, Austria, Brazil,
Canada, China, Colombia, Croatia, Czech Republic, Egypt, France, Germany, Greece, Hong Kong, Hungary, India,
Indonesia, Ireland, Israel, Italy, Japan, Kazakhstan, South Korea, Malaysia, Mexico, Netherlands, Philippines,
Poland, Portugal, Romania, Russia, Saudi Arabia, Singapore, South Africa, Spain, Taiwan, Thailand, Turkey,
Ukraine, United Arab Emirates, United Kingdom, United States, and Vietnam.

10Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Access to Remedy
Grievance Mechanisms
Avaya’s grievance mechanisms, managed by our Ethics & Compliance team, help us identify
breaches of our Code of Conduct in our operations and our supply chains, including risks
relating to modern slavery and human trafficking and provide an avenue for remedy.
When a report is submitted, it triggers an email alert to the Corporate Security, Compliance,and Legal teams who review the case. The investigation process can differ depending on thenature of the case, but we will typically start by reaching out to the reporter (via a tool thatmaintains confidentiality) to request additional details within the first 48 hours ofsubmission. Our investigations can include forensics, interviews, reviews, and other related
actions. Upon completion of the investigation, we either close the case due tounsubstantiated findings or take next steps to remediate the case, which differs dependingon the situation. All cases go through our Audit Committee and Board for process andfindings oversight. We aim to complete these processes and close a case within 60 days.
Our grievance mechanism has a set procedure for tracking relevant performance indicators.
We deliver quarterly reports to Avaya’s Audit Committee with data about the number ofcomplaints received, the types of complaints, and the resolution and management of cases,
among other data points. In addition to the quarterly presentation, we also post the reports
on our internal integrity website. We have never received a complaint about modern slavery
or human trafficking, and tracking this data is a key metric for the effectiveness of ourefforts to mitigate these risks within our operations and supply chains.

RBA Remediation Policy
As RBA members, our approach to remediating adverse human rights impacts, including
modern slavery and human trafficking, that we cause or contribute would be guided by the
RBA guidance. In line with our commitment to the RBA Code of Conduct, if modern slavery
or human trafficking (including the payment of recruitment fees) is identified in ouroperations we would provide remediation. The RBA’s remediation guidance is tailored to thespecific circumstances and needs of affected individuals and communities but is always
underpinned by addressing the root cause of the violation, mitigating the harm, andpreventing future occurrences.
As explained in the Human Rights Due Diligence section of this Statement, Avaya has
identified potential indicators of modern slavery and human trafficking in our supply chain.
We are still investigating these issues and as such have not taken any measures toremediate the potential impact of modern slavery, including the loss of income to the mostvulnerable families that result from measures taken to eliminate the practice. If we identify
actual human rights abuses or the presence of modern slavery and human trafficking, we
will follow the RBA’s remediation guidance and our commitment to the UN Guiding Principles
on Business and Human Rights.

11Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Consultation
For our first ever globally combined modern slavery Statement, Avaya did not consult withall controlled entities in its development. This is due to our corporate-level policies andprocedures representing the full scope of activities that occur for preventing modern slavery
and human rights in all our global operations. However, Avaya recognizes the need tocomprehensively consult with our controlled entities in the future to ensure our modern
slavery and human trafficking management procedures and disclosures are both effective
and representative of unique regional contexts. We are focused on developing better ways
to more meaningfully and frequently consult our controlled entities as we continue toadvance our human rights programs ahead of our second globally prepared Statement in
2025.

Looking Forward
Avaya aims to embody and promote ethical practices in all aspects of our business. While
we have implemented several risk management and due diligence initiatives for ensuringthat human rights are respected in our activities and supply chain, we acknowledge that
there is room for refinement and improvement. In light of this, we have a number of keyplans to continue advancing our human rights risk management processes across our value
chain.
First, we will continue to annually report on our conflict minerals supply chains. While weare no longer required to do so as a privately held company, we trust it is an important way
to continue promoting the procurement of ethical raw materials. 9 Similarly, our Ethics
Helpline offers stakeholders of our entire value chain access to a robust grievancemechanism, and we will continue to monitor and investigate the cases we receive throughthe helpline. This annual reporting helps us measure the effectiveness of our efforts to
reduce modern slavery and human trafficking within our raw material supply chain.
We are also in the final stages of expanding our existing Human Rights Statement into apublic facing policy that articulates our overarching and ongoing approach to human rights
due diligence in line with the UN Guiding Principles on Business and Human Rights and theOECD Due Diligence Guidance for Responsible Business Conduct. Additionally, we are
updating our company Code of Conduct to include references to human rights expectationsof employees, as well as rolling out new human rights training programs. We will be
leveraging our partnership with RBA to roll out a mandatory human rights training module
for our procurement and human resources team members, as Avaya employees currently
do not receive training related to modern slavery and human trafficking.

Before Avaya became a privately held company in May 2023, we were required to submit an annual conflictminerals report to comply with the Security Exchange Commission (SEC)’s Rule 13(p)(1) of the Exchange Act of
1934.
9

12

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Finally, we are engaging with external experts to conduct a gap assessment of our current
human rights management to identify areas of improvement and design a strategic
roadmap for how to do so. We aim to complete this workstream within the first half of 2024.

13

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Approval and Attestation - Canada
ApprovalThis Modern Slavery and Human Trafficking Statement (the Statement) has been reviewed
and approved by the Board of Directors of Avaya LLC, acting on behalf of Avaya LLC and on
behalf of its indirect, wholly-owned subsidiaries Avaya Canada Corp., Avaya Cloud Canada
Inc., and 3102455 Nova Scotia Company.

Attestation
In accordance with the requirements of the Canadian Fighting Against Forced Labour andChild Labour in Supply Chains Act (the Supply Chains Act), and in particular Section 11
thereof, I attest that I have reviewed the information contained in the Statement for theentities listed above. Based on my knowledge, and having exercised reasonable diligence, I
attest that the information in the Statement is true, accurate and complete in all material
respects for the purposes of the Act, for the reporting year listed above.
I have the authority to bind Avaya LLC.

Alan Masarek
Director, CEO & President of Avaya LLC
May 30, 2024

14

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Approval - UK
ApprovalThis Modern Slavery and Human Trafficking Statement dated May 2024 (the Statement) has
been reviewed and approved by the Board of Directors of Avaya UK as the UK trading
entity, and is applicable to the other UK incorporated Avaya group companies: Aurix Ltd.,
Avaya Capital Ireland (UK Inc.), Avaya ECS Ltd., Avaya International Holdings Ltd., Avaya
UK, Avaya UK Holdings Ltd., Esna Technologies Ltd., and Ubiquity Software Corp. Ltd.

[Signature]
Lee Hastings
Director of Avaya UK[Date] July 15, 202415

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Approval - Australia
ApprovalThis Modern Slavery and Human Trafficking Statement dated May 2024 (the Statement) has
been reviewed and approved by the Board of Directors of AVAYA AUSTRALIA PTY LTD.

[Signature]
Patrick Richard John Stevens
Director of Avaya Australia PTY LTD[Date] July 10, 2024

16

Docusign Envelope ID: 68A2658C-F1D1-4BAB-B539-4D509733CFFA

Appendix 1: Mapping of Sections to Laws
Page

Canadian Forced &Child Labour
Prevention Act 2023
Part 2

UK Modern Slavery
Act 2015
Part 6Australian Modern
Slavery Act 2018
Part 2Introduction

2

11.2

Our Business

2-4

11.3(a)5(a)16.1(b)Our Policies
and Due
Diligence
Processes

4-9

11.3(b)5(b), 5(c)16.1(d)Our Risk
Context

9-1011.3(c)5(d)16.1(c), 16.1(d)Access to
Remedy(incl. Assessing
Effectiveness)

10-11

11.3(d), 11.3(e),11.3(g)5(d), 5(e)16.1(d), 16.1(e)Consultation

11

Looking
Forward (incl.
Training)

1211.3(f)5(f)16.1(g)Approval andAttestation

13-16

11.4(b), 11.5(b)

6(a)

16.2

16.1(a)16.1(f)17