CODE OF CONDUCT
2024

Code of Conduct

Table of Contents
Foundation of Our Code��������������������������������������������������������������������������������������������������������������������������� 3
CEO Message������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������ 3
Our Vision and Mission������������������������������������������������������������������������������������������������������������������������������������������������������������������� 4
Corporate Values����������������������������������������������������������������������������������������������������������������������������������������������������������������������������� 5
Ethical Decision-Making������������������������������������������������������������������������������������������������������������������������������������������������������������������ 6

Building Trust with Each Other���������������������������������������������������������������������������������������������������������������� 8
Speaking Up/Anti-retaliation Policy����������������������������������������������������������������������������������������������������������������������������������������������� 8
Investigation Process���������������������������������������������������������������������������������������������������������������������������������������������������������������������� 9

Preventing Harassment���������������������������������������������������������������������������������������������������������������������������������������������������������������� 10
Diversity, Equity, Inclusion and Belonging�������������������������������������������������������������������������������������������������������������������������������������� 11

Building Strong Relationships���������������������������������������������������������������������������������������������������������������� 12
Gifts and Entertainment��������������������������������������������������������������������������������������������������������������������������������������������������������������� 12
Conflicts of Interest����������������������������������������������������������������������������������������������������������������������������������������������������������������������� 15
Anti-bribery and Anti-corruption������������������������������������������������������������������������������������������������������������������������������������������������� 16
Antitrust/Competition������������������������������������������������������������������������������������������������������������������������������������������������������������������ 17
Data Privacy����������������������������������������������������������������������������������������������������������������������������������������������������������������������������������� 19
Third Party and Business Partners����������������������������������������������������������������������������������������������������������������������������������������������� 20
Working with the Government����������������������������������������������������������������������������������������������������������������������������������������������������� 21

Protecting the Company������������������������������������������������������������������������������������������������������������������������ 22
Financial Reporting����������������������������������������������������������������������������������������������������������������������������������������������������������������������� 22
Intellectual Property��������������������������������������������������������������������������������������������������������������������������������������������������������������������� 23
Confidential and Proprietary Information������������������������������������������������������������������������������������������������������������������������������������������������24
Insider Trading������������������������������������������������������������������������������������������������������������������������������������������������������������������������������� 25
Cybersecurity��������������������������������������������������������������������������������������������������������������������������������������������������������������������������������� 26
Acceptable Use Policy������������������������������������������������������������������������������������������������������������������������������������������������������������������� 27
AI Policy������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������������ 28
Records Management������������������������������������������������������������������������������������������������������������������������������������������������������������������� 29
External Communication and Social Media�������������������������������������������������������������������������������������������������������������������������������� 30
International Trade����������������������������������������������������������������������������������������������������������������������������������������������������������������������� 31

Supporting Our Communities���������������������������������������������������������������������������������������������������������������� 32
Environmental Sustainability������������������������������������������������������������������������������������������������������������������������������������������������������� 32
Safe and Healthy Workplace�������������������������������������������������������������������������������������������������������������������������������������������������������� 33
Charitable Activities���������������������������������������������������������������������������������������������������������������������������������������������������������������������� 34
Political Involvement�������������������������������������������������������������������������������������������������������������������������������������������������������������������� 35
Human Rights�������������������������������������������������������������������������������������������������������������������������������������������������������������������������������� 35

Closing Thoughts����������������������������������������������������������������������������������������������������������������������������������� 36© 2024 Avaya LLC. All Rights Reserved.

2

Code of Conduct

Foundation of Our CodeCEO Message

The world’s largest brands and government agencies trust and rely on
Avaya to deliver customer and employee experiences that create
tangible value and business growth. We understand that trust is not
something that is simply given; it is earned through consistent actions,transparent communication, and acting with the highest levels of
integrity. It is earned through the daily actions of every Avaya teammember.

We believe that our commitment to transparency, accountability,and ethical business practices not only fosters trust, but it also provides
one of our greatest competitive advantages.
While our teams put our full focus on meeting (and exceeding) our
business objectives—and helping our customers to do the same—
we are also adamant about doing business the right way, aligned with
our values, and in a manner that further builds trust.

This is where our Code of Conduct comes in. It provides the frameworkfor our decisions and actions, and offers resources for asking questions
and getting assistance when needed. It is the basis for holding eachother accountable for making the right decisions, for the right reasons—and for following all applicable laws, rules and regulations.
Trust truly is the foundation for business success, and by taking
accountability in following our Code of Conduct, we commit to earningand maintaining the trust of all our stakeholders, each and every day.

Patrick Dennis
Patrick Dennis
Avaya Chief Executive Officer© 2024 Avaya LLC. All Rights Reserved.

3

Code of Conduct

Our Vision and Mission
VisionTo reimagine the ways people and businesses engage and experience the world.

MissionWe help organizations drive business momentum by creating unforgettable customer andemployee experiences.

About Avaya

Businesses are built by the experiences they provide, and every day, millions of those experiences are deliveredby Avaya. Organizations trust Avaya to provide innovative solutions for some of their most important ambitions
and challenges, giving them the freedom to engage their customers and employees in ways that deliver thegreatest business benefits.

© 2024 Avaya LLC. All Rights Reserved.

4Code of Conduct

Corporate Values

Avaya is committed to fostering a culture in which

each of us demonstrates the following three valuesin every interaction – with customers, partners,

suppliers, colleagues, community members, and otherstakeholders. We firmly believe that a culture that

embodies these values will drive the business forward
and better enable Avaya to service customer needs
and address customer challenges.

At Avaya We Value

Innovation Every Day

Innovation can be both large
and small, and persistent

Optimism That’s Contagious
The timing is right for us tocreate a groundswell

Leading With Trust

The position of leader is toextend and establish trustIf creativity is thinking new

Optimism is a positive force.

When we extend trust andthem. It is part imagination andfor us to really drive change.

can be trusted, everything falls

things, then innovation is doingpart engineering. And we don’t

stop until we solve the problem.
Innovation doesn't have to beradical or disruptive; or be as big
as what you think it is. And it's
not just about R&D.

It’s about thinking and thendoing — change a process, createa prototype, zig when others

zag — to put us on a different

trajectory and positively impact

It creates the right environment
It is finding joy in the challenge.
And having the belief to saythat “today is the day” we makethings better than ever before.

You will find optimism is also amagnet. It draws people in andmakes them believers, too. When
we choose to be optimistic,
it becomes widespread.

demonstrate that we, ourselves,
into place behind it: our behavior,
our relationships, our reputation,and our brand.

Ours is a culture of trust andaccountability. It is felt fromour leadership down to thefront lines. The integrity of ourorganization is magnified bypeople that trust one anotherand trust in themselves.

our company and our customers.

© 2024 Avaya LLC. All Rights Reserved.

5

Code of Conduct

Ethical Decision-Making

We make thousands of decision every day and generally we know thedifference between right and wrong, but it may not always be that

simple. We may be presented with an action where the “right thing
to do” may not be as clear. Conflicting priorities, such as choosing

between personal gains versus the right decision for the company,

may be a challenge to our judgement. Consider asking yourself thesequestions when faced with a difficult decision:

Policies

Laws

Does the action align with

Avaya’s Code, policies andIs the action legal?

procedures?

Ethicsy Is the action ethical andsocially responsible?

y Would my family, friends

and community approve?

Community Standardsy Is the action in the bestinterest of our employees
and customers?

y Would the action withstandpublic scrutiny?

Our Code. Our Responsibilities.

Complying with the Code and, by extension, Avaya policies, furthers our commitment to conduct business ethically andensures that each of us, as well as Avaya, complies with applicable laws and regulations. Violations of the Code, any Avaya
policy or applicable law will be subject to discipline, up to and including dismissal. Certain violations of the law may also
include fines, prosecution and prison sentences.
Responsibilities:

Comply with theRead and

understandthe Code.

Code, including
with all Avaya
policies, toensure ethicalconduct that

also complies

with local laws.

© 2024 Avaya LLC. All Rights Reserved.

Reportmisconduct

and raise issues
or concerns
without

Cooperate

fully with any

investigations

fear of retaliation

with respect tothe available

concerns.

through any ofchannels

allegations or

Ask questions if
you are unsure

about any aspectof the Code or

Avaya policies.

described below.

6Code of Conduct

Responsibilities for Managers:

We are each responsible for exhibiting ethical behavior andestablishing a culture where concerns and questions can be raisedand discussed by doing the following:

Be a role model

Recognize ethicalfor ethicalbehavior.

behavior.

Listen to employees when

Do not allow
retaliation.

Establish a culture where

issues are raised andconcerns can be raised andengage the appropriate

discussed.

support as needed.

Who Should Follow the Code?

The Code applies to all individuals who work for or represent Avaya, including:

Employees

Officersy Business Partners
Third Partiesy Distributors
y Suppliers

y Sales Agentsy Consultants© 2024 Avaya LLC. All Rights Reserved.

Directors

Subsidiaries­Contractors

All third parties are expected to abide by the guidelines within

the Code, the terms of their agreements with Avaya and each of
Avaya’s Channel Partner Code of Conduct and Supplier Code of
Conduct, as applicable.

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Code of Conduct

Building Trust with Each Other
Speaking up/Anti-retaliation Policy

We understand that coming forward to report misconduct
may not be easy. While we recognize that, we both expect

and empower you to do so. No issue is too small. If you feelsomething is being done in a manner that is unethical or in

violation of the Code, Avaya policies, or applicable laws, it isyour responsibility to report. Avaya will not retaliate against
anyone who makes a report in good faith. Employees can
submit reports utilizing one of several channels:

Direct manager

Leadership

Reports can be made anonymously using Avaya’s
Human Resources

Legal teamconfidential helpline which can be accessed throughthe following means:y In the U.S.: 1-877-99-ETHIC (1-877-993-8442)
y Outside the U.S.: +1-908-953-7276
y Via the Convercent website

Ethics andIntegrity Team

Avaya’s confidential
helpline

Employees are encouraged, but not required, tosubmit reports to their managers in the first instance.
If you feel that your concern has not been addressed,
please reach out to the Ethics and Integrity Team.

What is Retaliation?

Retaliation can take many forms, some subtle and some more direct. Any of the following actions taken as “punishment” forspeaking up or participating in an investigation could be instances of retaliation: threatening, bullying or belittling, suspension,
demotion or termination, denial of benefits, denial of raise or bonus, negative performance reviews (when not warranted);or removal from any key accounts or projects.
No Retaliation

Avaya has a zero-tolerance policy when it comes to retaliation in relation to anyone who brings forth a concern in good faith, even

if it later turns out to be unsubstantiated. If you believe you have been retaliated against, reach out to the Chief Compliance Officer.

Anyone who has been found to have retaliated against someone who raises a concern will be subject to appropriate discipline, up to
and including termination.

© 2024 Avaya LLC. All Rights Reserved.

8

Code of Conduct

Investigation Process

What Happens After I Make a Report?

No matter who you contact or which resource you use to report a concern, rest assured that it will be promptly reviewed andinvestigated in accordance with our policies and investigation taxonomy. You will have the option to provide your name andcontact information, or you can choose to remain anonymous, where permitted by law. During the investigation process,we listen for understanding and assume positive intentions.

You are required to fully cooperate with investigations and truthfully comply with all requests for information, interviews or
documents. Anyone who fails to cooperate with the investigation will be subject to appropriate discipline.

You may raise a question, issue, or concern throughany of the available reporting channels.

Reports will be kept confidential. You may choose toContact

report concerns anonymously.

Reports are typically reviewed within 24 - 48 hours
of receipt.

Your question, issue, or concern will be directed to

Review

the appropriate group(s) depending on the nature of
the situation.

You may be contacted by an investigator so that more
information can be gathered about your report.

Investigations usually take time, and even though

Investigation

you may not receive updates, it doesn’t mean there

is no progress. You are always welcome to reach out
to follow up.

When possible, you will receive an update that thereport was investigated and action was taken.

However, due to privacy and confidentiality concerns,

Closureyou may not receive any additional information about
the outcome of an investigation.

All reports are taken seriously and investigated. We seek to maintain confidentiality during the course of any investigation
where allowed by law. To respect the individuals involved in any investigation and to further maintain confidentiality,
information regarding investigation status, findings and results are not shared with reporters.

© 2024 Avaya LLC. All Rights Reserved.

9

Code of Conduct

Preventing Harassment

Harassment is any verbal, written or physical act, gesture, or object that is directed or used in such a manner as to affect or

impede an employee’s professional performance, or to create a hostile or offensive work environment. Harassment singles out
an employee because of the employee’s race, color, sex, sexual orientation, gender identity or expression, religion, national

origin, medical condition, ancestry, ethnicity, citizenship, age, marital, civil union or domestic partnership status, physical ormental disability, genetic information, past or present military status or protected veteran status or any other status protectedby the laws or regulations in the locations where we operate.

Speak up if you suspect discrimination
Showing

Accountability andTrustworthinessor harassment using one of the reporting
options in this Code.

Never make offensive or sexual advances,

comments, jokes, gestures or references at

Encourage a work

environment free fromharassment, bullying,
discrimination, andabusive behavior.

work or in any work-related communication.

Additional Policies and Resources

Global Harassment Prevention Policy© 2024 Avaya LLC. All Rights Reserved.

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Code of Conduct

Diversity, Equity, Inclusion, and Belonging

Avaya is an equal opportunity employer and promotes the richness of cultures, perspectives, experiences and skills
to work as one global community. We drive and maintain a clear Diversity, Equity, Inclusion, and Belonging (DEI&B)
strategy that is focused on building a workplace of the future that resembles the society in which we do business.

Diversity and the equal opportunity it facilitates are fundamental to our corporate values and promotes a place whereindividuality is celebrated, creating a culture of engagement, innovation, and inclusivity. It also makes Avaya morecompetitive in the marketplace.

Showing

Support Avaya’s equal opportunity policies.

Team or the Ethics

and Integrity Teamif you encounter a

Accountability andTrustworthiness

Consult with the Legal

If you are a supervisor, team leader or in aposition of authority, discuss this material
with your employees.

conflict between Equal

Opportunity Policy andlocal laws, customs orpractices.

Q: A team member was overheard telling a racial joke about their own family. It was offensive. What should you do?
A: Inappropriate comments, even when someone makes them about themselves, are inconsistent with Avaya’s

Corporate Values and are not acceptable. You are encouraged to bring this to the attention of Human Resources ormanagement or make a report to Avaya’s confidential helpline.

Q: You were uncomfortable with a comment made at your last staff meeting, but you didn’t want to talk to anyone andget labeled as a troublemaker. What should you do?

A: You can contact Avaya’s anonymous confidential helpline. All reports made in good faith are investigated.
Additional Policies and Resources

DEI&B Portal | Human Resources Policy Guide© 2024 Avaya LLC. All Rights Reserved.

11

Code of Conduct

Building Strong Relationships
Gifts and Entertainment
Our Policy

As a general rule you can accept a meal, gift or entertainment from non-government customers, suppliers or business partners if it is unsolicited,
inexpensive and not given to influence business decisions.

Similarly, employees may provide reasonable meals, gifts or entertainment to
non-government customers, suppliers or business partners provided that itis related to proper business purposes, is not offered to influence a businessdecision, and is permitted under applicable laws and Avaya’s Travel andEntertainment policy.

Gifts are often exchanged
as a part of business
relationships. Often these
consist of Avaya branded
items or other non-lavish
items consistent withlocal norms.

The graphic below provides guidance for necessary approvals for gifts and entertainment:

Non-Lavish Gifts (less than $100 USD)

and/or Entertainment (less than $250 USD)

Written approval from your direct manager

Lavish Gifts (more than $100 USD) and/orEntertainment (more than $250 USD)

Written approval from (i) your direct manager
and (ii) the Chief Compliance Officer(Convert USD to local currency)© 2024 Avaya LLC. All Rights Reserved.

12

Code of Conduct

Please note the following guidelines apply to all gifts,
entertainment or other advantages:

y Cash or cash equivalents are not acceptable forms of gifts inany circumstance.

y Gifts should not be lavish.

y Permissible gifts must be given with complete transparency
and accurately reflected in Avaya’s books and records
through appropriate receipts and documentation.

y Gifts, meals and entertainment for officials and employeesof governments (including government owned entities),in every country around the world, are highly regulated andoften prohibited and must be reviewed in advance by the
Ethics and Integrity Team.

y All travel for customers, partners, press or suppliers must bein accordance with Avaya’s Travel and Expense policy andreviewed in advance by the Ethics and Integrity Team.

Showing Accountability and Trustworthiness

Do not provide or accept gifts, entertainment or other favors of the type or amount that go beyond common courtesies
consistent with ethical and accepted business practices.

Do not use third parties such as partners, suppliers or family members to provide gifts, entertainment or favors.
Gift Receiving

y You can accept a gift, meal, entertainment orother favor from non-government customers,

partners or suppliers, provided it is unsolicited,reasonable and not given to influence yourjudgment. In other circumstances, you should
decline and explain Avaya’s policy.

y Before accepting a gift, an invitation for a mealor entertainment, or other favors that seemlavish or excessive, consult your supervisor
or email the Ethics and Integrity Team.

Gift Giving

Employees may provide reasonable gifts, entertainment,

meals or favors to non-governmental customers, partners,
or suppliers provided that:y You are not asked to provide it.

y It is not being offered to influence the recipient’s
business decision.

y It is permitted under applicable laws, regulations, rules,
and consistent with ethical and accepted businesspractices.

y It is consistent with Avaya’s policy.

© 2024 Avaya LLC. All Rights Reserved.

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Code of Conduct

Recognition Gifts

Knowledge Tip

Human Resources before presenting any

Team regarding the following:

Supervisors and employees must consult

Consult with your supervisor and the Ethics and Integrity

gift or other form of recognition to Avaya

employees to ensure compliance with Avaya’s
recognition policy.

y Golf outingsy Tickets to events such as concerts, sporting events ortheater showsy Trips to resorts

y Gifts for you and your family

Q: What is the difference between a gift and business entertainment?

A: Business entertainment can entail dinners, sporting events, trade shows or other customer events at which

representatives of both parties are generally in attendance and business is typically discussed. A gift is something given or
received, such as tickets for an event at which representatives of the organization extending the gift are not in attendance.

Q: A customer asks me to obtain four tickets to a large sporting event and hints that this will close the sale more quickly.
Can I buy the tickets?

A: This potential scenario raises a number of concerns. First, a gift cannot be solicited. Second, four tickets to an event
is considered lavish. Third, the facts do not suggest that a business conversation or product demonstration would betaking place.

Q: A supplier invites me to a sporting event that it is hosting with other customers, offering an opportunity to meet its
leadership and discuss business relationships. Can I go to the game?

A: You need to obtain approvals IN WRITING based on the Gifts and Entertainment approval matrix and its thresholds
prior to attending.

Additional Policies and Resources
Gifts and Entertainment Policy© 2024 Avaya LLC. All Rights Reserved.

| Travel and Expense Policy| Recognition Policy

14

Code of Conduct

Conflicts of Interest
Remember: Make decisions in the best interest of Avaya. Avoid conflicts of interest or even the appearance of a conflict.

Our Policy

Avoid situations in which your personal interests might conflict, or appear to conflict, with the interests of Avaya.

Conflicts of interest may arise when your financial or other outside interests produce conflicting loyalties, interfere with yourjob performance, or are potentially adverse to the interests of Avaya.
Showing Accountability and TrustworthinessYou should avoid even the appearance of a potential conflict of interest.

Prior to hiring, promoting or directly supervising a family member, close friend or someone with whom you are in a
relationship, you must obtain the approval of your manager, Human Resources and Legal.

Potential conflicts can easily be avoided or addressed if they are promptly disclosed and managed accordingly. Employees areencouraged to use the Conflicts of Interest questionnaire for the Ethics and Integrity Team to review the potential conflict.
Situations where conflicts may arise:y Outside activities: Work that interferes with your work at Avayay Membership on outside Board of Directors of companies ororganizations we do business withy Financial Interest of third parties with whom we do businessy Hiring / doing business with family membersy Personal relationshipsy Business opportunities
Q: A product manager would like to make an investment that would make him a controlling stockholder in a competitorof Avaya. Is this a conflict of interest?

A: Yes, the proposed investment would make him the owner of a business that competes with Avaya.

Q: Your spouse has accepted a position at a business partner that Avaya does business with. Do you need to report this?
A: Yes, most conflicts of interest can be eliminated by disclosing them and making sure steps are taken to prevent yourinterests from conflicting with Avaya’s.

Additional Policies and Resources
Conflicts of Interest Policy| Conflicts of Interest Questionnaire

Guidelines for Membership on Outside Board of Directors© 2024 Avaya LLC. All Rights Reserved.

15

Code of Conduct

Anti-Bribery and Anti-Corruption
Remember: Do not offer bribes, accept bribes or let others offer or accept bribes for you. Do not make any kind offacilitation payments.
Our Policy

Avaya prohibits giving or offering of anything of value to anyone to improperly:
Influence any decision that
impacts Avaya

Obtain or retain businessfor Avaya

Secure any businessadvantage for Avaya

Avaya also prohibits facilitation or grease payments, which are payments made directly to government officials designed to speed
up routine government processes or activities. Generally, facilitation payments are made in cash and to a person. Please note that
expediting fees that are published and universally available are not deemed facilitation payments and are acceptable.

Avaya also prohibits commercial bribery, which violates the laws of many countries (e.g., UK Anti-Bribery Act, US Foreign Corrupt
Practices Act). Any bribe or improper payment to current or prospective customers, including, but not limited to, government
officials, or suppliers could subject you to consequences beyond disciplinary action by Avaya, such as prosecution.

Prevent bribery by others who conduct business on our behalf by complying with the processes established to ensure that

we know the third parties with whom we are engaging in business, understanding the scope of each transaction and ensuring
discounts are passed down to the appropriate end customer.
Showing Accountability and Trustworthinessy Never give anything of value to influence a decision or obtain improper business.
y Follow the corporate gift giving guidelines.

y Do not donate Avaya funds to political entities.

y Notify the Ethics and Integrity Team if you are being directed to use a specificconsultant by a government employee, business partner, or supplier.

y Follow company guidelines for engaging partners, suppliers, and consultants.
Q: The Finance department manager needs to take an international business trip on short notice to conduct businessin person; however, she needs a visa to do so. The manager’s assistant learns that the process of obtaining a visa takes
longer than she’d anticipated, and now she’s looking for a way to expedite the process. What should she do?

A: In many cases, the office, agency, or department you are working with will offer an expedited service at a set andpublished fee schedule. Payment of this fee may be allowed under our policy. However, if you are asked to make afacilitation payment, seek guidance from the legal department. Facilitation payments are illegal under numerous
international anti-corruption laws and prohibited under Avaya policy.
Additional Policies and Resources
Anti-Bribery/Anti-Corruption Policy© 2024 Avaya LLC. All Rights Reserved.

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Code of Conduct

Antitrust/Competition
Remember: We abide by the law and are committed to doing business fairly with our partners, suppliers, and competitors.

Our Policy

We compete aggressively for business while maintaining high ethical standards. We comply with the Code, our Avaya policies
and applicable laws, regardless of how competitive the environment is.

We do not engage in anti-competitive practices such as price fixing, bid rigging, or dividing of territories.

We do not obtain competitive information through improper means such as deception, the misuse of a business relationship,
or from non-public sources such as former colleagues that work at competitors.
Showing Accountability and Trustworthinessy When you interact with customers, provide only truthful information about the quality, features and availability of our
products and services, and don’t make disparaging remarks about our competitors.

y Compete vigorously but deal fairly with our customers, business partners, suppliers, and competitors.
y Do not talk about our business strategies and plans with competitors and vice versa.

© 2024 Avaya LLC. All Rights Reserved.

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Code of Conduct

y Never enter into any agreement or understanding,whether formal or informal, with a competitor, customeror supplier to:▪ Raise, set or hold or otherwise fix prices on our products▪ Divide territories, markets or customers▪ Prevent another company from entering the market▪ Refuse to deal with a customer or supplier▪ Interfere with the competitive bidding process▪ Agree to discounts inconsistent with established policies▪ Discuss customer relations with competitors

y Avoid contact with competitors that could create theappearance of impropriety, such as when attending tradeshows or industry events.

y Obtain and share information ethically.

y Seek competitive information from public sources.

y Be fair, factual and complete in our advertising, sales andpromotional materials.

It is acceptable to maintain relationships with employees thatwork at competitors but important that these relationships are
not used to obtain proprietary information.

Q: A colleague who formerly worked at a competitor offers to provide the price lists from the competitor that were taken
just before the colleague resigned. What do you do?

A: You cannot use this information and you should contact the Ethics and Integrity Team.

Q: You are at a trade show and a competitor approaches you about dividing up territories and contract bids, so you canboth more easily hit your quota. How do you respond?

A: You need to immediately end the conversation and contact the Ethics and Integrity Team. This person has engaged
in anti-competitive behavior that can result in steep fines.
Additional Policies and Resources

Antitrust/Competition Compliance Policy© 2024 Avaya LLC. All Rights Reserved.

| Competitive Information and Comparative Claims

18

Code of Conduct

Data Privacy
Our Policy

How we handle the personal data entrusted to us by our customers, partners, suppliers and colleagues is critical to our
success. It is our policy to only gather information we need and to be transparent regarding the reasons for gathering suchinformation and our intended uses.

We only keep personal data if legally required and we respect the right of the individual to know what information we have,what we do with it, and when legally allowed, we will honor their right to be forgotten.
Showing Accountability and Trustworthinessy Familiarize yourself with our privacy policies.

y Familiarize yourself with our data classification and data retention policies and be careful to follow the policy, retaining
only the personal data required to be maintained.

y Be aware of the proper methods for handling and securing personal information.

y Seek guidance from the Data Privacy Team if you are unsure by emailing dataprivacy@avaya.com.

Additional Policies and Resources
Global Data Privacy Policy© 2024 Avaya LLC. All Rights Reserved.

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Code of Conduct

Third Party and Business Partners
Remember: Make decisions in the best interest of Avaya. Avoid conflicts of interest or even the appearance of a conflict.
Our Policy

At Avaya, we do business with organizations that meet or exceed our ethical standards. We select the third parties with whom wetransact business carefully and ensure they meet our requirements, abide by applicable law, follow the principles of the Code andAvaya policies. A third party’s conduct and reputation for service and integrity should reflect positively on our company. We selectsuppliers objectively based on merit, not on reciprocity or quid pro quo arrangements.

We perform due diligence on third parties with whom we seek to transact to ensure they act ethically and handle information
in a manner that would be acceptable under Avaya policies. Suppliers and business partners must abide by the guidelines
within the Code, terms of their agreements, and each of Avaya’s Channel Partner Code of Conduct and Supplier Code of
Conduct, as applicable.
Showing Accountability and TrustworthinessAvaya employees working with third parties such as suppliers, consultants, agents, sales representatives, business partners,
distributors and independent contractors must:y Follow all on-boarding procedures for suppliers and business partners.

y Monitor your suppliers and partners to ensure they are meeting their commitments and acting ethically.
y Engage the appropriate resources if you identify performance issues with your partner or supplier.

Additional Policies and Resources

Supplier Code of Conduct | Avaya Channel Partner Code of Conduct | Avaya Vendors Security Review© 2024 Avaya LLC. All Rights Reserved.

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Code of Conduct

Working with the Government
Our Policy

Activities that might be appropriate when working with private sector customers may be improper or even illegal when dealing
with government customers.

Those who work with government customers, be they local, state, federal or state-owned/controlled, in any country, or who
otherwise interact with government employees, are expected to follow all procurement, hospitality and entertainment,anti-bribery, anti-corruption and other applicable laws and requirements. Failure to comply with these requirements may
result in severe penalties, including potential civil and criminal fines, imprisonment and Avaya’s debarment from doing
business with the government.

Showing Accountability and Trustworthiness

Except in very limited circumstances and as otherwise permitted by law or regulation, you are prohibited from providing or

paying any gratuity or anything of value, including meals, refreshments, entertainment, travel and lodging expenses, directly or
indirectly to or for the benefit of a government employee or representative. For more specific guidance, consult Avaya’s Policy

for Working with the U.S. Government or a member of the Legal Team for specific guidance when dealing with any government.

Additional Policies and Resources
Global Trade Compliance Policy

Anti-Bribery/Anti-Corruption Policy

Policy for Working with the U.S. Government© 2024 Avaya LLC. All Rights Reserved.

21

Code of Conduct

Protecting the Company
Financial Reporting
Our Policy

Integrity in our recordkeeping inspires trust by our customers,

partners, suppliers, colleagues, investors and other stakeholders.
We prepare timely, accurate and complete financial information

for use in reports to management, investors, regulators and otherstakeholders.

Showing Accountability and Trustworthiness

Each of us has an obligation to follow all internal controls in recording and maintaining our company books and records.
y Maintain effective processes and internal controls thatfairly reflect transactions or events in a timely manner, as
well as prevent or detect inappropriate transactions.

y Follow the appropriate Schedule of Authorizations andy Take the time to review and verify that documents you
approve are factual and accurate.

y Know your customers and partners and understand theiruse of our products and data to prevent illegal activity.

obtain all necessary approvals for business transactions
and expenses.

Watch for and report signs of potential fraud, bribery,tax evasion or money laundering activity.

y Be honest, accurate and complete when preparing any

y Observe both the form and spirit of technical accountingy Never sign or enter into side agreements.

y Seek the advice of your controllership team if you

business documents.

y Never engage in inappropriate transactions thatmisrepresent the reporting of other parties, such as
customers or suppliers.

y Never engage in tax evasion or facilitate anyone else inengaging in tax evasion.

and ethical standards.

become aware of a questionable transaction.

y If you identify transactions that are questionable

immediately notify your manager, controller or the
Ethics and Integrity Team.

y Accurately, complete quarterly representation lettersor other required representations when asked.

Q: At the end of the quarter your supervisor mentions that he asked a business partner to place an order early to meet
his target and verbally committed to take the product back if the deal did not materialize with the end customer.
How should you respond to this?

A: You should contact the Ethics and Integrity Team and report the deviation in your quarterly representation letter.
Additional Policies and Resources
Accounting Policies |© 2024 Avaya LLC. All Rights Reserved.

Schedule of Authorizations

22

Code of Conduct

Intellectual Property
Remember: We aggressively defend and protect our intellectual property and respect the intellectual property of others.
Our Policy

Intellectual property includes but is not limited to:Patents
Graphics, Logos, andSlogans

Trade Secrets

Trademarks

Trade Names

Service Marks

Domain Names

Copyrights

Know-how, Source Code andDeveloped Technology

Proprietary information includes but is not limited to:Business Plans

Customer Lists

Internal Documents

Organization Charts

When you help protect these assets, you help protect our competitive advantage.

Use Avaya’s trademarks and service marks only in accordance with Avaya Standards and Guidelines which are available toemployees and partners on the Sales and Partner Portal.

If suppliers want to use Avaya’s name or other intellectual property certain restrictions will apply, and certain documents need
to be executed by Avaya’s Global Sourcing Organization.
If a partner wants to use Avaya’s name or other intellectual property similar restrictions apply and are available on the Sales
and Partner Portal and reflected in the reseller agreement.
Showing Accountability and Trustworthiness

All Avaya employees, contractors and agents have a responsibility to:
y Identify, protect, and defend Avaya’s intellectual property.

y Promptly identify and report unauthorized disclosure or violations of infringements by any third party.
y Respect the intellectual property of others.

y Abide by terms of use and End User Licensing Agreements when using third party software or materials.

y Classify, label, store and limit access to proprietary information in accordance with Avaya Security policies.

y Know that anything you create within the scope of your employment with Avaya may be considered Avaya intellectual property.
y Ideas for patents should be submitted on the Avaya Invention Disclosure Form.

y Questions regarding Avaya’s intellectual property can be directed to the Ethics and Integrity Team.
Additional Policies and ResourcesIntellectual Property Law & Management | Avaya's Third-Party Software Policy | Avaya Brand Guidelines
Global Sourcing Organization | Avaya Security Policies | Avaya Invention Disclosure Form

© 2024 Avaya LLC. All Rights Reserved.

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Code of Conduct

Confidential and Proprietary Information
Remember: Our proprietary information is a competitive advantage and must be properly protected to maintain our
position in the market and trust of our customers and partners.
Our Policyy We do not use or disclose material, non-public information about Avaya or any other company without establishing avalid need to know AND ensuring the proper non-disclosure protections are in place.

y We safeguard the confidentiality of confidential or proprietary information in our possession, whether it relates to Avaya
or another party.

y We respect other parties’ rights to proprietary information, including intellectual property, personally identifiable
information, and personal health information.

Showing Accountability and Trustworthinessy When necessary, ensure that a non-disclosure agreement is in place and do not disclose Avaya’s confidential or
proprietary information even after your employment with Avaya ceases.

y Understand and comply with the terms of any non-disclosure agreements.

y Consult Avaya Security policies to understand how to properly mark and handle proprietary information.
y Handle customer information in accordance with Avaya Security policies and customer agreements.
y Handle personal health information in accordance with Avaya policy.

Additional Policies and Resources

Avaya’s NDA Process | HIPAA Policies

Avaya’s Security Policy (Data classification guidelines, Protection of Information Assets)© 2024 Avaya LLC. All Rights Reserved.

24

Code of Conduct

Insider Trading
Our Policy

As you conduct business on behalf of Avaya, you may come across material, non-public information about Avaya or about third
parties (such as customers, partners, suppliers or strategic partners) maintained by Avaya.

Non-public information is considered material if a reasonable investor would likely consider it in their decision to buy orsell a security.

Material, non-public information is considered insider information and transacting in securities based on such information
is illegal. It is also illegal to provide insider information to others, such as friends, family or colleagues, so they can use it tomake trading decisions. If you have questions about insider trading, please contact the Ethics and Integrity Team.
Showing Accountability and Trustworthiness

Do not trade securities while in possession of material, non-public information about any company you interact with, including
but not limited to Avaya, its customers, partners, suppliers, or other strategic partnerships.

Comply with any applicable trading blackout periods. Comply with Avaya’s Insider Trading Policy. If you are not sure theinformation you have is considered insider information or if a blackout period is applicable to you, contact the Legal team.

Additional Policies and Resources
Insider Trading Policy© 2024 Avaya LLC. All Rights Reserved.

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Code of Conduct

Cybersecurity
Our Policy

We each play a role in securing Avaya’s proprietary

information as well as confidential information entrusted
to us by our customers.

Avaya maintains security systems and processes toprotect confidential data. Cyber threats constantly evolveto avoid detection by these systems. Attackers seek tolure unsuspecting individuals with authorized access into

providing the information they seek or gain unauthorizedaccess to Avaya’s network and systems.

Data breaches and data loss can result in financial andreputational damage to the company. In the event of abreach, we will be held accountable for compliance with
our security practices and our response.

Showing Accountability and Trustworthiness

Attacks come in many different forms. Always keep yourguard especially in the following situations:y When asked for your username or password byanyone other than Avaya IT.

y If you receive an email or text message from a leader
you normally don’t interact with, asking you to dosomething outside of process.
y Do not click on links in an email from an unknown
sender.

y Requests to change banking information in Avaya’s
systems or process invoices outside of process.

y Requests for information on projects you are working,organization charts, or other sensitive data.

Promptly report breaches or suspected breaches

as outlined in the Data Breach Response guideline.
Responding quickly and appropriately protects
Avaya and our customers.

Additional Policies and Resources
Data Breach Response© 2024 Avaya LLC. All Rights Reserved.

| Avaya Security Standards

26

Code of Conduct

Acceptable Use Policy
Our Policyy Unless otherwise prohibited by law, Avaya may monitor an individual’s use of network services (e.g., internet and email
access) to ensure the security and availability of Avaya’s network.

y Avaya’s assets which include employee time, work and work product; cash and accounts; physical assets; intellectual
property; and other proprietary or nonpublic information, must only be used for company business.

y Avaya’s assets should be:▪ Safeguarded against loss, damage, misuse or theft.

▪ Monitored for any loss, damage, misuse or theft, and any such events should be reported as soon as possible.
▪ Not used in a manner that would result in or facilitate the violation of law.

y Assets entrusted to the company's custody by customers, suppliers and others should be used and safeguarded in thesame manner as company assets.

y Sexually explicit content and content inconsistent with Avaya’s policies, Avaya’s corporate values, or generally acceptedbusiness norms are prohibited.

y Do not circumvent Avaya’s security controls that are intended to protect employees and the company.
y Refer to Avaya’s Security Policies for additional information.

Policies Additional Policies and Resources
AI Policy Data Breach Response | Avaya Security Standards© 2024 Avaya LLC. All Rights Reserved.

27

Code of Conduct

AI Policy
Our Policy

Artificial Intelligence (AI) technology presents unique
opportunities and challenges to every organization.
To maximize the beneficial opportunities inherent
in AI, while minimizing risks, we have establishedan AI Use Policy, AI Enablement Committee and AI

Risk Assessment Team. The AI Use Policy details theprinciples, responsibilities, and ethical considerations
for using AI at Avaya. It is designed to ensure that AI

technologies are used responsibly, transparently, andin alignment with our organizational values and legal
obligations. Avaya reserves the right to access andmonitor the use of AI technologies on any companyissued devices or device that appears on company
managed networks.

Showing Accountability and Trustworthiness

AI accountability is critical to maintaining trust and integrity within our organization. Familiarize yourself with the AI Use Policy,
and always remain vigilant and uphold our standards, including in the following situations:If you become aware of potential bias or
discrimination in AI-generated outputs.

If you become aware of unauthorized accessor misuse of AI systems or data.

If you become aware of data privacy concerns

regarding the use of AI such as inputting personal
data into AI technologies.

If you become aware of requests or attempts to bypass
established AI protocols or ethical guidelines.

Promptly report any of these issues (or any other concern) to your manager or email the Ethics and Integrity Team.
Your swift action ensures the responsible use of AI technologies and protects Avaya and its stakeholders.

Policies Additional Policies and Resources
AI Policy AI Policy© 2024 Avaya LLC. All Rights Reserved.

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Code of Conduct

Records Management
Our Policy

You have a responsibility to:

y Retain records, whether hard copy or electronic,in accordance with Avaya’s Records Retention
Schedule or applicable law.

y Ensure secure disposal of records that are no longer
needed as per Avaya’s Records Retention Schedule.

y Ensure secure disposal of Personal Data as per
Avaya’s Personal Data Retention schedule.

Showing Accountability and Trustworthiness

When working with company records, remember:y Familiarize yourself and comply with Avaya’s
records retention policy and schedules.

y Don’t destroy anything that should be retained.
y Prepare them accurately, in a timely manner,and in reasonable detail.

y Where applicable, sign them only if they are accurate
and complete.

y Retain records that are subject to a legal hold.

y Dispose of records containing personal data as
per the Personal Data Retention schedule.

Q: You no longer have many hard copy records as you keep everything in electronic format. Do you need to keep theelectronic copies for the same time as if they were hard copies?

A: Yes, electronically stored information is subject to the same requirements as hard copies.
Q: Is email subject to the same retention schedule as other documents?

A: No, email is not considered a record, it is a method of communication. Any information contained in email that is arecord – attachments or approvals, etc., must be removed from the email system and preserved in a manner that meetsthe retention guidelines.

Policies Additional Policies and Resources
AI Policy Records Management | Records Retention Schedule© 2024 Avaya LLC. All Rights Reserved.

|

Personal Data Retention Schedule29

Code of Conduct

External Communication and Social MediaOur Policy

Avaya believes in fostering a thriving online community. We support open
dialogue and the free exchange of ideas.

Avaya employees must use their best judgment and act responsibly whengenerating content for social media.

New technologies and vast social media tools available have given us many newcommunications options. In light of the fact that these are public forums, extra
care must be taken when using social media platforms for company business.
Showing Accountability and Trustworthinessy Use social media responsibly. Never misrepresent yourself or use social
media for deceptive practices.

y Never speak on behalf of Avaya unless authorized to do so. Play it safe.

Only re-post and share official company statements. Make it clear that theviews you express are solely your own.

y Refer all public inquiries to an Avaya Media Relations representative. Neverintimidate, harass or discriminate against fellow employees in an online setting.

y Never disclose or discuss Avaya’s confidential, proprietary or material,

non-public information in a public setting (i.e., in conversations in public
places, social media settings, group or insecure emails, or otherwise).

y Only send, store or receive Avaya confidential, proprietary or material,

nonpublic information using corporate approved systems such as email,instant messages, and file sharing.

Q: You’ve been working on Avaya’s latest product and want to let your industry colleagues know of a major milestonethat was just completed. Can you post something to an online industry chat room?
A: No. You cannot post non-public information to a public or semi-public forum.

Q: You’re involved in a time-sensitive project that requires a significant amount of travel. You take a lot of calls on

your mobile phone while in airports and public areas such as hotel lobbies, trade show floors, etc. Does this pose arisk to the company?

A: Yes. What you say in public, once heard, is no longer protected. You need to be mindful of your surroundings whenparticipating in sensitive conversations in public spaces.

Q: You’re leaving the office one evening and are approached by the press regarding a story on one of Avaya’s
executives. You’ve known this executive for years; can you speak to the reporter?

A: No. Any communications with the press must be reviewed and authorized by Avaya Public Relations.
Policies Additional Policies and Resources
AI Policy Social Media Policy | Competitive Information and Comparative Claims© 2024 Avaya LLC. All Rights Reserved.

30

Code of Conduct

International Trade
Our Policy

Avaya complies with all applicable import and export

controls, as well as economic sanctions laws that impose
controls on the transfer of goods, technology, technicalinformation, software and services.

Avaya also complies with all applicable customs laws,
which apply in some form to virtually every import inevery country (i.e., prohibitions, restrictions, duties, taxes
or fees payable by the importer). All items imported by

Avaya must be reported to all relevant customs agencies.
Avaya must comply with applicable anti-boycott laws

and regulations. If you learn of a boycott request or if you
are asked to participate in a boycott in any country, you
should consult the legal team before taking any action.
Showing Accountability and Trustworthinessy Familiarize yourself with Avaya’s Global Trade

Compliance Policy and be aware of activities that raiseissues under these laws.

y Follow all business procedures as it relates to export
controls.

y Ensure that licenses, and proper authorizations are inplace for the export of technology, software, products
and services.

y Trade Compliance laws differ from country tocountry and are often complex. Seek guidance fromthe global trade team regarding restrictive trade
procedures and boycotts to make sure you areoperating in compliance.

y Ensure accurate export documentation oftransactions to ensure compliance with “know yourcustomer, know your supplier” rules.

Additional Policies and Resources
Global Trade Compliance Policy

Review the Global Trade Support website as needed or contact the Global Trade Team at globaltrade@avaya.com© 2024 Avaya LLC. All Rights Reserved.

31

Code of ConductSupporting our Communities
Environmental Sustainability

Avaya is committed to conducting our business in an environmentally responsible manner, complying with the environmental
laws that apply to us and doing our part to help save and preserve the Earth’s finite resources.

Our planet-related commitments span our energy use, carbon emissions and waste recycling and disposal. Committed to doing

our part to combat climate change, we set ambitious carbon emission reduction targets and report our progress annually to CDP,
in our Sustainability Report and on the “Sustainability at Avaya” webpage.

We express our commitment to responsible product design and our commitments to conducting our business in anenvironmentally responsible manner in our Environmental, Health and Safety Policy.
Showing Accountability and Trustworthiness

Employees are responsible for supporting Avaya’s environmental commitments by, among other things:
y Hosting virtual meetings and reducing the need for business travel.

y Conserving energy by using the “hibernate” feature on computers, and turning off lights, printers, microwaves, and otherelectrical appliances before leaving the office.
y Participating in company-sponsored recycling programs and by finding ways to eliminate waste and conserve resources.
y Properly disposing of waste and reusing or recycling as much as possible.
y Supporting our partners’ and customers’ carbon reduction strategies.

Policies Additional Policies and Resources
AI Policy Environmental, Health and Safety Policy© 2024 Avaya LLC. All Rights Reserved.

32

Code of Conduct

Safe and Healthy Workplace

Avaya is committed to a work environment that empowers everyone to do theirbest work: one that encourages innovation, creative thinking, and teamwork.
A safe workplace inspires trust and allows us all to contribute and succeed.

The health and safety of our workforce is a top priority and through our programs
and practices, we seek to maintain a culture in which our workforce shares the
responsibility for keeping each other safe on the job.

Avaya is committed to maintaining industry standards in all areas of employee
safety and health. To support this commitment, we comply with all health andsafety laws of the countries where Avaya conducts business and endeavor tomaintain our facilities in a safe, clean, orderly, and healthy condition, free fromrecognized hazards.

Everyone associated with Avaya is responsible for immediately reporting

accidents, injuries, occupational illnesses and unsafe practices or conditions toyour manager, Human Resources Business Partner or the confidential helpline.

Avaya maintains a zero-tolerance policy for workplace violence, prohibits threats,
intimidation, physical intimidation and acts of violence. You are not permitted
to bring anything to work that could be considered a weapon. If you believe

there is a potential for violent behavior, contact Avaya Security immediately at

1-877-99-ETHIC or +1-908-953-7276. If there is an actual act of violence at yourlocation, please contact local emergency response.

Avaya prohibits employees from working under the influence of drugs and alcohol.
Working under the influence of these substances can impair judgement and createa safety hazard. Medication prescribed to you by a doctor can also affect your ability
to do your job safely. Check with your doctor about any impact your prescription

might have on your ability to perform your job and communicate any concerns orquestions about Avaya’s Global Reasonable Accommodation/Work Adjustment
Process to your supervisor, Human Resources or eocontact@avaya.com.

Reporting

Click here to report workrelated injuries, illnesses orincidents.

Click here to report motor
vehicle accidents (including
for owned, leased, rented or
personal vehicles), including
insurance notification
requirements.

Showing Accountability and Trustworthiness

Employees are responsible for their safety, the safety of those around them and for following safe work practices. Employees
are expected to:y Complete EHS training courses as required.

y Review local Emergency Preparedness Plans, follow response procedures, and participate in emergency evacuation drills.
y Report unsafe conditions to EHS and the location-specific Facilities Team.

These conditions may include but not be limited to: Electrical hazards, basic clutter, blocked access to fire safety
equipment, slip, trip and fall hazards, unsafe driving, unsafe practices at customer sites.

y Report work-related injuries, illnesses and incidents, as well as acts or threats of violence
Policies Additional Policies and Resources
AI Policy Environmental, Health and Safety Policy© 2024 Avaya LLC. All Rights Reserved.

33

Code of Conduct

Charitable Activities

Avaya believes in giving back, and we support the communities where
we live and work through various charitable activities. These efforts,

including volunteer time, product donations, and financial support will be
conducted in a lawful manner, without creating conflicts of interest and inaccordance with processes to vet the organizations we sponsor to ensure

they meet our standards and expectations as well as to ensure appropriate
internal approvals.

We act as a force for good in our communities, focusing our efforts
on education, hunger, health and wellness, and disaster relief.

We may promote charitable causes to partners, customers, suppliers andcolleagues, provided that we make it clear that we are acting on behalfof a charitable cause or organization and not on behalf of Avaya. When

we offer donations and charitable contributions, we have no expectationof receiving specific benefits or financial returns in exchange for this

support. We contribute only to reputable, not-for-profit organizations
and ensure our contributions are made in a transparent manner.

All charitable contributions made on behalf of Avaya are made inaccordance with Avaya’s Charitable Giving Approval Process andAvaya’s Schedule of Authorizations for Non-Monetary Transactions,
Sponsorships, and Charitable Donations.

Showing Accountability and Trustworthinessy Review the Charitable Giving Approval Process and Schedule of Authorization.
y Ensure that the charitable organization for which you are seeking support:

Is reputable.

Is not-for-profit.

Does not have any policies, practices, activities
or values that discriminate against any person,
population group, characteristic, lifestyle,affiliations or organization with regard to

Is not controlled bygovernment officials.

Is nonpartisan andadheres to fundamental

human rights principles.

categories protected by Avaya policy and/or global
and local law including, but not limited to age,
race, religion, gender, gender identity, gender
expression, disability or national origin.

y Disclose relationships with any organization for which you are seeking support
y Ensure that donations are not being made in exchange for business
Policies Additional Policies and Resources
AI Policy Charitable Giving Approval Process© 2024 Avaya LLC. All Rights Reserved.

| Schedule of Authorization (SOA)34

Code of Conduct

Political Involvement

Avaya does not permit employees to use their Avaya position or Avaya assets to influence the personal decisions of others

to contribute to or otherwise support political parties or candidates. Any involvement in political activities is personal andvoluntary and should be done on your own time and with your own resources.
Showing Accountability and Trustworthiness

Understand the restrictions on political involvement and reach out to Avaya Legal counsel with any questions regarding
company policies and federal laws that govern political activity.

Human Rights

Avaya has a longstanding commitment to ethical business conduct in our operations and supply chains, and we uphold andrespect human rights as contained in international laws and standards, including the United Nations Universal Declaration of
Human Rights (UDHR), the eight Core Labour Conventions developed by the International Labour Organization (ILO), and theOrganization for Economic Cooperation and development (OECD) Guidelines for Multinational Enterprises. We are committed
to ethical business conduct in our operations and supply chains and are opposed to all forms of corruption or businessconduct that is at odds with the principles enacted in this Code.

We recognize employee's lawful rights to freely chosen employment, fair wages and hours, freedom of association andcollective bargaining, and a work environment free from discrimination, harassment, and retaliation.

We explicitly prohibit human trafficking and the use of involuntary labor in our operations and within our supply chain

including child labor, forced, bonded or indentured labor, involuntary or exploitative prison labor, and other forms of modern
slavery. We implement and enforce effective systems and controls to ensure that modern slavery does not take place within
our operations and supply chains. Avaya complies with the employment laws of every country in which we operate, and we
expect the same of our business partners.

Avaya strives to do business with suppliers and other third parties that reflect our high standards of ethical business conduct bytaking steps to ensure our business partners understand the expectations we apply to ourselves and members of our supply chain.
Our commitment to upholding human rights in our operations and supply chain is embodied in our policies.
Policies Additional Policies and Resources
AI Policy Human Rights Policy | Supplier Code of Conduct© 2024 Avaya LLC. All Rights Reserved.

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Channel Partner Code of Conduct

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Code of Conduct

Closing Thoughts

Any failure to read, understand or acknowledge the Code does not exempt you from your responsibility to comply with its
provisions, applicable Avaya policies and applicable laws and regulations.
Waivers

Employment

with respect to any director or executive

bargaining or other labor agreement, the Code is not

Any waivers of any provisions of the Codeofficer requires the approval of by Avaya’s

Board of Directors or by a committee thereof.

Any such waivers will only be made in limited
circumstances and in conjunction with any

appropriate ongoing monitoring and will be
disclosed as required under applicable law
and regulations.

Unless otherwise provided by local law or a collective
a contract of employment and does not create any

contractual rights of any kind between Avaya and its
directors, officers or employees. Moreover, unlessprohibited by applicable law or unless an Avaya

employee’s terms and conditions of employment aregoverned by a collective bargaining or other labor

agreement or there exist other applicable law or public
policy exceptions, employment at Avaya is on an “atwill” basis in the United States and elsewhere, where
Amendments

We are committed to continually reviewing andupdating our policies. We therefore may amend
this Code at any time and for any reason.

© 2024 Avaya LLC. All Rights Reserved.

applicable. Please note employment in certain othercountries may not be "at will". “At will” means that an
employee may terminate his or her employment at

any time and for any reason, and, similarly, Avaya may

generally terminate an employee’s employment at any
time and for any reason, or for no reason at all.

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About Avaya

Businesses are built by the experiences they provide, and every day, millions of those experiences are delivered by Avaya.
Organizations trust Avaya to provide innovative solutions for some of their most important a​ mbitions and ​challenges,​g​ ivingthem the freedom to engage their customers and employees in ways that deliver the greatest business benefits.  
Avaya contact center and communications solutions power immersive, personalized, and unforgettable customer
experiences that drive business momentum. With the freedom to choose their journey, there’s no limit to the experiences
Avaya customers can create.

©2024 Avaya LLC. All rights reserved, Avaya, the Avaya Logo, and all trademarks identified by ®, TM or SM are registered trademarks, trademarks,
or service marks of Avaya LLC, and may be registered in certain jurisdictions. All other trademarks are the property of their respective owners.
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