Avaya Human Rights Statement
Avaya believes in the dignity of freely chosen work as expressed in the United Nations Declaration of
Human Rights. Avaya is committed to identifying risks and preventing the use of child labor, slavery andhuman trafficking in our business operations and supply chain. This statement was prepared inconformance with governmental requirements such as Section 3 of the California Transparency inSupply Chains Act of 2010, the United Kingdom (UK) Modern Slavery Act 2015, Chapter 30, Part 6,
Provision 54, and the U.S. Federal Acquisition Regulation 52.222-50.
Process
Avaya is an affiliate member of the Responsible Business Alliance (RBA)-- a nonprofit coalition ofelectronics companies committed to supporting the rights and well-being of workers and communities
engaged in the global electronics supply chain. As a participant in this leading organization, Avaya
commits publicly to the RBA Code of Conduct (Code) and actively pursues conformance to the Code andits standards throughout our supply chain. Avaya’s adoption of the Code is evident on our website at(http://www.avaya.com/usa/documents/supplier_code_conduct.pdf) and is adopted by suppliers aspart of the supplier contract process.
The Code defines human trafficking under Section A.1 within its provisions for Freely Chosen
Employment. It states that forced, bonded (including debt bondage) or indentured labor, involuntary
prison labor, slavery or trafficking of persons shall not be used and it outlines necessary management
systems to ensure workers’ rights are protected. The RBA also convenes regular teleconferences,webinars and other meetings that educate members on how to identify monitor and prevent risks
associated with labor recruitment practices.
Steps taken by Avaya to identify risks and prevent modern slavery in the organization’s manufacturing
supply chain and business operations include:
1. Verification: We evaluate and address risks of human trafficking and slavery through thefollowing three methods:a.

The Supplier Self-Assessment Questionnaire (SAQ). The SAQ is completed by Avaya
annually for RBA membership and upon request by Avaya suppliers. It is a selfevaluation that documents existing company policies and procedures e as compared to
the Code requirements.

b. The Verified Audit Process (VAP). The VAP are audits carried out on suppliers' facilities
which are completed by independent, third-party auditors specially trained in social andenvironmental auditing and the RBA VAP audit protocol. These audits help to ensure
consistent, industry-wide standards. Avaya reviews available VAP audit results that areavailable from suppliers.
c. Avaya participates in the global Conflict Free Source Initiative, an initiative developedby the RBA and the Global e-Sustainability Initiative (GeSi) by using the Conflict Minerals
Reporting Template which facilitates obtaining the country of origin information fortarget minerals from smelters and refiners of tin, tungsten, tantalum and gold as these1

target minerals have been implicated in slavery and human rights violations. Smelters
and refiners are declared conflict-free if verified through an independent third-party
audit that they have implemented systems to ensure sourcing of conflict-free materials.
2. Supplier Audits: The approaches listed above help us determine which suppliers may need to beaudited by identifying risk levels for slave labor or human trafficking practices. The VAP is acomprehensive assessment of supplier’s implementation of the RBA Code including labor,
health and safety, environment, ethics, and management systems. It incorporates audit
techniques such as on-site inspections, document reviews, and worker and management
interviews. Avaya analyzes VAP audit reports findings through RBA’s audit sharing system (theaudit reports are valid for two years). Additionally, as part of our contractual agreement withsuppliers we reserve the right to make unannounced visits at supplier facilities upon our
discretion for the purpose of carrying out supplier audits.
3. Certification: Section E of the RBA Code requires companies to have a management system that
contains “a process to communicate the Code requirements and to monitor supplier complianceto the Code.” This does not mean that suppliers submit certifications. However, Avaya expects
evidence such as written documentation to be provided if requested to substantiate supplier
claims and/or audit findings.
4. Internal Accountability: Noncompliance with the RBA Code on slavery and trafficking is taken
seriously. It is one of the most severe types of nonconformance and corrective action plans toremedy identified instances of nonconformance are expected to be implemented in the shortest
possible timeline. Avaya reserves the right to terminate relationships with third parties wherelegally able to do so, including suppliers, who are found to be non-compliant with supplierrequirements. Our own employees and contractors are required to adhere to our Operatingwith Integrity Code of Conduct which references the RBA Code requirements and strictly
prohibits human trafficking behavior. Employees or contractors suspected of human trafficking
activities will be investigated and violations are grounds for immediate termination. Any
employees or contractor who suspect that human trafficking violations are taking place in Avaya
business operations or in the supply chain are urged to report activities to our Ethics Hotline at
1-877-99-ETHIC (1-877-993-8442), if U.S-based, or to +1-908-953-7276 if located outside of theU.S.
5. Capacity-Building/Training: Avaya suppliers also receive information on the Code requirements,and expectations around human trafficking during our annual Supplier Day Summit, an annuallygathering of Avaya suppliers from around the globe Specific training is provided for Avaya
employees engaged in sourcing and procurement to help them spot and report issues.
Additionally, RBA members can leverage the Learning Academy, which contains online learning
modules that cover the RBA Code of Conduct, as well as modules specifically related to theCalifornia Transparency in Supply Chains Act.
The RBA Code is a fundamental part of our efforts to ensure that slavery and human trafficking is nottaking place in our supply chains and our own business. This summarizes the efforts Avaya takes in ourown business, as well as with our suppliers, to eradicate child labor, slavery and human trafficking fromour supply chain.
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