Title: Global Harassment Prevention Policy
Policy Family: Compliance
Version Number: 21.0

Last updated: Dec 2020

Policy Document Owner: Stacey Piña
1. OBJECTIVE
To reaffirm Avaya’s commitment to and zero tolerance policy for unlawful
discrimination, harassment, bullying, victimization, mobbing, and retaliationin the workplace.
2. APPLICABILITY
This Policy is applicable to all employees, applicants, contractors and worksites of Avaya Inc., its subsidiaries, or affiliates (“Avaya” or the “Company”)
worldwide.
3. POLICY
Avaya is committed to providing all its employees with a work environment
free from unlawful discrimination, retaliation and harassment (which includes
behavior considered to be unlawful victimization, bullying or mobbing). It is
Avaya’s policy to comply with both the letter and the spirit of all applicablelaws and regulations governing employment[1].
Avaya’s zero tolerance Global Harassment Prevention Policy strictly prohibits
unlawful workplace harassment, whether it occurs on or off Avaya premises,
because of known or perceived:sex, race, ethnicity, color, creed, religion, national origin or ancestry,citizenship, marital 11status, age, sexual orientation, gender identity,

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character or expression, allyship, affiliation, physical or mental
disability, veteran status or any other legally-protected class orcharacteristic.
Physical, verbal and electronic harassment are prohibited, regardless ofwhether committed by supervisory or non-supervisory personnel, or by aconsultant, vendor, client, or customer of Avaya.
This zero-tolerance policy prohibits behavior including, but not limited to:•Sexual harassment1 which encompasses, but is not limited to, thefollowing: quid pro quo harassment; unwelcome attention of a romanticor sexual nature; egregious, offensive or unwelcome sexual flirtations,advances, or propositions; abuse of a sexual nature; sexually suggestive,
explicit or graphic comments; sexually degrading language used todescribe an individual; and the display in the workplace of sexuallysuggestive objects, images or pictures.

•Unlawful harassment on the basis of race, ethnicity, color, creed,
religion, national origin or ancestry, citizenship, marital status, age, sex,gender, sexual orientation, gender identity, character or expression,
allyship, affiliation, physical or mental disability, veteran status or any
other legally-protected class or characteristic, which can be defined as
threatening, abusive, or intimidating comments or conduct that
unreasonably interfere(s) with an employee’s work performance or
creates an intimidating, hostile, or offensive work environment.

•Behavior defined by local law as unlawful harassment, bullying,victimization or mobbing.

1 Note: prohibited sexual harassment can occur between members of the sameor opposite sex.

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No manager or supervisor shall threaten or insinuate, either explicitly orimplicitly, that an employee’s or applicant’s submission or rejection ofsexual advances will in any way influence any personnel decision regarding
employment, wages, advancement, job assignment, career development, or
any other term or condition of employment.
Avaya further prohibits discipline, reprisal, unlawful bullying, harassment,
intimidation, threats, coercion, discrimination or retaliation2 in any form, for:•requesting a reasonable accommodation or work adjustment on thebasis of a protected medical condition or religious practice;•making a good faith report or complaint of unlawful conduct
including discrimination, harassment, fraud, theft, or violations of
Avaya’s Code of Conduct;•assisting or participating in a Corporate Compliance or Human
Resources investigation, compliance review, hearing, or any otherenforcement proceeding; or•

pursuing a discrimination or harassment claim, or opposing any act
made illegal by federal, state, or local equal opportunity law.

It is Avaya’s policy to promptly and diligently investigate all good faith claimsof discrimination, unlawful harassment, or other prohibited behavior, including
retaliation, in accordance with applicable law, to maintain confidentiality to theextent possible in light of the personal nature of these matters and theimportant privacy interests of all concerned, and to take prompt andappropriate remedial action, if appropriate.
Avaya cooperates with government officials in conducting investigations andother activities related to the administration of applicable federal, state, andlocal legislation. This policy is not intended to restrict communications oractions protected or required by law.
2For more information on Avaya’s policy prohibiting retaliation, please refer to Avaya’s Global

Equal Opportunity Non-Discrimination and Retaliation Prevention Policy.

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Each year, we voluntarily reaffirm Avaya’s commitment to harassment
prevention and to the real strength that diversity, equal opportunity and thispolicy bring to our Company. All Avaya employees are responsible for helping
to ensure that we prevent unlawful workplace harassment by reviewing andfully complying with this and all related Avaya Policies. These policies include,
but are not limited to Avaya’s:
Global Non-Discrimination and Retaliation Prevention Policy3
Global Reasonable Accommodation Policy1
Global Code of Conduct
Canada Anti-Harassment Policy4
U.S. Affirmative Action Policy5

All management level employees are required to become familiar with theprovisions of this Policy and to be able to discuss this material with employees.
Additionally, any manager or supervisor who becomes aware of potential
discriminatory or harassing conduct must report the alleged matter to Avaya
Ethics and Compliance Hotline to so that a timely confidential investigation canbe conducted and corrective action taken, if appropriate. Employees at any
level who do not comply with the provisions of this policy may be subject todiscipline, up to and including the immediate termination of employment.
Any employee who believes in good faith that they experienced harassment as
defined by this policy, have witnessed or have knowledge of potential unlawful
workplace harassment should immediately report the matter to: the Avaya
Ethics and Compliance Hotline at 1-877- 993-8442 (US) or 908-953-7276(outside the US), eocontact@avaya.com, Human Resources or a member of the3 Edit your Country/Language setting to choose your Region and Country selection = Global
4 Edit your Country/Language setting to choose your Region and Country selection = Canada
5 Edit your Country/Language setting to choose your Region and Country selection = UnitedStatesAvaya – Proprietary
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All good faith allegations will be confidentially and thoroughly investigatedincluding anonymous reports. Avaya’s electronic complaint form is available
via the Avaya Ethics and Compliance Hotline.

James Chirico

Faye Tylee

President & Chief Executive Officer

Global Head of Human Resources

December 2020
4. REFERENCES
Avaya is an Equal Opportunity Employer. Our commitment to equality is a corevalue of Avaya. All qualified applicants and employees are entitled to receive
equal treatment without consideration for race, religion, sex, national origin,disability status or any other protected characteristic. For more informationand support, contact Avaya’s Equal Opportunity hotline by phone at 1-877993-8442 (US) or 908-953-7276 (outside the US) or athttps://app.convercent.com/enus/Anonymous/IssueIntake/IdentifyOrganization.
[1] Avaya is a U.S. VEVRAA Federal Contractor subject to Executive Order11246, Section 4212 of the Vietnam Era Veteran’s Readjustment Assistance Actof 1974 (Section 4212), as amended and Section 503 of the Rehabilitation Actof 1973, as amended (Section 503). Accordingly, Avaya is committed to takingpositive steps to implement the employment-related aspects of the global
Equal Opportunity policy in the United States.

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AVAYA INC. ("AVAYA") HAS THE RIGHT TO AMEND, CHANGE, OR CANCEL ANYPOLICY SOLELY AT ITS DISCRETION AND WITHOUT PRIOR NOTICE, UNLESSOTHERWISE PROVIDED FOR IN YOUR EMPLOYMENT AGREEMENT OR GOVERNING
LAW. NOTHING PUBLISHED IN THIS HR POLICY PORTAL OR DISTRIBUTED BY
AVAYA IS AN EXPRESS OR IMPLIED CONTRACT FOR CONTINUED EMPLOYMENTOR EMPLOYMENT OF A SPECIFIC LENGTH OF TIME. AVAYA EMPLOYEES AREEMPLOYEES-AT-WILL; MEANING AVAYA EMPLOYEES MAY TERMINATE THEIREMPLOYMENT AT ANY TIME AND FOR ANY REASON. THAT ALSO MEANS THATAVAYA CAN TERMINATE ITS EMPLOYEES' EMPLOYMENT AT ANY TIME AND FORANY REASON. EMPLOYEES OF AVAYA'S SUBSIDIARIES IN NON-US JURISDICTIONSSHOULD REFER TO ANY APPLICABLE LAWS AND LABOR AGREEMENTS.

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