Title: Global Equal Opportunity Non-Discrimination and Retaliation Prevention
PolicyPolicy Family: Compliance
Version Number: 21.0

Last updated: Dec 2020

Policy Document Owner: Stacey Piña

1. OBJECTIVE
To reaffirm Avaya’s global commitment to prohibit discrimination in all its
forms and societal disparities; to affirm Avaya’s global commitment to zerotolerance for retaliation against employees who engage in protected activity;
to provide equal opportunity to all employees and applicants for employment
and to comply with all relevant applicable laws, directives, and regulations offederal, state, and local governing bodies and agencies.
2. APPLICABILITY
This Policy is applicable to all employees of Avaya Inc., its subsidiaries, oraffiliates (“Avaya” or the “Company”) worldwide, as well as all corresponding
work sites.
3. POLICY
Avaya is committed to drive positive change within our organization as wellas in our communities. Our priority is to ensure that our global organization
is a thriving and successful environment in which different ideas, ethnicities
and skills are blended together and celebrated. We are an equal opportunity
employer which believe in cultivating the richness of cultures, perspectives,
experiences and skills that make up our culture of unity and globalcommunity. Diversity, and the equal opportunity it affords, is a fundamental
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part of our Avaya values. It also makes Avaya more competitive in today’s
global marketplaces.
NON-DISCRIMINATION
Avaya has zero tolerance for unlawful workplace discrimination. It is Avaya’s
global corporate Policy to treat each individual with dignity and respect by:•Complying with both the letter and the spirit of all applicable laws andregulations governing employment;•Taking all necessary steps to prohibit unlawful discrimination and provide
equal opportunity to all qualified employees and applicants in all aspectsof employment;•Prohibiting unlawful workplace harassment, discrimination or retaliationin any employment decision or in the administration of any Avaya policyon the basis of known or perceived race, ethnicity, color, creed, religion,
national origin, citizenship, sex, gender, marital status, family
responsibilities, age, genetic information, physical or mental disability or
handicap, one’s status as a “disabled veteran”[1], “recently separatedveteran”, “armed forces service medal veteran” or “active duty wartime or
campaign badge veteran”; pregnancy, childbirth, and related medicalconditions or because of a person’s sexual orientation, gender identity,characteristics, or expression, or any other protected characteristics as
defined under applicable law;•

Making reasonable accommodations or work adjustments based on theverified physical and/or mental conditions of qualified employees orapplicants with disabilities or handicap and/or to reasonably
accommodate the sincerely held religious beliefs and affiliations ofqualified employees or applicants;•Preventing and prohibiting unlawful discrimination, bullying, mobbing,victimization or harassment because of one’s association with an

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individual or a representative of a group having any of the protectedcharacteristics described above;•Ensuring that maximum opportunity is afforded to all minority- andwoman-owned businesses to participate as suppliers, contractors, andsubcontractors of goods and services to Avaya, in a manner consistent
with applicable law; and complying with regulatory agency requirements
and with federal, state, and local procurement regulations and programs;
and•Advising employees of their right to report violations of this policy tomanagement, Human Resources, or to the Avaya Equal Opportunity
Compliance team without intimidation or retaliation of any kind as aresult of exercising such rights in good faith.

RETALIATION PREVENTION
Avaya has zero tolerance for unlawful workplace retaliation.

Retaliation isdefined as adverse employment action(s) taken because an individual, acting
in good faith, reported an actual or perceived violation of this Policy, opposed
practices prohibited by this Policy, or participated in the reporting andinvestigation process described below.
“Adverse” conduct includes but is not limited to: shunning and excluding anindividual from essential work functions or opportunities, discrimination orretaliation; express or implied threats or intimidation intended to prevent anindividual from reporting harassment, discrimination or retaliation; ordenying employment benefits because an applicant or employee reported
harassment, discrimination or retaliation or participated in the reporting andinvestigative process described herein.
No manager or supervisor shall threaten or insinuate, either explicitly orimplicitly, that an employee’s or applicant’s confidential good faith report ofa potential policy violation will in any way influence any personnel decision
regardingemployment,

wages,advancement,

jobassignment,

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careerdevelopment, or any other term or condition of employment.

No hardship,

loss, benefit or penalty may be imposed on an employee in response to:• Filing or responding to a good faith complaint of discrimination orharassment.
• Filing or responding to a request for reasonable accommodation.
• Assisting or participating in an investigation, compliance review, hearing,or any other enforcement proceeding,• Pursuing a discrimination or harassment claim, or opposing any act madeillegal by federal, state, or local equal opportunity law.
• Appearing as a witness in the investigation of a complaint.
• Serving as an investigator of a complaint.
Lodging a bona fide complaint will in no way be used against the employee
or have an adverse impact on the individual's employment status. However,filing groundless, false or malicious reports is an abuse of this policy and willbe treated as a violation.
All complaints and investigations are treated confidentially to the extent
possible, and information is disclosed strictly on a need-to-know basis.
Supervisors, managers and authorized investigators will take adequate steps
to ensure that the complainant and witnesses are protected from retaliation
during and after the investigation. All information pertaining to a complaint
or investigation under this Policy will be maintained in secure files.
Any person who is found to have violated this aspect of the Policy will besubject to discipline up to and including termination of employment.
Additionally, any manager or supervisor who becomes aware of potential
retaliatory conduct must report the conduct to so that an investigation can be
conducted, and corrective action taken, if appropriate.

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U.S. PAY TRANSPARENCY PROVISION:
Avaya is a U.S. government contractor and will not discharge or in any othermanner discriminate against employees or applicants because they haveinquired about, discussed, or disclosed their own pay or the pay of another
employee or applicant. However, employees who have access to thecompensation information of other employees or applicants as a part of theirassigned Avaya job functions cannot disclose the pay of other employees orapplicants to individuals who do not otherwise have authorization to accesscompensation information, unless the disclosure is (a) in response to aformal complaint or charge, (b) in furtherance of an investigation,
proceeding, hearing, or action, including an investigation conducted by
Avaya’s authorized personnel and (c) approved by Avaya’s Worldwide Laworganization.
No individual will be subjected to unlawful bullying, harassment, mobbing,victimization, intimidation, threats, retaliation, coercion or discrimination forrequesting a reasonable accommodation, reporting an allegation in goodfaith, assisting or participating in an investigation, compliance review,
hearing, or any other enforcement proceeding, or opposing any act madeillegal by federal, state, or local equal opportunity law in the performance of
Avaya work.

Avaya cooperates with government officials in conducting

investigations and other activities related to the administration of applicable
federal, state and local legislation.
Each year, we voluntarily reaffirm Avaya’s commitment to equal opportunity
and to the real strength that diversity and this policy bring to ourCompany. All employees are responsible for reviewing and fully complying
with this and all related Avaya Policies including, but not limited to Avaya’s:
Global Harassment Prevention Policy1
Global Reasonable Accommodation Policy1
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Global Code of Conduct
Canada Anti-Harassment Policy1
U.S. Affirmative Action Policy2
All management level employees are required to become familiar with theprovisions of this Policy and to be able to discuss this material withemployees.
We require all Avaya employees to comply fully with all aspects of this policy,
to conduct themselves in accordance with the principles of equal opportunity,
and report any suspected violations to the Avaya Compliance Hotline at
1-877-993-8442

(US)

or

1-908-953-7276(outsidetheUS),

eocontact@avaya.com, Human Resources or a member of the management
team.
Demonstrated commitment to equal opportunity is an investment in ourpeople and our future growth as an organization. Avaya’s ongoing efforts inthis direction have provided and will continue to provide us with a criticalcompetitive advantage in the marketplace.

James Chirico

Faye Tylee

President & Chief Executive Officer

Global Head of Human Resources

December 2020

1 Edit your Country/Language setting to choose your Region and Country selection = Canada
2 Edit your Country/Language setting to choose your Region and Country selection = UnitedStatesAvaya – Proprietary
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4. REFERENCES

Avaya is an Equal Opportunity Employer and a U.S. federal government
contractor. Our commitment to equality is a core value 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 information and support, contact
Avaya’s Equal Opportunity hotline by phone at 908-953-7276 (US) or athttps://app.convercent.com/en-us/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 taking
positive steps to implement the employment-related aspects of the global
Equal Opportunity policy in the United States
AVAYA INC. ("AVAYA") HAS THE RIGHT TO AMEND, CHANGE, OR CANCEL ANY
POLICY SOLELY AT ITS DISCRETION AND WITHOUT PRIOR NOTICE, UNLESSOTHERWISE PROVIDED FOR IN YOUR EMPLOYMENT AGREEMENT OR GOVERNINGLAW. NOTHING PUBLISHED IN THIS HR POLICY PORTAL OR DISTRIBUTED BYAVAYA 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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