Ivanti Channel Partner Code of Business Conduct
Date April 12, 2021

Ivanti Channel Partner Code of Business Conduct
1. Introduction
Ivanti has a long-standing reputation for integrity and trustworthiness among its customers
and this reputation depends upon the way in which Ivanti conducts its business and its
commitment to corporate social responsibility. As a well-respected security focusedorganization, Ivanti’s actions must be above reproach to maintain the confidence of its
customers and to avoid damage to its reputation.
Commitment to ethical business practices is a core value for Ivanti and this Channel Partner
Code of Business Conduct (the “Code”) is designed to ensure that all of Ivanti’s Channel
Partners have a clear understanding of how Ivanti expects to conduct its business with its
Channel Partners.
Ivanti expects all Channel Partners to fully comply with all of the principles and processes
in the Code. All of Ivanti’s Channel Partners must carefully review the commitments inthis Code and agree to abide by the commitments as a condition of doing business withIvanti.
2. Channel Partner Code of Business Conduct
This section sets out Ivanti’s specific expectations and requirements regarding theworkplace standards and business practices of its Channel Partners. These expectations areconsistent with the Ivanti's values, principles and policies regarding ethical businessconduct. Ivanti will seek to identify and engage suppliers who conduct their business basedon a set of ethical standards compatible with its own. Ivanti will not knowingly do businesswith Channel Partners who do not meet the standards outlined in this Code.
a. Conflicts of Interest
Channel Partners shall avoid actual or apparent conflicts of interest by disclosing
actual or potential conflicts honestly and promptly prior to making any decisionand ensuring that their employees (nor employee’s family members) do not makepersonal investments in companies that have a business connection with Ivanti.
b. Compliance with Laws
Channel Partners will comply with all applicable laws and regulations, whether
domestic or foreign, which govern the conduct of their businesses.
c. Employment and Wages
Channel Partners will employ employees who are, in all cases: present voluntarily,
not put at risk of physical harm due to their work environment, fairly compensatedand allowed the lawful right of free association. Channel Partners will, at aminimum, provide wages and benefits that comply with the laws of their countryof operation.
d. Working Hours
Channel Partners will not exceed prevailing local work hours except where workers
are appropriately compensated for overtime. Channel Partners should use less thansixty-hour work weeks and allow employees at least one day off in seven days, orequivalent leave privileges.
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Ivanti Channel Partner Code of Business Conducte. Anti-Slavery and Human Trafficking
Channel Partners prohibit slavery and human trafficking, this includes, but is not
limited to (i) engaging in any form of human trafficking; (ii) using forced labor for
any type of work; (iii) using child labor; (iv) procuring commercial sex acts; (v)denying an individual access to his/her identity or immigration documents, such as
drivers’ licenses, visas, or passports, regardless of issuing authority; denying accessincludes, but is not limited to, destroying, confiscating, and concealing; (vi) usingmisleading or fraudulent information when recruiting potential candidates, or in theprocess of an official offer of employment, contract, full-time, or otherwise; thisincludes, but is not limited to, using a language the potential employee is unfamiliar
with, making material misrepresentations regarding key terms and conditions (e.g.,wages, location of work, nature of work), or withholding any information regarding
key terms and conditions; (vii) charging applicants or potential candidates any
application or recruitment fee; (viii) using recruiters that are not compliant with thelabor laws of the country they are recruiting in; (ix) when required by law orcontract, failing to provide or pay for transportation; (x) when required by law orcontract, failing to provide or arrange housing that follows the housing and safety
standards of the correlating country; and (xi) when required by law or contract,
failing to provide in writing a recruitment agreement, employment contract, or othernecessary work documents.
f. Discrimination/Human Rights
Channel Partners must not discriminate against their employees in hiring practicesor any other term or condition of work (other than legitimate occupational
requirements allowed by law) on the basis of race, ancestry, place of origin, color,ethnic origin, citizenship, religion, faith, political opinion, sex, sexual orientation,age, marital status, same-sex partnership status, family status or disability.
g. Workplace Environment
Channel Partners will provide their employees with a safe and healthy working
environment consistent with all applicable laws and regulations and shall not use
corporal punishment or other forms of mental or physical coercion.
h. Environmental Protection
Channel Partners will comply with all applicable environmental laws andregulations in their country and all applicable Ivanti environmental policies.
i. Confidentiality and Privacy
Channel Partners will not disclose to others or use for their own purposes or thepurposes of others any trade secrets, confidential information, knowledge, designs,
data, skill, or any other information which Ivanti identifies to the Channel Partneras confidential or if such information by its nature should reasonably be understoodby the Channel Partner to be confidential. In accordance with the intent of Ivanti’sPrivacy Policy (https://www.ivanti.com/company/legal/privacy-policy), Channel
Partners will respect the privacy of personal data they collect, use or disclose as aconsequence of their business relationship with Ivanti.
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Ivanti Channel Partner Code of Business Conduct
j. Protection and Responsible Use of Customer Data
Channel Partners shall protect the personal and sensitive data of Ivanti’s customers,
employees and other persons obtained during Channel Partner’s business activities
by: (i) processing personal data lawfully, fairly and in a transparent manner; (ii)collecting personal data for specified, explicit and legitimate purposes and notprocessing it in a way that would be unlawful or incompatible with those purposes;(iii) having adequate security procedures and policies designed to protect personal
data from loss, unauthorized use or disclosure; (iv) collecting accurate personal data
and, where necessary, keeping it up to date; (v) collecting only the type(s) andamount of personal data that is relevant and required for the business relationshipand services being provided; (vi) not keeping personal data longer than is necessary
for the purpose for which the data was collected; (vii) respecting procedures toensure prompt responses to enquiries from customers regarding their data; (viii) not
selling customers data; (ix) organizing appropriate data protection training for theiremployees, agents and contractors; and (x) immediately informing Ivanti of any
security breach involving a loss of personal data.
k. Bribery, Corruption and Unlawful Payments
Channel Partners shall be knowledgeable about and adopt local anti-bribery &corruption policies. Channel Partner shall never offer a gift that affects or appears
to affect the impartiality of the person who receives it and shall apply local priorpre-approval procedures before offering or accepting a gift, entertainment or
hospitality. Channel Partners shall not give a payment or a gratuity to government
officials or employees to expedite a routine administrative action or make anycontributions, whether financial or in kind, to political parties or organizations, orto individual politicians (where it is legal to do so) on behalf of Ivanti without preapproval from Ivanti.
l. Insurance
To ensure the protection of Ivanti’s customers and business, Channel Partners shallmaintain appropriate insurance coverage as required by Ivanti, and as updated fromtime to time, for the duration of the business relationship with Ivanti.
m. Anti-Money Laundering
Channel Partners shall take all necessary steps prevent and detect any money
laundering and terrorism financing by understanding and complying with allapplicable laws and regulations, such as Title III of the Uniting and Strengthening
America by Providing Appropriate Tools Required to Intercept and Obstruct
Terrorism Act of 2001 (the “USA Patriot Act”).
3. Assessment and Monitoring
Ivanti reserves the right to assess and monitor on an ongoing basis a Channel Partner’s
practices regarding this Code. Assessments may include a review of relevant Channel
Partner records as well as inspection of Channel Partner facilities for compliance with thisCode. Ivanti will determine the frequency and extent of the assessments and ongoing
monitoring. Consistent with standard industry practice, all costs associated with thePage 4 of 5

Ivanti Channel Partner Code of Business Conductassessments and ongoing monitoring will be borne solely by Channel Partner. Channel
Partner will allow Ivanti and/or any of its representatives reasonable and timely access toChannel Partner’s facilities and to Channel Partner’s relevant records at all times.
4. Enforcement
Channel Partners who do not meet the requirements of this Code may, where consideredappropriate by Ivanti, be provided with the opportunity to bring their business into
compliance with this Code within a reasonable time frame determined by Ivanti. Ivantireserves the right to terminate its business relationship, including any and all agreements
between Ivanti and a Channel Partner, with any Channel Partner who fails to comply withthis Code.
5. Reporting and Addressing Code Violations
Any person who believes that a violation of this Code has occurred, is asked to report therelevant information in confidence to the Ivanti Business Conduct Web Reporting Portal
at https://secure.ethicspoint.com/domain/media/en/gui/49468/index.html.
Ivanti will make every effort to investigate all reported violations in a discreet, fair andconfidential manner and will take appropriate action to maintain the integrity of its
business.

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