Supply Chain Practices

The California Transparency in Supply Chains Act of 2010 (SB 657) requires certain companies doing business in California to disclose their efforts to eliminate human trafficking and slavery from their supply chains.
 
Avaya believes that workers at its suppliers’ facilities should be treated humanely, with dignity and respect, and have the right and the freedom to choose when and with whom they are employed. 
 
Code of Conduct
Operating with Integrity is Avaya’s worldwide code of ethics and business conduct. It provides information about the standards of integrity that Avaya requires Directors, officers and employees of Avaya and its subsidiaries to follow. We expect that our consultants, agents, representatives, business partners and suppliers will conform to the behaviors required by Operating with Integrity.
 
In addition to our worldwide code of conduct, our suppliers also must comply with our supplier codes of conduct.   Included within our supplier codes of conduct is the requirement that our suppliers behave in a lawful, ethical and socially responsible manner with respect to, among other things, human rights and acceptable working conditions.  Avaya will not tolerate child labor law violations or activities that promote human trafficking or forced or involuntary labor.
 
Direct Supplier Code of Conduct
Avaya maintains a direct supplier code of conduct, which applies to suppliers of goods and services used in the manufacture or distribution of our products or services.  The direct supplier code of conduct is based in large part on the electronic industry code of conduct promulgated by the Electronic Industry Citizenship Coalition (EICC). The EICC code outlines standards to ensure that working conditions in the electronics industry supply chain are safe, that workers are treated with respect and dignity, and that manufacturing processes are environmentally responsible.
 
Avaya regards its direct supplier code of conduct as part of a total supply chain initiative. As such, as part of our supply contracts, we require our direct suppliers to acknowledge and implement our direct supplier code of conduct. Direct suppliers are responsible for ensuring that all of their employees and any subcontracted party performing work for Avaya are informed and agree to comply with the direct supplier code.
 
Indirect Supplier Code of Conduct
Avaya also maintains an indirect supplier code of conduct, which applies to suppliers of indirect materials, or those goods and services purchased by Avaya for internal company use (i.e., materials other than those that are used in the manufacture or distribution of our products and services).  Avaya expects that all indirect suppliers and their employees understand and exhibit a dedication to integrity and ethics consistent with the behaviors described in the indirect supplier code of conduct.
 
Proactive Management
Avaya has requested confirmation from its primary direct suppliers as to whether or not they (i) are members of EICC and have adopted a version of the EICC code or are members of other similar organizations and/or (ii) have adopted and been certified to SA8000, a global social accountability standard for decent working conditions that has been developed by Social Accountability International, or an equivalent standard.  We have been advised that our primary direct suppliers are EICC members.  In addition, we have requested from our primary direct suppliers information regarding any third party audits that may have been conducted with respect to their EICC-based and related compliance programs.
 
While Avaya does not conduct formal audits of its supplier relationships, Avaya does engage in on-site visits of its primary direct supplier locations to observe performance with the terms of its supply agreements, which incorporate the supplier codes of conduct.  We are in the process of reviewing our supplier performance management process as it relates to EICC matters.
 
While Avaya does not require suppliers to certify that they and the materials that they incorporate into the products Avaya purchases from them comply with all applicable laws, Avaya’s supply contracts do contain provisions in which suppliers agree to comply with all laws related to their performance under those agreements.
 
Training and Enforcement
As indicated above, Avaya maintains a worldwide code of conduct.  In creating that code, we considered many different standards relating to the ethical and humane treatment of people, including the International Labour Organization (ILO) international labor standards and the United Nations Universal Declaration of Human Rights.  Avaya requires that its directors, officers and employees comply with the provisions of its code of conduct, and directors and employees receive training on that code.  In addition, Avaya is in the process of establishing training for those members of management and employees in senior roles within its organization who have direct responsibility for supply chain management as to how to mitigate risks within its supply chain with respect to human trafficking and slavery.
 
Because Avaya believes so strongly in ethical behavior, individuals who do not comply with the provisions of Avaya’s code of conduct may be disciplined. Unless otherwise prohibited by law (U.S. or other), discipline may include dismissal. To the extent permitted by law and contractual provisions governing termination rights, we reserve the right to terminate relationships with third parties, including suppliers, who conduct business in a manner that conflicts with Operating with Integrity.
 
For more information on Avaya’s direct supplier code of conduct, click here. 

For more information on Avaya’s indirect supplier code of conduct, click here.