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We believe that long-term, trusting relationships with investors, customers and employees are built through honesty, openness and fairness. We are committed to upholding the highest professional standards in all global business operations. We also expect that our employees and those with whom we do business will also adhere to these standards of conduct.
Outstanding, devoted employees are key to Ribbon Communications' success. Everyone is part of the company team, and each of us deserves to be treated with dignity and respect. In addition, every employee is responsible for his or her own conduct. Managers, in particular, set an example for other employees. Ribbon Communications requires all employees, including managers, to know and understand the Code of Conduct and other Ribbon Communications policies, as they apply to the employee or manager and to those under his or her supervision.
Each employee has a responsibility to understand legal and ethical boundaries and to comply with all applicable laws and regulations in all of Ribbon Communications' operations globally. In addition, each employee must use sound judgment and common sense in following the spirit of Ribbon Communications' polices and doing the right ethical thing whether dealing with other employees or with customers, partners and investors.
The Code of Conduct has been designed to deter wrongdoing and to promote:
The Code outlines the broad principles of legal and ethical business conduct embraced by Ribbon Communications. It is not a complete list of legal or ethical questions an employee might face in the course of business, and therefore, the Code must be applied using common sense and good judgment.
In addition, the Code includes Ribbon Communications' policy with respect to corporate reporting and disclosure, accounting and auditing controls and procedures, securities compliance and other matters pertaining to fraud against stockholders. Ribbon Communications' internal operating controls and corporate reporting and disclosure procedures are intended to prevent, deter and remedy any financial reporting violations. Even the best systems of controls and procedures, however, cannot provide absolute safeguards against such violations. Therefore, Ribbon Communications impresses upon all of its employees that they have a responsibility to report any inappropriate conduct or concerns relating to corporate reporting and disclosure, accounting and auditing controls and procedures and securities compliance.
The Code of Conduct is monitored by Ribbon Communications' Legal, Human Resources and Internal Audit organizations. The Code applies to all employees of Ribbon Communications, Inc. and its subsidiaries.
All Ribbon Communications employees are responsible for promptly reporting any issue or concern they believe in good faith may constitute a violation of the Code or any other Ribbon Communications policy. Employees who have questions regarding business conduct or possible violations of the Code should contact their manager, Human Resources, Internal Audit or the Legal Department. We also have established an internal employee hotline designed specifically to allow Ribbon Communications employees to report anonymously any concerns regarding situations at work that compromise the Code of Conduct. All submissions and phone calls will be kept anonymous. We strongly encourage employees to utilize this service to speak up about any ethical violations. It is against Ribbon Communications policy to retaliate against any employee for good faith reporting of violations of the Code of Conduct.
Ribbon Communications' ethics compliance program is also available to all customers, partners and stockholders who wish to bring to Ribbon Communications' attention any potential violations of or noncompliance with Ribbon Communications' Code of Conduct. If any person reasonably believes that Ribbon Communications or any of its employees or others, acting on behalf of Ribbon Communications, have violated any of the Company's Code of Conduct, or any securities laws or regulations, the person should immediately report any such potential violation to the Company's Chief Financial Officer, Mark Greenquist at firstname.lastname@example.org, (978) 614-8200 or by email to email@example.com. Any such complaints may be submitted on an anonymous basis. If you are concerned about maintaining anonymity, you may send correspondence directly to Ribbon Communications' Audit Committee at the following address:
Audit Committee of the Ribbon Communications Board of Directors
4 Technology Park Drive
Westford, MA 01886