Overview of Business Ethics
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.
Code of Conduct
The Code of Conduct has been designed to deter wrongdoing and to promote:
- Honest and ethical conduct;
- Full, fair, accurate, timely and understandable disclosure in financial reporting;
- Protection of confidential and proprietary information of Ribbon Communications and of our customers and partners;
- Compliance with applicable governmental laws, rules and regulations; and
- Prompt internal reporting of violations of the Code.
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.
Reporting Violations
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 in a number of jurisdictions to allow Ribbon Communications employees to report any concerns regarding situations at work that compromise the Code of Conduct. Anonymous employee reporting is permitted in accordance with applicable law. All submissions and phone calls will be kept confidential to the extent reasonably possible and legally permissible. We strongly encourage employees to utilize all the reporting options available to them 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 provision 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 Legal Officer, Patrick Macken, via email at pmacken@rbbn.com or by phone at (978) 614-8179, by email to the Legal Department at ribbon.law@rbbn.com, or by mail (recommended where anonymity is a concern) to Ribbon Communications' Audit Committee at the following address:
Audit Committee of the Ribbon Communications Board of Directors
c/o Corporate Secretary
6500 Chase Oaks Blvd
Plano, Texas 75023
Ribbon will maintain the confidentiality and anonymity of reports made by customers, partners stockholders to the extent reasonably possible and legally permissible.