Supplier Code of Conduct

Our Commitment

We work in an energetic global industry where the pace is fast and change is constant. But, there are some things that don’t change at Ribbon Communications (also, “Ribbon”) - our commitment to doing business honestly, ethically, and with respect for others. It is to this end that Ribbon Communications has implemented this Supplier Code of Conduct (“Code”) which mirrors many of the principles set forth in Ribbon Communication’s Code of Conduct.

It has always been paramount to our way of doing business at Ribbon Communications to comply with applicable law and to act with the utmost integrity, honesty, and transparency. Ribbon Communications is committed to acting responsibly in all our business dealings to ensure that we comply with applicable national and international legislation, including laws regarding anti-corruption, anti-trust, anti-bribery and fair competition, and human rights. Ribbon Communications will forgo business opportunities rather than act in an unethical manner and/or in violation of applicable law. Preserving an ethical workplace is critical to our long-term success as a company.

At Ribbon Communications, the message for each Ribbon Communications’ Supplier is clear: any success that is not achieved lawfully and ethically is no success at all. At Ribbon Communications, we obey applicable law and strive to hold ourselves to the highest ethical standards, and we expect the same of all our Suppliers. 

Human Rights and Labor

Ribbon’s Suppliers must commit to respect the human rights of workers, and to treat them with dignity and respect. This applies to Ribbon’s direct and indirect Suppliers, as well as all workers including temporary, migrant, student, contract, direct employe, and any other type of worker. In light of these commitments, Ribbon Communications’ Suppliers will:

Support Freely Chosen Employment: Forced labor in any form, including but not limited to, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons is not permitted. This includes transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction, or fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities including, if applicable, workers’ dormitories or living quarters. As part of the hiring process, all workers must be provided with a written employment agreement in their native language, or in a language which the worker can understand, that contains a description of terms and conditions of employment. Foreign migrant workers must receive the employment agreement prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. All work shall be voluntary, and workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given, which shall be clearly stated in workers’ contracts. Supplier shall maintain documentation on all leaving workers. Employers, agents, and sub-agents may not hold or otherwise destroy, conceal, or confiscate identity or immigration documents, such as government-issued identification, passports, or work permits. Notwithstanding the foregoing, employers can only hold documentation if necessary to comply with the local law. In this case, at no time shall workers be denied access to their documents. Workers shall not be required to pay employers’, agents’ or sub-agents’ recruitment fees or other related fees for their employment.  If any such fees are found to have been paid by workers, such fees shall be repaid to the worker. See Ribbon's Anti-Slavery and Human Trafficking Statement.

Comply with Young Workers Regulations: Child labor shall not be used in any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Supplier shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable laws and regulations. Supplier shall implement an appropriate mechanism to verify the age of workers. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported. Supplier shall provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks. If child labor is identified, assistance/remediation shall be provided.

Maintain Appropriate Working Hours:  Working hours shall not exceed the maximum set by local law. Further, a workweek shall not be more than 60 hours per week, including overtime, except in emergency or unusual situations. All overtime shall be voluntary. Supplier shall ensure that workers take at least one day off every seven days.

Provide Appropriate Wages and Benefits: Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. All workers shall receive equal pay for equal work and qualifications. Workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labor shall be within the limits of the local law.

Implement Non-Discrimination, Non-Harassment, and Humane Treatment Policies and Processes: Supplier shall commit to a workplace free of harassment and unlawful discrimination. There shall be no harsh or inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment. Supplier shall not engage in discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity or expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers. Workers shall be provided with reasonable accommodation for religious practices and disability. In addition, workers or potential workers should not be subjected to medical tests, including pregnancy or virginity tests, or physical exams that could be used in a discriminatory way.

Allow Freedom of Association and Collective Bargaining:  Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment. In alignment with these principles, supplier shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Where the right of freedom of association and collective bargaining is restricted by applicable laws and regulations, workers shall be allowed to elect and join alternate lawful forms of worker representations.

Health and Safety

Ribbon’s Suppliers must recognize that in addition to minimizing the incidence of work-related injuries and illnesses, a safe and healthy working environment enhances the quality of products and services, consistency of production and worker retention and morale.  Suppliers must also recognize that ongoing worker input and education are essential to identifying and solving health and safety issues in the workplace. At a minimum, Supplier will ensure that the following health and safety standards are followed and adhered to: 

Occupational Safety: Worker potential for exposure to health and safety hazards (chemical, electrical and other energy sources, fire, vehicles, and fall hazards, etc.) shall be identified and assessed, mitigated using the Hierarchy of Controls. Where hazards cannot be adequately controlled by these means, workers shall be provided with appropriate, well-maintained, personal protective equipment and educational materials about risks to them associated with these hazards. Gender-responsive measures shall be taken, such as not having pregnant women and nursing mothers in working conditions which could be hazardous to them or their child and to provide reasonable accommodations for nursing mothers. Workers shall be encouraged to raise safety concerns.

Emergency Preparedness: Potential emergency situations and events shall be identified and assessed, and their impact minimized by implementing emergency plans and response procedures including emergency reporting, employee notification and evacuation procedures, worker and drills. Emergency drills shall be executed at least annually or as required by local law, whichever is more stringent. Emergency plans shall also include appropriate fire detection and suppression equipment, clear and unobstructed egress, adequate exit facilities, contact information for emergency responders, and recovery plans. Such plans and procedures shall focus on minimizing harm to life, the environment, and property.

Occupational Injury and Illness: Procedures and systems shall be in place to prevent, manage, track and report occupational injuries and illnesses, including provisions to encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases, and implement corrective actions to eliminate their causes and facilitate the return of workers to work. Supplier shall allow workers to remove themselves from imminent harm, and not return until the situation is mitigated, without fear of retaliation.

Industrial Hygiene: Worker exposure to chemical, biological, and physical agents shall be identified, evaluated, and controlled according to the Hierarchy of Controls. When hazards cannot be adequately controlled, workers shall be provided with and use appropriate, well-maintained, personal protective equipment free of charge. Supplier shall provide workers with safe and healthy working environments, which shall be maintained through ongoing, systematic monitoring of workers’ health and working environments. Supplier shall provide occupational health monitoring to routinely evaluate if workers’ health is being harmed from occupational exposures. Protective occupational health programs shall be ongoing and include educational materials about the risks associated with exposure to workplace hazards.

Physically Demanding Work: Workers exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks shall be identified, evaluated, and controlled.

Machine Safeguarding: Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks, and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.

Sanitation, Food, and Housing: Workers shall be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the Supplier or a labor agent shall be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting and adequate conditioned ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.

Health and Safety Communication: Supplier shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including but not limited to mechanical, electrical, chemical, fire, and physical hazards. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Health information and training shall include content on specific risks to relevant demographics, such as gender and age, if applicable. Training shall be provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise any health and safety concerns without retaliation.

Environment

Ribbon’s Suppliers must demonstrate good stewardship of the environment by minimizing the adverse effects of their operations on the community, environment, and natural resources, while safeguarding the health and safety of the public.Suppliers are expected to meet the following requirements:

Environmental Permits and Reporting: All required environmental permits (e.g. discharge monitoring), approvals and registrations must be obtained, maintained and kept current and their operational and reporting requirements must be followed.

Pollution Prevention and Resource Reduction: Emissions and discharges of pollutants and generation of waste of all types, including water and energy, must be reduced or eliminated at the source or by practices such as adding pollution control equipment, modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.The use of natural resources, including water, fossil fuels, minerals, and virgin forest products, must be conserved by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling or other means.

Hazardous Substances: Chemicals and other materials posing a hazard if released to the environment must be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

Water Management and Solid Waste: Implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).Supplier must implement a water management program that documents, characterizes and monitors water sources, use and discharge, seeks opportunities to conserve water, and controls channels of contamination. Wastewater generated from operations, industrial processes and sanitation facilities must be characterized, monitored, controlled and treated as required prior to discharge or disposal. In addition, measures must be implemented to reduce generation of wastewater. Supplier must conduct routine monitoring of the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

Materials Restrictions: Supplier must comply with all applicable laws, regulations, and Ribbon requirements regarding the prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal.  

Air Emissions: Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations must be characterized, routinely monitored, controlled and treated as required prior to discharge. Supplier shall conduct routine monitoring of the performance of its air emission control systems.

Materials Restrictions: Supplier must adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal.

Storm Water Management: Supplier shall implement a systematic approach to prevent contamination of storm water runoff. Supplier shall prevent illegal discharges and spills from entering storm drains.

Energy Consumption and Greenhouse Gas Emissions: Supplier must establish a greenhouse gas reduction goal. Energy consumption and greenhouse gas emissions are to be tracked, documented, and publicly reported by Supplier against its greenhouse gas reduction goal. Supplier must look for and implement methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions.

Business Conduct and Ethics

Ribbon Suppliers must commit to, and enforce, the highest standards of ethical conduct and fair business practices including the following:

Business Integrity: The highest standards of integrity shall be upheld in all business interactions. Supplier shall have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion, and embezzlement.

No Improper Advantage: Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorized, given, or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Supplier agrees that it will not cause Ribbon or one of its customers to be in breach of any such laws and will maintain programs to prevent and detect violations of such laws. Supplier will report to Ribbon an allegation of bribery or corruption made in court, arbitration or in administrative proceedings against Ribbon or Supplier and will reasonably assist Ribbon in the investigation required by a government agency with regard to a breach of any such laws. Monitoring, record keeping, and enforcement procedures shall be implemented to ensure compliance with anti- corruption laws.

Disclosure of Information: All business dealings shall be transparently performed and accurately reflected in the Supplier’s business books and records. Information regarding Supplier’s labor, health and safety, environmental practices, business activities, structure, financial situation, and performance shall be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.

Intellectual Property: Intellectual property rights shall be respected. The transfer of technology and know-how is to be done in a manner that protects intellectual property rights, and customer and supplier information shall be safeguarded.

Fair Business, Advertising and Competition: Standards of fair business, advertising and competition shall be upheld. Appropriate means to safeguard customer information must be available.

Protection of Identity and Non-Retaliation: Programs that ensure the confidentiality, anonymity, and protection of supplier and employee whistleblowers must be maintained, unless prohibited by law. Supplier shall have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.

Responsible Sourcing of Minerals: Supplier shall adopt a policy and exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten, gold, and cobalt in the products they manufacture to reasonably assure that they are sourced in a way consistent with the Organization for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, or an equivalent and recognized due diligence framework. See also Ribbon’s Conflict Minerals Policy.

Privacy:  Supplier shall commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Supplier shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared. See also Ribbon’s Privacy Policy.

Monitoring and Compliance

Ribbon’s Suppliers are expected to establish and maintain an appropriate management and monitoring system to ensure compliance with the law and this Code as set forth below.

Compliance: Suppliers must keep all information necessary to document their compliance with the law and this Code. Ribbon requires all of its Suppliers to contractually commit to compliance with this Code and all applicable laws in the country or countries in which they are doing business for Ribbon. Further and upon prior written notice, Ribbon may, through itself or a third party, at Ribbon’s cost, audit Supplier’s books, records, practices, and facilities to ensure Supplier’s compliance with this Code and applicable law.

Reporting Noncompliance: Suppliers as well as their employees, contractors, suppliers, and subcontractors must report to Ribbon any known or suspected violations of applicable law, rules, regulations or this Code by Ribbon employees, contractors, suppliers, or by Supplier employees, contractors, or subcontractors. Reports can be made via email to Ribbon.Law@rbbn.com, via mail addressed to the Audit Committee of the Ribbon Communications’ Board of Directors, c/o General Counsel, 6500 Chase Oaks Blvd, Suite 100, Plano, Texas 75023, or via telephone at +(978) 614-8170.

Management System: Suppliers are expected to establish a management system whose scope is related to the contents of this Code. The management system shall be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the Supplier’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement. The management system should contain the following elements:

Supplier Commitment: Supplier shall establish human rights, health and safety, environmental, and ethics policy statements affirming Supplier’s commitment to due diligence and continual improvement, endorsed by executive management. Policy statements shall be made public and communicated to workers in a language they understand via accessible channels.

Management Accountability and Responsibility.  Supplier shall clearly identify senior executive and company representative(s) responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management systems on a regular basis.

Legal and Customer Requirements.  Supplier shall adopt or establish a process to identify, monitor, and understand applicable laws, regulations, and customer requirements, including the requirements of this Code.

Risk Assessment and Risk Management: Supplier shall adopt or establish a process to identify the legal compliance, environmental, health and safety, labor practice and ethics risks, including the risks of severe human rights and environmental impacts, associated with Supplier’s operations. Supplier shall determine the relative significance for each risk and implement appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.

Improvement Objectives: Supplier shall establish written performance objectives, targets, and implementation plans to improve the Supplier’s social, environmental, and health and safety performance, including a periodic assessment of Supplier’s performance in achieving those objectives.

Training: Supplier shall establish programs for training managers and workers to implement Supplier’s policies, procedures, and improvement objectives to meet applicable legal and regulatory requirements.

Communication: Supplier shall establish a process for communicating clear and accurate information about Supplier’s policies, practices, expectations, flow down- contractual obligations (including under this Code pursuant to a contract with Ribbon), and performance to workers, suppliers, and customers.

Worker/Stakeholder Engagement and Access to Remedy: Supplier shall establish processes for ongoing two-way communication with workers, their representatives, and other stakeholders where relevant or necessary. The process shall aim to obtain feedback on operational practices and conditions covered by this Code, and to foster continuous improvement. Workers shall be given a safe environment to provide grievance and feedback without fear of reprisal or retaliation.

Reports and Anti-Retaliation: Supplier shall create accessible mechanisms and procedures to assess employee’s suppliers and subcontractors’ understanding of, compliance with, and to obtain reports regarding actual or suspected violations of, Supplier policies, applicable law, and this Code.  All interested parties, including Supplier employees, must be able to make reports free from unlawful retaliation.

Audits and Assessments: Supplier shall conduct periodic self-evaluations to ensure conformity with legal and regulatory requirements, the contents of this Code, and customer contractual requirements related to social and environmental responsibility.

Corrective Action Process: Supplier shall establish a process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews.

Accountability Standards and Procedures: Supplier shall maintain internal accountability standards and procedures for employees, contractors, and suppliers failing to meet the standards set forth in this Code.

Documentation and Records: Supplier shall create and maintain documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

Supplier Responsibility: Supplier shall establish a process to communicate this Code’s requirements to its suppliers and to monitor supplier compliance to this Code.

References

Responsible Business Alliance Code of Conduct (2024) Version 8.0

Ribbon Privacy Policy

Ribbon Conflict Minerals Policy

Ribbon Code of Conduct

Ribbon Anti-Slavery and Human Trafficking Statement

Ribbon Sustainability Report

ILO Fundamental Conventions

• Freedom of Association and Protection of the Right to Organise Convention, 1948 (No.87)
• Right to Organise and Collective Bargaining Convention, 1949 (No.98)
• Forced Labour Convention, 1930 (No.29)
• Abolition of Forced Labour Convention, 1957 (No.105)
• Minimum Age Convention, 1973 (No.138)
• Worst Forms of Child Labour Convention, 1999 (No.182)
• Equal Remuneration Convention, 1999 (No.100)
• Discrimination (Employment and Occupation) Convention, 1958 (No.111)
• Occupational Safety and Health Convention, 1981 (No.155), and the Promotional Framework, 2006 (No.187)

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

OECD Guidelines for Multinational Enterprises

National Institute for Occupational Safety and Health (NIOSH): Heirarchy of Controls

Greenhouse Gas Protocol: Standards