Remember...
Anti-Bribery/Anti-Corruption
Our Policy
Avaya prohibits giving or offering anything of value to anyone to improperly:
- Influence any decision that impacts Avaya
- Obtain or retain business for Avaya
- Secure any business advantage for Avaya
Avaya also prohibits facilitation or grease payments, which are payments made directly to government officials designed to speed up routine government processes or activities. Generally, facilitation payments are made in cash and to a person. Please note that expediting fees that are published and universally available are not deemed facilitation payments and are acceptable.
Avaya also prohibits commercial bribery, which violates the laws of many countries (e.g., UK Bribery Act, US Foreign Corrupt Practices Act). Any bribe or improper payment to current or prospective customers, including, but not limited to, government officials, or suppliers could subject you to consequences beyond disciplinary action by Avaya, such as prosecution.
Prevent bribery by others who conduct business on our behalf by complying with the processes established to ensure that we know the third parties with whom we are engaging in business, understanding the scope of each transaction and ensuring discounts are passed down to the appropriate end customer.
Showing Accountability and Trustworthiness
Never give anything of value to influence a decision or obtain improper business.
Follow the corporate gift giving guidelines.
Do not donate Avaya funds to political entities.
Notify the Ethics and Integrity Team if you are being directed to use a specific consultant by a government employee, business partner, or supplier.
Follow company guidelines for engaging partners, suppliers, and consultants.
The Finance department manager needs to take an international business trip on short notice to conduct business in person; however, she needs a visa to do so. The manager’s assistant learns that the process of obtaining a visa takes longer than she’d anticipated, and now she’s looking for a way to expedite the process. What should she do?
In many cases, the office, agency, or department you are working with will offer an expedited service at a set and published fee schedule. Payment of this fee may be allowed under our policy. However, if you are asked to make a facilitation payment, seek guidance from the legal department. Facilitation payments are illegal under numerous international anti-corruption laws and prohibited under Avaya policy.