Following the Rimini Street Way

in our marketplace

Rimini Street strives to provide high-quality products and services in an efficient manner. However, we must hold fast to our high standards of integrity and ethical business conduct as we pursue our corporate goals. The following section of the Code, Following the Rimini Street Way in Our Marketplace, outlines what is expected from each of us to accomplish this goal.

Fair Dealing

Rimini Street has become an industry leader based on the quality of our people, products, and services. Our commitment to fair dealing means that we:

  • Respect the diversity of each other’s talents, abilities and experiences.
  • Value the input of others.
  • Foster an atmosphere of trust, openness, and candor.

We will better understand the needs of our clients and foster innovation if each of us embraces diversity and inclusion in all aspects of our business.

Antitrust and Fair Competition

RiminiStreet is committed to outperforming our competitors legally and ethically within the framework of a free enterprise system. Therefore, you should:

  • Never comment on competitors’ products or services in an inaccurate or untruthful manner.
  • Only use legitimate means of obtaining competitive information.
  • Respect the confidential information and intellectual property rights of our competitors and other third parties.
  • Always comply with antitrust and competition laws.

When dealing with competitors, you should never enter into any agreement, whether formal or informal, written or verbal, to set prices or other terms of sale; coordinate bids; allocate clients, sales territories, or product lines; or engage in any other activity that violates antitrust or competition laws. You should never discuss such topics with a competitor, even in an informal setting such as a trade show or client event.

Violations of antitrust or competition laws may result in imprisonment for the individuals involved, as well as severe legal penalties for both the individuals and our Company. Competition laws are complex and vary by country. For guidance, you should refer to our Antitrust Compliance Policy or consult the Legal Department. If you suspect an antitrust violation, report it immediately.

Q&A

How will I know if there is a problem?

The last page of the Code contains links to many of the Company’s global compliance policies. Rimini Street has also adopted other internal corporate policies, including country-specific and function-related policies, covering a variety of topics. Because these policies may vary by business unit or market, they are not linked to the Code. You can find all Rimini Street policies on our Company intranet sites. You can also ask your manager or HR for copies of applicable policies.

  • Is this course of action illegal?
  • Would it violate the Code or other policies?
  • Could it be considered unethical or dishonest?
  • Could it hurt Rimini Street’s reputation or put our Company at risk?
  • Will this hurt employees, clients, investors, or other third parties?
  • Will it reflect poorly on me or Rimini Street? Would I be embarrassed or ashamed if others knew about it?

Anti-Money Laundering

Money laundering is is the process of taking cash or assets obtained from illegal activities into legitimate financial activities. RiminiStreet’s operating practices ensure that our employees, products, services and facilities will only be used for legitimate purposes. You must not participate in or facilitate money laundering and you must not engage in conduct that is designed to avoid the Company’s financial controls. Failure to comply could result in disciplinary action up to and including clawbacks and/or termination.

Marketing and Sales Practices

Rimini Street’s marketing and sales practices must reflect our high ethical standards, and must be truthful, understandable and in compliance with all laws. We must:

  • Make only fair, factual comparisons between our products and those of our competitors.
  • Never misstate facts or confuse or mislead current or prospective clients about Company advertisements or promotions.
  • Follow all applicable RiminiStreet sales policies and procedures to ensure we do not engage in unethical or deceptive sales practices.
  • Never place or record an order for our products and services for a client without that client’s authorization.

Competitive Information

Gathering information about our product and service categories is essential to protecting our market position, but we must be careful to acquire information only in a legal, ethical, and respectful manner. If a co-worker, client, or business partner is in possession of competitive information that must be kept confidential, we must not encourage them to disclose it to us. Be particularly mindful of this restriction when talking to new Rimini Street employees about their former employers. While conducting RiminiStreet business, if you obtain or become aware of confidential, trade secret, or proprietary information about another company or competitor that has been inadvertently or intentionally disclosed, consult our Legal Department or contact the Compliance Helpline. Do not use or act on this information. We must not use information if we have no legal or ethical right to it.

Transactions and Relationships with Suppliers

At Rimini Street, we select our suppliers based on financial and non financial objective criteria, such as risk profile, quality, and total cost of service. We believe in doing business with suppliers who embrace and demonstrate our high standards of integrity and ethical business conduct. We expect others working with or on Rimini Street’s behalf, including suppliers, to act ethically and in a manner consistent with our…

Remember…

We must never ask a supplier or other third party to engage in any activity that violates the ethical and legal standards set forth in the Code or the Supplier Code of Business Conduct and Ethics.

“Supplier Code of Business Conduct and Ethics.” If you are responsible for evaluating and hiring suppliers or other third parties to work on behalf of Rimini Street, you should take reasonable steps to ensure these suppliers and third parties have a reputation for integrity and act in a responsible manner consistent with our ethical standards. This may include consulting with Procurement, LegalDepartment, or Ethics & Compliance colleagues before hiring third parties or suppliers.

Business Courtesies — Gifts, Meals, and Entertainment

In general, Rimini Street does not believe in offering gifts to or accepting gifts from third parties due to the risk of an appearance of improper conduct, and it is easiest to simply not engage in such exchanges.It is important to understand the applicable rules regarding business courtesies and to avoid even the appearance of improper conduct with our clients, suppliers, or any others with whom we do business.

Do

  • Accept or give business courtesies only if they comply with the Code, the law, and other Rimini Street policies, including the Global Business Courtesies Policy.
  • Racial slurs, ethnic, religious, age or sex-based insults, comments, stereotypes, or jokes.
  • Business courtesies must be appropriate under the circumstances.
  • Always use good judgment with business courtesies that involve entertainment.
  • Ask if a government official is involved before proceeding.
  • Team members who are in a position of procuring goods or services should be particularly mindful of accepting business courtesies in order to avoid the appearance of impropriety.

Business courtesies are broadly defined to include, but are not limited to, gifts; meals; entertainment; travel and lodging; and charitable donations made at the request of a client, supplier, or others with whom we do business. Business courtesies must be reasonable in value, infrequent, provided openly and transparently, given without expecting any return favor or improper benefit or business advantage, and not otherwise creating the appearance of impropriety. Also, please note the following general guidelines:

Do Not

  • Never give or accept cash, cash equivalents (such as American Express®, Visa®, or MasterCard® gift cards, gift certificates, or shopping cards) or any other item that can be easily converted to cash.
  • Never give or accept lavish or extravagant business courtesies.
  • Never provide, accept, or participate in entertainment that is indecent or sexually explicit or that may otherwise harm the reputation of Rimini Street.
  • Never solicit business courtesies from suppliers.
  • Never accept a business courtesy that would influence — or create an appearance that it would influence — your business decision or judgment.

If you are offered or wish to give a business courtesy that falls outside of these guidelines or does not appear to comply with applicable Company policies, contact Ethics & Compliance to obtain pre approval before accepting or offering the business courtesy. For more information, refer to the Global Business Courtesies Policy.

Special rules apply when offering business courtesies
to government officials or their family members. Business courtesies offered to or received from a government official even if part of a commercial contractual arrangement — must be pre approved, in writing, by Ethics & Compliance. For more information, refer to our Global Anticorruption Policy or contact the Compliance Helpline.

Q&As

A Rimini Street business partner who is bidding on work in my department has offered me her two tickets to a local concert because she cannot make the event. The tickets are not expensive. May I go?

No. Even if the tickets are inexpensive, accepting them would be inappropriate. Since the business partner is not attending the concert with you, this offer is considered a gift. Because this gift was extended during a competitive bidding process, accepting the tickets could suggest to others that the business partner is trying to win your favor and therefore Rimini Street’s business. You must ensure that all business decisions are made objectively and that there is not even the appearance of something improper. Politely decline the offer and report the incident to your manager and to Ethics & Compliance.