Following the Rimini Street Way

in the global community

RiminiStreet is committed to enhancing the communities we serve around the globe. We provide financial, technological, and volunteer resources to support our communities because they’re not just the places where we do business — they’re also the places where we live. The following section of the Code, Following the Rimini Street Way in the Global Community, describes our commitment to being good corporate citizens and what is expected of all Rimini Street team members in this regard.

Anti-Bribery and Anti-Corruption

Corrupt arrangements with clients, suppliers, government officials, or other third parties are strictly prohibited. “Corruption” generally refers to obtaining, or attempting to obtain, a personal benefit or business advantage through improper or illegal means.
Corruption may involve payments or the exchange of anything of value and includes, but is not limited to, bribery (including bribery of any public or government official, political candidate, or private individual), extortion, and kickbacks.

Corrupt activities are not only a Code violation, they can also be a serious violation of criminal and civil anti-bribery and anti-corruption laws, including but not limited to
theU.S.ForeignCorruptPracticesAct (“FCPA”) and the United Kingdom’sBriberyAct. For more information, consult the Global Anti-Corruption Policy or contact Ethics & Compliance. Should you become aware of any actual or potential corrupt payment, arrangement or agreement, report it immediately.

Key Terms

A kickback is a form of corruption that involves two parties agreeing that a portion of sales or profits will be improperly given, rebated or kicked back, to the purchaser in exchange for making the deal. For example, a kickback might involve a supplier who offers a Rimini Street employee a monthly payment equaling 5% of Rimini Street’s purchases as an inducement to the employee to retain the supplier’s services. Kickbacks, like other forms of corruption, are unethical and prohibited under the Code, our policies, and the law.

Remember…

Corruption may involve the exchange of anything of value. “Anything of value” is very broad and could include goods; services or merchandise, such as cash, cash equivalents, gift cards, vouchers, hospitality, meals, event tickets, retail certificates, entertainment, travel perks, use of vacation homes, airfare or accommodations; special favors or privileges, such as educational, employment, or club membership opportunities for friends and relatives; stock options; donations to designated charities; discounts; personal services; loans; cosigning of a loan or mortgage; or a promise of future employment.

Q&A

A long-time, trusted supplier offered me a commission in exchange for securing an annual contract with Rimini Street for his company. Is there any problem with this?

Yes, in this case, the “commission” for doing business constitutes a kickback, which is unethical and potentially illegal. Let the supplier know that this kind of request violates Rimini Street policy and report the incident to your manager and Ethics & Compliance.

Are there special requirements for charitable donations and sponsorships?

Because charitable donations and sponsorships can pose a corruption risk to Rimini Street, you should refer to the Global Anti-Corruption Policy for requirements and guidelines involving charitable donations and sponsorships to government entities or relating to government officials.

RiminiStreet is committed to conducting business fairly and legally and opposes all forms of public and private corruption. We comply with anti-bribery and anti-corruption laws and will not offer or pay improper payments or bribes to influence a business decision or gain a business advantage. We will not seek to improperly influence a government decision or gain a business advantage by offering or accepting gifts, entertainment, travel, employment, charitable donations, or other benefits to or from an intermediary. We will not request or accept any bribe, kickback, or improper payment to award a Rimini Street contract or business to a third party. Finally, we maintain internal financial controls to prevent bribery and corruption and keep accurate books and records so as not to disguise bribes or other improper payments as legitimate business expenses.

Laws prohibiting bribery and corruption apply to both government officials and private business persons (known as “commercial bribery”). In some countries, team members or third parties may come under pressure to offer improper payments or bribes to influence business decisions or gain business advantages such as sales, government permits,

or government or private services. Similarly, team members may be offered a bribe or kickback to award a Rimini Street contract or business. Never request, offer, or agree to bribes, kickbacks, or other improper payments.They are illegal in most countries, prohibited by Rimini Street, and can expose you and Rimini Street to criminal prosecution.

Be careful when dealing with government officials. For purposes of our Global Anti-Corruption Policy and applicable anti-bribery and anti-corruption laws, a government official is interpreted broadly to encompass a number of different categories. Please consult the Q&A for a detailed set of examples. Subject to a number of narrowly tailored exemptions identified in the Global Anti-Corruption Policy, all payments and gifts to, and entertainment of, government officials must be pre approved in writing by Ethics & Compliance. All payments, both direct and indirect, made to government officials must also be accurately recorded in our Company’s books and records. If you are unsure whether you might be dealing with a government official or have any other related questions you should contact Ethics & Compliance for guidance.

Key Terms

Commercial bribery is a form of bribery which involves corrupt dealing with the agents or employees of potential buyers to secure an advantage over business competitors. It is a form of corruption that does not necessarily involve government personnel or facilities.

“Facilitating payments” are improper payments made to a government official or employee to expedite or facilitate a routine government action. It is against Company policy to make facilitating payments unless there is an imminent threat to your or another individual’s health, safety, or welfare.Whenever possible, you must obtain pre approval from Ethics & Compliance and report such a facilitating payment immediately when pre approval is not possible. If you have any question whether a payment qualifies as a facilitating payment, contactEthics & Compliance.

For more information, consult our Global Anti-Corruption Policy or contact Ethics & Compliance. If you become aware of or if you are asked to make an improper payment or bribe or are offered a bribe or kickback to award aRimini Street contract or business, immediately contact your manager and report the information to Ethics & Compliance or the Compliance Helpline.

Business people in the office

Key Terms

Rimini Street prohibits retaliation against any employee who raises a concern in “good faith.” Good faith reporting means you have made a genuine attempt to provide honest and accurate information, even if you are later proven to have been mistaken. However, it is a violation of the Code to knowingly make a false statement or accusation, to lie to an investigator, or to interfere or refuse to cooperate with an investigation.

Q&As

What are examples of a “government official” under our Global Anti-Corruption Policy?

“Government officials”may include:

  • All government employees, including employees of regulatory agencies or departments, such as environmental, licensing, tax, and customs
  • Any candidate for political office, any political party, or an official of a political party
  • Representatives of public international organizations and charities, such as the World Bank,UNICEF, International Red Cross, or the World Health Organization
  • Mayors or other local city officials
  • Members of law enforcement, including the military, local police, and other enforcement agencies
  • Employees of state-owned enterprises, such as purchasing managers of government-run airlines, universities, school systems, hospitals, television stations, utilities (oil, gas, water, and electrical companies), laboratories, defense contractors, or other commercial enterprises that are owned, controlled, or managed by a government
  • Members of royal families
  • Spouses or immediate family members of any of the foregoing
I was told I could hire a local company to help get all the necessary permits from a foreign government. An advance payment has been requested to “help move the process along.” I have been told this is a common practice in this country. Is it OK for me to make this payment?

No. The request for an advance payment is a potential red flag, and the comment that such payment is intended to “help move the process along” is even more concerning. This advance payment may be considered a facilitating payment, which is not allowed as a matter of Company policy. Consult with Ethics & Compliance before proceeding.

International Trade Controls

As a global company, Rimini Street transfers products, services, and technologies across national borders. Our business transactions are subject to various sanctions, or trade controls and laws, including:

  • Government-imposed export controls, trade restrictions, trade embargoes, legal economic sanctions and boycotts.
  • Anti-boycott laws that prohibit companies from participating in or cooperating with an international boycott that is not approved or sanctioned by the U.S. government.
  • Sanctions by different governments around the world that restrict activities with certain countries, entities, or individuals.

RiminiStreet is committed to ensuring that these business transactions are accomplished in full compliance with applicable sanctions or trade controls and laws. If you are involved in the transfer of products, services, or technologies across national borders on behalf of our Company or our clients, you must comply with these laws, regardless of where you are located. If U.S.law conflicts with a local trade law, U.S. law may apply.Always consult with Ethics & Compliance for proper guidance on this subject.

Human Rights

RiminiStreet recognizes the importance of maintaining and promoting fundamental human rights in our operations around the world. We implement and maintain programs and policies that:

  • Promote a workplace free of discrimination and harassment.
  • Prohibit child labor, forced labor, and human trafficking.
  • Provide fair and equitable wages, benefits, and other conditions of employment in accordance with local laws.
  • Provide humane and safe working conditions, including safe housing conditions, where applicable.
  • Recognize employees’ right to freedom of association and collective bargaining.

We expect our suppliers and business partners to uphold these core principles as well. Always check your actions to ensure that they do not violate or contradict any of the basic human rights principles noted above. If you suspect a human rights abuse within our operations or supply chain, report it.

Environment

We are committed to engaging in environmentally sound practices.We therefore must meet or exceed the requirements set forth by applicable environmental laws, rules, and regulations that govern our business. We must also continually assess and strive to improve our processes in order to continue our commitment to environmental stewardship. If you know of a practice that is harmful to the environment or does not comply with our Company’s policies or with governing laws, rules, and regulations, you have a duty to report it.

Community Support

We make a positive difference in our communities through volunteer work and charitable contributions. While you are always free to make your own personal charitable contributions as you see fit, only authorized Rimini Street personnel and organizations can make donation commitments on behalf of the Company. Rimini Street gives back to our communities by partnering with select nonprofit organizations and through special initiatives, such as in-kind donations, employee time, and financial donations made through the Rimini Street Foundation, which is a program operated by the Company and privately funded by Rimini Street, Inc. You can contact the Rimini Street Foundation for more information.

Political Activities

Employees are encouraged to participate in their local political process in a manner consistent with applicable law and Company guidelines. Your decisions to contribute your own time or money to any political or community activity are entirely personal and voluntary. Employees may make political contributions in their own names. However, you may not use Company funds or resources or receive Company reimbursement for personal political activities, including contributions to political candidates or parties. You should avoid even the appearance of doing so.

Rimini Street obeys all laws in promoting our Company’s position relative to government authorities and in making political contributions.