Getting Started:

Understanding the Code and your responsibilities

At Rimini Street, we believe acting ethically and responsibly is not only the right thing to do, but also the right thing to do for our business. To further this commitment, Rimini Street has implemented its Global Ethics and Compliance Program, which is designed to communicate the ethical and legal standards that govern our business conduct. The following section of the Code, Getting Started — Understanding the Code and Your Responsibilities, provides an overview of the Code, summarizes your role in doing business the right way, and tells you how you can raise concerns or seek guidance on a variety of topics.

Why do we have a Code?

The Rimini Street Code of Business Conduct and Ethics (the “Code”) is our roadmap for doing business the right way — the Rimini Street Way. Put simply, you do business the right way when you act ethically and consistently with our Core Values, the Code, our policies, and the law.

Each of us is expected to embrace the principles of the Code and follow the Rimini Street Way in our workplace, in our marketplace, in our business operations, and in the global community.

Who must follow the Code?

The Code applies to anyone who works for or on behalf of Rimini Street, Inc., its subsidiaries, or controlled affiliates (collectively, “Rimini Street” or the “Company”). This includes:

  • All Rimini Street officers and employees around the world (including officers and employees of our subsidiaries).
  • Members of the Rimini Street, Inc. Board of Directors and directors of Rimini Street subsidiaries, when they act in their capacity as directors.
  • Entities in which Rimini Street owns more than 50 percent of voting rights or which Rimini Street has the right to control and every employee, officer, and director of such entities.

Rimini Street also expects all suppliers, consultants, contractors, and other service providers who work with or on behalf of our Company to act ethically and in a manner consistent with the standards set forth in our Supplier Code of Business Conduct and Ethics.

The Code applies to anyone who works for or on behalf of Rimini Street, Inc., its subsidiaries, or controlled affiliates (collectively, “Rimini Street” or the “Company”). This includes:

Remember…

The Code is the cornerstone of the Company’s Global Ethics and Compliance Program. It sets forth the basic principles we must follow to uphold our Company’s ethical and compliant business culture. It sets expectations as to required conduct, guides us in the resolution of ethical dilemmas, and provides contact information and other resources to assist in addressing our questions and concerns.

What is expected of me?

Employee responsibilities.
Every Rimini Street employee has a responsibility to:

  • Read and understand our Core Values and use them in your job every day.
  • Follow the law at all times. If there is a conflict between our legal and ethical standards and our business objectives, ensure our legal and ethical standards always come first.
  • Read and understand the Code and the other policies that apply to your job. No one expects you to memorize every policy, but it’s helpful to have a basic understanding of the issues covered by each policy.
  • Ask for help from your manager, Ethics & Compliance, or one of the other Rimini Street resources identified in the Code when you have questions about the application of the Code or other policies.
  • Never cover up or ignore any ethical conduct problem. Address the matter timely and seek guidance if necessary.
  • Immediately raise any concern you may have about suspected or actual misconduct, including violations of the law, the Code, or other Rimini Street policies. The various ways to raise concerns are described in more detail later in the Code.
  • Cooperate with Rimini Street’s investigations and report all information truthfully.

Additional responsibilities for management.
All managers are responsible for creating an environment that encourages compliance with the Code. To help us maintain the highest level of integrity, you should:

  • Meet with your direct reports periodically to ensure they understand our Mission, Core Values, the Code, and other policies that apply to their jobs.
  • Lead by example and encourage your employees to act with integrity in all that they do.
  • Ensure open communication by encouraging employees in your department to ask questions concerning the Code.
  • Contact Ethics & Compliance if you are made aware of an ethics issue or need assistance handling an ethics question or concern.
  • Never retaliate against anyone for raising an ethics issue, assisting in an investigation, or participating in any proceeding relating to an alleged violation of any law or regulation.
  • Once an ethical concern is raised, do not interfere with any investigation into the matter.
  • Encourage self-reporting of business conduct violations. If an employee voluntarily reports he or she was involved in an ethics violation, self-reporting may be considered when determining the appropriate disciplinary action to be taken.

Q&A

Where can I find Company policies?

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.

How do I seek guidance and report concerns?

The Code cannot address every possible situation that you might encounter in your daily work. If you cannot find an answer in the Code or if you have questions about how to interpret the Code, ask for help. And if you are aware of something that may be a violation of the Code, our policies, or the law, you must speak up and report it so it can be addressed.

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?

If the answer to any of these questions is “yes,” don’t do it. If you are still uncertain, seek guidance from Ethics & Compliance or one of the many other resources available to you.

You have several channels to seek guidance or report concerns:

  • Your direct manager or next-level manager. Your managers are excellent resources for guidance related to many Company and job-specific policies and processes, work responsibilities, co-worker issues, discipline disputes, promotion opportunities, and issues related to the work environment. In most cases, your direct manager is the best way to get your questions answered and address issues and concerns. If you are unable to address your questions or concerns with your direct manager, speak to another member of your local management team.
  • Your local Human Resources manager or business partner. Your Human Resources representative can help you with human resource issues and concerns or help you find the right person to answer your questions.
  • Ethics & Compliance Department. Any member of the Ethics & Compliance team is a resource that you can contact if you have a question or concern; suspect a violation of the law, the Code, or another Rimini Street policy; or are uncertain where to turn for help.

For contact information for Ethics & Compliance and the other resources available to you, please see the last page of the Code.

In addition to the resources listed above, you can ask questions, raise concerns, or make reports of suspected compliance violations by contacting the Rimini Street Compliance Helpline.

To assist Rimini Street in investigating your report, you are encouraged to communicate fully and

The Compliance Helpline is a 24-hour, toll- free ethics hotline available to all Rimini Street employees, clients, suppliers, contractors, and other business associates.

The Compliance Helpline is available anywhere in the world:

By phone, using a special toll-free telephone number based on the country from which you are calling. In the United States, call 844-754-3342. For a list of international country phone numbers, see our Compliance Helpline section at www.riministreet.com/company/ethics-and-compliance

By web, available at https://riministreet.i-sight.com/portal

provide all of the information you may have about the matter you are reporting. The information will be kept confidential, except as needed to conduct a full, fair investigation. You may remain anonymous if you so choose, except where restricted by local law.

Your identity, phone number, or IP address will not be recorded or included in any report that is provided to Rimini Street, unless you voluntarily provide such information.

Note: Due to local privacy laws in certain countries and the European Union, the Compliance Helpline may permit only specific types of calls, such as accounting, financial, auditing, and bribery matters. In those countries, contact your Human Resources manager to report other issues.

What if I am concerned about retaliation?

Retaliation is strictly prohibited at Rimini Street. Employees who come forward with concerns play an important role in maintaining a healthy, respectful, and productive workplace, as well as protecting our stakeholders. These employees help our Company address problems early — before more serious consequences develop. It‘s important for each of
us to create a work environment where everyone can raise concerns of ethics issues without fear of retaliation.

Rimini Street is committed to protecting the rights of those individuals who report issues in good faith either through one of the reporting means described in the Code or to government authorities. Our Company will not retaliate or permit retaliation against a person who in good faith:

  • Reports what he or she believes is a violation of the Code, our policies, or the law.
  • Raises a compliance question or seeks advice about a particular business practice, decision or action.
  • Cooperates in an investigation of a potential violation.

Retaliation against an employee for reporting an issue in good faith is itself a violation of the Code. If you know or suspect that retaliation has occurred or is occurring, you should report it.

What are the consequences of violating the Code?

If you violate the Code, the Company will take appropriate disciplinary action. You are expected to follow the Code and comply with our policies and the law while conducting business on behalf of Rimini Street as a condition of your employment. Violating the Code, our policies, or the law may result in:

  • Disciplinary action, up to and including termination of employment, depending on the nature and severity of the Code violation.
  • In the case of a violation of law, civil and/or criminal penalties may be imposed by a governmental agency or a court.
  • Clawback of bonuses or other incentive-based compensation

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

Will I get into trouble with my manager if I contact the Compliance Helpline about an ethics issue?

No. It is a violation of the Code for any employee to retaliate against another employee for reporting a concern or possible policy violation in good faith. We encourage you to raise concerns and ask questions about ethics and compliance issues using one of the many resources available to you.

Is protection from retaliation only available if I report my concerns through the Compliance Helpline?

Retaliation is unacceptable no matter how you report your concern whether through management, Human Resources, or the Compliance Helpline. If you believe you have been retaliated against, report your concern to Ethics & Compliance.

What happens when I contact the Compliance Helpline?

Compliance Helpline calls are answered by an independent third party with expertise in handling hotline calls. A call center representative will ask you questions and send a report to Rimini Street’s Ethics & Compliance Department for a confidential review. Appropriate professionals designated by Ethics & Compliance will investigate concerns, and, if warranted, remedial actions will be taken

Remember…

It is our responsibility to follow the Code, company policies, and all applicable laws, regulations and court orders. Failure to comply can carry serious consequences, which an include, depending on local law, clawbacks of bonus or other incentive- based compensation and/or in appropriate disciplinary action up to termination of employment.