Modern Slavery Act Transparency Statement 2021

This is a slavery and human trafficking statement for the purposes of section 54 of the U.K. Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018 (Cth). It covers the activities of Rimini Street, Inc. and its owned and controlled entities for the calendar year ended

31 December 2021.

Our Commitment

At Rimini Street, we are committed to doing business the Rimini Street Way – recognizing that the best and only path to success means that we must do the right things; that we must conduct ourselves in a way that demonstrates the highest integrity as well as respect for others, and for the laws, regulations and court orders by which we operate. Our  Code of Business Conduct

and Ethics and related policies are an extension of our core values, and provide a framework to guide our business practices. Guided by our core values, we have taken the steps outlined below during the reporting period to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business.

Rimini Street recognizes that modern slavery encapsulates a spectrum of abuse, including slavery, child labor, servitude and forced or compulsory labor, and human trafficking.

Rimini Street aims to promote continuous improvement in its operations and acknowledges its responsibility to ensure that workers within its supply chain are not being exploited, and that appropriate health and safety, employment, and human rights laws are complied with in addition to international standards.

This statement was approved by the Board of Rimini Street on February 22, 2022.

About us

Rimini Street is an enterprise software support company, established in 2005 and incorporated in the United States of America. Our registered office is located at 3993 Howard Hughes Parkway Suite 500, Las ).

Our Code of Business Conduct and Ethics outlines the Core Values and the principles that we expect all of our people to observe. Our Core Values are a uniting force which connect us across functional areas, business units and geographies. Most importantly, our Core Values enable us to make a positive difference among our stakeholders, including our clients, business associates, stockholders, communities and each other.

Our Core Values are:

  • People – We treat everyone with respect and communicate clearly, openly and honestly.
  • Integrity – We act with integrity in all we do.
  • Accountability – We uphold our commitments.
  • Client-Centric – We consider client interests in every decision.
  • Innovation – We drive continuous improvement, evolution and disruption of status quo in everything we do.
  • Trustworthy – We earn trust through consistent, reliable and high-quality execution.
  • Profitability – We strive for long-term, sustained profitability that benefits all stakeholders.
  • Community – We give back to the communities in which we work, live and serve clients.
  • Fun – We take time to celebrate our successes together as a team.

At Rimini Street, we take our ethical and legal obligations seriously.  We recognize 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.

Our structure

Rimini Street, Inc. is the global leader in independent, third-party enterprise software support services. We have more than 30 offices in over 20 countries and territories. We founded our company to disrupt and redefine the enterprise software support market by developing and delivering innovative new products and services that fill a then unmet need in the market. We believe we have achieved our leadership position in independent enterprise software support by recruiting and hiring experienced, skilled and proven staff; delivering outcomes-based, value- driven and award-winning enterprise software support products and services; seeking to provide an exceptional client-service, satisfaction and success experience; enabling clients to follow a business-driven roadmap aligned with their business objectives that better supports competitive advantage and growth; and continuously innovating our unique products and services by leveraging our proprietary knowledge, tools, technology and processes.  Rimini Street employees display an unwavering commitment to the Rimini Street Way We are united in embracing Rimini Street’s core values.

Our supply chain

We have identified our significant suppliers that support us in operating our business and conducted detailed risk assessments of these suppliers. While many of our suppliers are located or headquartered in the United States of America, we also work with suppliers in other countries all around the world including the United Kingdom, Australia, China, India, France, Singapore, Philippines, South Korea, Africa, the Middle East and Ireland.

The key types of goods and services that form our supply chain are:

  • software and IT services;
  • professional services (e.g., legal, accounting, audit, tax);
  • contract labor;
  • financial services;
  • marketing services;
  • IT devices and infrastructure; and
  • employee benefits providers.

We  also  have  various indirect  suppliers,  including IT  hardware,  office  supplies, cleaning services and facilities management for our offices globally.

We engage our suppliers across a variety of arrangements. Our significant suppliers are generally engaged on the basis of long term, stable arrangements.

Modern slavery risks

We recognize that any exposure to modern slavery risk may impact our business operations and would be inconsistent with our Code of Business Conduct and Ethics. We endeavor to take responsibility for reducing the risk that we might cause, contribute or be directly linked to modern slavery through our operations and supply chains. Rimini Street is committed to continually reviewing and enhancing our approach to managing modern slavery risks and we expect our suppliers to adhere to our Supplier Code of Business Conduct and Ethics.

At Rimini Street, we take our ethical and legal obligations seriously. We recognize the importance of maintaining and promoting fundamental human rights in our operations around the world. We implement and maintain programs and policies that:

Risk assessment methodology

For this reporting period, we undertook a risk assessment of the modern slavery risks within our operations and supply chains to evaluate the risk that we are causing, contributing to or directly linked to modern slavery practices. We adopted a risk assessment methodology which considers a number of indicators of modern slavery risks including sector and industry, type of products and services, geographical location and specific entity risk.

Our risk assessment has indicated that our operations and supply chain have a low / medium potential for modern slavery risks.

Risk profile

Rimini Street identified that our supply chain has a low risk potential for modern slavery risks in the categories of industry risk, and products and services.  Rimini Street identified that the majority of our suppliers operate within the professional services and technology industry. These sectors ordinarily have a low level of risk associated with modern slavery practices and are not comprised of positions that are vulnerable to human trafficking or associated practices. We determined that the risks associated with any specific product or service should be assessed as low for the period because our core suppliers predominantly specialize in software, technology, professional services and financial services.

We have minimal exposure to suppliers with cyclical production and/or high-risk raw material usage to manufacture the products and services consumed by Rimini Street.  As our

suppliers are predominantly headquartered or located in the United States of America and the United Kingdom, our geographic exposure risk to modern slavery practices during the period was deemed low.

Actions to assess and address risk

We understand the importance of working collaboratively with our employees, suppliers and the broader industry to combat modern slavery.  That is why during 2021 we introduced a number of steps to assess and address modern slavery in our operations and supply chains.

We plan to conduct further detailed risk profiling in 2022 of our supplier arrangements as part of a broader program of work. Where required, a detailed questionnaire will be issued to our suppliers.

Due diligence

While Rimini Street does not manufacture in the traditional sense with the use of factories, Rimini Street evaluates its supply chain to identify which suppliers pose risk in terms of complying with relevant laws, including but not limited to laws relating to slavery and human trafficking.

Rimini Street requires that all of its suppliers and partners comply with all applicable laws including, but not limited to, employment laws, anti-corruption laws and any other laws that broadly regulate how people work. We may also carry out appropriate due diligence and audits on suppliers to ensure their compliance with such laws.

Policies and procedures

At Rimini Street, we select our suppliers based on objective criteria, such as 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 Supplier Code of Business Conduct and Ethics.

Under our Code of Business Conduct and Ethics, in evaluating and hiring suppliers or other third parties to work on behalf of Rimini Street, our employees are required to 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.

Under our Supplier Code of Business Conduct and Ethics, we require our suppliers to adhere to a range of standards in relation to social and working conditions including those relating to certain recognized forms of modern slavery. For example:

  • Child Labor: Suppliers must comply with the minimum age requirements as prescribed by applicable laws and regulations. Suppliers must adhere to our contracts or other applicable supplemental guidelines which may provide standards at a higher level. Suppliers must not interfere with a child’s education by employing a child in violation of a country’s compulsory education laws. Supplier may use legitimate, voluntary workplace apprenticeship programs, such as student internships, as long as they comply with all laws and regulations. Workers under the age of 18 must not be asked or required to perform work that is likely to jeopardise their health, safety or well-being.
  • Forced Labor: Suppliers must use only voluntary labour. Any form of forced labour, including bonded, indentured, or involuntary prison labour is prohibited. Human trafficking and trafficking-related activities are also prohibited, including using misleading or fraudulent recruitment practices, charging recruitment fees, denying employee access to their identity documents, failing to provide return transportation costs or an employment agreement (if required) in the employee’s native language.
  • Freedom of Association: Suppliers should respect employees’ right to freedom of association including the right to collectively bargain, consistent with local laws and ensure that all employee relationships are of a voluntary nature. Employees must not be subject to intimidation or harassment in the exercise of their right to join or to refrain from joining any organization.
  • Harassment and Discrimination: Suppliers must promote a work environment free from verbal, physical, or mental abuse, threats, violence, or any form of harassment during employment or recruitment. Similarly, Suppliers must not engage in unlawful discrimination in hiring and employment practices such as promotions, rewards and access to training. Employees must not be subject to discrimination based on, but not limited to, to non-job-related characteristics such as: race, color, ancestry, citizenship, national origin, religion, veteran status, disability, medical condition, genetic characteristic or information, age, gender, sexual orientation, gender identity or expression, sex, creed, marital status, family status, pregnancy, or other legally protected status.
  • Hiring and Termination: Suppliers must comply with applicable laws governing eligibility for employment, recruitment, and termination. Suppliers must not knowingly employ individuals who are not authorized to work, as determined by governing law.
  • Wages, Benefits, and Working Hours: Suppliers must comply with all applicable laws governing wages, benefits, and working hour requirements, including compensation, benefits, and overtime. Accurate written records of employees’ regular and overtime hours should be maintained.

In respect of the UK Modern Slavery Act, the development of this modern slavery statement for the 2021 builds upon our previous UK Modern Slavery Act Statement and enhances our commitment to addressing modern slavery risks in our business and driving accountability for ethical business practices across our organization.

Training

During this reporting period, Rimini Street offered employee onboarding and annual refresher training on a number of company policies and procedures, including on our Code of Business Conduct and Ethics. Within our Code of Business Conduct and Ethics, readers are also referred to our Supplier Code of Business Conduct and Ethics.

COVID-19

The COVID-19 pandemic has brought further challenges to modern slavery and highlighted social and economic inequalities worldwide. At Rimini Street, in response to the COVID-19 pandemic we provided special compensation bonuses for lower-paid employees and for our employees who tested positive for COVID-19. The business was not required to make any significant changes to its operations in response to the pandemic that would heighten exposure to modern slavery risks.

Under our Supplier Code of Business Conduct and Ethics, we require our suppliers to adhere to a range of standards in relation to social and working conditions including those relating to certain recognized.

Additionally, Rimini Street liaised with its material suppliers throughout the COVID-19 pandemic including with respect to their approach to managing staff and the effects of the pandemic.

Assessing our effectiveness

We are committed to ensuring the effectiveness of our actions by regularly reviewing our modern slavery processes. On an annual basis, our senior management team will conduct meetings to evaluate whether we are appropriately identifying and managing our modern slavery risks. Additionally, when engaging a new supplier, Rimini Street will assess whether our existing risk management processes remain appropriate.

We are monitoring our performance against a number of key performance indicators to assess the effectiveness of our actions. These include:

  • the extent of compliance with our Supplier Code of Business Conduct and Ethics; and
  • the number of suspected modern slavery incidents identified. At Rimini Street, we have a dedicated Compliance Helpline for reporting incidents of non-compliance across a range of areas. The helpline provides a mechanism by which complaints can be made and directed to relevant business units to address. The process for logging and referral of complaints will identify any complaints made that specifically relate to modern slavery matters. The 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, the relevant phone number is 844-754-3342. For a list of international country phone numbers, see the Compliance Helpline section of our corporate website or at  https://riministreet.i-sight.com/portal.

This statement was approved by the Board of Rimini Street in its capacity as principal governing body of Rimini Street on February 22, 2022. This statement was signed by Seth. A Ravin in his capacity as Chairman and Chief Executive Officer of Rimini Street.

Seth A. Ravin

Co-Founder, Chairman and Chief Executive Officer

Rimini Street, Inc

February 22, 2022