California Transparency in Supply Chains Acts

Vantive seeks to foster and maintain a culture of compliance with applicable laws, rules and regulations, and the highest standards of ethics and business conduct with respect to forced labor and human trafficking and slavery. Our commitment to fostering this culture of compliance extends to our relationships with suppliers. Specifically, Vantive does not support, encourage or endorse any form of forced labor or human trafficking and slavery in our operations or in our supplier networks. We take a number of steps with respect to verification of our supply chain and certification of materials to ensure suppliers are operating in an ethical manner with respect to forced labor, including the following:

• On an annual basis, Vantive conducts a sustainability survey of its select suppliers to assess whether these suppliers have programs to address potential human rights risks, including human trafficking and slavery, and whether they have been alleged to have violated any human rights standards. This survey is conducted by Vantive and not a third party.

   

• Supplier contracts include language that permit Vantive, upon advance notice, to access facilities at which any products and services provided to Vantive are manufactured and delivered to assess suppliers’ compliance with Vantive’s Ethics & Compliance Standards for Suppliers. Vantive does routinely conduct quality audits of its suppliers and is currently evaluating the need to audit compliance with company standards for human trafficking and slavery.

   

• We have incorporated rules against forced labor into our Ethics & Compliance Standards for Suppliers and commercial agreements with suppliers. Suppliers who conduct business with Vantive are required to acknowledge receipt of Vantive’s Ethics & Compliance Standards for Suppliers. Specifically, the standards forbid the production or manufacture by suppliers of products or services (or incorporation of any materials therein) in violation of laws governing workers’ human rights, including human trafficking and slavery.

   

• Employees and contractors of Vantive are expected to know, understand and live up to Vantive’s Code of Conduct. Employees have a duty to report any known or suspected violation of the code, or any laws, rules or regulations applicable to Vantive. Reporting such violations helps to safeguard the reputation and integrity of Vantive and its employees. See Vantive’s Code of Conduct for Vantive’s internal accountability standards and procedures for employees and contractors.

   

• Vantive provides training sessions on Vantive’s Code of Conduct for new and existing employees. Additionally, Vantive has a procurement ethics course for those who have direct responsibility for supply chain management. Since 2012, this module has included material to educate procurement professionals about human rights risks, including human trafficking and slavery.

   

• Vantive's Ethics & Compliance Helpline, a telephone and web resource, is available to employees, their families, suppliers and customers as another channel to report or seek guidance on issues. The Ethics & Compliance Helpline has the ability to connect callers to counselors, 24 hours a day, seven days a week, in 150 languages.

Please also see Vantive's Global Human Rights Policy.