Administering the Code

Rimini Street’s Ethics & Compliance Department is accountable for promoting, monitoring, and enforcing the Code. However, the ultimate responsibility for following the Code and for maintaining Rimini Street’s culture of compliance rests with each one of us individually. The following section of the Code, Administering the Code, describes some key concepts regarding the administration and application of the Code.

Ethics & Compliance Department

You may contact Ethics & Compliance with questions at any time.

  • For general inquiries, contact [email protected].
  • Contact the Compliance Helpline for guidance on ethics and compliance matters or to report an
    actual or suspected violation of the law, the Code, or any Rimini Street policy.
  • You can also send a postal mail letter to Rimini Street, Inc., Attn: Ethics & Compliance, 1700 S. Pavilion Center Drive, Suite 330, Las Vegas, Nevada 89135, USA.

Rimini Street Policies and Local Laws

RiminiStreet publishes several global policies, which are designed to give employees guidance that is the same for all locations. The Code is an example of a global policy. 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. It is your responsibility to know all of the policies that might apply to your areas of the business. If you’re not sure about the policies in your area, please talk to your manager, Ethics & Compliance, or the Legal Department.

RiminiStreet conducts business in many countries around the world. Our employees are citizens of many countries.As a result, our operations are subject to many different laws, customs, and cultures. Our operations must comply with all applicable local laws and regulations in addition to the Code. In some instances, the laws of two or more countries may conflict, or a local law may conflict with the Code. When you encounter a conflict, contact the Legal Department or Ethics & Compliance for guidance on how to apply the Code in your country.

Remember…

We are expected to comply with the Code and all laws, rules, and regulations that govern our business around the world. However, if a provision of the Code conflicts with applicable law, the law controls. Because Rimini Street, Inc. is incorporated in the United States, our employees around the world are often subject to U.S. laws. The laws of other countries also may apply to the Company’s operations and personnel, whether in the U.S. or in other countries. If you are uncertain what laws apply to you or if you believe there may be a conflict between different applicable laws, consult the Legal Department or Ethics & Compliance before proceeding.

Investigating Misconduct

All reports of suspected violations of the Code or the law will be taken seriously and promptly reviewed.
As appropriate, Ethics & Compliance will assign investigator(s) to review all reported instances of alleged Code violations. The investigator(s) will:

  • Act objectively in determining facts through interviews or a review of documents.
  • Contact employees who may have knowledge about the alleged incident(s).
  • Recommend corrective actions and/or disciplinary measures where appropriate.

In accordance with applicable law, Rimini Street strives to:

  • Protect the confidentiality of the individuals involved, to the extent practical.
  • Inform an employee of the accusations reported against them at a time when such a disclosure will not jeopardize the investigation.
  • Where appropriate, allow employees to review and correct information reported.

If asked, you must cooperate fully with an inquiry or investigation.

The Code is Not a Contract

The Code is not a contract. It does not convey any specific employment rights or guarantee employment for any specific period of time, nor does it create any contractual or other rights for stockholders, suppliers, or any other person.

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

We acknowledge periodically our commitment to the principles set forth in the Code. This acknowledgment includes a commitment to seek guidance in the event of uncertainty. We also affirm that we will not retaliate against anyone for reporting a concern or seeking guidance.