Accurate Business Records

Rimini Street’s focus on honesty and integrity underscores our commitment to accuracy in our Company’s books and records. Business records, including our financial statements, contracts, and agreements, must always be accurate and reflect an accurate presentation of the facts. No matter what type of document or how insignificant it might seem, the information contained in a business record must always be truthful and complete. Financial records must reflect all components of the financial transactions and events. Likewise, all of your transactions, no matter what the monetary amount, must be properly authorized, executed, and recorded. You are responsible for sharing such

information with the Company as is necessary and relevant to enable the full, fair, accurate, timely, and understandable disclosure in the periodic reports required to be filed by the Company with the U.S. Securities and Exchange Commission (“SEC”) and other governmental authorities.

In addition, anything provided to a government official must be properly and accurately recorded in Rimini Street’s business records in accordance with our Global Anticorruption Policy.

If you notice an inaccuracy in a business record, ora failure to follow our internal control processes, you must promptly report it.

Public Disclosures

Our investors and the general public rely on our Company, and the law obligates us to report accurately on our business, our earnings, and our financial condition. The disclosures we make in our public communications, regulatory disclosures, and reports submitted to the SEC and to other governmental agencies must always be full, fair, accurate, timely, and understandable. Our senior financial officers — including, but not limited to, our Chief Executive Officer, Chief Financial Officer, and Chief Accounting Officer — have additional responsibilities. They are required to:

• Help maintain reliable internal controls, assess their quality and effectiveness, implement improvements, and report or resolve weaknesses that could materially affect or render financial disclosures or reports inaccurate.
• Inform the Disclosure Committee of transactions, events, or circumstances that could have a material impact on our Company’s financial reports.
• Fairly and accurately represent material facts or circumstances when interacting with our auditors and those individuals who prepare our Company’s financial statements.
• Ensure that those who perform accounting or financial reporting functions know and adhere to these principles.

All of us, including our senior financial officers, must immediately report accounting or auditing irregularities. In addition, we must report the following:

• Any violation of any law, rule, or regulation
• Any incidence of fraud, whether or not material, by any person, including those with accounting or financial reporting responsibilities in connection with financial disclosures, reports, or SEC filings.
• Any material information, including any deficiency in our internal controls over financial reporting, that could affect or render untrue the information contained in our public communications or periodic reports filed with the SEC or other regulatory body.

If you are involved in any aspect of preparing our financial statements or the certifications on which they rely, you must always follow our financial policies, our system of internal controls, and generally accepted accounting principles.

If you learn of potential misconduct related to our financial reporting, accounting, auditing, or internal controls, you have a duty to report it immediately. Please refer to our Policy Regarding Reporting of Accounting, Auditing and Other Matters for more information.

Fraud and Misrepresentation

Fraud involves deliberate, intentional deception or misrepresentation of information. You misuse Company resources and commit fraud when you intentionally conceal, alter, falsify, or omit information for your benefit or the benefit of others. Fraud may be motivated by the opportunity to gain something of value (such as meeting a performance goal or obtaining a payment) or to avoid negative consequences (such as discipline).Examples of fraud include:

• Misstating financial information in our Company’s business records.
• Presenting false medical information to obtain disability benefits.
• Falsely reporting time worked to earn more pay or to avoid discipline for being late or absent from work.

You should also avoid the appearance of fraud. For example, never spend Company funds with out proper approval. Similarly, never enter in to an agreement on behalf of our Company unless you are authorized to do so.

Engaging in any type of fraudulent activity at Rimini Street is never acceptable.If you learn of a potential fraud, report it to the Compliance Helpline.

Conflicts of Interest

All team members are expected to act in the best interest of Rimini Street at all times and be aware of actual and potential conflicts of interest. A conflict of interest occurs when our personal interests interfere in any way with the interests of Rimini Street. Actual conflicts — as well as the appearance of conflicts — must be avoided.

Public Disclosures

Some situations involving potential conflicts of interest include:

• Outside employment — or conducting non-Rimini Street business — with a Rimini Street business partner, supplier, competitor, or client.
• Investing or having a financial interest in a Rimini Street business partner, supplier, competitor, or client.
• Service on a board of directors or as advisor of an organization whose interests conflict with Rimini Street.
• Family or close personal relationships within Rimini Street.
• Pursuing a business opportunity for yourself that you learned about through your work at Rimini Street.

Outside Business Activities: Outside business activities, such as employment, self-employment, or working on a consulting basis, are permitted only if they do not involve cooperating with or becoming a client, competitor, or supplier of Rimini Street. Rimini Street team members are expected to devote their full working time and attention to their duties for Rimini Street. As such, permitted outside business activities must be conducted during nonworking hours only and cannot interfere with your job duties at, or performance of satisfactory work for, Rimini Street.

Financial Interests: Conflicts of interest may arise when you have a significant financial interest in
or receive any personal benefit from a current or prospective client, supplier, or competitor or a have a family member who does.

Q&As

What is a “significant financial interest”?

A “significant financial interest”is a direct or indirect aggregate interest of an employee or their family member in any outside enterprise that conducts business, seeks to conduct business, or competes with the Company. As a minimum standard, a “significant financial interest”is defined as more than:

• 1% of any class of the outstanding securities of a firm or a corporation.
• 10% interest in a nonpublic company, partnership, or association.
• 5% of the total assets or gross income of the employee.

Board Service: While serving on a board of directors for a nonprofit organization is encouraged and does not require prior approval from Ethics & Compliance, you are required to obtain prior approval from your direct manager as well as the Company’s CEO or the EVP with responsibility over Global Human Resources, and you may only accept the position if it does not interfere with your job performance at Rimini Street.

Family or Close Personal Relationships: We encourage the family of team members to work for Rimini Street; we believe it creates greater commitment and loyalty to our Company. However, we must observe certain rules in these circumstances. To avoid a personal conflict of interest or the appearance of one, we will not hire, continue to employ, promote, or transfer a team member to a position where their relationship to another team member:

• Creates a direct supervisory/subordinate relationship with a family member or romantic partner;
• Has the potential for creating an adverse impact on work performance, safety, security, or morale; or
• Involves an actual or potential conflict of interest or the appearance of a conflict of interest.

If a change in personal relationships occurs for current team members that results in an actual or potential conflict of interest, the Company will make reasonable efforts to minimize problems of supervision, safety, security, or morale through reassignment of duties, relocation, or transfer.

Corporate Opportunities: Rimini Street property and confidential information or your position with Rimini Street should never be used for personal gain, nor should you personally gain from a business opportunity that is discovered because of your job with Rimini Street. The key to addressing conflicts of interest is prompt and full disclosure. It is your responsibility to tell your manager about any situation you think creates, or could create, a conflict of interest. Managers are encouraged to bring such matters to the attention of Ethics & Compliance for advice. If you are ever in doubt as to whether a particular activity may be a conflict of interest or create the appearance of a conflict of interest, contact Ethics & Compliance or the Compliance Helpline. Directors and executive officers may be subject to additional restrictions above and beyond those stated above. Please refer to Rimini Street’s Corporate Governance Guidelines for additional information.

Protecting Company and Third-Party Assets

Rimini Street relies on you to use Company assets honestly and efficiently. Assets include physical property, such as facilities, supplies, equipment, and Company funds. They also include intangible assets, such as Company time, confidential information, intellectual property, and information systems. You should use Company assets only for legitimate business purposes and protect them from theft, loss, damage, or misuse. If you are aware of Company assets being misused, report it.

Company Funds
The obligation to protect Company funds is particularly important if you have spending authority, approve travel and entertainment expenses, or manage budgets and accounts. You must always:

• Ensure the funds are properly used for their established purpose.
• Obtain required approval before incurring an expense.
• Accurately record all expenditures.
• Verify that expenses submitted for reimbursement are business-related, properly documented, and comply with our policies.

Confidential Information
During your employment, you may have access to information about Rimini Street, its employees, business, or operations that is confidential, competitively sensitive, and/or proprietary. You should assume that Company information is confidential or competitively sensitive unless you have clear indication that Rimini Street has publicly released or otherwise authorized the disclosure of such information. Even within our Company and among your coworkers, you must only share confidential information on a need-to- know basis.

In addition, some of us may receive or have access to confidential, sensitive, or proprietary information about our clients, suppliers, business associates, or other third parties. We have a duty to safeguard this third-party information and honor all contractual commitments and legal requirements. Our obligation to safeguard third-party information continues even after employment ends.

Intellectual Property
Our intellectual property, or IP, is another important Company asset that must be protected at all times. IP refers to certain intangible assets developed through creative work done by our employees and partners. IP is safe guarded by legal protections including patents, trademarks, copyrights, and trade secrets. Our technology, software, and technical data contain large amounts of IP, and our policy is to protect the Company’s IP rights to the fullest extent possible. You should never allow a third party to use our IP without proper authorization and a license agreement that has been approved by the Legal Department.

In addition to protecting our IP, we also respect the IP rights of others. This includes avoiding infringement of any third party’s patents, trademarks, copyrights,

and trade secrets. When we work with third parties, we have a duty to ensure through contracts that our Company obtains appropriate rights to IP created in such engagements.

Please refer to Rimini Street’s Acceptable Use Policy for more information. If you have questions or concerns about our Company’s IP or the IP of a third party, contact Ethics & Compliance or Global Security for assistance.

Email, Internet, and Information Systems
We each have a responsibility to use our Company’s network, communications, and information systems ethically and legally and with special care. We should secure all confidential data using good judgment

in order to protect it from theft or loss. Confidential data may be stored on Company devices or held or processed by third parties on our behalf and in accordance with applicable law. Appropriate controls should be put in place to protect confidential data, such as restricting access on a “need to know” basis, password protection, encryption, and physical security. Only share information (such as through email, postings to social media sites, and granting systems access) based on a real business need.

While in some locations occasional personal use of these systems is permitted, our usage must be
appropriate and in line with existing local policies and must not interfere with our daily work.

To the extent permitted by local law, Rimini Street reserves the right to monitor, record, disclose, audit, and delete without prior notice the nature and content of an employee’s activity using our Company’s email, phone, voicemail, internet, and other systems. The Company also reserves the right to block access to inappropriate Internet websites, as well as the transmission of inappropriate emails or files.

For more information, please refer to our Information Security Management Policy as well as related policies and procedures. And if you suspect a data breach or become aware of any situation in which our Company’s physical premises, network, computers, or information systems have been compromised, immediately report the situation to your manager or to Global Security.

Data Privacy

Many countries have privacy laws that govern the appropriate collection and use of personal information. Personal information broadly refers to any information that identifies or relates to an identifiable person, such as an email address, physical address, payment card information, or government identification number. If you access this type of information or the systems that process it, you must comply with all applicable policies and laws regarding the processing of such information. You must:

• Only access, collect, and use personal information that you need and are authorized to handle for legitimate business reasons.
• Disclose personal information only to authorized persons who have a legitimate business reason to know the information and who are obligated to protect it.
• Securely store, transmit, and destroy personal information in accordance with applicable policies and laws.
• Promptly report any actual or suspected violations of our policies or applicable privacy laws, actual or potential data breaches, or other risks to personal information through the Compliance Helpline.

Rimini Street is committed to complying with applicable privacy laws in the countries where we conduct business, including such laws regarding the cross-border transfer of certain personal information. Consult with Ethics & Compliance if you have any questions, including about how to comply with rules about transfer of personal information outside of the country in which it was collected.

Records Management

Rimini Street generates a large volume of records and documents each day. The business records that you work with must be maintained, retained, and destroyed in accordance with all legal and regulatory record keeping requirements. To manage your business records properly, you should:

• Comply with our records management policies for all documents, files, electronic records, and emails.
• Follow the instructions in all litigation hold notices or similar record retention notifications.

Some examples of material, nonpublic information include:

• Advance notice of changes in senior management.
• Unannounced mergers, acquisitions, or financing transactions.
• Pending or threatened litigation.
• Nonpublic financial results.
• Development of a significant new product.
• An unannounced stock split or other extraordinary transactions.

In addition, we must avoid trading in Rimini Street securities when our Company has imposed internal trading restrictions. If you are advised that you are subject to a trading window or special blackout, do not trade in Rimini Street securities until the restriction has been lifted.

“Tipping” is also a violation of the Code. Tipping occurs when you provide material, nonpublic information about a company to someone else, who then uses that information to trade securities. You should also refrain from discussing material, nonpublic information with other Rimini Street employees unless they have a business need to know. Remember, you may be held liable for violating insider trading laws if you tip, even

if you did not personally make a trade based on the information you provided.

Insider trading and tipping are not only violations of the Code — they are serious violations of securities laws and will expose all individuals involved to immediate termination, as well as civil liability and criminal prosecution. For more information about insider trading, consult Rimini Street’s Insider Trading Policy, or contact Ethics & Compliance or the Compliance Helpline.

It is important for us to speak on behalf of Rimini Street with one consistent voice. Therefore, only designated Rimini Street spokespersons may make public statements on our Company’s behalf.

If a securities analyst requests information from you, even if the request for information is informal, do not respond to the request unless you are certain you are authorized to do so. Instead, refer that person to our Investor Relations Department. Refer media and
industry analyst requests to the Vice President, Global Communications. Requests from all other individuals, including government officials, may be referred to the Legal Department or Ethics & Compliance.

Refer to our External Communications Policy for additional details.