Oracle is committed to maintaining high standards of business ethics and complying with applicable law, and expects the same commitment from the systems integrators, developers, distributors, resellers, and others admitted to the Oracle PartnerNetwork (“OPN”). We want to take this opportunity to remind all of our partners of the important ethical and legal obligations that must be abided by when doing business as an OPN member.
Every OPN member is obligated to comply with the Oracle Partner Code of Conduct and Business Ethics (“Code”). The Code, the OPN agreements, Oracle ordering and other documents prohibit our partner companies, their owners, directors, officers, employees, resellers and agents from making or promising to make payments of money or anything of value, directly or indirectly, to any official (regardless of rank) of a government or public international organization, to political parties or candidates for political office, or to any officer, company director or employee of a private-sector customer or supplier, for the purpose of obtaining or retaining business or securing any improper advantage. In addition, our partners must comply with all other applicable laws, rules and regulations applicable to their business, wherever conducted, including those that further restrict or prohibit the provision of gifts, meals, entertainment and anything else of value to government officials or employees of private-sector companies. OPN members are also obliged to comply with Oracle policy and business practices. For example, no order may be placed with Oracle until a corresponding end user agreement has been concluded with and signed by the customer. Placing an order with Oracle in anticipation of reaching agreement with the end user, sometimes referred to as "pre-loading" or "channel stuffing," is prohibited.
It is incumbent on OPN members to accurately document all transactions relating in any way to Oracle business in their financial books, records and statements, and in reports and other documents provided to Oracle. The handling and disbursement of funds related to an Oracle transaction must be conducted strictly in accordance with the applicable Oracle contract and Oracle policy and business practices. No undisclosed or unrecorded fund or asset related to Oracle or any Oracle transaction may be established or maintained for any purpose, nor may any Oracle partner enter into or permit a side agreement, whether oral or written.
Finally, we expect that our partners will promptly report to Oracle any conduct believed in good faith to be an actual, apparent, or potential violation of the Oracle Partner Code of Conduct and Business Ethics or an Oracle contract or policy, including any behavior or activity by any Oracle employee that appears inappropriate.
To report an incident, please contact Oracle's Integrity Helpline toll-free, 24 hours a day, seven days a week, by calling 800-679-7417 or, in EU countries, by calling 866-455-1215. Reports may also be made online at any time through the Oracle Integrity Helpline.
As a reminder, Oracle offers an International Anti-Corruption Training Course in several languages. This course provides helpful guidance on the professional behavior expected of all Oracle partners when dealing with both public-sector and private-sector customers. Executive-level employees from partner companies, as well as other employees with any responsibility for public-sector or private-sector sales, are strongly encouraged to complete this Anti-Corruption Training Course when the partner is signing or renewing a distribution agreement with Oracle.
Oracle will remain vigilant in ensuring compliance with these laws and policies and requires the same from all members of its global partner community.
Please forward this communication to others in your company involved with Oracle business, either directly or indirectly. Thank you for your attention to this important matter.
| || ||Juana Schurman,|
North America Compliance & Ethics Officer