Ethical Supply Chain Management

Openwave seeks to build long-lasting, strategic relationships with its customers, vendors and employees, and holds others accountable to high standards.

Openwave also monitors the Corporate Responsibility of its principal suppliers:

• Cisco, Corporate Social Responsibility
• HP, Global Citizenship
• NetApp, Global Corporate Citizenship
• Oracle, Corporate Citizenship
• Zones, Corporate Social Responsibility and Governance

Openwave maintains open and frank business dealings with its suppliers and strives to develop mutually advantageous business relationships. Openwave expects its suppliers to adhere to high ethical standards and to avoid engaging in any activity that involves even the appearance of impropriety. Openwave expects its suppliers to conduct their business in a manner which is consistent with the Openwave Code of Conduct and Ethics. Openwave also expects its suppliers to comply with all applicable laws and regulations and to ensure that all goods and services provided by them conform to all applicable legal standards.

The Openwave Code of Conduct and Ethics (the “Code”) reflects the business practices and principles of behavior that support Openwave's commitment to maintaining the highest standards of business conduct and ethics. All agents, contractors and vendors agree to conform to the Code standards when working for or on behalf of, or providing services to, Openwave. Adherence to the Code, and its procedures, is a pre-requisite to continued business with Openwave. The Code reflects only a part of our commitment to proper business conduct and ethics and it is the responsibility of each vendor to apply common sense, together with their own highest ethical standards, in making business decisions where there is no stated guideline in the Code.

Violations of the Code will not be tolerated and Openwave reserves the right to take all necessary actions in the event of a violation of the Code up to and including termination of the vendor's contract and, in appropriate cases, civil legal action or referral for regulatory or criminal prosecution.

International Business Laws
All of Openwave's vendors are expected to comply with the applicable laws in all countries to which they operate or conduct business, including laws prohibiting bribery, corruption or the conduct of business with specified individuals, companies or countries. The fact that, in some countries, certain laws are not enforced or that violation of those laws is not subject to public criticism will not be accepted as an excuse for noncompliance.

U.S. laws, rules and regulations, which extend to all of our activities outside the U.S., include, but are not limited to:

• The Foreign Corrupt Practices Act, which prohibits directly or indirectly giving anything of value to a government official to obtain or retain business or favorable treatment and requires the maintenance of accurate books of account, with all company transactions being properly recorded;
• U.S. Embargoes, which restrict or, in some cases, prohibit companies, their subsidiaries and their employees from doing business with certain other countries identified on a list that changes periodically (including, for example, Cuba, Iran, Syria, North Korea and Myanmar (formerly Burma)) or specific companies or individuals;
• Export Controls, which restrict travel to designated countries or prohibit or restrict the export of goods, services and technology to designated countries, denied persons or denied entities from the U.S. or the re-export of U.S. origin goods from the country of original destination to such designated countries, denied persons or denied entities;
• Anti-boycott compliance, which prohibits U.S. companies from taking any action that has the effect of furthering or supporting a restrictive trade practice or boycott that is fostered or imposed by a foreign country against a country friendly to the U.S. or against any U.S. person; and
• The Immigration Reform and Control Act of 1986 and other laws concerning immigration and the hiring of legally documented workers.

Labor Standards and Risks Certification

Openwave received SA8000 certification for the Redwood City office. SA8000 certificate number 45090 was effective on November 8, 2010 and expires on November 7, 2013.

Openwave is also working towards SA8000 certification for its Belfast and Tokyo offices. This process is expected to be completed by the end of Calendar Year 2011.

In addition, the Openwave Tokyo office implemented a Health and Safety program in 2007 and has also established a Health and Safety committee to comply with requirements imposed by Japanese authorities.