I am pleased to confirm that GXS Co., Ltd. reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labor, Environment and Anti-Corruption. In our first annual Communication on Progress, we describe our actions to integrate the Global Compact and its principles into our business strategy, culture and daily operations.

Noriyuki Hayakawa
President, GXS Co., Ltd.

Our goal is to influence all our employees and business partners to respect the Universal Declaration of Human Rights. The Code of Business Conduct and Ethics (the “Policy”) applies to all employees, officers and directors of Open Text Corporation and its affiliates and subsidiaries around the world, including GXS Co., Ltd. (collectively, “the Company”). Adherence to this Policy is a condition of employment, and failure to adhere to this Policy is considered a serious violation of the employment relationship and will lead to disciplinary action that may include dismissal.

The Company has taken the following measures to prevent human rights violations in its work locations, such as conducting training sessions for all employees to raise awareness on no discrimination and no harassment at workplace in accordance with the Policy.

The Company is committed to maintaining a workplace in which the Company can receive, retain and address concerns regarding any matter governed by the Policy. To achieve this goal, the Company has established the Whistleblower Policy to encourage all of its employees, officers and directors to raise such concerns on a confidential basis, free from discrimination, retaliation or harassment, anonymously or otherwise.

We provide employees with a safe and healthy working environment, and we recognize that an effective health and safety program is an integral part of every job activity in all of its operations. We have developed an Occupational Health and Safety Policy, which outlines our commitment to providing a safe working environment to all our employees.

In our Policy, we declare that the Company is an Equal Opportunity Employer. Our goal is to provide a working environment that is inclusive of everyone regardless of race, ancestry, religion, place of origin, color, ethnic origin, citizenship, creed, gender, gender identification, veteran status, culture, national origin, pregnancy, sexual orientation, age, marital status, family status, mental or physical disability, social conditions, political belief or any other factor unrelated to job requirements or other basis protected by applicable laws.

Through our Report Incident Procedure, the Company has established a process that ensures all our employees are able to alert the Company when employees, managers, contractors, or visitors violate the Company policies, including Respect in the Workplace Policy, Workplace Violence Prevention Policy and Workplace Harassment & Discrimination Policy. This process is used to report and investigate harassment claims including, but not limited to physical, sexual, and psychological along with any actions related to diversity discrimination. This process also applies when investigating claims relating to violations of the Policy.

The Company is committed to improving the sustainability of its business operations. We will continue to pursue a variety of sustainability initiatives and look for new ways to improve environmental performance.

The Company continues to review its operations with objectives to evaluate progress, minimize negative impacts to the environment, transfer good practices and raise awareness among all employees regarding the importance of improving the sustainability of our business operations.

In the year 2015, the Company will establish a new Corporate Sustainability Policy, which will be implemented at the global level.

The Company has zero tolerance of any offer or acceptance of bribes, facilitation payments and other improper payments, by its employees and representatives.

By having the Anti-Corruption Policy in place, all our employees and representatives, from its senior executives through all levels of the organization, understand the Company’s commitment to carry out our business ethically, fairly, openly and honestly.

There is full compliance by the Company, its employees and representatives with the anti-corruption laws of any jurisdiction in which the Company is doing business either directly or through a representative.
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The Company employees understand that they are encouraged and required to raise concerns regarding bribes and other improper payments to help attain this objective in conjunction with the Company’s Whistleblower Policy.