INTRODUCTION AND ACCOUNTABILITY

Speak Up

Speaking up takes courage, and it is critical to our success. It only takes one misguided or inappropriate action to put our reputation for integrity at risk. If you observe, experience or suspect conduct that violates this Code, a CDW policy or the law, you must promptly report it in good faith — with honesty and sincerity, and without malice.

You also have a responsibility to report concerns and raise questions if you have any doubt whether an action on behalf of CDW is ethical, legal and/or consistent with Company policies. Do not assume someone else will deal with it or that it is somebody else’s responsibility. This is our collective responsibility.

If you need to ask a question or raise a concern about misconduct or potential misconduct, it often makes sense to first raise the issue with your supervisor or manager. However, if you are not comfortable doing that (for any reason), or if you are not satisfied that your concern was adequately addressed, CDW has many resources who are available to help.

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What happens when you speak up?

CDW will take every report, question and concern about misconduct or potential misconduct seriously and will not tolerate retaliation against anyone who makes a good faith report, cooperates with an investigation or audit, or refuses to participate in activities that violate applicable laws, regulations, company policies or standards of ethical conduct.

By “good faith report,” we mean that you reasonably believe the information you report is accurate and complete. If it turns out that you made an honest mistake, you will not be in trouble or face disciplinary action. However, if a report is made in “bad faith” — for instance, if a false or misleading report is made in an effort to get someone in trouble (as opposed to an honest mistake) — the person making the report may be subject to disciplinary action. If you believe you or a fellow coworker has been subjected to retaliation, promptly report the matter to one of your Ethics and Compliance Resources.

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For more information, visit the resource link below:

CDW — Your Voice Has Power Infographic

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The Ethics Helpline

The Ethics Helpline is available for confidential questions and advice (about policies, laws the right course of action, etc.) and for reports of possible violations (of this Code, CDW policies or laws). It also provides callers the choice to remain anonymous.

The Ethics Helpline can be reached in several ways:

  • Phone — See Ethics Helpline Dialing Instructions by country
  • Internet — CDW.ethicspoint.com

The Ethics Helpline is operated by an independent third party and is available 24 hours a day, 365 days a year. Translation services are available.

Coworkers should also feel free to contact Ethics and Compliance directly by sending an email to CDWWay@cdw.com.

Your Ethics and Compliance Resources include:

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Tough Decision?

Ask Yourself:

Can I?

  • Is there a company policy prohibiting it?
  • What does The CDW Way Code say?
  • Is it legal?
  • Am I the right person to make the decision?

Should I?

  • Would I be proud to explain this to my customers, family, friends, manager or fellow coworkers?
  • Is it consistent with The CDW Way?

Am I sure?

  • Do I need to seek help or advice from someone else?
  • Have I looked at this decision from every angle?