Vendor Code of Conduct

  1. Introduction
  2. Honest and Ethical Conduct
  3. Compliance with Contracts and Business Records
  4. Compliance with Laws, Rules and Regulations
  5. Anti-Corruption and Anti-Bribery Policy
  6. Conflicts of Interest Policy
  7. Gifts and Entertainment
  8. Health and Safety
  9. Fair Dealing
  10. Confidentiality and Protecting Information
  11. Data Protection and Privacy
  12. Intellectual Property
  13. Human Rights, Labor Laws and Fair Labor
  14. Environmental Responsibility
  15. Responsible Sourcing of Minerals
  16. Sustainability Commitment
  17. Compliance

1. Introduction

This Vendor Code of Conduct (“Code”) is established to set out the basic standards of conduct to which all vendors, suppliers, service providers, contractors and their affiliates, employees, individual contractors, agents and representatives, (collectively, “Vendors”) of CompuCom Systems, Inc. and its subsidiaries and affiliates (collectively “Compucom”) are required to comply
when conducting business with or on behalf of Compucom. All Vendors are responsible for being familiar with and complying with this Code as well as relevant laws, regulations and industry standards of legal and ethical conduct.

2. Honest and Ethical Conduct

Vendor must conduct its business affairs fairly, impartially, and in an ethical and transparent manner. Vendor’s personnel are expected and required to conduct themselves in the same way. Vendor conduct that may raise questions as to a Vendor’s or Compucom’s honesty, integrity, impartiality, or reputation is prohibited. Any activity, conduct, or transaction that could create an
appearance of unethical, illegal, or improper business conduct must also be avoided. Vendors must at all times act in good faith, responsibly with due care, competence and diligence, without misrepresenting material facts and otherwise to conduct itself in a manner that meets with our ethical and legal standards.

All business dealings should be transparently performed and accurately reflected on the Vendor’s business books and records in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices are unacceptable.

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3. Compliance with Contracts and Business Records

Vendors must comply with their obligations under their agreements with Compucom and others. Vendors must maintain accurate and complete books and records of, and honestly and accurately record and report information related to, its business dealings with Compucom and our customers.

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4. Compliance with Laws, Rules and Regulations

Vendors are required to comply with all applicable laws, rules, and regulations, including all applicable national, state, provincial, and local laws, ordinances, rules and regulations.

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5. Anti-Corruption and Anti-Bribery Policy

Vendor must be familiar with and comply with all applicable anti-bribery and anti-corruption laws and regulations and in addition, even if not applicable to Vendor, must comply with the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. Vendor shall not engage in any form of corrupt practices including, without limitation to, extortion, fraud, impersonation, false declarations or bribery. Bribes, implied or offered, with the intention of obtaining or retaining a business or other improper advantage are not to be offered or accepted.

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6. Conflicts of Interest Policy

Vendor’s activities must not pose a conflict of interest or the appearance of a conflict. Vendor must not deal directly with any Compucom associate who might personally benefit directly or indirectly from Compucom’s dealings with Vendor or if the associate or the associate’s spouse, domestic partner or other family member or relative holds a financial interest in Vendor.

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7. Gifts and Entertainment

Vendors must not offer or provide gifts, entertainment or anything of value to any Compucom associate or other person that creates or might give the appearance of creating undue influence or that may appear excessive under the circumstances.

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8. Health and Safety

Compucom’s commitment to a secure and healthy work environment spans across customer locations, Compucom facilities and Vendors' facilities. Vendors must adhere to the following principles:

  • Identify, assess, and mitigate potential worker exposure: Recognize and address health and safety hazards, including chemical, electrical, and energy sources, fire, vehicles, and fall hazards.
  • Prohibited items on worksite premises: Possession of firearms or other dangerous weapons at worksite premises, including customer locations and Compucom facilities, is strictly prohibited.
  • Emergency preparedness: Proactively identify, assess, and minimize the impact of potential emergency situations and events through appropriate controls.
  • Injury and illness management: Robust procedures must be in place for managing, tracking, and reporting occupational injuries and illnesses. This includes providing necessary medical treatment, investigating cases, and implementing corrective actions to eliminate root causes.
    Facilitate the swift return of workers to their duties.
  • Chemical, biological, and physical agent exposure: Identify, evaluate, and control worker exposure to these agents. Provide necessary personal protective equipment at no cost to workers.
  • Physically demanding tasks: Identify, evaluate, and control hazards associated with physically demanding tasks to safeguard the well-being of our workforce.
  • Machinery safety: Evaluate production and other machinery for safety hazards and implement controls.
  • Facilities and amenities: Ensure workers have ready access to clean toilet facilities, potable water, sanitary food preparation areas, storage, eating facilities, and other clean and safe amenities.
  • Information and training: Provide workers with essential workplace health and safety information, including necessary training. Establish a mechanism for raising health and safety concerns without fear of retaliation.
  • Regulatory compliance: Comply with all applicable health and safety regulations and laws. This includes enforcing compliance among their respective suppliers, fostering a collective effort to ensure a secure and healthy working environment for all involved parties.

In the event of non-compliance or potential risks, vendors are required to collaborate with Compucom to address and rectify these issues promptly. This reflects our commitment to a shared responsibility for the safety and well-being of our workforce.

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9. Fair Dealing

Vendors must deal fairly with Compucom, its customers, suppliers, competitors, other associates, and with other persons and organizations with whom Compucom does business. Vendors must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing or deceptive trade
practice. Vendors must be familiar with and comply with laws and regulations which prohibit restraints of trade, predatory economic activities, and unfair or unethical business practices. Additionally, vendors are expected to uphold standards of fair business, advertising, and competition in all their dealings with Compucom.

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10. Confidentiality and Protecting Information

Vendors are required to safeguard all confidential information entrusted to them by Compucom or by persons with whom Compucom does business. Confidential information includes all non-public information that might, if disclosed, be used by third parties to harm the interests of Compucom, its customers or persons with whom Compucom does business, whether or not such information is marked as confidential.

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11. Data Protection and Privacy

Vendor must be knowledgeable of and comply with all relevant laws, regulations, and industry standards relating to data security and privacy, and must maintain the security and integrity of all data of Compucom and its customers, as well as all Vendor data relevant to Vendor’s business dealings with Compucom. Vendor must at all times comply with Compucom’s Privacy Policy and, where applicable, Compucom’s California Privacy Policy.

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12. Intellectual Property

Vendor must not infringe on the intellectual property rights including trademarks and copyrights of Compucom, its customers, or any third party.

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13. Human Rights, Labor Laws and Fair Labor

Vendors must comply, and require each of their suppliers to comply, with all domestic and international labor laws, child labor laws, laws upholding the rights of persons with disabilities, and fair labor practices. Vendors must observe and comply with international principles relating to human rights, including but not limited to the Trafficking Victims Protection Act and the UK
Modern Slavery Act of 2015.

Non-compliance with local minimum wage, maximum working hour requirements, and other wage law regulations is strictly prohibited,, as are forced labor scenarios and labor contracts that impose unreasonable legal or practical limitations on the workers’ ability to leave their employment.

Vendors must ensure a harassment-free workplace, pledging zero tolerance for illegal discrimination based on race, color, age, gender, sexual orientation, ethnicity, religion, disability, union membership, marital status, or political affiliation. This commitment extends to prohibiting any form of harsh or inhumane treatment, including violence, gender-based violence, sexual
harassment, abuse, corporal punishment, coercion, bullying, public shaming, or verbal abuse against workers.

Vendors must uphold workers' rights to form and join unions, engage in collective bargaining,peaceful assembly, and express concerns about working conditions without fear of retaliation.

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14. Environmental Responsibility

Vendors must endeavor to be environmentally responsible and comply with applicable environmental laws and regulations. Vendors are expected to adhere to the following principles, where applicable:

  • Environmental Permits & Reporting: Obtain, maintain, and follow operational requirements for all required environmental permits, approvals, and registrations.
  • Pollution Prevention: Minimize emissions, discharges, and waste generation through source reduction practices.
    • Hazardous Substances: Identify, label, and safely manage hazardous substances, ensuring proper handling, movement, storage, and disposal.
  • Solid Waste Management: Implement a systematic approach for solid waste management, including reduction and responsible disposal or recycling.
  • Air Emissions Control: Characterize, monitor, and control air emissions, treating them as required prior to discharge.
  • Materials Restrictions: Adhere to laws, regulations, and customer requirements regarding prohibited or restricted substances in products, ensuring proper labeling for recycling and disposal.
  • Water Management: Implement a water management program, conserving water, controlling contamination, and treating wastewater before discharge.
  • Greenhouse Gas Emissions: Consciously consider greenhouse gas emissions, employing strategies and selecting options that actively minimize environmental impact and enhance energy efficiency when feasible.

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15. Responsible Sourcing of Minerals

Manufacturers are encouraged to take reasonable steps to ensure responsible mineral sourcing in alignment with internationally recognized guidelines.

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16. Sustainability Commitment

Vendors are expected to demonstrate a commitment to environmental responsibility and sustainable practices. As part of this commitment, vendors are required to establish and implement sustainability goals directed towards environmental responsibility, sustainable procurement, human rights, fair labor, and ethical behavior.

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17. Compliance

Vendors are expected to adopt or establish a management system aimed at ensuring compliance with this Code and identifying, as well as mitigating, operational risks associated with its provisions.

Vendors must cooperate and reasonably assist Compucom in its investigation of any actual or potential violation of laws, regulations, or this Code. This Code is for the benefit of Compucom, and no other person is entitled to enforce this Code. This Code does not, and should not be construed to, create any private cause of action or remedy in any other person for a violation of the Code.

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Effective January 2024