COMPUTACENTER GROUPSUPPLIER CODE
OF CONDUCT

1. Introduction to our Supplier Code of Conduct
1.1 Who we are
Computacenter is a leading independent technology partner trusted by large corporate and public sector organisations around the world. As a
reseller of IT products and provider of IT solutions and services around the globe we source, transform, and manage our customers’ technology
infrastructure to deliver digital transformation, enabling their users and their businesses worldwide. In this Code of Conduct (“Code”), when werefer to “Computacenter” or “Computacenter Group” or “us/we”, we mean Computacenter plc and any of its subsidiary organisations.

1.2 Our Values - Winning Together
Computacenter is a people-centric company that depends on its employees to deliver real value to its customers. Our Winning Together Values
are at the heart of how we operate as a business and our approach to sustainability and business activities is driven by them and comprise thefollowing. These are the values on which we built this company, and they are the values on which we will continue to grow Computacenter.

We win by:

We do it together by:

Putting customers first
We work hard to get to know our customers, understand their needs
and put them at the heart of everything we do. This lets us use ourskills and experience to help them in the right way at the right time.

Understanding people matter
We’re committed to being diverse and inclusive. We build supportive,
rewarding relationships and celebrate success. We’re proud of thepeople we work with and we treat people as we expect them totreat us.

Keeping promises
We’re straightforward, open and honest in all of our dealings.
We’re pragmatic and do our very best to keep our promises.
When that’s difficult, we help our customers find other ways tosolve their problems.

Considering the long term
We’re building a sustainable and efficient business for the long term.
This leads our decisions and actions and helps people trust us.

1.3 Sustainability
In order to deliver against our values, we must adopt sustainable practices and have organised our sustainability strategy into three areas:

PEOPLE

PLANET

SOLUTIONSSupporting our people and communities
through positive social impact.

Taking a responsible approach to ensuring
sustainable operations, from supply chain
to our environment, direct and indirect.

Helping our customers meet theirsustainability goals through creative andefficient service operations.

1.4 Our Partners/Suppliers
We work with suppliers and partners to our business across all major markets and are aware that there can be challenges with setting global
ethical standards across multiple countries. To ensure that we can continue to operate in alignment with our values and sustainability goals webelieve it is necessary to ensure that our supply chain is similarly aligned and is operating in a lawful and responsible manner.
Our Supplier Code of Conduct sets out a number of minimum standards that we require of our supply chain that are founded mainly in law andunderpinned, amongst other things by:• the UN Declaration of Human Rights and other global treaties and the legislation of a number of key territories including the US, UK, and EU; and• a general desire to behave responsibly and decently towards stakeholders – whether customers, suppliers, employees, or the world at large.
Taken together, these set minimum standards that we would always expect our suppliers to meet in addition to compliance with all of the lawsthat apply to their business activities internationally within the individual countries across the world where they operate.

1.5 Who does this policy apply to?
This policy applies to any business, company, organisation, partner, person, or other entity that contracts with any Computacenter company tosupply goods or services (“Supplier”). By signing any such contract, the Supplier automatically confirms its acceptance of the content in thispolicy.
A Supplier’s contract with Computacenter may contain provisions addressing one or more of the subject areas of this policy. Nothing in this policy
is meant to supersede more stringent provisions in any particular contract. Having reviewed our activities globally, we do not consider that we
operate in particularly high-risk activities or market sectors however we may in certain circumstances require higher standards than set out inthis Code of Conduct and we may discuss this with Suppliers as appropriate.

1.6 Consequences of breachOur requirements as set out in this Code are the minimum that we would ask of our suppliers. Suppliers are expected to notify Computacenter ofany breach of these standards in writing as soon as is reasonably possible and in any event within no longer than 2 working days and to promptly
take appropriate steps to remedy them. Breaches of the requirements of this Code are considered by us to be very serious and could lead to us
terminating relationships with a Supplier where we feel this is appropriate in order to protect ourselves and our customers.

1.7 “Speaking Up”
Suppliers, their employees, workers or subcontractors should report any concerns or a possible violation of this Code to us at Computacenter.
Supplier’s employees and workers/contractors may contact our external ‘Speak Up’ (whistleblowing) service available 365 days a week 24/7 toreport an incident or violation, which you may do anonymously here . We take these reports seriously and will investigate any report received in atimely manner. We will not tolerate any retribution or retaliation taken against any individual who has reported a concern in good faith.

2. What we require from our suppliers:
Working with suppliers:

Choosing the suppliers we work with
Conflicts of Interest
Supplier Due Diligence
Supply Chain Control

Compliance with law and regulation:

Human Rights
Employment practices and Labour Rights
Product Safety, Workplace Health and Safety
Environmental Responsibility and Stewardship
Data Protection, Confidential Information, andIntellectual Property incl. Product Piracy and Plagiarism
Prevention of Corruption, Money Laundering, Fraud
and Tax Evasion
Gifts and Hospitality
Compliance with Competition Laws
Conflict Minerals
International Trade Controls
Land, Forest, and Water Rights, Forced Evictions
Use of Private or Public Security Forces

Reporting concerns:

Reporting Concerns

3. Working with suppliers
3.1 General Requirements
We need to ensure that all our working relationships are professional, open, and honest and adhere to the principles of fair business practices.
This includes anyone (e.g., colleagues, customers, and suppliers) that we or any supplier working for us have business dealings with.
How our supply chain behaves is important to us and to our customers. As our Supplier you must:
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Conduct business with Computacenter and other customers in a responsible manner.
Treat everyone, including your own employees with respect and dignity.
Be open and honest in all business relationships.
Act with integrity and always be professional.
Comply with all laws and regulations that apply to you, and any products or services provided by you.
Act in good faith and in Computacenter’s interests.
Act in an environmentally responsible way.

In particular, Computacenter will not accept:
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Bullying, harassment, or discrimination.
Risking damage to our reputation.
Unlawful behaviour.
Dishonesty.
Working with anyone (suppliers, contractors, third parties) who carries out unethical practices.

We apply and require our suppliers to adopt the following principles which are guided by our company values:• We are honest, forthright, fair, and trustworthy in all of our activities and contacts.
• We avoid conflict between private and professional interests.
• We maintain a positive work atmosphere where all are treated with mutual respect.
• We ensure industrial, health and environmental protection in accordance with the relevant regulations and standards.
•	We are equally respectful of all employees, customers, and business partners, regardless of race or ethnic origins, gender, gender
reassignment, religion or belief, disability, age, sexual orientation, marital status, or caste.

3.2 Choosing the companies we work with
Companies we work with are selected on the basis of open and fair competition. Our policy on the combat of bribery and corruption contains
important, compulsory rules that are a precondition to the award of contracts to third parties.
We expect our own suppliers to behave in a similar manner and require them in particular to comply with all applicable laws, rules, andregulations in the countries in which they operate. We require them to maintain suitable measures to ensure compliance within their own
business and in their supply chain with such laws, rules, and legal regulations, including among others all applicable human rights, competition
and anti-corruption legislation and good industry practice.

3.3 Conflicts of interest
Suppliers must be honest, direct, and truthful when answering questions from Computacenter about the relationship of the supplier or its
employees to Computacenter employees. Supplier must avoid any conflict of interest as well as the appearance of any conflict. In particular, a
supplier must not deal directly with any Computacenter employee whose spouse, partner, or other family member or relative is employed by orholds a financial interest in such supplier unless this has been first disclosed and approved in writing.

3.4 Supplier Due Diligence, Compliance Audits
Based on applicable legislation for supply chain control, Computacenter will conduct due diligence of suppliers both in the initial phase of
establishing a contractual relationship, and during the operational supply relationship.
Suppliers are required to accept and cooperate with related activities of Computacenter, including the right to audit the Supplier’s compliancewith this Policy in an appropriate manner which may include requiring a Supplier to confirm compliance in writing. We expect all our Suppliers tocooperate with any audit, including provision of an appropriate level of documentation which substantiates in a clear and transparent manner theadherence to this Policy.
The Supplier and Computacenter will discuss any questions in relation to this policy in good faith and in a truthful and respectful manner.

3.5 Supply Chain Control
Suppliers are required to use best efforts to be familiar with the business practices of their suppliers, sub-contractors, and other business partners
and to require all such suppliers, sub-contractors, and business partners to comply with this policy or the values and principles laid down in this policy
where this relates to any product or service to be supplied to or on behalf of Computacenter. This requirement should be in writing where the law
requires this.

4. Compliance with Law and Regulation
4.1 Human Rights; including Combating Slavery and Human Trafficking
Computacenter supports and respects internationally recognised human rights of people in all our business interactions and relationships. We arecommitted to making certain that we are not complicit in any human rights violations and hold our suppliers and partners to this same high standard.
This means we expect all our suppliers to take actions to ensure that their practices support and protect individual human rights.
Our commitment to human rights means we have adopted the principles of internationally proclaimed human rights as informed by international
standards and conventions across our business dealings, in particular the UN Global Compact, the Universal Declaration of Human Rights, the UN
Guiding Principles on Business and Human Rights, the UN Conventions on Rights of the Child, and fundamental conventions of the International Labour
Organisation (ILO), and understand our responsibility to respect and support human rights.
It is therefore a requirement that, as a minimum, all our suppliers:• Adhere to local and national laws.
•	Provide wages, benefits and conditions of work that are just and fairwith transparent payment terms and which are sufficient to satisfy
the basic needs of workers and their families.
• Prohibit any threat of violence, harassment, and intimidation.
• Prohibit the use of worker-paid recruitment fees or bonded labour.
• Prohibit compulsory overtime.
• Prohibit child labour.
• Prohibit discrimination.
• Prohibit confiscation of workers original identification documents.
•	Provide access to remedy, compensation, and justice for victims ofmodern slavery.
• Ensure that workers are free to terminate their employment.

• Ensure workers have freedom of movement.
•	Ensure that working hours comply with national legislation andapplicable international guidelines.
•	Ensure workers have freedom of association and that the right tocollective bargaining is respected.
•	Have in place appropriate speaking-up/whistleblowing andgrievance procedures and enable employees to communicate openly
with management regarding working conditions without fear of
reprisals.
• Comply with any applicable “hidden worker” or similar legislation.
•	Prohibit the hiring or use of private or public security forces for theprotection of the Supplier’s activities.

4.2 Employment Practices and labour rights
All suppliers must conduct their employment practices in full compliance with all applicable laws and industry good practice that apply to them andshould strive to provide decent work for their workers.

4.3 Product Safety, Workplace Health and Safety, Environment
We require our suppliers to comply with all applicable product safety, workplace health and safety and environmental legislation and good industry
practice and in particular to develop and implement adequate health and safety management practices in all aspects of their business. Suppliersmust in particular:•	Be committed to manufacturing and delivering safe products to Computacenter and providing a safe working environment that supports accident
prevention and minimises the exposure to health risks of their workers.
•	Implement processes to ensure that their workers comply with all applicable occupational health and safety laws and regulations and mandatory
standards.
• Provide a safe and healthy work environment for all workers, taking action to minimise the causes of hazards inherent in the working environment.
•	Establish and implement business continuity plans that address topics including but not limited to natural disasters, pandemics, workplace
incidents, emergencies, and other potential business interruptions.
• Prohibit the use, possession, distribution, or sale of illegal drugs.

4.4 Environment Responsibility and Stewardship
Across all the countries and territories where the Computacenter Group operates, we have a commitment to minimising our ecological footprint forour people, planet, and global communities. We are taking tangible steps to measure and mitigate our environmental impact and secure sustainablebusiness practices for the long-term. Our commitment to sustainable operations puts longevity in the driving seat with policies and practices aimed
at safeguarding our business, people, and environment against risks, known and emerging.

As such, we require our suppliers to be environmentally responsible and to comply with all applicable environmental legislation and good industry
practice.This includes suppliers recognising and understanding their environmental impact within their operations and practices as well as
understanding how they can further their efforts in the following:• Using more recycled products, or products with a high recycled content,• Improving efficiency in the use of finite or scarce resources (such as energy, water, raw materials).
• Reducing greenhouse gas / climate gas emissions.
• Reducing energy consumption and ensuring energy efficiency.
• Fostering and use of renewable energies.
• Minimising transportation and logistics activity, particularly wasted journeys.
• Reducing travel.
• Reducing waste and ensuring its proper disposal.
• Reducing carbon footprint.
• Protecting biodiversity.
• Minimising other environmental impacts such as noise, water, and ground pollution• Prohibiting exports of hazardous waste in contravention of law and the Basel Convention.
We further require that suppliers do not engage in or support the unlawful eviction or unlawful taking of land, forests and waters in the acquisition,
development, or other use of land. We require our suppliers to report all incidents that could lead to a violation of the laws, regulations and otherprovisions concerning environmental protection.

4.5 Data Protection, Confidential Information and Intellectual Property
Computacenter prioritises data protection, safeguarding confidential information and respecting intellectual property rights. As a global technology
services company, we recognise the critical role our suppliers play in maintaining the highest standards and this Supplier Code of Conduct setsout our expectations of our suppliers and any subcontractors or third-party entities appointed by our suppliers to data, protection, confidential
information and adherence to intellectual property rights including the prohibition of product piracy and plagiarism.
Suppliers will comply with all applicable laws concerning data protection and it is the supplier’s responsibility to implement appropriate policies
and procedures to ensure personal data is protected and that any confidential business information or trade secrets gained by virtue of thebusiness activities with Computacenter (“Confidential Information”) is held in strict confidence and not improperly used or disclosed to third parties.
Computacenter suppliers are responsible for implementing and maintaining appropriate technical and organisational measures to protect personal
data against unauthorised access, disclosure, alteration, or destruction.
Suppliers must respect and uphold the intellectual property rights of Computacenter, including not using, copying, reproducing, or distributing
intellectual property without the necessary rights and permissions, respecting software licensing agreements and not engaging in piracy orunauthorised use of software and promptly notifying us of any suspected infringement or misuse of our intellectual property.

4.6. Records Management
Suppliers must ensure that records are managed in accordance with established records management principles, legal requirements and goodindustry practice.
•	Any information and data processed, transmitted, and processed on behalf of Computacenter or our customers adheres to relevant records
management policies and standards.
• Information is anonymised where required.
•	Information and data are used only for the purpose intended and are accessible and usable for as long as they are required for Computacenter’sbusiness purposes.
•	Appropriate processes and policies are in place for the disposal of records.

4.7. Prevention of Corruption, Money Laundering, Fraud and Tax Evasion
In the conduct of business, Computacenter does not tolerate any form of criminal activity whatsoever (including, but not limited to corruption, bribery,money laundering, fraud, tax evasion, etc.).
All suppliers must ensure that they do not engage in or involve Computacenter in money-laundering activities. Suppliers must conduct business infull compliance with the requirements of all anti-bribery and corruption and anti-money laundering and anti-tax-evasion legislation applicable to thejurisdictions in which suppliers conduct business, together with laws governing lobbying, gifts, and payments to public officials including facilitation
payments political campaign contribution laws, and other similar or related regulations.
Suppliers must not, directly or indirectly, promise, authorise, offer, or pay anything of value (including but not limited to gifts, travel, hospitality,
charitable donations, or employment) to any employee or representative of Computacenter, government or public official (as defined in applicablelegislation) or other party to improperly influence any act or decision of such person for the purpose of promoting the business interests of supplieror Computacenter in any respect, or to otherwise improperly promote the business interests of supplier or Computacenter in any respect, irrespectiveof such value, local custom, the tolerance of such payments by local authorities, or the alleged necessity of the payment in order to obtain or retain
business or any other advantage. To avoid any doubt, Computacenter does not tolerate the payment of any “facilitation payments” regardless ofwhether these are permitted in any particular jurisdiction.
We also require Suppliers to report signs of any personnel, representatives, or partners performing unethically or being engaged or suspected ofbeing engaged in bribery or kickbacks.

4.8. Prevention of Money Laundering and Fraud
Each Supplier must ensure that Computacenter does not become involved in money-laundering or fraudulent activities as a result of or in its
interactions with Supplier. For this purpose, it is important that you pay attention to the following ‘warning signals’:
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cash payments.
payments through a third party (except for clearing offices).
payments stemming from countries that are known for high-risk payment transactions.
transactions that do not harmonise with a customer’s business or activities.
suppliers or business partners that do not adequately identify themselves and/or that fail to provide an address.

In all cases, Suppliers must report all transactions where there is reason to believe that an offence has taken place to Computacenter’s Group
Legal and Compliance department and Supplier’s employees and workers/contractors may equally report such transactions via the independent,
confidential reporting hotline provided by Safecall.

4.9. Anti-Facilitation of Tax Evasion
Computacenter has a zero-tolerance approach to all forms of tax evasion, whether under UK law or under the applicable laws of any country that
Supplier is based or and transacts in. This means that our Suppliers must not undertake any transactions which:(a) cause Supplier or Computacenter to commit a tax evasion offence; or(b) facilitate a tax evasion offence by a third party.
We adopt our Values in all of our third-party relationships and do not engage in activities of tax evasion. At all times, business should be conducted ina manner that is open and transparent and prevents any opportunity for tax evasion.

4.10. Gifts and Hospitality
We require our suppliers to use good judgment when exchanging business courtesies. Gifts, meals, entertainment, hospitality, and trips that areexcessive or lack transparency or an obvious legitimate purpose may be seen as bribes, may create the appearance of a conflict of interest, or may
be perceived as an attempt to improperly influence decision making. Giving business courtesies to Computacenter personnel, if permitted at all,should be modest and infrequent. Suppliers must never give anything to gain an improper business advantage. In particular:•	Suppliers must not offer anything of value to obtain or retain a benefit or advantage for the giver, and do not offer anything that might appear toinfluence, compromise judgment, or obligate the Computacenter employee.
• Entertainment and meals should be modest, infrequent, and occur in the normal course of business.

4.11. Compliance with competition laws
Computacenter is committed to the rules of fair competition.
Suppliers will strictly comply with all applicable antitrust and competition laws, trade practice laws and any other competition laws, rules andregulations dealing for example with monopolies, unfair competition and restraints of trade, and relationships with competitors and customers.
Suppliers will not enter into agreements or arrangements with competitors or engage in other acts that may harm competition, including, but notlimited to, price fixing or market allocations.

4.12. Conflict Minerals
Suppliers will ensure they are aware of applicable legal requirements in relation to “conflict minerals” including tin, tantalum, tungsten, their ores, andgold originating from conflict areas and shall ensure compliance with such laws. Additionally, suppliers will take best efforts to avoid the use of raw
materials in its products that directly or indirectly finance armed groups violating human rights.

4.13.

International Trade Controls

Suppliers will comply with all legislation governing:••••transactions with countries, products and individuals that may be restricted due to embargoes.
‘blacklists’ or so-called ‘terrorist lists’.
dual use merchandise.
any products or services where end use is subject to approval; and resale to third parties.

Suppliers must ensure that they have adequate and effective measures to ensure that their actions do not put them or Computacenter into a positionof non-compliance with such legislation and will proactively highlight to Computacenter any risk or concerns in respect of such legislation andcompliance for resolution prior to execution.

4.14. Land, Forest, and Water Rights, Forced Evictions
Computacenter supports the protection of human rights especially when it comes to unlawful eviction and the prohibition of unlawful taking of land,
forests and water in the acquisition, development or other use of land, forests and waters, the use of which secures the livelihood of a person.

4.15. Use of Private or Public Security Forces
Any Supplier that utilises private or public security forces to protect a project must provide those security forces with human rights training that isdeemed acceptable to Computacenter. Suppliers must maintain strict control over their security forces at all times, and must ensure that such forces
do not engage in torture, cruel, inhumane or degrading treatment, cause any damage to life or limb, or impair the right of anyone to organise or
exercise their rights to freedom of association.

Document Control
Policy Version

V2.1

Classification

Unrestricted

Approval dateNovember 2023

Next Review dateNovember 2024

Owner

Fraser Phillips - Group Legal and Compliance Director