Exertis
Supplier Codeof PracticeExertis Supplier Code of PracticeContentsIntroduction

Introduction

At Exertis, we aim to develop successful long-term relationships with all our suppliers.

Health & Safety

01

Employment & Human Rights

02

Environmental Protection

03

Bribery & Corruption

04

Confidential Information

05

Data Protection & Privacy

06

Competition (Anti-Trust) Laws

07

Tax Compliance

08Intellectual Property

09

Product Safety & Quality

10

Export Controls,
Sanctions & Embargoes

11

Conflict Minerals

12Managing Compliance13

We will work with you constantly to ensure that your products are brought to marketin the most effective manner possible and that buyers of your products receive a highstandard of support.
We want to build this relationship on a sustainable basis – one that works for you
and works for us in the long-term. So, it’s important that while everything we dois commercially-focused, it is also ethical and legal. Taking this approach protects
your business and reputation as much as our own. We are committed to thisapproach in every area of our business.
To help us to achieve this, we have developed this Code of Practice setting outthe key ethical and legal standards that apply to the business we do together.
Please ensure that you take suitable steps to meet the standards set out inthis Code, including by communicating this Code to the relevant people
within your business.
By each of us following the standards in this Code, we will develop a business
relationship that is sustainable in the long-term. Any person who is dealing withus, at any level of seniority, should feel free to raise concerns about whether
these standards are being met by Exertis.
If you have a concern, we want to know about it. To the extent we lawfully can,we will treat all notifications in confidence. Please contact me directly or use
our dedicated email address doing-the-right-thing@exertis.com

Tim Griffin
Managing Director
DCC Technology & Exertis Group

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“Following the standardsin this Code will allow us
to develop a business
relationship that is sustainable
in the long-term”
About Us
Exertis is one of the largest and fastest growing technology distribution and specialist
service providers. Exertis is the trading name of the businesses in the DCC Technologydivision, one of four divisions within DCC plc, a FTSE 100 company. We are a global
distributor of consumer, business and enterprise products.
Exertis is a leader in distributing technology, driving innovation and adding value
through our specialist services.
At Exertis, our core business is the distribution of products and services from the world’s
leading and emerging technology companies, some 2,400 of them. We are a key partof the channel that enables our vendors’ products and solutions to reach businessesand consumers though our network of resellers and retailers.

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Supplier Code of Practice01

Health & Safety
Principle
Ensuring the health and safety of everyone we deal
with is fundamental to business performance andlong-term business success. No task is so
important that you cannot choose to do it safely.
What this means> We will always support you when you choose to work safely.
> If anyone in your business believes safety is at risk of being compromised,they must feel able to intervene and stop the work.

> Our suppliers should comply with all applicable laws and regulations regarding

occupational health and safety, and provide a clean, safe and healthy workplace,designed to prevent accidents, injury and illness during the course of work.

> Suppliers working at an Exertis premises must work in a way that (i) assures theirown safety and the safety of others and (ii) is in compliance with applicable healthand safety requirements including our policies and procedures.

> Suppliers should provide their employees, including new or reassigned workers,
with regular and recorded health and safety training.

> Any emergencies that may impact Exertis activities must be reported promptly.
> You will facilitate reasonable HSE inspections by us. You will also provide us withaccurate HSE performance information where we request it.

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Supplier Code of Practice02

Employment
Principle
Exertis observes internationally-recognised humanrights standards including the United Nations
Universal Declaration of Human Rights, the United
Nations Guiding Principles on Business and Human
Rights and the International Labour Organisation’s
Declaration on Fundamental Principles and Rights
at Work. We ask our suppliers to do the same.
What this means
Specifically, you should ensure that your employees and other workers are:> p rovided with a safe working environment;> paid fairly and on time for the work they do;> n ot subject to any form of duress by their employer, such as having
to repay large loans or having their passport retained;> n ot discriminated against because of their gender, disability, religion, age, ethnicity,marital status, sexual orientation or any other status protected by applicable law;> n ot subjected to any form of slavery; and> n ot under the legal minimum age of employment.
You should promptly advise us if you are not able to meet these standards at any point.
In many countries, national laws set standards that are at least as high as those set out
in human rights standards. Where that is the case, national laws should be followed.
However, where national laws do not provide a suitable level of protection, human rights
standards should be observed. If a conflict between national law and international humanrights standards occurs, we expect you to respect national law while endeavouring
to protect human rights.

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Supplier Code of Practice03

Environmental Protection
Principle
We expect you to comply with all laws
and regulations that support the protectionof the environment.
What this means
You will ensure that your activities are conducted in compliancewith all applicable environmental laws and regulations, including:> t he use of natural resources such as water;> licencing of certain operations, storage and emissions;> t he safe transport of products;> t he reuse of packaging and other forms of waste; and>  carbon emissions.
You must observe our policies and procedures on environmental protection while
undertaking work for Exertis, including regarding spillages or releases of productsthat have an impact on the environment or on third parties.

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Supplier Code of Practice04

Bribery & Corruption
Principle
You will not be involved in bribery
or any other form of corrupt activity.
What this means
Bribery may exist where a person does not act in the best interests of the organisationthat they represent because of some personal benefit they have received or hope
to receive from a third party.
You will maintain and communicate suitable policies in your business that makeclear that none of your employees should offer, give or accept any bribe.
Specifically, any gifts, hospitality, sponsorship or other benefits that you offer
or receive in the context of the work you do for Exertis must be modest
and not designed to improperly influence the outcome of any decision.

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Supplier Code of Practice05

Confidential Information
Principle
You will not share confidential information
inappropriately or use confidential informationthat should not be in your possession.
What this means
While we always want to hear about developments in the marketplace,
we do not want you to share with us confidential information that
we are not permitted to receive. And, equally, you must not sharewith any third party any confidential information that you have about us.
If you inadvertently send us confidential information that we should
not have received, you must notify us immediately. And, if you inadvertently
share confidential information about Exertis with any third party, you mustagain immediately let us know.

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Supplier Code of Practice06

Data Protection & PrivacyPrinciple
You will collect and use personal information
carefully and in compliance with relevant
data protection and privacy laws.
What this means
We may collect information about our employees, customers or other individuals
and you may process that data on our behalf. Where this is the case, you must
always follow relevant data protection and privacy laws and ensure that allof your employees who handle that information understand that it should
be used securely and for legitimate reasons. You must maintain suitable IT
and management controls to ensure personal information is properly used.
You must let us know immediately if you have any incidents – for example,
a data security breach – relating to information you are processing
on our behalf.

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Supplier Code of Practice07

Competition (Anti-Trust) Laws
Principle
You will take all steps reasonably necessary toensure that you are fully compliant with applicablecompetition (also known as anti-trust) laws.
What this means
You accept that Exertis will always act independently in making its
commercial decisions.
As stated in section 5, you must not share confidential information about
us with any of our competitors and you must not share with us confidential
information that you have about our competitors.
It is against the law for us to agree with you what price we will sell your products
at or to have any agreement or arrangement that puts a floor on the prices wesell them at.
The same also applies to our customers. It is against the law for us to tell them
what price they can sell your products at or to require or incentivise themto keep their prices above a certain level.
You will ensure that you provide suitable training on relevant competition
laws to relevant employees within your business.

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Supplier Code of Practice08

Tax Compliance
Principle
You will not engage in or facilitate any deliberate
underpayment of taxes that are due.
What this means
You will correctly declare all income and be transparent with tax authorities
about your transactions.
You will take reasonable steps to prevent your employees, contractorsor representatives from facilitating tax evasion by third parties.
You will notify us immediately where you have concerns regarding any action
taken by your employees, contractors or agents in relation to your dealings
with Exertis, or where you suspect that another party in our supply chain
may have engaged in tax evasion.

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Supplier Code of Practice09Intellectual Property
Principle
You will not sell products or provide services that
deliberately or clearly infringe the intellectual
property rights of any third party.
What this means
You will respect the intellectual property rights of third parties by only using trademarks,
designs and technology that have been legitimately acquired and licensed.

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Supplier Code of Practice10

Product Safety & Quality
Principle
We respect the rights of the consumers of
the products we sell. Every product you sell
us must be safe, comply with relevant standards
and be accompanied by legally-required
product information.
What this means
You must ensure that any product you sell us is safe for the purpose for which it is intended
and complies with all relevant standards for that product. You will provide or make available
to us relevant product safety documentation, as may be required by law.
You must also notify us immediately where you have any concerns that a product may
be unsafe or not compliant with standards relevant to it.
Where relevant, you will work to address satisfactorily customer concerns about
the products you sell us.

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Supplier Code of Practice11

Export Controls & Sanctions
Principle
You will strictly comply and without exception
conduct your business in accordance with allapplicable export controls, sanctions andembargoes laws and regulations.
What this means
Some governments maintain restrictions on products (including their components, materials,designs and technology) and may prohibit or require licences prior to supplying controlled
products to certain recipients and users. They may also maintain restrictions on doing
business with certain countries, industry sectors, organisations or individuals.
You will maintain suitable controls to ensure that the products, whether hardware, software,
information and services, you sell comply with applicable export controls and sanctions laws.
You must advise us and provide the export control classification information as well as
supporting documentation and/or copy of applicable authorisation or exemptions if any ofthe products you sell are classified as dual-use products or are otherwise subject to export
controls restrictions.

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Supplier Code of Practice

12Conflict Minerals
Principle
We will not sell products that contain
restricted “conflict minerals”.
What this means
The US and the EU have each passed laws restricting theuse of minerals from conflict affected countries and regions.
We rely on you to ensure that any products we buy from you
do not contain conflict minerals and, in particular, comply withthe requirements of US and EU laws on this subject.
You must conduct and record appropriate and ongoing due diligencein your own supply chain to ensure that conflict minerals are not used
or introduced. You must make evidence of your due diligence available
on request by us and you must let us know immediately of any
breach that you become aware of.

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Supplier Code of Practice13

Managing Compliance
Principle
You will have in place appropriate internal policies
and procedures to cover your legal and ethicalobligations, including the areas covered in thisCode of Practice. You will ensure that you keep
adequate, accurate and secure records so you
can demonstrate compliance.
What this means
We expect you to have in place an appropriate set of internal controls to ensure thatyou meet the standards set out in this Code. These controls should be supported byclear leadership on ethics and compliance matters from senior people in your business.
Keeping records of your internal controls, such as risk assessment due diligence, policy
communications, training and other internal communications, is important because
it allows you to prove the controls you had in place if there are problems in the future.
In the same way that we engage with you about the subjects covered in this Code,it is your responsibility to communicate your policy on those subjects to your suppliers,
representatives and other third parties involved in your business.
We will take suitable steps where a supplier does not follow the standards set out
in this Code of Practice. This may include not placing any further orders and thetermination of our agreement.

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NotesVersion September 2021 - Always refer to the most recent document by visiting our website at www.exertis.com