Exhibit 14

SYSTEMAX INC.
CORPORATE ETHICS POLICY

The Systemax Inc. Corporate Ethics Policy was prepared to
provide the shareholders, employees and customers of Systemax Inc. (the
Company) and the general public with a statement of the Company's
commitment to ethical business conduct. This applies to the Company and all of
its subsidiaries in North America and Europe. The Company is committed to acting
as a responsible and ethical corporate world citizen. The officers and employees
of the Company will conduct its business with the highest regard for its ethical
and legal obligations and with the utmost loyalty to its shareholders and
customers.

Policies:

Loyalty to the Company and its Shareholders:

Officers and employees of the Company owe a duty of loyalty to
the Company and those who invested in the Company. No officer or employee will
allow any considerations such as the receipt of gifts, financial interests in
other businesses, or personal or family relationships to interfere with their
independent exercise of their business judgment and work activities to the
benefit of the Company. Officers and employees will be sensitive to the
confidential business information of the Company and guard against any misuse or
waste of the Company's assets or corporate opportunities. This includes, but is
not limited to, trade secrets, intellectual property rights such as trademarks
and patents, product sourcing information, strategic plans, etc. Company
employees will refrain from the use of Company property for personal use other
than on an incidental basis. Officers and employees will comply with internal
controls or procedures of the Company, which are intended to allow for better
management and protection of the Company's assets in order to maximize the value
of the Company to its shareholders.

Fair Treatment of Fellow Employees:

Officers and employees will not discriminate against any
employee or potential employee on the basis of sex, race, religion, handicapped
status, age and be sensitive to the rights of all employees to work in an
environment free from all aspects of discrimination, including an environment
free from all forms of harassment based on any employee's race, color, religion,
sex, national origin, age, handicap, veteran status, marital status, or sexual
preference.

Gifts and Relationships with Customers and Suppliers:

All customers and suppliers will be treated fairly based solely
on appropriate business factors. Gifts of significant economic value should not
be offered or provided to any customer or potential customer. Gifts of
significant economic value should not be accepted from any supplier or potential
supplier either directly or indirectly provided, however, that no
amount of cash may ever be accepted as a gift. Company employees may not solicit
any gift, entertainment or other gratuity. Gifts include tangibles and
intangibles such as cash, excessive entertaining, tickets to events, services,
etc. Gifts of a significant economic value include more than one
gift from the same source, which in the aggregate is of a significant economic
value. Gifts received or offers of gifts that are more than $100 must be
reported immediately to an employee's supervisor.

No gift, friendship, or other non-business aspect of any
relationship with any customer or supplier should affect an employees
obligation to deal with all customers, prospective customers and suppliers in a
manner consistent with the best interests of the Company. Neither an employee
nor any member of his/her family may have any financial or economic involvement,
such as employment by, a business venture with, or investment in any customer or
supplier of the Company (other than the ownership of the stock of publicly
traded companies) without written disclosure to the Company and approval of the
Company.

Competitors:

The Company competes vigorously but fairly. Employees shall not
engage in conduct that results in the Company using any trade secrets,
copyrights, trademarks, patents or other proprietary or confidential information
belonging to a competitor.

Compliance With Applicable Laws and Regulations of
Governmental Bodies and Agencies:

The Company and its employees will comply fully with all
applicable laws and regulations, including antitrust laws (which establish.
standards for dealing fairly with competitors, suppliers and customers), laws
regarding safety in the workplace, laws relating to the preservation of the
environment, laws protecting employees and prospective employees from
discrimination or sexual harassment, securities laws (which require fair
disclosure of the Company's business and financial information to the public and
prohibit any use of secret information about the Company in deciding to buy or
sell stock of the Company), customs laws, including country of origin marking
and value laws, and other laws regulating products as well as laws prohibiting
corrupt practices such as payments to public officials or improper political
activities.

While the Company encourages its employees to participate in the
political process, they are cautioned not to create the impression that they
speak or act on behalf of the Company. Certain U .S. and foreign laws prohibit
the Company from contributing to political candidates of parties or party
officials except under limited conditions.

A variety of U.S. and foreign laws govern the accurate and
complete entry of accounting and financial information. The Company and its
employees are to maintain all such financial records in an accurate and complete
manner in accordance with such laws.

The numerous applications of domestic and international laws to
the activities of the Company cannot be set forth fully here, but all officers
and employees should be sensitive to the ongoing need to assure appropriate
consideration of any activity that might violate any such laws.

Procedures in the Event of a Concern:

All officers and employees of the Company have an obligation to
discuss any concern they have with regard to the application of these policies
to any conduct in which they participate, are asked to participate, or become
aware of. Normally, such concerns should be brought to the attention of the
immediate supervisor of the employee or officer. The Company is aware that in
certain situations it may be unrealistic to discuss concerns with a supervisor
and encourages any employee or officer to contact any of the following in such
circumstances:

Richard Leeds- Chairman and CEO

Steven Goldschein- Senior Vice President and CFO

Curt Rush- General Counsel

Human Resources Department-New York Office

Importance of Compliance With These Policies:

It is the duty of all officers and employees to see that these
policies are followed. Every officer and employee of every business unit of the
Company is expected to comply with the policies set forth above. Failure to do
so may not only harm the Company and your fellow employees, it may subject you
to disciplinary action, including termination of employment under appropriate
circumstances.