Exhibit 99.20
  HR Policy
 Executive Stock Ownership & Retention Policy
 Doc Ref:
    
    IMDate:
    
    December 1, 2009Contact:
    
    CompensationDepartment:
    
    Human ResourcesPage:
    
    1 of 4
   1.0
    
    PURPOSEThe Human Resources Committee of the Companys Board of Directors (the Committee) has
adopted guidelines requiring that the Companys executive officers acquire and retain
long-term ownership of common stock of the Company in order to align their personal
financial interests with the long-term interests of the Companys stockholders. To further
this goal, the Committee has adopted this amended and restated Executive Stock Ownership and
Retention Policy (the Policy) effective December 1, 2009.2.0
    
    APPLICABILITY
 2.1.
    
    Covered Individual.This Policy applies to all Section 16 reporting officers of
the Company and such other key employees of the Company as determined from time to time
by the Committee (collectively the Covered Individual).2.2.
    
    Covered Awards.This Policy applies to all Equity Compensation Awards
outstanding as of the Effective Date under any of the Companys equity award plans and
all future Equity Compensation Awards granted under any of the Companys equity award
plans as such plans may exist from time to time. With respect to any individual who
becomes a Covered Individual on or after the Effective Date, this Policy shall apply to
all Equity Compensation Awards held by such individual on the date he or she becomes a
Covered Individual and to all Equity Compensation Awards received thereafter. For
purposes of this Policy, the term Equity Compensation Awards shall mean all stock
options, stock appreciation rights, restricted and unrestricted stock awards,
restricted and unrestricted stock units, performance shares, performance units, or any
other stock-based incentive awards that are granted under the Companys equity award
plans for compensatory purposes. Notwithstanding anything to the contrary herein, this
Policy shall not apply to any Equity Compensation Award held by a
Covered Individual that is subject to a pre-arranged stock trading plan designed to
comply with Rule 10b5-1 of the Securities Exchange Act of 1934, as amended, and the
Companys insider trading policy, as in effect on or prior to the Effective Date.
 3.0
    
    POLICY
 3.1.
    
    Administration.
The Policy will be administered by the Committee unless the Board of Directors
determines to administer the Policy itself. The Committee or the Board of Directors,
as applicable, in its role of administering the Policy is the




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HR Policy
 Executive Stock Ownership & Retention Policy
 Doc Ref:
    
    IMDate:
    
    December 1, 2009Contact:
    
    CompensationDepartment:
    
    Human ResourcesPage:
    
    2 of 4
   Administrator. The
Administrator may delegate ministerial administrative duties to one or more officers
or employees of the Company.
 3.2.
    
    Salary Multiple Thresholds.Each Covered Individual is required to achieve and
maintain a salary multiple threshold based on a multiple of base annual salary for such
Covered Individual as set forth in the following table:
 Covered Individuals
    
    Salary Multiple ThresholdChief Executive Officer
    
    6x base annual salaryPresident & Chief Operating Officer
    
    4x base annual salarySenior Executive Vice Presidents
    
    4x base annual salaryExecutive Vice Presidents
    
    3x base annual salarySenior Vice Presidents (Section 16 officers)
    
    3x base annual salary
 3.2.1
    
    Valuation Methodology.The value of a Covered Individuals
stock ownership requirement is based on his or her then current base annual
salary. This value may increase or decrease as a result of a change in the
Covered Individuals title or base annual salary. The value of the Covered
Individuals stock ownership is based on the average closing price of a share
of Ingram Micro Class A Common Stock (as adjusted for stock splits and similar
changes to the stock) as reported on the New York Stock
Exchange during the four week period ending closest to June 30 of each year
multiplied by the number of shares of Ingram Micro Class A Common Stock
owned by the Covered Individual.3.2.2
    
    Eligible Equity. For purposes of determining whether a Covered
Individual has satisfied the stock ownership requirements of this Policy,
eligible equity shall include all shares of Ingram Micro Class A common stock
(i) owned by the Covered Individual, (ii) owned jointly with the Covered
Individuals spouse and/or children, (iii) owned by the Covered Individuals
spouse, (iv) held by a Covered Individual in the Ingram Micro




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HR Policy
 Executive Stock Ownership & Retention Policy
 Doc Ref:
    
    IMDate:
    
    December 1, 2009Contact:
    
    CompensationDepartment:
    
    Human ResourcesPage:
    
    3 of 4
   401(k) Investment
Savings Plan, (v) held in custodial accounts or trust for the economic benefit
of the Covered Individual or the Covered Individuals spouse and/or children,
whether acquired through open market purchase, (vi) underlying vested
restricted stock, restricted stock units, performance shares or performance
share units, or (vii) received from the exercise of stock options.
 3.3.
    
    Stock Retention Requirement.As of the Effective Date, until a Covered
Individual has satisfied his or her applicable salary multiple threshold, the Covered
Individual is required to retain 50% of the Net Shares resulting from the vesting of
all restricted stock or restricted stock unit awards and 50% of the Net Shares
resulting from the exercise of all stock option awards. Shares subject to the
retention requirements of this Policy shall not be pledged, hypothecated, made subject
to execution, attachment or similar process, or in any manner be made subject to a
hedge transaction or puts and calls.
 3.3.1
    
    Net Shares. For purposes of this Policy, Net Shares means
those shares that remain after payment of withholding taxes and the exercise
price of stock options, if applicable, including shares sold or netted with
respect thereto.
 3.4.
    
    Undue Hardship.There may be instances where abiding by this Policy
may place an undue financial hardship on a Covered Individual, though it is anticipated
that such instances will be rare. The Administrator may, in its sole discretion, waive
or develop an alternative stock ownership requirement for a Covered Individual that
reflects the intent of this Policy while taking into consideration the Covered
Individuals personal financial circumstances. The Administrator shall make such a
determination after receipt of a written request from the Covered Individual
requesting the waiver and specifying the reasons therefore. There shall be no time
limit on when the Administrator may consider the request.
 4.0
    
    DETERMINATIONS IN DISCRETION OF THE ADMINISTRATOR.
 4.1.
    
    Modification.The Administrator reserves the right to modify or terminate this
Policy at any time if it determines in its sole discretion that such action would be in
the best interest of the Company.4.2.
    
    Compliance.The Administrator has the discretion to enforce this Policy on a
case-by-case basis. Violations of this Policy will be taken into consideration by




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HR Policy
 Executive Stock Ownership & Retention Policy
 Doc Ref:
    
    IMDate:
    
    December 1, 2009Contact:
    
    CompensationDepartment:
    
    Human ResourcesPage:
    
    4 of 4
   the
Administrator as it considers the authorization of future long-term incentive awards.
Future grants may be discontinued or significantly reduced, depending on the
circumstances, at the sole discretion of the Administrator.
 5.0
    
    DEFINITIONSFor purposes of this policy, the following terms will have the meanings set forth below:
 5.1.
    
    Company
shall mean Ingram Micro Inc., a Delaware corporation, and its wholly owned
subsidiaries and affiliates.5.2.
    
    Effective Dateshall mean the date on which this Policy was adopted by the
Company.
 6.0
    
    REVISION HISTORYThis Policy supersedes any previous policy of the Company concerning stock ownership
guidelines. In the event of any conflict or inconsistency between this Policy and any other
materials previously distributed by the Company, this Policy shall govern.
 6.1.
    
    Adopted July 29, 19986.2.
    
    Amended and restated December 1, 2009