Supplier Code of Conduct Policy

I.   Intended Purpose

This Supplier Code of Conduct aligns with international business conduct models by supporting the Universal Declaration of Human Rights, the United Nations Global Compact Principles, the Sustainable Development Goals (SDGs), and the Convention on the Rights of the Child. It ensures ethical practices by prohibiting child labor, human trafficking, and forced labor, while promoting fair wages, collective bargaining, and non-discrimination. Our Code also emphasizes environmental responsibility, anti-corruption measures, and compliance with global trade laws, ensuring suppliers uphold high standards of ethical business practices.

II.   Scope

Respect, integrity, and corporate citizenship are part of Connection’s core values, and these values foster a culture of mutual trust and respect that drive our company’s commitment to diversity, equity, inclusion, and environmentally sound business practices. We expect suppliers of PC Connection Inc., (“Connection”) and/or any Connection family of companies to align with our values and operate using the highest ethical and legal principles. We expect suppliers to ensure that any employees, affiliates, distributors, subcontractors, agents, or other representatives of suppliers providing products or services to Connection or to Connection’s customers on behalf of Connection to comply with Connection’s Supplier Code of Conduct (the “Code”).

Labor and Human Rights

We believe in the importance of respecting human rights and promoting fair labor practices in business operations. At Connection we treat our employees with respect and dignity and expects its suppliers to do the same.

• Child Labor. Suppliers will not directly or indirectly employ workers that are younger than the applicable required minimum age.
• Human Trafficking and Forced Labor. Suppliers will not knowingly source materials from supply chains associated with human trafficking and should take reasonable efforts to ensure that their own suppliers comply with this requirement.
• Wages and Working Hours. Suppliers must comply with all applicable wage and hour laws, including those relating to minimum wage, overtime hours, and other elements of compensation, and must provide all legally mandated benefits. Suppliers will not require employees to work more than the maximum number of hours permitted under applicable laws and shall be allowed at least one day off per week.
• Freedom of Association. Suppliers must respect workers’ rights to collective bargaining and be compliant with existing local laws and without intimidation, reprisal, or harassment.
• Discrimination. To the extent prohibited by applicable law, Suppliers must not discriminate against any person because of their race, color, sex, religion, national origin, age, disability, sexual orientation, gender identity, genetic information, veteran status, or any other basis.

Environment

We recognize the importance of protecting the environment and mitigating our impact on it. We understand that our operations and the products we sell can have environmental implications. Therefore, we are committed to conducting our business in an environmentally responsible manner and expect our suppliers to comply with all relevant environmental laws and regulations applicable to our business operations.

• Environmental Responsibility. Suppliers are expected to identify environmental impacts and mitigate negative effects on the community, environment, and natural resources, demonstrating a commitment to sustainability initiatives.
• Environmental Compliance. Suppliers must comply with relevant environmental laws, regulations, and customer requirements. This includes adhering to applicable laws and regulations regarding the management of hazardous substances, solid waste, and material restrictions.
• Environmentally Friendly Technologies. Suppliers are encouraged to develop and promote technology that is environmentally beneficial.

Health and Safety

We recognize the importance of a safe and healthy working environment to prevent work-related injuries and diseases. Suppliers are expected have systems in place to minimize workplace incidents and meet applicable health and safety laws and regulations.

• Health and Safety Laws. Suppliers must obey all relevant health and safety laws and ensure a safe work environment for workers. When on-site at any Connection or customer location, suppliers, its affiliates, agents, or representatives must follow Connection policies and site requirements.
• Workplace Environment. Suppliers are required to ensure a workplace environment that is free from physical, psychological, and verbal harassment, as well as any other forms of abusive conduct.

Ethical Business

We promote the conduct of all company business in accordance with high standards of integrity and in compliance with all applicable laws and regulations. We expect suppliers to uphold high standards of ethics and integrity.

• Conflict of Interest. Suppliers are expected to avoid all conflicts of interest or situations giving the appearance of a potential conflict of interest and to provide written notification to all affected parties if an actual or potential conflict of interest arises. This includes a conflict between the interests of Connection and personal interests or those of close relatives, friends, or associates.
• Global Trade Compliance. Suppliers must comply with all export-import laws, customs duties and all other laws to their international business activities.
• Anti-Corruption, Gifts, and Improper Payments. Suppliers are prohibited from engaging in corruption, extortion or embezzlement in any form and must comply with all applicable anti-corruption laws and regulations of the countries in which they operate such as the U.S. Foreign Corrupt Practices Act, and as applicable any other international anti-corruption conventions. Suppliers will not offer or accept bribes or employ other means to obtain an undue or improper advantage. Bribes, kickbacks, facilitating payments and similar payments to government officials or to Connection employees or agents acting on Connection’s behalf are prohibited. Connection employees are discouraged from accepting gifts of more than minimal value or lavish entertainment from suppliers. When business meals and entertainment are appropriate to further business relationships, those expenses may not be extravagant in nature.
• Intellectual Property Rights. Suppliers must respect and refrain from infringing upon the intellectual property rights of others, including patents, trademarks, copyrights, and other proprietary rights.
• Fair Dealings and Competition Laws. Suppliers should not take unfair advantage of anyone else through manipulation, concealment, abuse, misrepresentation of material facts or any other unfair dealing. Supplier will not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of applicable antitrust and competition laws. Supplier will uphold fair business standards in advertising, sales and competition.
• Conflict Minerals. Conflict minerals (3TG) include cassiterite, columbite-tantalite, gold, wolframite, and their derivatives like tin, tantalum, and tungsten. Suppliers must check if their products contain these minerals and, if so, conduct due diligence to identify their sources and support efforts to eliminate minerals that fund armed groups in the Democratic Republic of Congo or nearby regions. Suppliers should provide conflict mineral reports (CMRTs) and policies showing their commitment to becoming conflict-free and documenting the origins of the minerals they purchase.
• Data Confidentiality. Suppliers must comply with applicable data protection and security laws, along with relevant regulations, especially concerning the personal data of customers, consumers, employees, and shareholders. Suppliers must protect the confidential information entrusted to them by Connection and may only use and disclose such information in a manner authorized by Connection. Confidential information includes any business information of Connection, its customers or suppliers that is not generally known to the public.
• Maintain Records. Suppliers are expected to create accurate records, and not alter any record entry to conceal or misrepresent the underlying transaction represented by it. All records, regardless of format, made or received as evidence of a business transaction must fully and accurately represent the transaction or event being documented. Records should be retained based on the applicable retention requirements.
• Monitoring Compliance. Suppliers must establish and maintain a process of ensuring compliance with the Connection Supplier Code of Conduct. Supplier must maintain all documentation necessary to demonstrate its compliance with the Connection Supplier Code of Conduct. Upon Connection request, Supplier should be prepared to provide Connection or its affiliates access to such documentation.

Compliance and Reporting

Suppliers may also demonstrate their commitment to these principles through compliance with their own code of conduct or company policies that embrace these standards, provided that Connection may ask to verify compliance by any of the following methods and to take corrective action if there is a reason for concern:

1. Self-Assessments: We may ask suppliers to fill in a questionnaire on compliance.
2. Certifications/Statements: We may ask suppliers for a certification or statement confirming compliance.

Violation of this Code can be reported through the following options:

Telephone:	Ethics Hotline 1.800.461.9330
Internet:	Anonymous Reporting https://www.convercent.com/
Mail:	VP of Legal and Admin Connection 730 Milford Road Merrimack, NH 03054-4631