Supplier Code of Conduct Policy

I. Intended Purpose

This Supplier Code of Conduct sets expectations for ethical, responsible, and legally compliant business practices across Connection’s supply chain. It aligns with recognized international standards, including the Universal Declaration of Human Rights, United Nations Global Compact Principles, Sustainable Development Goals, and Convention on the Rights of the Child.

II. Scope

Connection expects suppliers of PC Connection, Inc., (“Connection”) and its family of companies to align with our values and conduct business ethically and legally. Suppliers must ensure that their employees, affiliates, distributors, subcontractors, agents, and other representatives providing products or services to Connection, or to Connection customers on Connection’s behalf, comply with this 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.

• Child Labor. Suppliers will not directly or indirectly employ workers below the applicable minimum age.
• Human Trafficking and Forced Labor. Suppliers must not use, support, or knowingly source from supply chains associated with human trafficking, forced labor, prison labor, bonded labor, or other involuntary labor. Suppliers must take reasonable steps to identify and address forced-labor risks, including risks subject to import restrictions such as the Uyghur Forced Labor Prevention Act, and provide supporting documentation upon request.
• Wages and Working Hours. Suppliers must comply with applicable wage, hour, overtime, benefits, and compensation laws, and must not require employees to work more than legally permitted.
• Freedom of Association. Suppliers must respect workers’ lawful rights to freedom of association and collective bargaining without intimidation, reprisal, or harassment.
• Discrimination. Suppliers must not discriminate on any basis prohibited by law, including race, color, sex, religion, national origin, age, disability, sexual orientation, gender identity, genetic information, veteran status, or other protected status.

Environment

We expect suppliers to comply with applicable environmental requirements and to reduce adverse environmental impacts associated with their operations.

• Environmental Responsibility. Suppliers are expected to identify and mitigate environmental impacts on communities, the environment, and natural resources, while seeking opportunities to reduce emissions and hazardous waste and promote reuse and recycling.
• Environmental Compliance. Suppliers must comply with applicable environmental laws, regulations, customer requirements, hazardous substance controls, solid waste requirements, and material restrictions.

Health and Safety

We recognize the importance of a safe and healthy working environment to prevent work-related injuries and diseases.

• Health and Safety Laws. Suppliers must comply with applicable health and safety laws, provide a safe work environment, and follow Connection policies and site requirements when on-site at Connection or customer locations.
• 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 expect supplier to conduct business with integrity and comply with all applicable laws and regulations.

• Conflict of Interest. Suppliers must avoid actual or apparent conflicts of interest and promptly notify affected parties in writing if one arises.
• Global Trade Compliance. Suppliers must comply with applicable export, import, customs, sanctions, and trade compliance laws.
• Anti-Corruption, Gifts, and Improper Payments. Suppliers must not engage in corruption, extortion, embezzlement, bribery, kickbacks, facilitation payments, or other improper payments, and must comply with applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act where applicable.
• Intellectual Property Rights. Suppliers must respect intellectual property rights of others, including patents, trademarks, copyrights, and other proprietary rights.
• Fair Dealings and Competition Laws. Suppliers must deal fairly and not use manipulation, concealment, abuse, or misrepresentation of material facts. Supplier will not engage in collusive bidding, price fixing, price discrimination or other unfair trade practices in violation of applicable antitrust and competition laws.
• Conflict Minerals and Responsible Mineral Sourcing. Suppliers are expected to support responsible sourcing of 3TG minerals—tin, tantalum, tungsten, and gold—and other minerals that may present heightened human rights or conflict-related risks. Where applicable, suppliers should conduct appropriate due diligence, work with their manufacturers, OEM partners, and upstream suppliers, and provide reasonable documentation upon request.
• Data Confidentiality. Suppliers must comply with applicable data protection and security laws and protect Connection confidential information, using or disclosing it only as authorized by Connection.
• Maintain Records. Suppliers must maintain accurate records that fairly reflect business transactions and retain them as required.
• Monitoring Compliance. Suppliers must maintain processes and documentation to demonstrate compliance with this Code and provide reasonable access to such documentation upon request.

Compliance and Reporting

Suppliers may demonstrate compliance through their own code of conduct or policies, provided they are consistent with this Code. Connection may request verification, including:

1. Self-Assessments: We may ask suppliers to complete 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