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Ethics & Compliance

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CDW's ethics and compliance program is designed to uphold the trust of our coworkers, shareholders, customers, partners, and communities. The program includes seven core components that guide program design, execution, and continuous improvement:

  • Culture
  • Structure and oversight
  • Compliance risk management
  • Standards
  • Communication and training
  • Discipline and incentives
  • Reporting and investigations

We safeguard stakeholder trust by adhering to The CDW Way Code and by meeting all legal and regulatory obligations. These standards also guide responsible decision-making across all emerging technologies.

The CDW Way Code:

  • Applies to all coworkers and our Board of Directors.
  • Defines our standards for corporate behavior.
  • Provides direction on the ethical and legal issues coworkers may encounter.
  • Reinforces the importance of organizational and individual accountability to maintain trust in our partnerships.
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Upon hire and annually, coworkers receive training and complete acknowledgement of compliance with the Code. Compliance is reinforced through centralized incident tracking, consistent investigations, and disciplinary measures when appropriate. Training covers anti-discrimination, anti-harassment, and respectful workplace practices.

Our ERM operating model identifies emerging and potential ethics and compliance risks through:

  • Periodic risk assessments.
  • Ongoing monitoring of regulatory developments and enforcement.
  • In-country program reviews for global consistency.
  • Targeted program enhancements and prioritization of resources.
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Reporting Ethics Concerns

Reporting Ethics Concerns

Our Ethics Helpline, operated independently 24/7, is available to anyone inside or outside CDW who wishes to report or address concerns. The helpline can be used confidentially and anonymously to ask questions, seek guidance, or report possible violations. All reports are investigated promptly, thoroughly, and fairly, and appropriate action is taken whenever necessary.

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