Introduction and Accountability
Taking Care of One Another
Earning and Maintaining Trust
Acting with Professional and Sound Judgment
Conclusion and Resources
EARNING AND MAINTAINING TRUST
Avoid Conflicts of Interest
We avoid conflicts of interest. We owe our fellow coworkers and shareholders our best impartial judgment and loyalty.
A conflict of interest occurs when other interests interfere with that impartiality or loyalty. Because it is impossible to describe every potential situation in which a prohibited conflict may arise, CDW relies on you to exercise sound judgment and to seek guidance when you are uncertain as to the correct course of action. When in doubt, it is always best to disclose a potential conflict and seek guidance in resolving it appropriately.
How IT's Done ...
- Know how to recognize a conflict of interest.
- Do not use CDW opportunities, assets, information, or the power or authority entrusted to you in your CDW role for personal gain or to support an outside business venture.
- Remove yourself from decisions that involve CDW and a family member or others whom you have a significant personal relationship.
- Similarly, remove yourself from decisions involving CDW and a company in which you or a family member has a significant financial interest.
- Contact your manager if you have any questions about whether something might present a conflict of interest or the appearance of a conflict of interest.
Significant personal relationship
A "significant personal relationship" includes your spouse, domestic partner, children, parents, in-laws, grandparents, individuals with whom you have dating or physical relationships, close friends and outside business relationships.
Significant financial interest
A “significant financial interest” generally means an ownership greater than 5% of your (and/or your immediate family members') total net worth, or that you own 1% or more of the outstanding shares of a public company or have a partnership interest in a privately held company. If in doubt about whether you have a “significant financial interest” in a company, contact your supervisor or manager, the Ethics and Compliance Office or the Ethics Helpline for guidance.
The CDW Way
When it comes to conflicts of interest, appearances do matter. The appearance of a conflict, even if it does not impact your actions, can lead others to doubt your impartiality and loyalty.
Make the Connection
It is important to recognize that a conflict of interest exists if your circumstances would lead a reasonable person to question whether your motivations are in the best interests of CDW.
A conflict of interest can arise in many situations, including:
- Family and romantic relationships with coworkers or the coworkers of our suppliers, partners or customers
- Giving or receiving gifts, hospitality or travel in a manner inconsistent with CDW policy
- Outside work activities
- Dealing with family members employed by a vendor or partners
- Dealing with a vendor or partner who employs family members
- Dealing with a partner in which you or a family member have a financial interest
For more information, visit the resource links below:
RECOGNIZE
Is there a conflict of interest? Could someone question if my motives are in the best interest of CDW?
REPORT
If so, promptly report the conflict or potential conflict to your manager.
REMEDIATE
After reporting, address the conflict:
- Most often, you will need to remove yourself from the conflicting situation.
- In some cases, you may be permitted to engage in the activity if you obtain the approval of your manager and take steps to remediate the conflict.