Insight is committed to providing its clients with information technology hardware, software and services procured from a legal and ethical supply chain. The Insight Vendor Code of Conduct describes both legal and social responsibility requirements for all of our third-party vendors (“Vendors”). Vendors, in their activities, will operate in full conformance with the laws, rules and regulations of the countries in which they operate and will conform to these requirements and communicate our Vendor Code of Conduct to their lower tier suppliers and vendors.

At Insight, honesty and integrity are our guiding principles. We expect our vendors to share this commitment. Insight requires our vendors to ensure that working conditions in their operations and supply chains are safe, that all workers are treated with respect and dignity, and that business operations are environmentally responsible and conducted ethically. We will assess conformance to these requirements and will consider a vendor’s conformance in making sourcing and procurement decisions.

We are fully aware of the responsibility we bear towards our customers, shareholders, employees and the communities in which we work. Thus, we have given ourselves a strict set of ethical standards to guide us in our business dealings.

We expect all of our vendors, i.e., all companies who do business with any company or division of Insight, to adhere to the same ethical standards. For this purpose, Insight has drawn up this Vendor Code of Conduct, which sets the minimum standards for doing business with Insight.

Laws and Ethical Standards
Vendors and their employees are required to strictly observe all applicable laws and regulations. Violations of law by even one vendor can harm Insight’s reputation and ability to carry on business. Vendors should require that all their employees are familiar with the basic legal requirements that pertain to their duties and responsibilities.

Insight’s commitment is strengthened by its observance of business conduct models such as the Universal Declaration of Human Rights, the Global Compact Principles, the Sustainable Development Goals (SDG) and the Convention on the Rights of the Child, which define the general challenges and commitments in the sections of this Code. Insight also supports industry initiatives, including the Responsible Business Alliance (RBA). Vendor should support the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labor Organization Declaration on Fundamental Principles and Rights at Work, in accordance with national laws and practice. Vendor shall comply with all laws applicable to its business. This especially applies to:

Human Rights & Labor
At Insight, we treat each other with respect and dignity and we hold our vendors to the same standard. Vendors must comply with all applicable laws regarding employment, wage and labor rights. We support fundamental human rights for all people and expect our vendors to do the same.

Discrimination
Vendors are expected to have a work environment that is free from any discrimination and harassment. This includes harassment or discrimination on a basis of race, color, religion, sex, gender identity, union membership, maternity, national origin, age, marital status, military service, disability, sexual orientation, genetic information, citizenship, or social or economic status.

Labor
Vendors are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees or any other type of worker.

1. Freely Chosen Employment – Vendors must not participate in human trafficking; use forced, bonded, involuntary or slave labor; or purchase materials or services from companies using forced, involuntary or slave labor. Workers must be allowed to maintain control over their identification documents (e.g., passports, work permits or any other personal legal documents). The vendor shall ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. The vendor shall be responsible for payment of all fees and expenses (e.g., licenses and levies) relating to workers, where legally required. Punishment, mental and/or physical coercion are prohibited. Vendors must ensure that workers' contracts clearly convey the conditions of employment in a language understood by the workers. Disciplinary policies and procedures shall be clearly defined and communicated to the workers. Vendors must be able to certify that materials included in their products comply with the slavery and human trafficking laws of the country or countries in which they do business.
2. Child Labor Avoidance – Vendors must provide a workplace that is free from all forms of child labor in their operations. Vendor must not, in the absence of local law, employ workers under the age of 15. Workers under the age of 18 may not perform work likely to jeopardize their health, safety or education.
3. Harassment and Humane Treatment – Vendors must treat all workers with respect and dignity. They may not subject workers to corporal punishment, physical, sexual, psychological or verbal harassment or abuse. Where it is allowed by law, vendors should have a system that allows employees to anonymously report their concerns. In addition, vendors must provide an environment that allows employees to raise concerns without fear of retaliation. Retaliation against an individual who has made a complaint concerning discrimination, discriminatory harassment, including sexual harassment, or against individuals cooperating with an investigation of a discrimination or harassment complaint, will not be tolerated.
4. Compensation and Working Hours – The vendor shall comply with all applicable national laws and mandatory industry standards regarding working hours, overtime, days of rest, and wages and benefits. The vendor shall pay workers in a timely manner and clearly convey the basis on which workers are being paid. Deductions from wages as a disciplinary measure shall not be allowed, if not legally permitted. Vendors are expected to pay their employees a living wage. Vendors must meet all legal requirements relating to wages, benefits and compensation to employees.
5. Hiring, Diversity and Employment Practices – Vendors are expected to support diversity and equal opportunity in their workplaces. Vendors must prohibit discrimination based on race, color, religion, sex, gender identity, union membership, maternity, national origin, age, marital status, military service, disability, sexual orientation, genetic information, citizenship, or social or economic status.
6. Freedom of Association and Collective Bargaining - Vendors must respect an employee's lawful rights to associate with others to form and/or join an organization of their choice and bargain collectively, without interference, harassment, or retaliation. This includes the right for employees to communicate openly with management regarding working conditions without fear of retaliation.

Health, Safety & Well-being of Employees
At Insight, employee health, safety and well-being are fundamental to our success. Vendors are expected to have implemented effective health and safety management practices within their business. Vendors must recognize that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production, and worker retention and morale. Vendors shall abide by all applicable laws and regulations relating to safety and health within their work environments.

1. Well-being of Employees - All employees should be able to perform their duties in a safe and hygienic working environment. Vendors are expected to provide a working environment that ensures the safety and quality of health of its employees. This includes having safety procedures in place and providing appropriate personal protective equipment to minimize the risk of accident or injury, where applicable.
2. Safety Training - Vendors are expected to provide necessary and applicable occupational health and safety training and to implement processes to prevent catastrophic events. This includes conveying information to identify potential emergency situations and providing safety and health information related to hazardous materials, where applicable. It is also necessary to ensure that health and safety programs are consistent for contractors and subcontractors working at vendors' facilities.
3. Incident Management - Vendors are expected to have systems for employees to report health and safety incidents, as well as managing and tracking reports of incidents. Such incidents are required to have corrective action plans to mitigate potential risks. Vendors must provide necessary medical treatment and facilitate workers' return to work.
4. Workplace Violence - Any acts of physical intimidation, assaults or threats of violence against another person, including Insight employees, customers, and the public, or the destruction of Insight or personal property, are strictly prohibited. Vendors may not possess weapons on Insight property. Vendors may not store a weapon in any Insight vehicle, regardless of its location, or store a weapon in a personal vehicle while on Insight property.
5. Operating Permits and Licenses - Vendors must comply with all applicable laws and regulations with respect to the health and safety of employees. Vendors also must have all permits and licenses required to operate.

Sustainability & Environmental Responsibility
At Insight, we strive to understand the potential impact of our operations and products on the planet, and minimizing our corporate footprint through many efforts including our supply chain. Vendors are expected to recognize that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public. Vendors must comply with all laws and regulations related to all emissions, water discharge, toxic substance and hazardous waste disposal.

1. Respect for the Environment - Vendors must comply with all applicable environmental laws, regulations and directives regarding waste, air emissions, hazardous materials, and wastewater discharge including the manufacture, transportation, storage, disposal, and release to the environment of such materials.
2. Sustainable Consumption - Vendors are expected to use natural resources in an efficient and responsible manner. To minimize or eliminate negative environmental impacts, vendors are expected to engage in the development of sustainable practices and activities.
3. Quality and Safety of Products - Vendors must ensure products supplied to Insight are manufactured and distributed in accordance with applicable laws. Products also must comply with all applicable quality and safety standards.
4. Continuous Improvement - Vendors are expected to implement appropriate environmental management policies that seek to reduce the environmental impacts of operations. Accordingly, vendors are expected to continually improve the policies in their own organizations and promote sustainability throughout their value chains.

Ethics
We are fully aware of the responsibility we bear towards our customers, shareholders, employees and the communities in which we work. Thus, we have given ourselves and our vendors a strict set of ethical standards to guide our business dealings. Vendors and their agents are to uphold the highest standards of ethics.

1. Business Integrity – Vendors shall abide by all applicable laws and regulations in the countries in which it operates, including but not limited to the Foreign Corrupt Practices Act, the UK Anti-Bribery Act and all applicable international anti-corruption and anti-competition conventions.
2. Anti-Corruption/Improper Payments – Bribes, kickbacks and similar payments are strictly prohibited. This applies even when local laws may permit such activity. Employees, vendors and agents acting on behalf of Insight are strictly prohibited from accepting such considerations under any circumstances. Facilitating payments (e.g., payments made to expedite or secure performance of a routine governmental action like obtaining a visa or customs clearance) are also prohibited.
3. Antitrust – Vendors must not fix prices or rig bids with their competitors. They must not exchange current, recent, or future pricing information with competitors.
4. Counterfeit Parts - We expect our vendors to develop, implement, and maintain methods and processes appropriate to their products to minimize the risk of introducing counterfeit parts and materials into deliverable products. Effective processes should be in place to detect counterfeit parts and materials, provide notification to recipients of counterfeit product(s) when warranted, and exclude them from the delivered product.
5. Data Protection & Disclosure of Information – Proper management of confidential information is imperative to the success of the business. Vendors must protect Insight information, electronic data and intellectual property with appropriate safeguards and should utilize such information only within the scope of the business arrangement for which it pertains. Any transfer of confidential information must be executed in a way that secures and protects the intellectual property rights of Insight, its customers and its vendors. Vendors may receive our confidential information only as authorized by a confidentiality or non-disclosure agreement and must comply with their obligations not to disclose the information, to not use the information except as permitted by the agreement, and to protect the information from misuse or unauthorized disclosure. Our vendors can expect Insight to similarly safeguard their confidential information. Vendors may not utilize the Insight trademark, images or other materials to which Insight owns the copyright, unless explicitly authorized.

   
   Vendors shall adhere to relevant data protection and security laws, as well as to respective regulations, in particular with regard to personal data of customers, consumers, employees and shareholders. The vendor shall comply with all said requirements when personal data is collected, processed, transmitted or used.

   Vendors shall safeguard and make only appropriate use of confidential information. The vendor shall not disclose any information that is not known to the general public.

6. Media - Vendors are solely responsible for what they or their agents or personnel post online. We expect vendors to forward all media request/inquiries across all channels (print, broadcast, online, radio, social media, etc.) regarding Insight, or work done by vendor for Insight, for review and approval to PublicRelations@insight.com. Vendors should not speak about Insight to media or in any public forum without consent from the Insight Public Relations department.
7. Fair Business, Advertising and Competition – Vendors are expected to conduct business in accordance with all applicable antitrust or anti-competition laws and regulations. This includes, but is not limited to, improper exchange of competitive information, price fixing, bid rigging or improper market allocation.
8. Trade Regulation - Vendors shall comply with all applicable trade and import regulations, including sanctions and embargoes that apply to their activities.
9. Anti-boycott Laws - United States laws, and the laws of many other countries, prohibit persons from taking actions or entering into agreements that have the effect of furthering any unsanctioned boycott of a country. Insight vendors are required to comply with all anti-boycott laws applicable in their jurisdiction.
10. Embargoes and Sanctions - Insight complies fully with international economic sanctions and embargoes restricting persons, corporations and foreign subsidiaries from doing business with certain countries, groups and individuals. Economic sanctions prohibit or restrict doing business with targeted governments and organizations, as well as individuals. Sanction prohibitions also may restrict investment in a targeted country, as well as trading in certain goods, technology and services with a targeted country. Insight vendors are required to comply with all economic sanctions and embargoes applicable in their jurisdiction.
11. Conflict Minerals – Insight expects its vendors to take steps to determine if their products contain conflict minerals (tin, tantalum, gold and tungsten) and if so, implement supply chain due diligence processes to identify sources of these minerals and support efforts to eradicate the use of conflict minerals which directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries.
12. Political Contributions or Charitable Donations - Vendors are not authorized to make any type of political contribution or charitable donation on Insight’s behalf.
13. Unauthorized Lobbying – Vendors are not authorized to undertake any type of lobbying or other similar representative efforts on Insight’s behalf before any kind of government entity, official or body or representative without the express written consent of Insight.

Management System
A solid management system and commitment are key to enriching the social and environmental condition of the overall supply chain. Vendors shall adopt or maintain a management system that is designed to ensure compliance with applicable laws, regulations and customer requirements; conformance with the principles of this Code; and identification and mitigation of operational risks.

1. Accurate Records and Accounting – Vendors are expected to accurately records, maintain, and report with respect to their business, including but not limited to financial accounts, quality reports, time records, expense reports, resumes and submissions to Insight, their customers and/or regulatory authorities.
2. Business Continuity Planning - Vendors shall be prepared for any disruptions of its business (e.g., natural disasters, terrorism, software viruses, illness, pandemics, infectious diseases). This preparedness especially includes disaster plans to protect both employees as well as the environment as far as possible from the effects of possible disasters that arise within the domain of operations.

Questions or Comments
Any Vendor may direct questions or comments about this Vendor Code of Conduct to the Insight Compliance Department at compliance@insight.com.

Violation of the Vendor Code of Conduct
Vendors must take prompt action to remedy any violation of Insight’s Vendor Code of Conduct, as well as other legal requirements applicable to its activities, and to inform Insight if the violation involves goods or services provided to Insight. A violation of this Code, including a failure to promptly take action to remedy or report a violation will jeopardize the vendor's business relationship with Insight. If an audit is necessary to confirm a vendor's compliance with this Code, we require full and timely cooperation.

We ask that you make certain the contents of this Code are shared with those in your organization who have contact with Insight employees and/or work at Insight facilities. We also ask that you share this Code with your employees accountable for your company's relevant policies and work practices.

Please do not hesitate to contact us should you have any questions or concerns related to the Code

Questions or concerns may also be submitted to https://insight.alertline.com.

Non-Compliance Reporting
Violations of this Vendor Code of Conduct can be reported confidentially any of the following ways:

Effective December 30, 2020