ROAD TO SUCCESS..The success of CDW depends in large part on the development, use and protection of...

CDW LLC

US Coworker Handbook

ROAD TO SUCCESS..

Effective February 2016

ROAD TO SUCCESS | COWORKER HANDBOOK

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TABLE OF CONTENTS

THE “ROAD TO SUCCESS” .................................................................................1

CDW’S GOLDEN THREAD ..................................................................................2

RELATIONSHIP OF ROAD TO SUCCESS AND THE CDW WAY AND THE CDW WAY CODE ...................................................................................................3

QUALITY MANAGEMENT AND CUSTOMER SATISFACTION ................4

EQUAL OPPORTUNITY, AFFIRMATIVE ACTION AND NONDISCRIMINATORY POLICY ......................................................................5

PROHIBITION OF SEXUAL AND OTHER UNLAWFUL HARASSMENT .............................................................................. 7

ACCOMMODATIONS FOR DISABILITIES ......................................................9

PAYROLL AND BONUSES ................................................................................10

PROBATIONARY PERIOD .......................................................................................... 10

TIME RECORDING .......................................................................................................... 10

OVERTIME ......................................................................................................................... 10

PAY PERIODS ................................................................................................................... 10

DIRECT DEPOSIT ........................................................................................................... 10

LOST PAYCHECKS ........................................................................................................ 10

PERFORMANCE EVALUATIONS ............................................................................ 11

SALARY INCREASES ................................................................................................... 11

BONUSES ............................................................................................................................ 11

NONCASH COMPENSATION .................................................................................... 11

OFCCP’S REQUIRED PAY TRANSPARENCY POLICY STATEMENT 11

COWORKER REFERRAL PROGRAM ................................................................... 12

GARNISHMENTS, LIENS, WAGE ASSIGNMENTS AND CHILD SUPPORT ................................................................................................. 12

BENEFITS .............................................................................................................. 13

DISCOUNTED PURCHASE PROGRAM FOR COWORKERS .................... 13

MATCHING CHARITABLE GIFTS PROGRAM .................................................. 13

RECOGNITION PROGRAMS ..................................................................................... 14

TIME AWAY FROM WORK ...............................................................................15

HOLIDAYS .......................................................................................................................... 15

VACATION .......................................................................................................................... 15

SICK/PERSONAL DAYS ............................................................................................ 16

FAMILY AND MEDICAL LEAVE ACT .....................................................................17

UNPAID MEDICAL LEAVE FOR COWORKERS NOT YET COVERED BY FMLA ..................................................................................................... 18

LEAVES RELATED TO DOMESTIC VIOLENCE .............................................. 18

PERSONAL LEAVE OF ABSENCE/OTHER TIME OFF ................................ 18

MILITARY LEAVE ........................................................................................................... 18

BEREAVEMENT LEAVE .............................................................................................. 18

SCHOOL VISITATION ................................................................................................... 19

JURY DUTY ........................................................................................................................ 19

TIME OFF TO VOTE ....................................................................................................... 19

CDW COMMUNITY SERVICE DAY OFF .............................................................. 19

WORK SCHEDULE ............................................................................................. 20

HOURS ................................................................................................................................ 20

HOURLY COWORKERS BREAKS ........................................................................ 20

LUNCH ................................................................................................................................ 20

ATTENDANCE ..................................................................................................... 20

OCCURRENCES ............................................................................................................. 20

UNEXCUSED ABSENCES .......................................................................................... 21

UNEXCUSED LATE ARRIVALS/EARLY DEPARTURES ............................ 21

NOTIFICATION REQUIREMENTS FOR ABSENCES OR LATENESS ................................................................................................................. 21

EMERGENCIES, SAFETY/SECURITY & BUSINESS CONTINUITY ..... 22

EMERGENCIES ................................................................................................................22

EVACUATION PROCEDURES .................................................................................22

BUSINESS CONTINUITY PROGRAM (BCP) ...................................................22

SAFETY .............................................................................................................................. 23

PHYSICAL SECURITY................................................................................................. 23

ROAD TO SUCCESS | COWORKER HANDBOOK

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TABLE OF CONTENTS (continued)

WORKPLACE INJURIES AND WORKERS’ COMPENSATION .............. 26

EMPLOYMENT PRACTICES ............................................................................27

ALCOHOL AND DRUGS ..............................................................................................27

ALCOHOL AND DRUG RULES IN THE WORKPLACE ...............................27

TESTING FOR DRUGS AND ALCOHOL ........................................................... 28

TESTING PROCEDURES .......................................................................................... 28

REPORTING OBLIGATIONS .................................................................................. 28

WORKPLACE VIOLENCE ......................................................................................... 29

DRESS CODE/APPAREL GUIDELINES ............................................................. 29

ROMANTIC OR SEXUAL RELATIONSHIPS IN THE WORKPLACE ...... 30

EMPLOYMENT OF FRIENDS AND RELATIVES ............................................. 30

SHIPPING AND EXPORT COMPLIANCE........................................................... 30

OUTSIDE EMPLOYMENT ........................................................................................... 31

COMPANY OUTINGS ................................................................................................... 31

VENDOR SPONSORED EVENTS ........................................................................... 31

PERSONNEL RECORDS AND UPDATING OF PERSONAL INFORMATION ...................................................................................... 31

MAILING OR SHIPPING PERSONAL ITEMS ..................................................... 31

NONSMOKING ENVIRONMENT ............................................................................. 31

MOBILE DEVICES .......................................................................................................... 31

PARKING AND CARPOOLING PRIVILEGES .................................................... 32

AUTO SAFETY GUIDELINES ................................................................................. 32

DISPUTE RESOLUTION PROCEDURE .............................................................. 32

SOLICITATION AND LITERATURE ....................................................................... 32

TRANSFERS AND PROMOTIONS ....................................................................... 33

RESIGNATION, TERMINATION AND REFERENCES .................................. 33

COBRA RIGHTS ............................................................................................................. 33

INFORMATION SECURITY AT CDW ........................................................... 35

COMMERCIAL EMAILS ....................................................................................41

PARTICIPATING IN SOCIAL MEDIA THE CDW WAY ............................ 43

OTHER POLICIES ............................................................................................. 45

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ROAD TO SUCCESS | COWORKER HANDBOOK | 1

THE “ROAD TO SUCCESS”

CDW* was founded on two fundamental beliefs that still carry forward today:

• Coworkers are critical to the success of CDW’s business.

• No one does the job better than CDW coworkers.

At CDW, we refer to one another as “coworkers” to signify the mutual respect we have for each other as members of the CDW team. Throughout the “Road to Success,” “coworker” is used synonymously with “employee.”

We believe in providing a rewarding and challenging work environment to coworkers, one that allows each of us to grow professionally and yet have fun while we work. To help coworkers be successful and perform at their best, we have prepared the “Road to Success” as a guide to explain how CDW works, as well as to outline the expectations CDW has of its coworkers. By reviewing the information provided in this guide and agreeing to abide by the policies and procedures in it, you are well on your way along the “Road to Success” as a member of the CDW team.

This coworker handbook gives a general overview of CDW’s policies, procedures and benefits for coworkers based in the United States. It is not intended to include the details of each policy, procedure and benefit, nor does it include all policies. More information on CDW’s policies, procedures and benefits may be found on Connect, CDW’s intranet site. In addition, a complete description of any benefit governed by a plan document may be found in the benefit plan document. In the event there is an inconsistency between “Road to Success” and any CDW benefit plan document, the benefit plan document should be followed.

CDW’s coworkers are located throughout the United States and Canada. This version of “Road to Success” covers CDW coworkers based in the United States. In a few instances, the policies in this guide may deviate in some way from the laws in your state. In all instances, it is the intent of CDW to comply with state law, and if state law conflicts with the policies in this coworker handbook, state law will be followed.

CDW policies, including the provisions in “Road to Success,” may be revised occasionally, sometimes without notice. It is up to you to routinely review the policies and procedures on Connect and keep yourself apprised of any changes. “Road to Success” is maintained on Connect, and hard copies are available for review from the Coworker Services Business Partner Team. Hard copies may be checked out from the Coworker Services Business Partner Team for anyone to review on their own time. Should you have any questions or desire additional information concerning any of the topics discussed in “Road to Success,” feel free to talk with your supervisor, manager or anyone on the Coworker Services Business Partner Team.

This coworker handbook is not a contract between CDW and its coworkers; nor do these policies and procedures in any way modify the “at will” employment relationship between CDW and its coworkers. You are free to terminate your employment at any time, with or without cause and with or without notice. CDW reserves the same right.

*Throughout the “Road to Success,” “CDW” and the “Company” mean CDW Corporation and its US Subsidiaries



CDW’S GOLDEN THREAD

The Golden Thread communicates CDW’s business purpose (vision, value proposition), our 3-part strategy, our six company goals, the specific priorities we’ve set for the year and the guiding principles fundamental to our success (The CDW Way).

CDW’SGOLDENTHREAD

We run our business with passion and integrityWe empower others to do their jobsWe keep our commitments

We treat others with respectWe resolve conflict directlyWe listen

We include stakeholders in the decision processWe live our “Philosophies of Success” every dayWe make things happen

FINANCIAL: Exceed financial

targets

COMPANY: Position CDW for

long-term, sustainable growth

PARTNER: Maximize partner

return on investment

COMPETITION: Grow faster than

the market

CUSTOMER: Become indispensable

to our customers

COWORKER: Celebrate, motivate and develop the

best coworkers in the industry

To be the leading IT solutions

and services provider in the markets we serve

We help our customers achieve their goals by delivering integrated solutions and services that

maximize their technology investment

OUR VALUE PROPOSITION

THE CDW WAY

OUR 2016 PRIORITIES

OUR STRATEGY

OUR GOALS

VISION

EVERYTHING WE DO REVOLVES AROUND THE CUSTOMER.

2 Enhance our ability to sell and deliver high-growth, integrated solutions

3 Expand our services capabilities

1 Increase share of wallet from existing customers while adding new customers

1. Grow share in core IT offerings

9. Evolve our go-to-market strategy

4. Invest in infrastructure for sustained growth

3. Expand our services capabilities

2. Focus on five fastest-growing solutions: data center, collaboration, cloud, security and mobility

5. Execute gross margin, cost and productivity initiatives

8. Expand international capabilities

7. Continue to improve coworker engagement through focused action planning

6. Maximize partner model



RELATIONSHIP OF ROAD TO SUCCESS TO THE CDW WAY AND THE CDW WAY CODE

CDW is committed to providing a fair and equitable work environment for all coworkers. This commitment is reflected in The CDW Way and The CDW Way Code (our code of business conduct and ethics) (the “Code”). These are available on Connect or in hard copy for review from the Coworker Services Business Partner Team. While The CDW Way lists the shared values that guide our behavior, the Code sets forth the general standards of behavior necessary to ensure we abide by these values every day. The policies set forth in the “Road to Success” go a step further to provide more detailed guidance on specific topics and requirements.

Coworkers are expected to evaluate all of their actions against The CDW Way and generally act in accordance with the highest standards of personal and professional integrity in everything they do on behalf of CDW. At a minimum, this requires that coworkers comply with all applicable laws, rules and regulations and that they know, understand and follow the standards set forth in the Code, this handbook and all other relevant CDW policies posted on Connect.

Coworkers are accountable for their actions and are required to exercise good judgment in everything they do on behalf of CDW. Part of that responsibility includes ensuring that you understand and abide by the values and standards we set for ourselves in the Code and all policies and procedures relevant to your job responsibilities. Additionally, every coworker has a responsibility to seek guidance when they are unsure of what those values, standards and policies require, and to raise the issue if they believe someone else is not acting consistently with those values, standards and policies.



QUALITY MANAGEMENT AND CUSTOMER SATISFACTIONOne of CDW’s goals is to be the world’s biggest — and best — direct technology provider for business, government and education. What makes CDW different from our competitors is our emphasis on customer satisfaction. We provide the best technology experience in the industry and this begins with the quality of our service. As part of your employment, you will be responsible for the quality of your own work. We expect you to do this by learning our Circle of Service philosophy and the quality procedures and operating instructions that apply to your department.

Finance & Legal

Product & PartnerManagement

™

Operations

Marketing

Coworker Services

Customer

InformationTechnology

Technology Services

Sales

Everything we do revolves around the customer™

CDW Circle of Service



EQUAL OPPORTUNITY, AFFIRMATIVE ACTION AND NONDISCRIMINATION POLICYA. Equal OpportunityWe believe that to excel, we must continue to hire the best talent and encourage the full participation and commitment of all coworkers. In keeping with this belief, it is CDW’s policy to hire and to provide coworkers with the opportunity to grow, develop and contribute fully to our collective success without regard to race, color, sex, religion, national origin, genetic information, gender, sexual orientation, gender identity, disability, age, marital status, citizenship status, veteran status or any other characteristic protected by law. CDW also provides reasonable accommodations to qualified individuals with disabilities unless doing so would result in an undue hardship.

CDW is committed to equal opportunity in all aspects of employment, including recruiting, hiring, promotions, transfers, demotions, layoffs or terminations, compensation, benefits, training, firm-sponsored education, social and recreational programs or events, and all other terms, conditions and privileges of employment. All employment decisions, including hiring and promotion decisions are based on job-related criteria, such as skills, abilities, education and experience.

As part of our efforts, CDW maintains Affirmative Action Plans covering minorities, women, individuals with disabilities and veterans, and makes a good-faith effort to meet all aspects of its plans. We are committed to taking affirmative action to provide job opportunities to everyone equally. Our employment-related decisions are always based only on job-related criteria.

CDW also is committed to providing a work environment free from harassment. We will not tolerate harassment of any applicant or coworker based on race, color, sex, religion, national origin, genetic information, gender, sexual orientation, gender identity, disability, age, marital status, citizenship status, veteran status or any other characteristic protected by law. CDW’s complete policy prohibiting sexual and other unlawful harassment immediately follows this policy in “Road to Success.”

B. Responsibilities and Investigations1. Support required from all We know that positive, results-oriented action to advance equal employment opportunity serves the best interests of the Company, our coworkers and the communities in which it operates. Toward this end, CDW’s Senior Vice President of Coworker Services, with the support of CDW’s Executive Committee and Board of Directors, has assumed responsibility for ensuring equal opportunity and the absence of discrimination, harassment or retaliation at CDW.

Managers and supervisors at all levels are expected to support and advance the Company’s efforts and to perform their assigned responsibilities in this area in a manner that ensures effectiveness. Each coworker also is urged and expected to give his or her fullest cooperation and to ensure his or her individual conduct conforms to our commitment to equal opportunity.

2. ReportingCDW encourages reporting of all perceived incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Prompt reporting is encouraged so that constructive action may be taken before relationships become unduly strained. While no fixed reporting period has been established, early reporting and intervention are the most effective means for resolving actual or perceived incidents of discrimination or harassment.

Reports should be made to a manager or supervisor or to the Coworker Services Business Partner Team. In addition, reports may be made at any time by calling the Ethics Helpline at 877.7 CDW WAY (877.723.9929) or via a secure, confidential online reporting tool found on Connect or CDW.ethicspoint.com. The Ethics Helpline is administered by a third-party service provider and is available 24 hours a day, 365 days a year. If you prefer, your communications with CDW Way Direct may be confidential and/or anonymous.

Complaints to a supervisor or manager, or to the Coworker Services Business Partner Team, may be made orally or in writing, and whether made orally or in writing will be treated with the same importance and investigated. Coworkers making oral complaints may be asked to also provide a written statement that includes details of the incident or incidents, dates and times, location, names of the individuals involved and names of witnesses, and any other relevant information.

Besides making a report, if you believe you or another individual is being discriminated against or harassed, we encourage you to let the offender know what behavior or action you perceive as offensive or biased and ask that it be stopped or corrected, depending on the situation. Often, this action alone will resolve the problem. We understand, however, that an individual may prefer to report a particular incident through the reporting procedures and CDW encourages such reporting.



Managers and supervisors are required to promptly report to the Coworker Services Business Partner Team all complaints of discrimination, harassment or retaliation they receive (including formal and informal complaints, as well as reports made by coworkers who witness conduct perceived to be discrimination), regardless of whether the coworker asks you not to report it.

3. InvestigationsCDW will make every reasonable effort to resolve all complaints. Any complaint received will be investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary or believed appropriate, interviews with others who may have observed the alleged conduct or have relevant knowledge. Confidentiality will be maintained throughout the investigatory process to the extent possible while allowing the Company to conduct an appropriate investigation and take corrective action or legal action, as CDW determines is necessary or prudent.

4. ResolutionConduct found to be inconsistent with or in violation of the Company’s policies will be dealt with appropriately. Responsive action may include, for example, training, referral to counseling, and/or disciplinary action, such as a warning, withholding a pay increase or promotion, reassignment, suspension without pay or termination, as CDW believes appropriate under the circumstances. The Company also will take corrective action, as appropriate, to remedy the effects of any discrimination, harassment or retaliation and prevent its reoccurrence.

If either party to a complaint made under this policy disagrees with the resolution, he or she may raise the issue with CDW’s General Counsel.

5. Commitment and QuestionsAlthough CDW is fully committed to taking prompt, appropriate remedial action in those instances when a violation of our EEO policies occurs, our principal goal is to create a professional workplace governed at all times by integrity, respect and dignity, and to prevent unlawful discrimination, harassment and retaliation. It is incumbent upon each coworker to develop a better understanding of these issues and to eliminate any form of unlawful discrimination, harassment or retaliation from our workplace.

If you have any questions or concerns regarding equal employment opportunity, the Company’s commitments and expectations under this policy, or your responsibilities, we encourage you to talk to a supervisor, manager or the Coworker Services Business Partner Team. In addition, reports may be made at any time by calling CDW Way Direct (our ethics helpline) at 877.7CDW WAY (877.723.9929) or via its secure, confidential online reporting tool found on Connect or CDW.ethicspoint.com. CDW Way Direct (our ethics helpline) is administered by a third-party service provider and is available 24 hours a day, 365 days a year. If you prefer, your communications with CDW Way Direct (our ethics helpline) may be confidential and/or anonymous.

C. Prohibited RetaliationIn addition to our commitment to equal opportunity, CDW strictly prohibits any retaliation (including any threats or adverse employment action) against any individual for making an internal report of any conduct, act or practice believed to violate this policy or CDW’s Harassment Policy (collectively referred to as “EEO Policies”), or any other Company policy or standard of conduct, or for participating in the Company’s investigation of any reported violation.

Also prohibited is unlawful harassment, intimidation, threats, coercion, retaliation or discrimination in the terms and conditions of employment (including but not limited to discharge) against anyone for engaging in any protected activity, including protected “whistleblower” activity, under any equal employment opportunity law or regulation (“EEO Laws”) or any other federal, state or local law. Protected activity is defined by the specific applicable laws, but may include (1) filing a complaint of alleged unlawful conduct under the EEO Laws or other applicable law; (2) participating or assisting in any investigation undertaken by a regulatory agency related to compliance with EEO Laws or other regulatory laws; (3) testifying in a proceeding of the relevant regulatory agency; (4) opposing unlawful acts or practices, or exercising rights under the applicable statute, including rights under EEO Laws; and (5) disclosing information to certain categories of government officials that the coworker reasonably believes to be: a) evidence of gross mismanagement of the contract or subcontract related to funds made available by the American Recovery and Reinvestment Act of 2009 (“Covered Funds”); or b) a gross waste of Covered Funds; or c) a substantial and specific danger to public health or safety related to the use of Covered Funds; or d) a violation of law, rule or regulation related to an agency contract awarded or issued, relating to Covered Funds.



By way of example, unlawful harassment, intimidation, threats, coercion, retaliation or discrimination in the terms and conditions of employment (including but not limited to discharge, demotion or suspension) is strictly prohibited against any coworker for:

(1) reporting conduct or acts that the coworker reasonably believes violate the federal wire fraud, mail fraud or bank fraud, or the securities fraud statutes, or the rules or regulations of the Securities and Exchange Commission, or any provision of federal law relating to fraud against shareholders (collectively, “reportable offenses”), when the report is made to any of the following entities or persons:

(a) a federal regulatory agency, or (b) a member of Congress or congressional committee, or (c) a Company supervisor or manager with supervisory authority over the coworker, or (d) any Company representatives with authority to investigate, discover or take steps to end any misconduct in violation of these laws

(e.g., the CEO, CFO, General Counsel or Vice President of Coworker Services).

(2) filing, causing to be filed, or testifying, participating or otherwise assisting in a proceeding related to any reportable offense.

PROHIBITION OF SEXUAL AND OTHER UNLAWFUL HARASSMENTAs part of our policy to ensure equal opportunity for all coworkers, CDW is committed to maintaining a workplace free of sexual harassment and harassment based on race, color, sex, religion, national origin, genetic information, gender, sexual orientation, gender identity, disability, age, marital status, citizenship status, veteran status or any other characteristic protected by law. All managers, supervisors and other coworkers are protected by this policy and are responsible for ensuring that harassment in violation of this policy does not occur. This policy also prohibits workplace harassment of coworkers by non-CDW employees (and vice versa), including customers, partners or vendors.

Definition of Prohibited HarassmentProhibited harassment includes the following behaviors when they are directed against a person because of his or her race, color, sex, religion, national origin, genetic information, gender, sexual orientation, gender identity, disability, age, marital status, citizenship status, veteran status or any other characteristic protected by law.

1. Verbal conduct such as epithets, insults, slurs, derogatory jokes or comments, unwanted sexual advances, catcalls, invitations or comments.

2. Derogatory and/or sexually oriented computer graphics, posters, photography, cartoons, drawings, faxes, emails or gestures.

3. Physical conduct such as leering, assault, unwelcome touching, blocking normal movement or interfering with work.

4. Unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when submission to such conduct is made either explicitly or implicitly as a term or condition of employment or submission to or rejection of such conduct is used as the basis for employment decisions (such as a raise, promotion or transfer).

5. Other conduct that has the purpose or effect of interfering with that person’s work performance or creates a hostile, intimidating or offensive environment.

6. These behaviors are unacceptable both in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events.

Protection Against RetaliationCDW strictly prohibits any retaliation against any coworker because he or she has made a report or complaint or participated in any investigation under this policy. Retaliation is a serious violation of this policy and, like harassment itself, will cause the coworker violating this policy to be subject to disciplinary action, up to and including termination of employment.



Reporting a ComplaintCDW encourages reporting of all perceived incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Prompt reporting is encouraged so that constructive action may be taken before relationships become unduly strained. While no fixed reporting period has been established, early reporting and intervention are the most effective means for resolving actual or perceived incidents of discrimination or harassment.

Reports should be made to a manager or supervisor or to the Coworker Services Business Partner Team. In addition, reports may be made at any time by calling the Ethics Helpline at 877.7 CDW WAY (877.723.9929) or via a secure, confidential online reporting tool found on Connect or CDW.ethicspoint.com. The Ethics Helpline is administered by a third-party service provider and is available 24 hours a day, 365 days a year. If you prefer, your communications with CDW Way Direct may be confidential and/or anonymous.

Coworkers may also raise concerns regarding harassment and retaliation through federal, state or local government agencies located where a coworker resides. For example, coworkers located in Illinois may contact the Illinois Department of Human Rights to address issues of harassment or retaliation covered by this policy. Coworkers may review the website for the governmental agencies in their state to identify the specific protected characteristics in their state and the method for initiating a claim or investigation through that governmental agency. However, one of CDW’s key principles is to deal with matters directly, and we encourage coworkers to utilize the various means within the Company to address any concern of harassment and/or retaliation.

Complaints to a supervisor or manager, or to the Coworker Services Business Partner Team, may be made orally or in writing, and whether made orally or in writing will be treated with the same importance and investigated. Coworkers making oral complaints may be asked to also provide a written statement that includes details of the incident or incidents, dates and times, location, names of the individuals involved and names of witnesses, and any other relevant information.

Besides making a report, if you believe you or another individual is being discriminated against or harassed, we encourage you to let the offender know what behavior or action you perceive as offensive or biased and ask that it be stopped or corrected, depending on the situation. Often, this action alone will resolve the problem. We understand, however, that an individual may prefer to report a particular incident through the reporting procedures and CDW encourages such reporting.

Managers and supervisors are required to promptly report to the Coworker Services Business Partner Team all complaints of discrimination, harassment or retaliation they receive (including formal and informal complaints, as well as reports made by coworkers who witness conduct perceived to be discrimination), regardless of whether the coworker asks you not to report it.

Response to Complaint/ConfidentialityAll reports of unlawful harassment will be investigated and resolved in a thorough and timely manner. The purpose of the investigation is to make a reasonable determination as to the merits of the report or complaint and to determine any appropriate disciplinary action or other corrective measures. It is a fact-finding process, which will ordinarily consist of a review of relevant documents (including, where appropriate, personnel files) and separate interviews with the complaining party, the accused party and any witnesses. The Company will take all reasonable measures to ensure that information gathered during the investigation process is only disclosed to those with a need to know the information.

Disciplinary ActionAny coworker found to have engaged in unlawful harassment or retaliation in violation of this policy will be disciplined. Disciplinary action may include any or all of the following: a verbal warning, a written reprimand, requirement to attend appropriate training, work restrictions, position change, salary reduction, suspension, dismissal or any other action the Company determines is appropriate.

False AccusationsThe Company recognizes that the question of whether a particular course of conduct constitutes unlawful harassment requires a factual determination. The Company also recognizes that false accusations can have serious effects on innocent people. If an investigation results in a finding that a person who has accused another of harassment has maliciously or recklessly made false accusations, the accuser will be subject to appropriate disciplinary action, up to and including dismissal.

ConclusionCDW requires that each person exhibit, in his or her conduct and communications, sound judgment and respect for the feelings and sensibilities of every other coworker at CDW. While these procedures are intended to govern the Company’s investigation and resolution of all harassment complaints, the Company will take whatever steps it deems appropriate in a particular instance to safeguard the safety and well-being of all coworkers.



ACCOMMODATIONS FOR DISABILITIESCDW welcomes coworkers and applicants with disabilities and recognizes that to provide equal access and opportunities to qualified individuals with disabilities, reasonable accommodations may be needed. This policy provides information on the process of obtaining reasonable accommodations for coworkers. CDW also provides reasonable accommodations to applicants that are needed during the hire process, and applicants needing accommodations should talk to a member of the Talent Acquisition team.

The Americans with Disabilities Act (ADA) prohibits discrimination in the workplace on the basis of disability and requires that employers provide reasonable accommodations to qualified individuals with disabilities. A reasonable accommodation refers to a change in the job or environment that allows a qualified coworker with a disability to perform the essential functions of his or her job. Some examples of accommodations include:

• Redesigning work areas and equipment or acquiring new equipment

• Ensuring facility accessibility to those with physical disabilities

• Modifying work schedules or providing unpaid leave

Accommodations are made on a case-by-case basis, taking into account the type and severity of the disability and the specific job requirements involved. CDW works with eligible coworkers to identify the most appropriate accommodation in a given situation. CDW will work with eligible coworkers who prefer to provide their own accommodation to ensure compatibility with CDW’s systems.

Accommodation ProcessIf you require accommodations to perform your job duties properly and safely, you should advise your Coworker Services Business Partner of your need and submit a completed Accommodation Request Form available on Connect.

Once CDW is aware of a coworker’s disability and request for accommodation, Coworker Services will enter into an interactive process with the coworker to gather any required medical information and determine what reasonable accommodations may be necessary. Often, Coworker Services will need to request information from the coworker’s medical care provider(s) as part of this process. Sometimes, CDW will ask the coworker to see a medical care provider selected by CDW to gather additional information. The nature of the information gathered during this process includes the nature of the coworker’s condition and limitations related to the coworker’s job, and possible accommodations that would allow the coworker to perform the essential functions of his or her job. It is very important that you cooperate during the interactive process, including providing permission to CDW to gather needed information from your medical care providers. Coworkers who do not cooperate in the interactive process may not be provided accommodations.

During the interactive process, CDW also will determine whether it can provide accommodations without undue hardship to the Company.

Once accommodations have been identified and agreed to, these accommodations will be documented by Coworker Services. The accommodations will be implemented as soon as reasonably possible. If at any time the coworker believes the accommodations being provided are not effective, need modification or are no longer required, the coworker should contact Coworker Services.

Disclosure of a disability and whether to request an accommodation is voluntary and a coworker has no obligation to disclose this information or request an accommodation. An individual may not acquire a disability, or may not realize accommodations are needed, until after hire. A coworker may self-identify as having a disability and request an accommodation during the hiring process, when first hired, or at any other time while employed by CDW. Accommodations, however, are not retroactive and the interactive process may take some time. Coworkers therefore are encouraged to request an accommodation as soon as they are aware they need one.

CDW will maintain all information submitted about a disability separately from personnel records and the information will be kept confidential, except that (a) supervisors and managers may need to be informed regarding restrictions on the work or duties of qualified individuals with disabilities and necessary accommodations; (b) security and safety personnel may be informed, to the extent appropriate, if and when a condition might require emergency treatment; and (c) government officials engaged in enforcing laws such as those administered by the Office of Federal Contract Compliance Programs or the Americans with Disabilities Act may be informed.



PAYROLL AND BONUSESPROBATIONARY PERIODEach new coworker undergoes a probationary period for the first 90 calendar days of employment. During the course of, or at the end, of this period, the coworker may receive, at their supervisor’s or manager’s discretion, a performance review or evaluation. The 90-day probationary period does not affect a coworker’s “at will” employment. A coworker may terminate his or her employment with CDW any time during the 90-day probationary period, and CDW may do the same. Likewise, successful completion of the probationary period does not guarantee ongoing employment with CDW or affect a coworker’s “at will” employment status.

TIME RECORDING Coworkers are required to swipe in and out when entering and leaving the facility. Your identification badge has a barcode and you swipe your badge through one of the card readers located throughout the buildings whenever you enter or leave the CDW buildings. Additionally, coworkers must swipe before starting work, when leaving for and returning from lunch, and when leaving work at the end of the day. Hourly coworkers in Nevada and California must swipe for all breaks, and hourly coworkers in all other locations must swipe for breaks of 20 minutes or longer.

You may not swipe in or out for another coworker. Any violation of this policy may lead to disciplinary action up to and including termination of all parties involved.

If you are not onsite, but have network access, you have the ability to punch in and out electronically through a web-based tool. If you are unable to record your time by swiping or through the web-based tool, your supervisor or manager will need to manually enter your time for you. Any changes in your time should be completed by your supervisor or manager.

OVERTIMECDW pays overtime in accordance with applicable federal and state laws and regulations. Nonexempt coworkers receive 1.5 times their regular rate of pay for all hours actually worked in a week in excess of 40 hours. If you take holiday or vacation time during the pay period, CDW considers those hours as being “actually worked” and factors them in when calculating overtime eligibility. CDW pays overtime in accordance with the Fair Labor Standards Act (FLSA) or when applicable per state’s wage-hour laws in which the coworker is performing services.

Sick time and absences other than vacation and holidays are not counted as hours actually worked. All overtime must be scheduled with your supervisor’s or manager’s prior approval.

PAY PERIODSCoworkers are paid every two weeks (biweekly). Payday is every other Friday, unless the Friday is a holiday, in which case you will be paid on Thursday. Pay periods begin on Sunday and continue through the second Saturday thereafter.

DIRECT DEPOSITYour paycheck can be directly deposited into your checking or savings account, or a combination of both. If you choose direct deposit, you will receive a voucher/pay stub in place of an actual check. It could take two full pay periods for direct deposit arrangements to take effect. If you participate in this benefit, you can also elect to suppress your pay statement. This would still give you access to the information; it would just be electronic access as long as you remain employed with the organization. CDW strongly encourages all coworkers to participate in direct deposit to support CDW’s green efforts.

If you elect to have your paycheck deposited into more than one account, whichever account becomes your primary account will systematically be designated as the same account any expense reimbursements will post against.

LOST PAYCHECKSYou are responsible for your paycheck after it has been issued. Lost or missing checks should be reported immediately to Payroll so that a stop payment order can be placed with the bank and a new check issued. CDW will incur a stop payment charge from our bank and this cost will be passed on to the coworker.



PERFORMANCE EVALUATIONSNoncommissioned coworkers receive a written performance evaluation annually, as described in more detail below. The performance evaluation provides an opportunity for supervisors and managers to help coworkers clearly define and understand their responsibilities, to discuss past performance and new initiatives, and to assess future training opportunities. It also provides coworkers with an opportunity to more fully comprehend the level of performance expected of them and to discuss personal career objectives with their supervisor or manager.

Managing and improving our performance on an annual basis is an important part of running our business. At CDW, we have a program called PMP (Performance Management Process). The purpose of the PMP is to ensure that our coworkers align their efforts with the organization’s overall goals. There are three parts to the PMP process: Objective Setting, Developmental Planning and Performance Appraisal.

Evaluations are based on two areas of emphasis: what we do — achieving business objectives based on the CDW Roadmap and how we do it — based on The CDW Way. In PMP, coworkers’ ratings are based on the degree to which they meet their objectives and how they exemplify The CDW Way behaviors in daily work.

To help coworkers achieve their goals, coworkers may also use the individual development plan. The purpose of the plan is to identify personal developmental goals and actions that can help the coworker make a full contribution in their role and to their team. Coworkers are expected to collaborate with their managers to identify development goals and activities toward completion of those goals.

SALARY INCREASESOur compensation programs are designed to enable CDW to attract, motivate and retain the best talent, to pay coworkers equitably and to encourage and reward excellent performance.

Noncommissioned coworkers are eligible for an annual salary increase each year that aligns with the annual Performance Management Process. CDW pays similarly for similar work regardless of race, color, sex, religion, national origin, genetic information, gender, sexual orientation, gender identity, disability, age, marital status, citizenship status, veteran status or any other characteristic protected by law. Whether or not a coworker receives a salary increase depends on his or her level of performance, total compensation compared to the market value of the position, and the overall financial success of the Company.

BONUSESCDW coworkers may be eligible for a performance incentive or be eligible to participate in bonus program(s) as part of their overall compensation package. Although bonuses can be based on performance, productivity and/or other criteria, they are discretionary and are not guaranteed. In addition, coworkers who are subject to disciplinary action by CDW prior to any payment of bonus(es) may not be eligible for payment. CDW may prorate any special, monthly, quarterly, trimester or annual bonus during a leave of absence (including but not limited to: FMLA, personal leave, military leave or individuals receiving disability benefits such as maternity, short-term disability, long-term disability or workers’ compensation). Bonuses will not be prorated for those days when a coworker takes time off using paid vacation or sick time. If a coworker’s employment terminates prior to a bonus payment, most bonuses will not be paid out, as active employment at the time of payout is typically required. These guidelines are not meant to be exhaustive; where applicable, a bonus plan document will govern.

NONCASH COMPENSATIONCoworkers who receive nonconsumable (not food or beverage), noncash compensation (trips, merchandise, etc.) will have the value of such compensation included in their taxable income as required by law. Additionally, coworkers who are eligible to receive noncash compensation must be employed with CDW at the time the item is redeemed. For additional information, speak with your manager or Coworker Services.

OFCCP’S REQUIRED PAY TRANSPARENCY POLICY STATEMENTThe contractor will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or (c) consistent with the contractor’s legal duty to furnish information.



COWORKER REFERRAL PROGRAMIf a coworker refers an individual for any full-time position who is then hired and retained by CDW for 90 days, the coworker will be eligible to receive a referral bonus as long as the referring coworker is employed on the 90th day and is the original source of referral. CDW offers a referral bonus of $1,000 for management positions and $500 for sales account managers and all other CDW coworkers. The cash bonus will be taxed as income. From time to time, CDW may temporarily increase the referral bonus for certain positions.

All coworkers, including supervisors and managers, may participate in the Coworker Referral Program. To be eligible for the bonus, the coworker must be the original referral source and not part of the interviewing or hiring decision team.

If multiple coworkers submit the same candidate for the same requisition and the job seeker is hired for that requisition, the referral bonus will be issued to the coworker who first referred the candidate for that requisition.

Where to find information: Connect homepage -> Departments -> Coworker Services -> myCareers

Important reminder: You must submit referrals through the Coworker Referral process as noted above. The Talent Acquisition Team will no longer accept emailed resumes of referrals.

GARNISHMENTS, LIENS, WAGE ASSIGNMENTS AND CHILD SUPPORTBy law, CDW is required to honor legal garnishments of a coworker’s wages. As provided by law, an administrative fee may be charged for all garnishments to offset expenses used to process the necessary paperwork. Please contact Payroll with any questions regarding a garnishment.



BENEFITSCDW is committed to providing coworkers with high-quality, affordable benefits and unique extras that reflect our dedication to protecting your health and investing in your future. Our comprehensive list of benefits and perks provide balance and flexibility to fit your individual needs. Visit the Benefits website at www.cdw.hrintouch.com to learn more about program offerings and eligibility requirements.

DISCOUNTED PURCHASE PROGRAM FOR COWORKERSOne of the perks CDW provides to coworkers is the ability to purchase any of the products we sell at discounted prices. The coworker price in our system is calculated with a formula that equates to essentially 1 percent over CDW’s cost of the product.

Please refer to the Coworker Purchase Pricing Program Sharepoint site on Connect for full details on this benefit: A few highlights about how the discount program works and the restrictions that apply:

• Discounted pricing is available only on products that coworkers or their immediate families will use themselves or products the coworker gives as a gift purchased with his or her own money. There are no exceptions to this policy. For example, coworkers may not purchase products and then resell them.

• Discounted purchases do not qualify for price protection. Thus, if the price of the item the coworker buys goes down after the invoice is created, the coworker will not be able to void the sale or change the invoice price to reflect the new pricing.

• As with all of our customers, products that are allocated by the manufacturer or otherwise are in short supply will be sold on a first-come, first-served basis. Coworkers receive no special priority.

• Coworkers can buy products at the coworker discount in any of the following ways: , ordering online after setting up a Coworker E-Account (see above-referenced Sharepoint site for details), calling the main sales line (800.750.4239) to place an order, or having any account manager place an order for them.

• Coworker Purchase Pricing for orders with a desktop, notebook or tablet: The following additional benefits are available for coworkers who purchase a desktop, notebook or tablet, and have been employed at CDW for at least six months:

— A one-time rebate of $100

— Once every 12 months — the option to pay for the purchase through payroll deductions

— Temporary coworkers are not eligible for the additional benefit of the Coworker Purchase Pricing Program

MATCHING CHARITABLE GIFTS PROGRAMCDW is proud to provide our coworkers* with a Matching Charitable Gifts Program. Through this program, the Company allows our coworkers to participate in directing our corporate contributions. To have your personal donations matched by CDW, please access the matching gifts program through the CDW Angelpoints link provided on the Community Relations page on CONNECT. Submitted requests received each calendar quarter will be processed and checks will be sent to the organizations after quarter-end. So that everyone has an opportunity to take advantage of this benefit, CDW will match a maximum of $2,000 per year for each eligible coworker to qualified charitable organizations of their choice. For more detail, please see the Program Guidelines for Coworker Matching Charitable Gifts and read through the CDW Angelpoints User Guide located on the Community Relations page on Connect.

*Coworkers must be employed at least 90 days to be eligible to participate in this program and must be employed at quarter end when matches are reviewed for your request.

http://www.cdw.hrintouch.com



RECOGNITION PROGRAMSCDW recognizes outstanding performance not only through pay increases and advancement opportunities, but also through various recognition programs such as Coworker of the Month. Listed are some of the programs in place:

• Celebrating Service Celebrating Service is a program that recognizes your loyalty and long-term commitment to CDW. The program honors coworkers starting with a Service Plaque on their three-year anniversary and continues to recognize service milestones at each five-year anniversary. Beginning with a five-year anniversary, coworkers will be able to select a premium anniversary gift from a catalog with a variety of choices. As coworkers attain more tenure, they will be able to choose gifts of higher value, they will have the opportunity to select a travel option, and they can even be awarded additional time off, including sabbaticals.

• CHEERS! CHEERS! is CDW’s informal peer-to-peer recognition program that publicly celebrates everyday coworker accomplishments that often go unnoticed. Managers and coworkers may utilize this program to let fellow coworkers know that they are appreciated for the way they make things happen at work. An email will automatically be sent to the nominee and their manager with the CHEERS! reason and a printable certificate. Randomly selected CHEERS! submission will be posted on LCD screens in locations where available.

• Coworker of the Month (COTM) The COTM program is designed to recognize coworkers who are team players who go above and beyond their job responsibilities to help fellow coworkers, vendors and customers. Nominations are submitted for an anonymous panel to review. Each month, one coworker is chosen and recognized as the COTM.

• Coworker of the Year (COTY) The 12 Coworkers of the Month meet with executive leadership to celebrate their honor of going above and beyond the normal job scope and exemplifying CDW’s values. These 12 individuals choose one amongst themselves to be recognized companywide as the Coworker of the Year.

Full program details can be viewed on Connect.



TIME AWAY FROM WORKHOLIDAYSCDW provides seven paid holidays for coworkers who regularly work more than 20 or more hours a week:

• New Year’s Day • Memorial Day • Independence Day • Labor Day

• Thanksgiving Day • Christmas Eve Day* • Christmas Day

To receive holiday pay, you cannot call off work on either the day before or the day after the holiday.

Coworkers are eligible for paid holiday time if a holiday falls on one of their regularly scheduled workdays. For example, a coworker who normally works five hours on Mondays will be paid five hours of holiday pay for Memorial Day.

*CDW will be closed Christmas Eve when it falls on a weekday. Hourly coworkers who are required to work on a holiday and receive prior approval to work on the holiday will receive pay for the hours worked, plus holiday pay. Salaried coworkers scheduled to work on a holiday will receive, upon management approval, a floating holiday.

If a CDW observed holiday falls on a weekend, the Company-paid holiday may be scheduled for a weekday. Some coworkers may be scheduled to work on that Company-paid holiday if the Company determines it is necessary.

Holiday pay for coworkers who work in a 24/7 environment, such as the Network Operations Center (NOC) or Safety & Security, is treated under a separate policy. Please speak with your manager or a member of the Coworker Services Business Partner Team for more information.

CDW recognizes that some coworkers may wish to observe, as periods of worship or commemoration, certain days that are not included in CDW’s regular holiday schedule. Accordingly, coworkers who would like to take a day off for those reasons may do so with their supervisor’s or manager’s prior approval. Coworkers may use accumulated days of paid time off for these occasions, or they may take the time off as an unpaid, excused absence.

VACATIONVacations with pay provide CDW coworkers with an opportunity to rest and relax away from the demands of the workplace. We encourage you to take your vacation and enjoy time relaxing!

Vacation Accrual. Paid vacation time is given to coworkers working a minimum of 20 hours per week based upon their average hours worked and is adjusted proportionately. The chart below lists the monthly accrual rates for full-time coworkers who work at least 40 hours per week:

Service Years Accrual Max. Accrual

Less than 4 (0 to 47 months) 6.667 hrs./month = 80 hrs./year 120 hours maximum

4-5 (48 to 71 months) 10.0 hrs./month = 120 hrs./year 180 hours maximum

6 or more (72+ months) 13.334 hrs./month = 160 hrs./year 240 hours maximum

For example, a full-time coworker will begin accruing 6.667 hours of vacation time per month (the equivalent of 80 hours per year) upon hire. The accrual rate goes to 10 hours per month (the equivalent of 120 hours per year) upon reaching his or her fourth anniversary and to 13.334 hours per month (the equivalent of 160 hours per year) upon reaching his or her sixth anniversary. Accrual takes place on the first business day of the month for the prior month, and you must be employed on the last day of the month just completed to receive your accrual for the month. For example, a coworker who resigns and their last day worked is March 20 would not receive any accrued vacation time for March. Please note, it may take one to two days for accruals to be reflected in the system.

Vacations may not be taken during your first six months of employment. Full-time coworkers are strongly encouraged to take at least five consecutive business days of vacation within one year. Accrued but unused vacation rolls over into the following year, but the maximum amount of vacation time that can be accrued but unused at any given time is the equivalent of one-and-one-half year’s accrual. A simple way to calculate your maximum vacation accrual is to multiply your accrual rate by 18. Anytime your vacation account reaches this limit, no hours will be added to it until you use some vacation time. Unused, accrued vacation time is paid out upon dismissal. For your convenience, accrued vacation hours appear on your paycheck and are available in CTMS. Coworkers who have questions on the calculation of their vacation time should contact the Payroll Team.

Part-time coworkers who work fewer than 20 hours per week are not eligible for paid vacation time. Unpaid time off depends on each department’s business needs, and approval is granted at the discretion of management.



Vacation is paid in the normal time frames of your paycheck. Vacation will not be paid in advance.

Scheduling Vacations. CDW’s business needs, particularly our ability to serve the customer with excellence, always will govern vacation scheduling. As a result, CDW may need to restrict the number of coworkers who are absent from work on any given day and may limit vacation time scheduled in conjunction with paid holidays. All coworkers must secure approval from their supervisor or manager before making vacation plans. Whenever possible, please obtain approval for vacation days at least one week in advance. In general, coworkers should schedule vacations with their supervisor or manager as soon as possible since vacations are scheduled on a first-come, first-served basis.

Salaried coworkers may request vacation time in half-day (four-hour) increments; hourly coworkers may request vacation time in any increment approved by their manager.

SICK/PERSONAL DAYSCDW provides paid sick days to all coworkers based upon their average hours worked. Sick days accrue by the month according to each coworker’s employment status. For example, a full-time coworker who works at least 40 hours per week accrues 3.334 hours per month, which is the equivalent of five days per year. Accruals for part-time coworkers who work at least 20 hours per week are adjusted according to hours worked.

Paid sick days may not be used during the first 90 days of employment. Accrued but unused sick time rolls over into the following year, but over the years, a coworker may not accumulate more than 65 days of accrued but unused time. Unused sick days are not paid out upon termination. It is your responsibility to contact your manager and CDW’s leave of absence administrator (if appropriate) when you have an unscheduled absence from work. You should contact CDW’s leave of absence administrator if you believe your absence may be covered by the FMLA (see more detail in the following section), will be requesting Short-term Disability for your absence, or if your absence from work is due to a work-related injury. Management may request the coworker’s healthcare provider to provide documentation of illness, or other information, as warranted upon a coworker’s use of a sick day. Any coworker who misses three consecutive days of work may be required to provide written documentation of illness and ability to return to work from his or her healthcare provider. Written documentation may be in the form of a note or fax from your physician if your illness does not require an office visit. Sick days should not be taken in conjunction with a holiday. To receive holiday pay, you cannot call off work on either the day before or the day after the holiday.

Two of the five sick days you accrue each year may be used for personal reasons even if you are not sick. To use a sick day for personal reasons, you should secure approval, at least five days in advance, from your supervisor or manager. Any personal days unused at year-end revert to sick days and are available for use in subsequent years only if you are sick.

Salaried coworkers may request sick/personal time in half-day (four-hour) increments; hourly coworkers may request sick/personal time in any increment approved by their manager.

Please see Occurrences under Attendance policy below for additional information related to the usage of sick time.



FAMILY AND MEDICAL LEAVE ACTUnder the federal Family and Medical Leave Act (FMLA), all CDW coworkers may be eligible for up to a maximum of 12 weeks of unpaid family/medical leave during any rolling 12-month period. Coworkers in some states may have additional family/medical leave rights based on state laws, and it is CDW’s intent to comply with all applicable laws governing family/medical leave.

Family/Medical leave may be available for the following reasons:

• The birth, adoption or foster care placement of a child

• Serious health condition of a family member

• Coworker’s own serious health condition (including work-related injuries)

• Any qualifying “exigency” leave (see Military Leave policy)

• Care for a covered service member with a serious illness or injury (see Military Leave policy)

If a coworker is eligible for family/medical leave, he or she generally will be entitled to reinstatement to the same or a comparable position upon return from a leave of up to 12 weeks.

To be eligible, a coworker must have been employed by the Company for at least one year and must have worked a minimum of 1,250 hours in the preceding 12 months.

A family member is defined as spouse, same-gender domestic partner, child or parent of the coworker. A child is defined as a coworker’s son or daughter, which includes a biological, adopted or foster child, a stepchild, a legal ward, child of a state-recognized domestic partner, or child of a person standing in loco parentis, who is either under age 18 or incapable of self-care because of a mental or physical disability. “In loco parentis” means “in the place of the parent,” which will be determined on a case-by-case basis considering the intent of the individual to assume the status of parent toward the child. Factors considered will include the age of the child, the amount of support provided, the degree to which the child is dependent upon the individual and the extent to which duties commonly associated with parenthood are exercised.

Family/medical leave is unpaid, although you may substitute any paid time off benefits for which you qualify (e.g., sick days or vacation). Paid time off under CDW’s short-term disability plan runs concurrently with family/medical leave. During family/medical leave, vacation and sick time continue to accrue until all available FMLA time (whether paid or unpaid) is exhausted. No additional vacation or sick time will accrue if the coworker remains on leave beyond his/her FMLA entitlement.

Coworkers requesting family and medical leave must give adequate notice to their supervisor or manager. In addition to notifying their manager, coworkers must contact CDW’s absence management administrator to request a leave of absence and to report any full or partial day absences related to their leave. Contact information for CDW’s leave of absence administrator can be found on the Benefits Communication Portal. Coworkers will be required to provide certification from the treating healthcare provider and complete all required documentation. When the need for leave is foreseeable, as in the case of pregnancy or other planned treatment, you must provide at least 30 days’ advance notice. Failure to meet these obligations may result in denial of your leave request.

If you are not able to return to work upon the conclusion of the initial leave, it is your responsibility to request an updated physician’s statement or an extension from Coworker Services. Failure to report back to work upon the conclusion of any leave will be considered a voluntary termination. When returning from leave, you are requested to notify your supervisor or manager at least one week before your expected return date.

If at any time during an approved leave of absence you believe you could return to work in your former role or a different role with reasonable accommodation, you should contact Coworker Services. We will then enter into an interactive process with you and your medical care provider to determine if you are disabled within the meaning of the Americans with Disabilities Act, if CDW has any open roles for which you qualify, and if CDW can provide reasonable accommodation without undue hardship.

Subject to applicable legal restrictions, group insurance benefits for which you are eligible and enrolled will be continued by CDW during a family/medical leave, provided the coworker continues payment of his or her portion of the premium contribution. If a coworker is more than 30 days late in paying a premium, the coworker’s group insurance coverage may be terminated.

Visit the Benefits Communication Portal for more information concerning family and medical leave and your benefits while on leave. Visit the Benefits website at CDW.hrintouch.com to learn more about program offerings and eligibility requirements or contact your Coworker Services Business Partner.

http://CDW.hrintouch.com



UNPAID MEDICAL LEAVE FOR COWORKERS NOT YET COVERED BY FMLAFull-time coworkers who have completed their 90-day probationary period, but who are not yet eligible for family and medical leave, may, at the Company’s discretion, be granted unpaid medical leave, not to exceed six weeks, for their own serious health condition. A serious health condition is defined as one’s own illness, injury, impairment, or physical or mental condition that involves inpatient care in a hospital, hospice or residential medical care facility, or continuing treatment by a healthcare provider. Unpaid leave needed for other personal emergencies (e.g., care for a sick family member, care for a newborn, adopted or newly placed foster child), or requests for leave longer than six weeks may be granted in exceptional circumstances, on a case-by-case basis. Decisions as to whether or not such time will be granted are at the sole discretion of Coworker Services and management.

To request unpaid medical leave under this policy, you must contact CDW’s leave of absence administrator as soon as you know the leave is needed and provide the requested information.

LEAVES RELATED TO DOMESTIC VIOLENCE For information concerning leaves related to domestic violence, contact your Coworker Services Business Partner.

PERSONAL LEAVE OF ABSENCE/OTHER TIME OFFIf all paid time off has been exhausted, leaves of absence for nonmedical reasons and for reasons not covered by the FMLA (or applicable state law) may be granted under certain exceptional circumstances at the Company’s sole discretion. Please contact your Coworker Services Business Partner for more information on this policy. During an unpaid personal leave, vacation pay and certain other benefits do not continue to accrue. Written notice must be provided to your supervisor or manager in a timely manner indicating the dates of your leave. If you do not return on the specified date, your employment is subject to termination.

MILITARY LEAVE A coworker will be authorized to take military leave and will be given re-employment rights in compliance with applicable law. For regular full-time coworkers with one full year of service prior to the commencement of military leave, CDW will supplement military pay during the first two years of a military leave by paying the difference between military pay and the coworker’s average compensation during the six months or 12 months prior to the commencement of the leave, whichever average is higher for that coworker. To receive this supplemental pay, a coworker must be in good standing and submit appropriate governmental pay stubs and other documentation, as requested by Coworker Services.

The FMLA provides that eligible coworkers are entitled to 12 work weeks of leave because of any qualifying “exigency” arising if a covered reservist or National Guard member (coworker’s spouse, child or parent) is on active duty or called to active duty status in support of a contingency operation. Qualifying exigencies include: deployment with seven days or less notice, military events, childcare and school activities, financial and legal arrangements, counseling, up to five days of rest and recuperation, and post-deployment activities. CDW may require a copy of the family member’s active duty orders and/or may verify the need for leave with the U.S. Department of Defense.

The FMLA also allows eligible coworker’s (service member’s spouse, son, daughter, parent or next of kin) up to a total of 26 workweeks of leave in a single 12-month period to care for a covered service member with a serious injury or illness incurred in the line of active duty. A serious injury or illness is defined as one that is occurred in the line of duty (CDW may seek certification from the U.S. Department of Defense) that renders the service member medically unfit to perform the duties of his or her office, grade, rank or rating. Illnesses or injuries that manifest after military service are not covered. Spouses are limited to a combined total of 26 weeks of leave under this exigency.

Visit Connect for more information regarding military leaves of absence.

BEREAVEMENT LEAVECDW offers paid leave for a death in the immediate family, defined as a spouse, domestic partner, child, stepchild , parent, stepparent, parent-in-law, grandparent, great-grandparent, sibling, grandchild, great-grandchild and legal guardian (or equivalent domestic partner relationship). Coworkers are eligible to receive a maximum of three paid days. Time off for bereavement will not be considered an occurrence under the attendance policy unless proper authorization is not secured at the time of the leave.



SCHOOL VISITATIONCDW grants each eligible coworker who is a parent or legal guardian of a child up to eight hours of unpaid time off within the normal school year to attend school conferences or classroom activities if the conference or classroom activities cannot be scheduled during nonwork hours. When possible, at the coworker’s request, managers should make a good-faith effort to allow the coworker to make up those lost hours within that payroll week. Coworkers utilizing this policy must submit a verification statement from the school to Coworker Services within two working days of the school visitation or may receive disciplinary action for an unexcused absence from work.

If you need time off for school visitation, you must consult with your supervisor or manager at least seven days in advance to schedule the time off so as not to unduly disrupt the operations of the Company.

JURY DUTYCoworkers are eligible for paid time off for the duration of their jury duty obligations. Jury duty is considered a paid leave of absence.

Coworkers must notify their supervisor or manager as soon as they receive an initial notice of impending jury service, and again when they learn scheduled reporting dates. Included in the information provided to one’s supervisor or manager would be: the days the coworker is on call for jury service and/or anticipated length of any trial for which the coworker is selected as a juror. Coworkers are excused for jury duty, and will be paid under this policy, for those days they are actually required to be at the courthouse. If presence is not actually needed at the courthouse, coworkers are expected to work. For days when you go to the courthouse and are excused early, if you are able to return to the office for at least half (four hours) your workday, CDW expects you to return to the office.

TIME OFF TO VOTECDW encourages all coworkers to exercise their right to vote. Any coworker entitled to vote in a general or special election, including primaries, whose scheduled work hours do not provide two consecutive hours before or after work to vote while polls are open is entitled to time off to vote. Coworkers will not be penalized for exercising this privilege. Coworkers, however, may not be paid for any time taken to vote.

Coworkers who need to take time off to vote must obtain approval from their supervisor or manager prior to Election Day. Your supervisor or manager may specify the hours during which you may be absent. Generally, time off to vote will be scheduled at the beginning or end of the coworker’s scheduled work hours.

CDW COMMUNITY SERVICE DAY OFFAt CDW, we believe that giving to the community involves more than writing a check; it also involves hard work. To support our local communities, we offer each coworker the opportunity to take off one day with pay per calendar year to perform community service. A coworker must schedule his or her day in advance with his or her supervisor or manager to assure the smooth delivery of service to our customers. To take advantage of this benefit, a coworker must enter in request for Community Service Day Off in CTMS.

1. REQUIRED — Enter a NOTE in your CTMS request with the name of the organization you are volunteering with and what you will be doing. 2. Manager will approve the request in CTMS if adequate coverage is available to allow coworker to be out of office.

If manager approves …

3. Request in CTMS will be routed to Community Relations to review the activity and organization that coworker will be involved with (this is why NOTES with details are required). • If more information is needed, your request will be routed back to you with notes. • If approved, you are done. Thank you for taking the time to volunteer in your community.



WORK SCHEDULEHOURSRegular workdays are Monday through Friday, with hours varying depending upon the business needs of each department. All coworkers are required to arrive to work at their regularly and predetermined scheduled times and remain at work during their normal work hours and until their department’s daily critical needs are met. Individuals in certain positions also must communicate their departure to their supervisors or managers. Because every CDW coworker is dedicated to serving all our customers, special events or promotions may occur that involve working on a Saturday or Sunday.

HOURLY COWORKERS BREAKS Where applicable, coworker breaks are scheduled based upon department needs and workload. Generally, these breaks are given with the understanding that coworkers may leave their workstations.

LUNCHSupervisors or managers may be responsible for scheduling lunch periods. CDW policy is to make available at least a 30-minute lunch period for hourly coworkers. For State specific breaks information, please contact a member of the Coworker Services Business Partner team. Food and drink are permitted in designated areas within our distribution centers.

ATTENDANCECoworkers are an integral part of our success. When a coworker is absent or late, it affects the service to our customers and places an extra burden on other coworkers. For this reason, it is important that each coworker attend his or her job regularly as scheduled.

OCCURRENCESCoworkers are responsible for their attendance and are held accountable through our occurrence system. An occurrence is defined as any unscheduled time lost from work, including sick time, of four hours or more regardless of reason. Time off of work that is not counted as an occurrence includes: preapproved vacation, holiday, rotation, preapproved personal days, leave taken pursuant to the Family Medical Leave Act and other approved leaves protected by law or outlined in the “Road to Success.” Absences of more than one consecutive day, or a recurring absence, are counted as one occurrence. When a coworker misses three consecutive days of work, he or she may be required to provide written documentation of illness and the ability to return to work from the treating healthcare provider.

The Company will keep track of attendance based on a rolling 12-month period. Excessive absenteeism generally will be addressed pursuant to the guidelines below (for coworkers with more than 90 days of service). CDW, in its discretion, may vary these attendance guidelines and jump to a higher level of progression earlier, depending on the circumstances of a particular situation and/or the needs of the department and/or Company.

Occurrence Action

1-5 Documentation of absence; no action to coworker

6 Verbal warning; remind coworker of policy

7 Written warning; provide coworker with a copy of his/her attendance record and place the same in coworker’s personnel file

8 Final written warning*; coworker is warned, in writing, that next occurrence will result in further disciplinary action.

9 Suspension* (typically five days unpaid)

10 Termination

*Any occurrence within six months of a final written warning or suspension will result in progression to the next level of discipline, regardless of the number of occurrences in a 12-month rolling period. After a coworker has no occurrences for six months, the rolling 12-month guidelines will typically be applied for subsequent occurrences.



Absenteeism during a coworker’s first 90 days of service generally is addressed pursuant to the following guidelines:

Occurrence Action

1 Verbal warning; time off may be unpaid.

2 Written warning; time off may be unpaid.

3 Termination

UNEXCUSED ABSENCESIn addition to the discipline a coworker may receive based on the number of occurrences accumulated in a rolling 12-month period, the Company, in its discretion, also may discipline a coworker for an unexcused absence, up to and including termination. Unexcused absences include such things as failing to properly notify the Company when you are sick, failing to obtain prior approval for a planned absence or missing work for an inappropriate reason. A coworker who incurs three consecutive days of unexcused absence will be considered to have voluntarily terminated his or her employment.

UNEXCUSED LATE ARRIVALS/EARLY DEPARTURESAll coworkers are expected to be available and ready to perform their job functions at their assigned starting time. They are also expected to perform their job function until their assigned departure time. Each department will determine and communicate the time required for each coworker to report to work, available and ready to perform their job function from arrival time to departure time.

The Company will keep track of late arrivals and early departures based on a rolling 12-month period. Excessive late arrivals or early departures generally will be addressed pursuant to the guidelines below (for coworkers with more than 90 days of service). CDW, in its discretion, may vary these guidelines and jump to a higher level of progression earlier, depending on the circumstances of a particular situation and/or the needs of the department and/or Company.

Occurrence Action

1-5 Documentation of the late arrival or early departure; no action to the coworker.

6 Verbal warning; remind coworker of policy

7 Written warning, provide coworker with a copy of his/her lateness or early departure record; copy of warning goes to Coworker Services Business Partner Team for coworker’s personnel file.

8 Final written warning*

9 Suspension* (typically five days unpaid)

10 Termination

*Any occurrence within six months of a final written warning or suspension will result in progression to the next level of discipline, regardless of the number of occurrences in a 12-month rolling period. After a coworker has no occurrences for six months, the rolling 12-month guidelines will typically be applied.

Late arrivals during a coworker’s first 90 days of service generally is addressed pursuant to the following guidelines:

Occurrence Action

1 Verbal warning; Company may require coworker to make up missed time.

2 Written warning; Company may require coworker to make up missed time.

3 Termination

NOTIFICATION REQUIREMENTS FOR ABSENCES OR LATENESSExcept in unusual emergency situations, coworkers must report their own absence or lateness no later than the start of his/her workday to the individual’s supervisor or manager, assigned contact person, or if these individuals are not available, then you must contact the Coworker Services Business Partner Team.



EMERGENCIES, SECURITY/SAFETY & BUSINESS CONTINUITY (SSBC)EMERGENCIESIn any given day, a coworker, or CDW as a whole, may face an emergency situation. To handle the various issues that may arise, we have implemented the following procedures and programs:

Emergency Telephone Number: Ext. 79000 or 847.968.9000

This is not a substitute for calling 911 — it is to be used after the police, fire department or paramedics have been notified.

Use this number in the event of an accidents, theft, fire, safety issue, bomb threat, explosion, workplace violence, assault, etc. This number can be dialed from any location at any time of day.

Nonemergency Telephone Number: Ext. 76015 or 847.371.6015

Evacuation ProceduresDuring an emergency and after an announcement has been made or fire siren/bells have activated, evacuate the building in a calm, orderly manner. In the event of a tornado or severe storm situation, you will be directed to a safe area within the building such as stairwell without windows, bathroom or interior room without windows. There is a trained Emergency Response Team (ERT) in each location to assist you with an evacuation. Each ERT member will be wearing a red hat. Evacuation maps, plans and evacuation meeting area maps are posted on Connect.

In the event of an evacuation, follow these procedures: (There is a trained ERT member in each location to assist you with an evacuation; each designated member will be wearing a red ERT baseball cap.)

• Immediately leave the building, utilizing escape routes and emergency exits

• ERT members will direct evacuation efforts

• Collect valuables (purse, coat, etc.), ONLY if it is safe to do so

• Direct any vendors or visitors to evacuate the building

• Assist any coworker, vendor or visitor who is physically challenged

• DO NOT USE ELEVATORS

Gather at the designated evacuation meeting areas to be counted:

• ERT members will conduct a roll call of coworkers

• No coworker should leave the evacuation meeting area, either to re-enter the building or leave the area, until advised to do so by the ERT Team Leader

Business Continuity Program (BCP) CDW is committed to the continuation of business even during a natural or man-made disaster. If an emergency occurs, such as fire, explosion, etc., or a nonemergency and significant business interruption occurs such as an infrastructure failure, power outage, server outage, LAN failure, phone outage, etc., please notify our Security Operations Center immediately through one of following Emergency Numbers:

CDW Emergency Numbers (To report a business interruption)

In-house ......................................................................Ext. 79000

Outside .........................................................................847.371.6015

Satellite (if phone system is down) ..............321.752.2920

CDW Life/Safety Check-in Numbers (To let us know your status after an emergency)

In-house ......................................................................Ext. 79000

Outside .........................................................................847.371.6015

Text ................................................................................847.630.4284



Also, by calling the Communication Hotline at either of the following numbers, you will be instructed on what to do and where to go if the building cannot be occupied after a business interruption occurs:

CDW Communication Hotline Numbers (To obtain information after a business interruption has occurred)

Local ...............................................................................847.968.9529

Toll-Free ......................................................................877.215.1110

The Communication Hotline provides instructions/information related to incident, but coworkers cannot leave messages on this system. For additional information, please refer to the BCP Brochure available on Connect.

SAFETY CDW strives to maintain a working environment that provides for the safety and well-being of all coworkers, visitors and the surrounding community. CDW is committed to complying with health and safety standards that apply to its operations and activities. All coworkers are always to keep in mind the issues of health, safety and fire prevention. Tell your supervisor or manager, or make a report directly with the SSBC, if you learn of any unsafe condition or situation in any CDW facility that you feel might cause an accident or injure someone.

To help keep you safe, the Company has implemented a number of occupational health and safety programs and procedures, including the following:

• Accident Prevention Program • Athletic Trainer Program • Blood-borne Pathogen Program

• CPR/First Aid/AED Program • Contractor Safety Guide • Ergonomic Online Program

• Emergency Evacuation Plans • Fall Protection Program • Field Coworker Safety Guideline

• Hazard Communication Program • Hearing Conservation Program • Hot Work Permit Program

• Lock Out/Tag Out Program • Powered Industrial Vehicle Program • Personal Protective Equipment Program

• Safe Lifting Program • Safety Committee Program • Safety Orientation

• Safety Poster Awareness Program

Details on all of these programs can be found in the CDW Safety Program maintained by the Safety Manager. Many of these programs can be located on Connect under SSBC, Safety. The CDW approach to preparing these safety programs has been to incorporate, to the fullest degree practicable, industry-recommended hazard-control programs and procedures.

To further ensure safety in our workplace, CDW has put in place established systems and procedures for communicating with coworkers on matters concerning safety and health; identifying, evaluating and reducing workplace hazards; implementing procedures for injury/illness investigation; mitigating hazards in the workplace; training coworkers; and maintaining records.

PHYSICAL SECURITYCDW strives to maintain a secure working environment for all coworkers and is committed to complying with all applicable security standard operations and activities. To meet these goals, the Company has implemented a number of security programs and procedures, including the following:

ID Badges

Depending on location, SSBC is responsible for printing and distributing new hire ID badges. All new coworkers are to pick up badges from SSBC.

A coworker who has misplaced his or her badge and needs it replaced must complete the badge request form located on Connect. ID badges are expensive and an important measure of Company security; therefore, CDW asks coworkers who need replacements to please exercise proper care with their badges.

Coworkers also understand and agree that photos taken for ID Badges may be used for the purposes of facial recognition scanning and monitoring activities which may include creating and storing records of your facial geometry.



Office/Distribution Center Security

Access Control — All CDW buildings are equipped with an access control system that is activated with your coworker ID badge. This system/control is in place to help keep unauthorized individuals from entering our office and distribution center areas. Please make sure you have your ID badge displayed at all times. Be careful not to allow unauthorized individuals from “tailgating” into the office/distribution center behind you. Help keep CDW safe. Each coworker must badge in when entering a facility. If there is a group of coworkers entering at the same time each one must scan their ID badge before entering. The door can remain open for everyone but everyone must scan their badge.

Alarm Systems — All CDW buildings are protected by an electronic intrusion alarm system. Please be careful when entering and leaving buildings before or after regular business hours. If you are working after hours, just call the Security Operations Center (847.371.6015), and let them know. If you don’t, you might set off one of the alarms. Your supervisor or manager will let you know which doors you can and cannot use and what the business hours are for your assigned location. We will never inhibit a coworker who has to work after hours.

Security Officers — In some of our buildings, receptionists and security officers monitor entrances and exits.

Data Center Security

Biometric Access Control — In addition to access control and alarm systems, all CDW data centers are protected by biometric scanners, including hand scanners combined with smart card ID technology. If assigned to work in one of these facilities, you will be given instructions on the use of these additional security controls. These Biometric Access Controls may collect, use and store biometric data, including, but not limited to, records of your image, voice patterns, fingerprints, handprints, retinal scans and facial geometry (“Biometric Data”).

Parking Lot Security

In some locations, you are required to register your vehicle. If you use special needs or carpooling parking, then you will be assigned a Parking Permit Tag that hangs on your vehicle rearview mirror.

Distribution Center Security

Entrances — All distribution center coworkers (including those in Technical Support, Will Call) are required to enter and exit through the designated distribution center entrances. The security officers are instructed to search all coworker belongings thoroughly when a coworker is leaving or entering the distribution center entrances. All entrances have a security officer to prevent theft. This is a necessary measure for everyone’s protection because it secures our inventory.

Metal Detectors — Metal detectors are used at the entry/exit points from the distribution centers. Please empty any metal you have in your pockets into holding containers located next to the metal detector. (At the Western Distribution enter, you will need to pass through the detector both entering and exiting.) If the metal detector activates when you go through it, you will asked to step aside and a hand metal detector will be used to identify what is causing the activation.

Lockers — Lockers are provided at the entrances so that you can hang up your coat or jacket and store any personal belongings you bring in that are not allowed in the distribution centers. You must provide your own lock.

Coat and Hat Policy — No coats or hats are allowed in the distribution centers. (Exceptions may be made in cold weather for coworkers working on the docks.)

ID Badges — Please wear your ID badge at all times while in the distribution centers so that you can be identified and be able to enter and exit properly.

Camera Systems

For the protection of coworkers, CDW monitors entrances and exits to all of our facilities via cameras equipped with video and audio recording capability, as well as other areas throughout the facilities and parking lots. These are digitally recorded and stored on back-up tapes. These Camera Systems may use facial recognition technology scanning and monitoring technology that collects and uses your biometric data. This data is only stored on individuals determined to be a safety risk and could include ex-coworkers, ex-contractors and known local offenders. Data is not stored on current active coworkers.



Reasonable Searches

To maintain security and protect against theft, CDW reserves the right to search individuals and all personal property brought into or onto Company premises, including but not limited to, lunch boxes, thermoses, purses, briefcases, backpacks, wallets, personal electronic and computer equipment and devices, including but not limited to, notebooks, tablets, e-readers , CDs, DVDs, storage devices (external hard drives, flash drives, USB drives, etc.), smartphones, mobile/cellular phones, any mobile and portable electronic devices and their contents (“Personal Electronic Equipment”), and private vehicles parked on CDW’s premises. In addition, CDW may inspect the contents of lockers, storage areas, file cabinets, desks and work areas at any time and remove all Company property or other items that violate Company policies and procedures. Such searches may be conducted by SSBC without prior announcement, but ordinarily will only be conducted when CDW believes there has been a violation.

You are expected to cooperate with such searches. Refusal to cooperate may result in disciplinary action up to and including termination.

Property Protection

CDW property, such as equipment, computers, furniture, etc., is provided so you can successfully do your job. It is important, therefore, to be careful when using this property. CDW property should be used only for Company business.

Any CDW-issued or personal office equipment/property removed from our distribution centers must be approved by your manager and registered with SSBC prior to removal. This includes Personal Electronic Equipment.

After verifying authorization, SSBC will attach a barcode label or an “Approved by Security” sticker to the property or product. Upon exiting the distribution center, please stop at the security desk to have the barcode label and your Coworker ID scanned. As long as the two match, you can leave with the property, product, equipment or supplies.

Any property such as equipment, computers, furniture, etc., removed from the office area must be accompanied by a Property Removal Form and signed by your manager. Upon exiting the office, please turn in this form to the security officer.



WORKPLACE INJURIES AND WORKERS’ COMPENSATIONSafety is a priority at CDW, and we strive to create safe working conditions and promote safe work practices. In the event of an injury, you should immediately notify your supervisor or manager. For any accident, no matter how minor or severe, a coworker must complete a Manager’s Incident Form with his or her supervisor or manager before leaving the work site, or if they are unable, as soon as practicably possible. The Manager’s Incident Form can be located on Connect under SSBC, safety area. Failure to timely report a work-related injury is grounds for disciplinary action. The Company can require any current coworker to undergo testing for drugs and/or alcohol when the coworker is involved, by action or omission, in an accident which results or could result in property damage or in any person’s injury.

It is Company policy not to take adverse action against a coworker who reports a workplace injury or makes a workers’ compensation claim for making such report.

Workers’ Compensation Leave

Any coworker who misses at least four days of work because of a work-related injury will be placed, if eligible, on Family and Medical Leave within two days of notification by CDW. While on workers’ compensation leave, CDW will continue to pay its portion of the premiums due on the coworker’s CDW-sponsored group health and dental insurance for the period of time you are on workers’ compensation leave. You will be required to pay CDW your portion of the premium on or before the date such premium is due. Failure to return to work following a doctor’s approval will constitute a voluntary resignation on your behalf. Once your Family and Medical Leave is exhausted, vacation and all other CDW benefits, including sick leave, holiday pay, shall not accrue or vest during your workers’ compensation leave. You may continue to be carried on the rolls of the company as a “regular coworker on leave status,” for up to 12 months in a rolling 18-month period under CDW’s medical leave of absence policy. Upon your termination, CDW may deduct any delinquent insurance premiums from your final paycheck.

If at any time during an approved leave of absence you believe you could return to work in your former role or a different role with reasonable accommodation, you should contact Coworker Services. We will then enter into an interactive process with you and your medical care provider to determine if you are disabled within the meaning of the Americans with Disabilities Act, if CDW has any open roles for which you qualify, and if CDW can provide reasonable accommodation without undue hardship.

Modified Duty Program

To allow coworkers to return to work as soon as possible, CDW has a modified duty program for injured coworkers with temporary limitations. CDW’s modified duty program attempts to identify temporary assignments, within a coworker’s restrictions for a specific time period, depending on the circumstances. Please see your CWS Business Partner for additional information and forms.



EMPLOYMENT PRACTICESCoworkers are expected at all times to conduct themselves in a positive, respectful manner that promotes the best interests of the Company. Conduct that interferes with operations, discredits or is not in the best interests of CDW or is offensive to customers, vendors or coworkers will not be tolerated. CDW has established the conduct guidelines discussed in this section to encourage a pleasant and productive work environment. These guidelines are not intended to cover every situation, and in all instances, you are expected to conduct yourself in a responsible and professional manner that reflects the exercise of good judgment appropriate to a work environment.

ALCOHOL AND DRUGSCDW is committed to programs that promote safety in the workplace, and coworker health and well-being. Consistent with the spirit and intent of this commitment, CDW has developed this policy covering the sale, use, possession or distribution of drugs and alcohol by CDW coworkers. Your involvement with drugs and alcohol, both on and off the job, can adversely affect job performance, jeopardize the safety of others and weaken confidence in CDW. The Company believes this policy is necessary to ensure that CDW continues to fulfill its responsibilities to both its coworkers and its customers.

CDW will not accept any risk to safety, quality or productivity that may be caused by drug or alcohol use, either on or off the job. Our objective is to have all of our coworkers report to work in a condition to perform their duties safely and efficiently. It is Company policy to achieve a workplace free of the effects of drug and alcohol use.

Coworkers needing help or rehabilitation in dealing with a drug or alcohol problem are encouraged to contact, on a confidential basis, either the Coworker Services Business Partner Team or the Employee Assistance Program (EAP). Through the EAP, a coworker can receive a confidential referral to counseling and treatment services.

Conscientious efforts to seek assistance on a first-time basis will not result in disciplinary action against the coworker solely because the coworker seeks chemical dependency counseling or treatment, provided the coworker seeks help voluntarily before she/he is referred for discipline or scheduled for testing under this policy. Participation in the EAP does not, however, relieve a coworker of his or her responsibility to comply with all Company policies and rules and to meet all job performance and conduct standards.

The drug and alcohol policy outlined below covers all individuals who work in any capacity at CDW. Job applicants also are covered. Compliance with this drug and alcohol policy is a condition of employment at CDW.

Alcohol and Drug Rules in the Workplace• The use, sale, purchase, manufacture, possession, transfer or receipt of an illegal drug, or being under the influence of an illegal

drug, during working time or at any time while on Company property, in a Company vehicle or otherwise on Company business is absolutely prohibited. For purposes of this policy, “illegal drugs” are any drug that is not legally obtainable or that is legally obtainable, but has not been legally obtained or has been legally obtained but is not being used for prescribed purposes or in prescribed amounts.

• The use of alcohol or being under the influence of alcohol during working time or at any time while on Company property, in a Company vehicle or otherwise on Company business, is absolutely prohibited, with the following exception: This policy is not intended to prohibit the incidental consumption of alcoholic beverages by Company personnel at business-related events or Company-sponsored activities at which such beverages are served, or in Company-approved social or entertainment activities related to sales or other corporate or public relations functions. However, coworkers attending or participating in such events or activities are prohibited from being impaired by the use of alcohol while so engaged and are otherwise subject to the prohibitions contained in this policy.

• The use, or being under the influence, of any legal drug by any coworker during working time or at any time on Company property, in a Company vehicle or otherwise on Company business, is prohibited if such use or influence may detrimentally affect the safety of coworkers, customers or members of the public, the coworker’s job performance, or the safe or efficient operation of the Company. Coworkers whose use of a legal drug may result in such detrimental effects are required to report such drug use to their immediate supervisor. For purposes of this policy, “legal drugs” are those drugs that have been prescribed by a doctor and those over-the-counter drugs that have been legally obtained and are being used for the purpose for which they are prescribed or manufactured.



Testing for Drugs and AlcoholApplicants for Employment. The Company will conduct drug testing of applicants for employment in all positions with the Company. Testing will be required after the Company has extended an offer of employment conditioned upon a negative drug test result. Applicants who refuse to undergo drug testing, or who otherwise interfere or tamper with the testing process, will be denied employment.

Current Coworkers. The Company may require any current coworker to undergo testing for drugs and/or alcohol under the following circumstances:

1. “Reasonable suspicion” — When the Company has reason to suspect, based upon observed behavior or circumstances in which the Company reasonably believes that the coworker may be under the influence of drugs or alcohol whose use violates the rules of conduct in this policy. For the purpose of requiring a drug or alcohol test, “reasonable suspicion” exists if facts and circumstances warrant a rational inference that a person is using alcohol or drugs and/or is mentally or physically impaired due to being under the influence of alcohol or drugs.

2. “Post-accident” — When the coworker is involved, by action or omission, in an accident which results or could result in property damage or in any person’s injury.

3. “Business need” — For example, when screening is required by a customer contract.

4. “By agreement” — As a condition of any agreement between the Company and the coworker.

5. “Upon rehire” — When a coworker is rehired by the Company.

Any coworker has the right to refuse to submit to a drug and/or alcohol test; however, if a coworker refuses to submit to a test or fails to cooperate in the testing process as required under this policy, the coworker will be terminated.

Testing ProceduresTesting for drugs required under this policy will be performed by a laboratory retained by CDW that is certified by the U.S. Department of Health & Human Services to conduct such tests. Breath alcohol tests will be performed by a certified Breath Alcohol Technician. Coworkers and applicants subject to a drug or alcohol test must report to the Company’s designated collection/test facility within the time assigned and follow the procedures required by the facility. Refusal to comply with the facility’s procedures will be treated as a refusal to submit to a drug and/or alcohol test.

Reporting ObligationsIt is your responsibility to immediately report unsafe working conditions or hazardous activities that may jeopardize your safety or the safety of fellow coworkers. This includes reporting any violation of this drug and alcohol policy. If you fail to report such a violation, you may be subject to discipline up to and including termination. If you are concerned about your identity being released, please know that CDW will try to keep all sensitive information as anonymous as practically possible. Additionally, if you are convicted of a drug-related crime, you must notify CDW within five days of the conviction.



WORKPLACE VIOLENCECDW is committed to providing a safe and secure working environment for all coworkers, customers and vendors. In keeping with this commitment, CDW strictly prohibits acts or threats of violence of any nature in the workplace, no matter to whom they are directed. This policy applies to all coworkers and visitors on Company property, including our facilities and parking lots, as well as to all coworkers while in the course and scope of performing their job, whether or not they are on Company property at the time. This policy also prohibits acts or threats of violence at any CDW-sponsored functions such as parties, dinners or group outings.

While not exhaustive, the following provides examples of the types of conduct prohibited by this policy:

• Any direct, conditional or veiled threats of harm (comments such as “you had better watch your back”)

• Intimidation

• Threatening to harm or harming another person

• Threatening to harm or harming yourself

• Bringing any firearm, a gun, illegal knife, explosives or other weapon of any kind into the workplace or to any CDW-sponsored function

• Engaging in dangerous, threatening or unwanted horseplay

• Striking, punching, slapping, pushing or assaulting another person

• Fighting or challenging another person to fight

• Stalking

CDW will take prompt and appropriate action in response to any acts or threats of violence, which may include immediate suspension or termination of employment.

Any coworker who is concerned about their own or another’s safety or violence must report it immediately to a member of management, to the Coworker Services Business Partner Team or to security personnel. Coworker reports made pursuant to this policy will be held in confidence to the fullest extent possible, and CDW strictly prohibits any retaliation against any coworker who makes a good-faith report of any conduct or act believed to violate this policy.

DRESS CODE/APPAREL GUIDELINES

At CDW, we have the benefit of being able to wear business casual attire. We want to project a professional image at all times to our customers while still enjoying the freedom of dressing casually. If we want to continue with a policy allowing business casual, it is important that we comply with these guidelines.

Acceptable personal appearance is an ongoing requirement of employment with CDW. Radical departures from conventional business attire or personal grooming and hygiene standards are not permitted. Distracting or revealing clothing is never appropriate. When in doubt, err on the conservative side.

If dressed or groomed inappropriately, you will be asked to leave and return properly dressed. You will not be paid for the time lost.

In general, casual business wear means casual clothing that is appropriate for an office environment. It is clothing that allows you to feel comfortable at work, yet always looks neat and professional. Casual and comfortable does not mean sloppy.

CDW-approved logo apparel is acceptable casual dress for men and women any day of the week. CDW logowear should have a collar; or, when wearing a CDW pullover, a collared garment must be worn with it. When interfacing with customers, men must wear a suit and tie, business casual with a jacket, or a collared CDW shirt and should have their shirts tucked in at all times. On days when coworkers do not have face-to-face customer contact, men have the option of wearing dress shirts, collared short-sleeve shirts or a collared CDW shirt; dress slacks and khakis are also acceptable. For women, the following are acceptable forms of dress whether or not they have interaction with a customer, pantsuits, dress slacks, khakis, skirts and dresses. Blue jeans and tennis shoes are only acceptable on Fridays, if you are also wearing a collared CDW shirt, a CDW sweater or a women’s collarless CDW shirt.



The following are considered inappropriate for the workplace for both men and women: leggings, spandex, shorts, athletic wear, tank tops, tennis shoes, flip flops, rugged-style sandals, halter tops, non-CDW sweatshirts, see-through blouses or shirts, any type of revealing clothing, or tops revealing bare backs or midriffs.

While a dress code may seem trivial, customers and others visiting CDW notice how we dress. The success of our professional business casual policy and whether it remains in place requires all of us to exercise good judgment on what is acceptable to wear and to rigorously follow these guidelines.

Special Considerations for the Distribution Centers Shorts are acceptable in the Vernon Hills and Las Vegas distribution center year-round. Jeans are acceptable every day of the week. CDW shirts are required at all times. In Las Vegas, each department has its own shirt color (see Coworker Services or your manager if you have questions). T-shirts are acceptable. No jewelry can be worn for safety reasons, except for small stud earrings. Coworkers in the distribution center must always make safety a priority when choosing what to wear. For example, do not wear any loose clothing that could become stuck in the conveyor belt; wear shoes that adequately protect your feet.

ROMANTIC OR SEXUAL RELATIONSHIPS IN THE WORKPLACEConsensual romantic or sexual relationships between coworkers or between a supervisor or manager and a coworker, may at some point lead to significant difficulties for all concerned — the coworker, the supervisor or manager, and the Company. Any such relationship may, therefore, be contrary to the best interests of the Company.

Accordingly, if a romantic or sexual relationship between a supervisor or manager and a coworker should develop, it shall be the responsibility and mandatory obligation of the supervisor or manager promptly to disclose the existence of the relationship to the Coworker Services Business Partner Team. The coworker may make the disclosure as well, but the burden of doing so shall be upon the supervisor or manager. If a romantic or sexual relationship between coworkers becomes serious, it is the responsibility and mandatory obligation of both coworkers promptly to disclose the existence of the relationship to the Coworker Services Business Partner Team.

Upon being informed or learning of the existence of such a relationship, the Company may take all steps that it, in its discretion, deems appropriate.

At a minimum, for a relationship between a coworker and his or her supervisor or manager, the coworker and supervisor or manager will not thereafter be permitted to work together, and the supervisor or manager will be asked to withdraw from participation in activities or decisions (including but not limited to hiring, evaluations, promotions, compensation, work assignments, scheduling and discipline) that may reward or disadvantage any coworker, if participating in such activity or decision could be questioned because of the relationship. For a relationship between coworkers, one of the coworkers may be required to transfer to a different department. Typically, the decision about which coworker will transfer is left to the two coworkers in the relationship to decide.

EMPLOYMENT OF FRIENDS AND RELATIVESCDW appreciates coworkers who recommend friends, family or acquaintances for employment. Referrals are welcome at all times; however, please understand that such referrals cannot be given preferential treatment.

Relatives of coworkers are ineligible to work together when potential problems of supervision, favoritism, safety, security, morale or actual or perceived conflicts of interest may exist. Under this policy, relatives may not be eligible for employment, promotion or transfer to specific positions. CDW will determine in its sole discretion whether such an actual or potential problem exists.

Relatives, for purposes of this policy, include a coworker’s parent, child, grandparent, grandchild, spouse or domestic partner, brother, sister, in-law, step relationship, first cousin, aunt, uncle, niece, nephew, legal guardian and anyone who shares your residence (regardless of whether related). All coworkers are required to report to the Coworker Services Business Partner Team the employment by CDW of a relative.

SHIPPING AND EXPORT COMPLIANCECDW is committed to compliance with the letter and spirit of all U.S. export control laws and regulations. Under no circumstances should any sales or exports be made that are contrary to these laws and regulations. To ensure compliance, all orders with a final destination outside the United States must be reviewed by the CDW International Compliance group prior to release, including orders that may be shipping domestically prior to export. Please see full policy on Connect. If you have any questions about any sale, transaction or shipment involving a non-U.S. destination, contact International Compliance (email: [email protected]) before closing the sale, authorizing the transaction or allowing shipment. If you have reason to believe that an export violation has already occurred, report it immediately to CDW’s General Counsel.



OUTSIDE EMPLOYMENTIf you decide to accept full-time employment with CDW, the Company requires that your activities and conduct away from CDW not conflict with or adversely affect your ability to efficiently perform your assigned duties. If you engage in any other business or employment, it must not interfere with your job performance or required hours of work at CDW, involve the use of CDW time or resources, jeopardize our confidential or proprietary information, or be within the same industry or for a direct competitor of CDW. To assure compliance with this policy, please inform your manager or supervisor if you take another part-time or full-time position with another company or create your own business entity in addition to your full-time job at CDW.

COMPANY OUTINGSCDW encourages team building, and from time to time departments or groups may hold events offsite as part of our team-building efforts with potential for risk of injury or liability. Managers and supervisors wishing to hold such an event offsite must notify the Treasury Department of the proposed event as soon as possible and must obtain the approval of the Treasury Department prior to planning the event (for insurance purposes). When attending such events, coworkers are expected to exercise good judgment and act with respect toward all coworkers in attendance.

VENDOR-SPONSORED EVENTS

From time to time, vendors will sponsor events designed to build teamwork and camaraderie. When attending such events, coworkers are expected to exercise good judgment and act with respect toward all in attendance.

PERSONNEL RECORDS AND UPDATING OF PERSONAL INFORMATION

A coworker may review and copy his or her own personnel record up to two times per year. A coworker’s personnel record includes all documents that have been or are intended to be used in determining the coworker’s qualification for employment, promotion, transfer, additional compensation, discharge or other disciplinary action, except as provided under applicable law. Requests to review or copy a personnel record must be made in writing to the Coworker Services Business Partner Team. A coworker’s review of his or her personnel record must be conducted in the presence of a member of the Coworker Services Business Partner Team, and no documents may be removed by a coworker from his or her personnel record. A reasonable fee (not to exceed actual cost) may be charged for copies requested by a coworker.

Any coworker who believes that any material in his or her personnel record is incomplete, inaccurate or irrelevant may submit a written request for revision to the Coworker Services Business Partner Team. If the request is denied, the coworker may submit a written statement to the Coworker Services Business Partner Team explaining his or her position, which will be placed with the disputed material in the coworker’s personnel record.

Coworkers are responsible for ensuring their personal information in applicable CDW systems is accurate. A coworker may update their personal information through the self-service function in CTMS/Peoplesoft. Coworkers may contact [email protected] with questions.

MAILING OR SHIPPING PERSONAL ITEMSRemember that all CDW resources and technology are for business-use only. Generally, personal items of any nature should not be mailed/shipped to or from CDW. Shipping or receiving personal items to or from CDW directly affects CDW’s profits by interfering with the Company’s productivity, hampering efficient service to our customers and incurring the nonbusiness expense of mailing/shipping costs.

NONSMOKING ENVIRONMENTCDW is a nonsmoking, tobacco-free work environment. Consumption of tobacco products is only allowed in a designated smoking area. Further, please be considerate of our neighbors and do not smoke on adjoining properties.

In addition, it is the position of CDW that e-cigarettes fall under the consumption of tobacco products with other items such as chewing tobacco. The use of these products is only permitted in designated smoking areas outside of the building. The use of these e-cigarettes at coworkers’ desks is strictly prohibited.

MOBILE DEVICESWhile CDW realizes that coworkers may need to use mobile devices such as cellphones, smartphones, tablets or pagers for various reasons throughout the workday, it is expected that these devices are used with common sense and in a respectful manner. To the extent possible, landlines should be used as the primary device for receiving and making business-related phone calls. Volume should be set to vibrate or silent mode or at a very low volume to not disturb other coworkers. Personal communications should be limited and as always, good judgment should be applied.

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Coworkers who are assigned to the Distribution Centers are prohibited from bringing mobile devices into the warehouse, unless issued by CDW. There may be times where unusual or extenuating circumstances might justify using a personal mobile device in the Distribution Centers; therefore, you must obtain prior approval from your manager or the Coworker Services Business Partner Team to be allowed to carry a personal mobile device.

Additionally, coworkers doing business on mobile devices must abide by all state and local laws on cellular phone use and texting while driving. In those locations where use while driving is permitted, coworkers needing to use cellular phones while driving should always use hands-free devices.

PARKING AND CARPOOLING PRIVILEGES

Coworkers are required to park only in the portions of the CDW parking lot designated for use by coworkers. If you park in customer or visitor parking spaces, in the loading dock area or other designated parking spots, you may be subject to disciplinary action and your car may be towed at your expense and without warning.

CDW encourages coworkers to carpool and at some locations provides specially convenient parking for those coworkers who do so. To receive carpool privileges, coworkers must officially register with Security. Any coworker participating in CDW’s program must carpool at least three days a week with a two-person rider minimum. If you do not have at least two people riding in the car on any given day, you may not park in the carpooling spaces. Carpooling privileges will be revoked if these guidelines are violated.

CDW’s parking lots are considered part of the Company’s premises; all CDW policies and procedures apply to coworkers and their vehicles while in the parking lots.

CDW assumes no responsibility for any damage to, or theft of, your vehicle or personal property left in the vehicle while it is parked on CDW premises.

AUTO SAFETY GUIDELINESCDW has developed auto safety guidelines to enhance the safety of those individuals who are required to drive as part of their employment duties, and to provide accident reporting guidelines and personal insurance requirements. If you are a coworker who engages in work-related driving, please review these guidelines which are posted in the Policy Library on Connect.

DISPUTE RESOLUTION PROCEDURE Coworkers are encouraged to make every effort to work out differences and resolve disputes directly with their peers, supervisors and managers. If a coworker cannot resolve a dispute directly, he or she may contact the Coworker Services Business Partner Team for assistance. The Coworker Services Business Partner Team will assist the coworker in resolving the dispute informally, or the coworker may use the CDW Dispute Resolution Procedure.

To begin the Dispute Resolution Procedure, a coworker submits the dispute in writing to the Coworker Services Business Partner Team, including a proposed resolution. The Coworker Services Business Partner Team then mediates a resolution between the coworker and the involved party(ies). If the dispute is not resolved through this mediation, the corporate officer responsible for the coworker’s department will decide the appropriate resolution of the dispute. The decision of the corporate officer will be final.

Please note: If the dispute concerns discrimination or harassment, the coworker should follow the procedures for reporting discrimination and harassment set forth under the Company’s Equal Opportunity, Affirmative Action and Nondiscrimination Policy or Prohibition of Sexual and Other Unlawful Harassment. These policies are in “Road to Success” and are also available through the Coworker Services Business Partner Team.

SOLICITATIONS AND LITERATURE The Company recognizes that coworkers are interested in events, activities and organizations outside the workplace. However, in an effort to create a productive and harmonious work environment, we have adopted the following rules related to solicitation and the distribution of literature.

Individuals not employed by the Company may not solicit or distribute literature in the workplace or on Company property at any time for any purpose.

Coworkers may not engage in solicitation of another coworker for any purpose during working time. Working time includes the work time of either the coworker doing the soliciting or the work time of the coworker to whom the solicitation is directed.

Noncompany literature may not be distributed during working time or in work areas. Work areas include all areas except the cafeteria, restrooms,



lobbies and parking lots. Working time includes the working time of either the coworker distributing the literature or the working time of the coworker to whom the literature is directed.

Coworkers are prohibited from making commercial or charitable solicitations on Company premises without prior permission from management. These include, among other things, asking for donations, buying or selling chances, placing orders for merchandise other than merchandise sold by CDW, or selling tickets.

Coworkers also must recognize that they represent CDW, particularly when wearing CDW apparel. While we respect and honor coworkers’ freedom to support and participate in all kinds of political, religious and other causes, coworkers may not do so in any manner that ties CDW’s name or logo to the cause.

TRANSFERS AND PROMOTIONSCDW encourages promotion and mobility from within the Company. Generally, you may apply for any open position provided you have been in your current position for at least one year, you have not received any disciplinary actions in the past six months and you have a satisfactory performance record.

If you are interested in an open position, apply online through the Internal Transfers section on Connect.

To find the internal transfer eligible positions, go to Connect.

In making decisions for promotions or transfers, management will consider personal achievement, education, demonstrated ability, as well as the coworker’s past contributions to CDW.

RESIGNATION, TERMINATION AND REFERENCESEmployment at CDW is “at will,” which means you are free to terminate the employment relationship at any time, with or without cause and with or without notice. CDW has the same right. The Company requests that if you choose to end the employment relationship, you provide at least two weeks’ notice to allow the Company to transition your duties and responsibilities.

If your employment with CDW ends for any reason, you will be asked to return any Company property in your possession, including any confidential or proprietary information you may have. You will be paid any accrued but unused vacation and your final regular pay no later than the next regularly scheduled payday. If you need information on distribution of any amounts you may have under the 401(k) Profit Sharing Plan, you should contact our 401(k) provider.

Requests for employment and/or income verifications should be directed to CDW’s verification assistance service provider. Instructions for utilizing this service can be found by searching “Verification”, “Employment”, or “Mortgage” within Connect. Coworkers should review these instructions before directing a verifier to this service.

COBRA RIGHTSThe Consolidated Omnibus Budget Reconciliation Act of 1986 (COBRA) allows coworkers and their family members (their spouses, same gender domestic partners and dependent children) to continue medical, dental and/or vision coverage (including flexible spending accounts*) for certain periods of time if their coverage would otherwise end due to a “qualifying event.” Coworkers and their family members who elect continued coverage are required to pay the full cost of coverage, plus an administrative fee (generally 2%).

For you and your family members receiving medical, dental and/or vision coverage, qualifying events include your termination of employment (for reasons other than gross misconduct) and your reduction of work hours. If you experience one of these qualifying events, you and your family members will be notified by CDW’s appointed administrator of your COBRA options and obligations via postal mail.

For your family members receiving medical, dental and/or vision coverage, qualifying events also include your divorce, legal separation, termination of a same gender domestic partnership, death or enrollment in Medicare. If you die or become enrolled in Medicare, your spouse and dependent children will be notified by Coworker Services of their COBRA options and obligations via postal mail. If you become divorced or legally separated, or your child no longer qualifies as a dependent under the medical or dental plan, you or a family member must notify CDW’s appointed administrator within 60 days after the qualifying event. Upon receiving the notice, CDW’s appointed administrator will notify your dependent spouse and children of their COBRA options and obligations via postal mail.



The period of continuation coverage depends upon the qualifying event and is set forth generally in the following chart:

Qualifying Event Qualified Beneficiaries

If coverage will end due to: Employees may continue coverage for up to:

Each spouse, domestic partner or dependent child may continue

coverage for up to:

Your termination of employment (for reasons other than gross misconduct) or reduction in hours of employment

18 months 18 months

Your death N/A 36 months

Your divorce or legal separation or termination of a same gender domestic partnership

N/A 36 months

Your child’s loss of dependent status N/A 36 months

Your enrollment in Medicare N/A 36 months

The period of continuation coverage for you and your family members may be extended from 18 months to 36 months if one of you is determined by the Social Security Administration to be disabled at any time during the first 60 days of continuation coverage, and CDW’s appointed administrator is notified within 60 days of the determination and before the end of the initial 18 months of continuation coverage. Also, the period of continuation coverage for your spouse or dependent children may be extended from 18 months to 36 months if a second qualifying event occurs (namely, your death, divorce, legal separation or enrollment in Medicare, or your child’s loss of dependent status) during the first 18 months of continuation coverage, and CDW’s appointed administrator is notified within 60 days of the second qualifying event (except in cases of your death or enrollment in Medicare).

It is the responsibility of you and your family members to notify Coworker Services of any change in marital or dependent status (including births, adoptions, establishment or termination of a same gender domestic partnership, and changes in full-time student status) to protect your family’s rights under COBRA.

Coworkers and their spouses receive a notice outlining their COBRA options and obligations in greater detail within 90 days of enrollment in a medical, dental and/or vision plan. Please contact Coworker Services or CDW’s appointed administrator with any questions you may have.

More information on CDW’s policies, procedures and benefits may be found on Connect, CDW’s intranet site.

*Please note that continuation coverage for your flexible spending account will cease at the end of the plan year in which the qualifying event occurs.



INFORMATION SECURITY AT CDWWhen our customers, coworkers, business partners and others share information with us, especially Confidential Information, they trust that we will take appropriate care to safeguard the information, and respond appropriately in the event of a threat to that information. Preserving this trust is important to CDW, as failure could cause irreparable damage to CDW’s reputation, and could lead to monetary penalties, loss of business and competitive disadvantages.

This Policy is designed to help ensure that appropriate protection is applied to the information created, received or stored, whether in electronic or print form, as part of our operations. All of us must be personally dedicated to this protection, review any communications regarding this Policy, and attend all required training.

Applicability The provisions in this Policy govern the usage of CDW’s “Information Systems”, which include CDW’s enterprise network infrastructure, software, information, or applications. This Policy applies to any person who is authorized to access Information Systems, including all full- and part-time coworkers of CDW and others (including temporary coworkers, contractors, consultants, business partners, vendors and other third parties), collectively “Authorized Users.” Authorized Users granting third parties access to Information Systems and/or Confidential Information (defined below) are required to ensure that the third party commits in writing to comply with the provisions of this Policy or equally stringent requirements.

To the extent that any applicable legal, regulatory or contractual requirements are stricter than what is contained in this Policy, Authorized Users must abide by those stricter requirements.

Policy Understand the Sensitivity of the Information You Have (or Have Access To) — The first step in protecting Confidential Information is to know when you have it. For purposes of this Policy, information should be considered confidential if the subject or source of the information (the Company, a customer, a coworker, etc.) has not publicly disclosed the information. Some key examples of Confidential Information, whether in electronic or paper form, include:

• Personally Identifiable Information (“PII”) which is an individual’s first name or first initial and last name in combination with any one or more of the following data elements that relate to such person, when either the name or the data elements are not encrypted:

— Social Security number; or

— Driver’s license number or state-issued identification card number; or

— Financial account number, credit card number or debit card number, in combination with any required security code, access code, or password that would permit access to the person’s financial account; or

— A user name or email address, in combination with a password or security question and answer that would permit access to an online account.

• Protected Health Information (“PHI”) is any individually identifiable health information held or transmitted by a covered entity (e.g., hospital or physician) or CDW, in any form or media, whether electronic, written or oral. This is information, including demographic data, that relates to (i) the past, present or future physical or mental health or condition of an individual; (ii) the provision of healthcare to an individual; or (iii) the past, present, or future payment for the provision of healthcare to the individual, and either identifies the individual or could reasonably be used to identify the individual; or

• Nonpublic information about the present or planned business operations of CDW and/or its affiliates, such as proprietary information, trade secrets, know-how, inventions, patents and trademarks, copyrights, business development, marketing and sales programs, purchasing manners and methods, the identity and addresses of actual or potential customers, customer and supplier/vendor information, coworker information, pricing information, financial data, regulatory approval strategies, results of investigations, research, testing methodologies and results, certain computer programs, manufacturing methods and processes, technologies and protocols, product development strategies and processes, safety information, programs and protocols, product design and related items.

Limit Collection, Access, Sharing and Storing of Confidential Information — One of the best ways to protect against a breach of Confidential Information is to limit what you collect, access, share and store.

• Limit your collection of, use of, and access to Confidential Information to what is necessary to perform your job responsibilities.

• Do not share Confidential Information with others, including anyone outside the Company, unless they have a legitimate business need for the information and appropriate authorization.



• Do not store Confidential Information longer than required by CDW’s Record Retention Policy which can be found in the Policy Library on Connect.

• Authorized Users may be granted access to a third party’s (e.g., business partner or customer) information systems on behalf of CDW. In those circumstances, access to a third party’s information systems should be limited to authorized activities directly related to the work required. You are expected to conduct yourself according to the third party’s information security policies while accessing their information systems or information. Should there be differences between CDW and the third party’s policies, follow the more stringent policy.

• Authorized Users who are no longer affiliated with CDW are not to retain or access or attempt to access Confidential Information on CDW’s Information Systems. All CDW-owned or leased equipment and Confidential Information must be returned to CDW prior to or upon separation.

Protect Confidential Information — Once entrusted with Confidential Information, you have a responsibility to protect it against unauthorized access, unauthorized alteration, loss or disclosure. The following are some common sense requirements that you must follow to help fulfill this responsibility:

1. Safeguard Confidential Information in Your Daily Activities.

• Secure Confidential Information when unattended or not in use.

• Do not discuss or view Confidential Information where unauthorized parties may be able to hear or view the information.

• Choose secure passwords and change them when prompted or when you suspect password compromise.

• Do not share, reveal, post, or write down your User ID or passwords. Always keep User IDs, passwords, encryption keys and PINs confidential and secure. You are responsible for all actions associated with your User ID and password.

• Do not circumvent password entry by using auto logon, password memorization programs or similar means.

• Lock or log off when you are away from your computer or mobile device (for Windows, Windows Key + L).

• When printing Confidential Information, use the Secure Print feature (under printing properties, preferences, job type), or send it to printers located in a restricted area accessible only by parties authorized to view the information, or remove from the printers immediately.

• When disposing of Confidential Information in hard copy, ensure that it is either shredded or placed in an appropriately labeled and locked shredding bin.

• Authorized Users who have been issued an RSA SecureID (either a soft token or keyfob) for remote access to CDW’s Information Systems must ensure that the SecureID is kept secure and report if the device is lost or stolen.

2. Safeguard Confidential Information While Using the Internet, Email and Instant Messaging (“IM”).

• Do not put credit card numbers, Social Security numbers or PHI in email or IM (including your personal information). If you receive an email containing such information, do not reply or forward and permanently delete (SHIFT + DEL) the email immediately.

• Use secure communications or encryption when sending Confidential Information outside of CDW. Email and IM are not, by themselves, a secure communications means. Authorized Users must not forward, including auto-forwarding, Confidential Information from their CDW email to any non-CDW account including personal accounts (e.g., Gmail, Yahoo and Hotmail). If you believe you have a need to transmit Confidential Information, contact [email protected].

• Do not open any files or macros attached to an email from an unknown or untrustworthy source. Delete spam, chain and other junk email without forwarding.

• Do not execute auto pop-up applications without first being sure of their source or function.

• Do not download files or software from unknown or suspicious sources or use unauthorized peer-to-peer programs. Only authorized CDW-owned software may be downloaded and/or used within CDW or on CDW-owned or leased devices. Forward any suspicious email as an email attachment to [email protected].

• Any attempt to breach or circumvent any of CDW’s security measures and safeguards, including running unauthorized scans, is prohibited.

• Any unauthorized action which damages or disrupts CDW’s electronic communications or Information Systems, alters their normal performance, or causes them to malfunction is prohibited.

• Nonsanctioned use of mobile devices to back up, store and otherwise access any Confidential Information is prohibited.

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3. Safeguard Your Computers, Mobile Devices and Portable Media.

• Mobile devices are defined as corporate or personally owned notebooks, tablets, cellphones, smartphones, external storage devices (including thumb/USB drives), or any device storing Confidential Information or connecting to CDW’s Information Systems.

• All mobile devices used to access CDW’s Information Systems must have CDW’s approved Mobile Device Management (“MDM”) software and auto-discover solution installed and enabled. By accepting the agreement terms of the MDM application, personal mobile devices will be remotely wiped, if possible, should the device be lost or stolen.

• Use caution when accessing or storing Confidential Information on any mobile device and do not store Confidential Information on an unencrypted mobile device. If your device is using CDW’s MDM solution, it’s encrypted.

• All corporate notebooks must be encrypted using a CDW-approved encryption method.

• All computers used by Authorized Users that are connected to CDW’s Information Systems, whether owned by Authorized Users or CDW, must have anti-virus software installed and enabled.

• Secure all mobile devices whether or not they are actually in use and/or being carried. Securing includes, for example, using passwords/PINs, encryption, engaging the automatic lock-out feature, not leaving the device visible in public places, and bringing them as carry-on baggage on an airplane.

• A lost or stolen mobile device will be remotely wiped of all data, if possible, and locked to prevent access by anyone other than CDW IT.

• Do not circumvent or prevent any automatic updates to anti-virus or malware detection software or operating system security patches provided by CDW.

• Personal notebooks accessing CDW’s Information Systems must use the CDWGuest wireless network and may only use Citrix or other approved methods (e.g., VPN) to access CDW’s Information Systems.

• If you lose a mobile device, you must contact the Security Operations Center (847.371.6015 or ext. 76015) immediately.

• All portable media, such as CDs, DVDs, thumb drives, flash drives, USB drives, hard drives, backup tapes and other media storing Confidential Information or connecting to CDW’s Information Systems, must be encrypted. For more details on encryption software, see the Information Security page on Connect.

• Portable media or mobile devices to be destroyed or reissued must be sent to the IT Service Desk ([email protected], or 888.239.2943) for proper data deletion and disposal handling.

4. Safeguard Information When Using Online Collaboration Tools.

• Authorized Online Collaboration Tools, which are Internet-based collaboration and repository services linked to a CDW email address, are an extension of CDW’s data storage.

• Authorized Users must exercise caution to avoid accidental disclosure when sharing information using Online Collaboration Tools.

• Information on Online Collaboration Tools must only be made available to those who are authorized to view it based on a legitimate business need.

• Only place customer Confidential Information on Online Collaboration Tools when expressly authorized by the customer and when necessary for a legitimate CDW business purpose.

• Do not place credit card data, Social Security numbers, or PHI on any Online Collaboration Tools.

• Remove or relocate information stored in Online Collaboration Tools upon completion of the task or project for which it is required. The exceptions are for information subject to a Legal Hold, or pursuant to CDW’s Record Retention Policy.

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Report Suspected Data Incidents Immediately — If you have reason to suspect that the confidentiality, integrity, or availability of Confidential Information has been compromised, such as when it is lost, stolen, disclosed or otherwise accessed by someone without valid authority (known as a “Data Incident”), you must report it immediately. Contact the Security Operations Center (847.371.6015 or ext. 76015) to report a suspected Data Incident. Some examples of Data Incidents include situations in which:

• Your mobile device, portable media or any other device which contains or may be used to access Confidential Information is lost or stolen;

• You are missing Confidential Information once in your possession;

• An unauthorized party may have gained access to Confidential Information; or

• You accidentally sent Confidential Information to the wrong person (whether by email, fax or mail).

Questions Contact the Enterprise Information Management Department (847.371.6068, ext. 76068 or [email protected]) with questions pertaining to Information Security at CDW.

See the Information Security page on Connect for additional details on CDW’s Information Security Program and CDW’s Records Retention Program.

Contact the Ethics and Compliance Office (877.946.0777 or ext. 76160) with questions regarding the reporting of Data Incidents. If you would prefer more confidential and/or anonymous guidance, contact the CDW Ethics Helpline (877.7CDW WAY or 877.723.9929), or the secure online tool located at CDW.ethicspoint.com.

Disciplinary Action As with all our CDW policies, it is important that Authorized Users live up to these requirements. Failure to do so may lead to disciplinary action, up to and including termination of employment or the relationship with CDW, civil action, or reporting to law enforcement officials.

ACCEPTABLE USAGECDW is committed to providing an environment that encourages the use of computers and Information Systems (including CDW’s enterprise network infrastructure, software, information or applications) as essential tools to support the Company’s business while fostering a culture of openness, trust and integrity. In addition to the Information Security at CDW Policy (as well as CDW’s other Information Security Policies) which are designed to ensure appropriate usage of CDW’s Information Systems, the following policy is designed to further outline the acceptable uses of CDW’s Information Systems. This Policy applies to all Authorized Users, which includes any person who is authorized to access Information Systems, including all full- and part-time coworkers of CDW and others (including temporary coworkers, contractors, consultants, business partners, vendors and other third parties).

Responsibilities It is the responsibility of all Authorized Users to comply with the following rules and guidelines for computer usage:

1. Use of the Company’s Information Systems will be governed by the same standards as all other business activities. All Company policies and practices, including those concerning harassment, discrimination and solicitation, and the CDW Way Code, apply fully to CDW’s Information Systems and Authorized Users.

2. Authorized Users are expected to use good judgment in the use of the Company’s Information Systems and should exercise the same restraint and caution in creating electronic messages that they would use in writing formal paper documents.

Unacceptable Uses As further guidance, the activities described below would be considered a violation of this Policy. This list is by no means exhaustive, but instead is an attempt to provide a framework to judge activities that are unacceptable.

1. The use of CDW’s Information Systems to make discriminatory, threatening or harassing statements (whether through language, frequency or size of messages) or to copy, connect, post or download inappropriate material, including but not limited to pornographic material or inappropriate humor.

2. The use of CDW’s Information Systems to engage in activity that is illegal under local, state, federal or international law or contrary to CDW policies or values.

3. The use of CDW’s Information Systems in any activities that may cause embarrassment, loss of reputation or other harm to CDW, its customers or partners.


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4. Sending unsolicited email messages, including junk mail, jokes, chain letters, pyramid schemes or other advertising material to individuals who did not specifically request such material (email spam).

5. Unauthorized use of or altering of email address information.

6. Failure to comply with “Email, the CDW Way” (CDW’s policy governing commercial emails).

7. Providing proprietary information about, or lists of, CDW’s coworkers, customers, email addresses, vendors or product information to parties outside of CDW without proper authorization.

8. Inappropriate or excessive use of the Internet for nonbusiness purposes.

9. Unauthorized use of copyrighted material and/or software, including but not limited to digitization and distribution of photographs, copyrighted music, and the installation of any copyrighted software for which CDW does not have an active license.

10. Illegally exporting software, technical information, encryption software or technology, in violation of international or regional export control laws.

11. Use of hardware and/or software that has not been legally purchased by or licensed to CDW.

12. Revealing your account password to others or allowing use of your account by others. This includes family and other household members when work is being done at home.

13. Circumventing user authentication or security of any computer, network or account.

Questions If you have a question or concern about any issue and whether it is appropriate, please contact your manager or the Enterprise Information Management Department (847.371.6068, ext. 76068 or [email protected]).

Disciplinary Action As with all our CDW policies, it is important that Authorized Users live up to these requirements. Failure to do so may lead to disciplinary action, up to and including termination of employment or the relationship with CDW, civil action or reporting to law enforcement officials.

ELECTRONIC MONITORING

This Policy applies to all Authorized Users, which includes any person who is authorized to access Information Systems, including all full- and part-time coworkers of CDW and others (including temporary coworkers, contractors, consultants, business partners, vendors and other third parties). It covers all of CDW’s enterprise network infrastructure, software, information or applications (“Information Systems”), including Internet, intranet, telecommunications and extranet-related systems. It also covers any equipment owned or leased by CDW and any other equipment (including personal equipment) Authorized Users may use to access, store, backup, relocate or transfer CDW company or customer information or to access Information Systems (“Equipment”). Equipment includes, but is not limited to, electronic and computer equipment and devices, notebooks, tablets, e-readers, CDs, DVDs, storage devices (external hard drives, flash drives, USB drives, etc.), software, operating systems, network accounts providing electronic mail, web browsers, File Transfer Protocols (FTPs), smartphones, desk phones, mobile/cellular phones and any other mobile devices.

CDW Information Systems and Equipment are maintained and made available to Authorized Users for the purpose of conducting CDW business. While you may use Information Systems and Equipment for appropriate, limited, and nonexcessive personal use, subject to CDW policies, you have no right to, and should have no expectation of, privacy in Information Systems or Equipment, your activities on and using Information Systems or Equipment, or information, content, or communications stored on or transferred using Information Systems or Equipment including any personal information. If you “delete” information, content or communications, you understand that CDW may be able to retrieve such information, content and communications, and you have no right to, and should have no expectation of privacy in deleted information.

CDW may, at its sole discretion, monitor your activities, usage, files, information, content and communications on all Information Systems and Equipment at any and all times and with or without notice. Monitoring may include, but is not limited to, accessing, viewing, recording, intercepting, copying, printing, scanning or reading information, content and communications (including, for example, phone calls, VOIP calls and video, voicemails, emails, instant messages and text messages) transferred using or stored on Information Systems and Equipment. Monitoring may also include, but is not limited to, tracking and logging your activities and usage of Information Systems and Equipment, including, for example, your web browsing history and activities. CDW may collect and use biometric data, including, but not limited to, records of your image, voice patterns, fingerprints, handprints, retinal scans and face geometry (“Biometric Data”). CDW’s rights to monitor, perform security scans, and access and retrieve information apply regardless of who owns the applicable Equipment.




CDW also electronically monitors CDW premises and facilities, including but not limited to, monitoring your ID badge activity, using video and audio recording equipment, and using biometric and facial recognition scanning and monitoring technology that collects and uses your Biometric Data, as further described in the Physical Security section of the Road to Success Coworker Handbook.

Nothing in this Policy regarding monitoring of Information Systems and Equipment is meant to limit CDW’s lawful monitoring of your activities, usage, files, information, content and communications on publicly available sites and online services including, social networking accounts and posts.

CDW may provide information or content resulting from monitoring to law enforcement officials. As CDW Authorized Users, you will be expected to fully cooperate with CDW in the administration of the activities described in this Policy. Cooperation may include providing any information, including necessary personal passwords and file locations to the extent permitted by law, needed to locate or access Information Systems or Equipment or information, content and communications stored on or transmitted using Information Systems and Equipment. Additionally, CDW may in its sole discretion wipe or remotely wipe any information or content including any personal information and content on Information Systems and Equipment at any time with or without notice to you.

As with all our CDW policies, it is important that Authorized Users live up to these requirements. Failure to do so may lead to disciplinary action, up to and including termination of employment or the relationship with CDW, civil action or reporting to law enforcement officials.

CONFIDENTIAL INFORMATION

The success of CDW depends in large part on the development, use and protection of Confidential Information. CDW firmly believes that every CDW coworker contributes directly to the success of the enterprise and believes each coworker should have access to all of the information necessary for him or her to perform to the fullest. CDW elects to treat all coworkers as if they are privy to Confidential Information and subject to the rules for insider trading. CDW’s business affairs, particularly Confidential Information and trade secrets, represent important Company assets that each coworker is obligated to protect.

“Confidential Information” means information relating to the present or planned business of the Company, our vendors and our customers, which has not been released publicly by authorized representatives of the Company. This information may include, for example, trade secrets, know-how, inventions, patents and trademarks, copyrights, business development, marketing and sales programs, purchasing manners and methods, the identity and addresses of actual or potential customers, customer and supplier/vendor information, coworker information, compensation information, individually identifiable health information (protected health information, “PHI”), personally identifiable information (“PII”) such as Social Security numbers, driver’s license numbers or state-issued identification card numbers, financial account numbers including credit card or debit card numbers, email addresses, passwords, training programs and materials, pricing information, financial data, regulatory approval strategies, results of investigations, research, testing methodologies and results, certain computer programs, manufacturing methods and processes, technologies and protocols, product development strategies and processes, safety information, programs and protocols, product design and related items used by the Company in its business. It is your duty and obligation to preserve and protect such Confidential Information both during and after your employment with the Company.

All Confidential Information is the property of CDW. Coworkers are to hold it in strictest confidence and not access, use or disclose it at any time, either during or after the coworker’s employment by the Company, to any person, firm or corporation, without the prior written authorization of CDW, except to the extent such disclosure or use is required in the performance of the coworker’s duties for the Company. This includes disclosures via any method of communication, including CDW’s Information Systems. Coworkers are to take all appropriate steps to safeguard Confidential Information in his or her possession at all times.

Coworkers are not at any time, while either employed by CDW or thereafter, to take any Confidential Information that is written, computerized, machine- readable, model, sample or other form capable of physical delivery. To further protect its Confidential Information, CDW does not allow the use of personal cameras (including those in cellphones) at any time on Company property. In addition, upon completion of providing services for CDW, Coworkers will promptly deliver and return to CDW all such Confidential Information in his or her possession, custody or control.

The provisions of this policy apply to CDW’s Confidential Information, as well as any of our vendors’ or customers’ Confidential Information of which you become aware or may access as a result of your employment with the Company.

CDW does not condone nor will tolerate any CDW coworker’s theft, misappropriation or other improper acquisition, disclosure or use of trade secrets or confidential and proprietary information of its competitors or any other person or entity. We expect and require all CDW coworkers to avoid obtaining such information. Just as we require you to protect the Company’s Confidential Information, CDW recognizes that you may have entered into an agreement with a previous employer to protect that employer’s Confidential Information. We expect you to abide fully with any valid aspects of such agreements.

This policy is not intended to interfere with any coworker’s rights under Section 7 of the National Labor Relations Act.



COMMERCIAL EMAILSEmail, the CDW Way (our Commercial Email Policy)

Introduction The U.S. CAN-SPAM Act of 2003 and related regulations place certain restrictions on the use of email in sales and marketing activities. The penalties for noncompliance can be significant, and CDW adopted this Policy to provide coworkers with the information and tools to help ensure we comply with these requirements.

Applicability This policy applies to all emails sent from CDW or on behalf of CDW (note that a separate policy applies to CDW-Canada and emails sent to Canadian recipients and is available on Connect). Coworkers must use good judgment and common sense when sending emails from or on behalf of CDW, and must follow the policy requirements listed below.

Policy

1. All CDW business emails must be sent via CDW systems only — All emails sent by coworkers that in any way relate to CDW’s business must be sent through CDW’s electronic communications systems or through the CDW eCommerce Team using an approved bulk email delivery service provider. Coworkers must not send business-related emails through their personal email service providers or any other unapproved providers. All email delivery service providers must be approved by the CDW eCommerce Team.

2. Email campaigns are restricted to CDW eCommerce — Only the CDW eCommerce Team may engage in the following types of campaigns:

• Joint email marketing campaigns

• “Forward-to-friend” or “Tell-a-Friend” campaigns involving emails

• Collecting or “harvesting” email addresses from websites

• Emails sent to leased or rented lists

• Affiliate marketing programs

• SMS/text messaging campaigns

• Wireless email address campaigns

• SMTP campaigns

All contracts with third parties who send emails on behalf of CDW or sell or rent email address lists to CDW must be handled by the CDW eCommerce Team and approved by the CDW Legal Department. Vendors who provide email delivery and scrubbing services on behalf of CDW must also certify to CDW that they will comply with the CAN-SPAM Act.

3. Use accurate “from” and “subject” lines, and approved email signature blocks — There are legal requirements related to emails considered to be Promotional Emails or Transactional Emails. Promotional emails are emails that primarily advertise or promote services or products or CDW websites, whether or not the emails are meant to promote a specific product or service or website. Transactional emails are emails sent primarily to (i) complete or confirm a transaction which the recipient has already agreed to; (ii) provide warranty, product recall, or safety or security information with respect to a CDW product; (iii) notify the recipient of a change in terms, features or status of an account, or an account balance; or (iv) deliver goods, services, updates or upgrades that the recipient is entitled to based on an existing agreement with CDW. Transactional emails may contain some promotional content so long as all the transactional content comes at the beginning of the message, prior to any promotional content. Both Promotional emails and Transactional emails must include the following elements:

• Accurate “from” line — Email “from” lines must refer to CDW and not be deceptive or misleading.

• Accurate “subject” line — The “subject” line must be clear and must not be deceptive or misleading. For Promotional emails, the subject line must accurately reflect the promotional content of the email and clearly indicate that the email is an advertisement or solicitation — it must not imply or suggest that the message is nonpromotional or include language unrelated to the offer in the email. Appropriate uses of phrases such as “a special offer,” “limited time offer,” or “you might be interested in this offer” are acceptable. The “subject” line of Transactional emails must include language that clearly and accurately indicates that the email is transactional in nature and must not include any promotional content.



• Approved email signature — Promotional and Transactional emails sent to personal distribution lists must include a simple way for the recipient to opt out of, or unsubscribe from, future emails from CDW. To accomplish this, all emails sent to personal distribution lists must include a CDW-approved signature block (available on CDW Connect in the Policy Library, Commercial Email Policy guidance document: Approved Email Signatures), that includes the following elements located clearly at the end of the email:

- Postal address: A valid postal address for the CDW company you work for. Coworkers can obtain the current address for all CDW locations on the CDW website.

- CDW Privacy Footer: Including opt-out instructions as well as a link to the Privacy Policy on CDW.com.

Unsubscribe from Email from Me* | Unsubscribe from CDW Corporate Marketing Email | Privacy Policy The material in this email may not be promotional in nature; however, if you wish to opt out of future promotional emails from me and/or CDW, click the links above. You may continue to receive nonpromotional emails from me and/or CDW.

*Each coworker must customize the “Unsubscribe from Email from Me” link using the instructions included in the Approved Email Signatures document (available on CDW Connect in the Policy Library, Commercial Email Policy guidance document: Approved Email Signatures).

Promotional or Transactional emails sent by CDW’s eCommerce Team must include opt-out/unsubscribe instructions approved by the CDW eCommerce Team and Legal.

4. Promptly honor all requests to opt out of Promotional emails – CDW must promptly honor opt-out preferences from our customers (within ten days). As such, each coworker has the responsibility to honor existing requests prior to sending any Promotional emails, and to process any recipient’s request not to receive Promotional emails. If you receive a request to opt out of Promotional email from you (as opposed to all CDW corporate marketing email), you must:

• Promptly stop sending email and update Outlook contacts/lists: Promptly stop sending the customer Promotional email and remove the customer’s email address from any personal distribution lists in Outlook; and

• Acknowledge the opt out request: Do not try to persuade a customer to stay opted in or ask for additional information other than the email address to opt out.

If you receive a request to opt out of all CDW corporate marketing email, change the customer’s email promotions preference in SPS. If you have any questions or problems with the opt-out process or how to handle a particular opt-out request or complaint, send an email to CDW Email Policy or call ext. 74357, option 2 for help. It is essential that opt-out requests are promptly honored, as failure to do so could lead to penalties and fines.

Opt-out/unsubscribe methods must function for 30 days after delivery of the email – Opt-out links must go directly to the opt-out page and must not include any promotional content, encouragement to remain opted in, require a recipient to take any further action to opt out, or require a recipient to provide any information to opt out, other than the email address the recipient would like to have opted out of CDW’s Promotional emails.

5. Check opt-out lists before sending Promotional emails – Check the CDW email promotional preference in SPS before sending any Promotional emails to a prospective customer or any current customer you have not contacted at least once in the last six months (Transactional emails do not have to be scrubbed against opt-out lists).

6. Individual coworkers must never sell, disclose, transfer, purchase or rent any email addresses without consent of the email-address owner — Coworkers must not use any email addresses obtained or “harvested” (1) from a website or online service operated by a third party that includes a notice that the operator will not sell or transfer email addresses or that restricts collection of email addresses from the site or service; or (2) via an automated means that generates possible email addresses (e.g., by combining names and letters). Additionally, Promotional and Transactional emails sent to multiple customers outside of CDW should not include recipients’ email addresses in the “To:” or “cc:” line, as doing so will disclose email addresses to other recipients — use the “bcc” line instead.

7. Do not send Promotional emails disguised as Transactional emails. Never send Transactional emails that do not relate to an actual customer request or transaction (for example, never send an unsolicited quote).



8. Never use automated means to create multiple online accounts or multiple user accounts or use open proxies or relays to send Promotional emails — Use of scripts or relays is prohibited.

9. Do not send promotional content via SMS/text messaging — Never send promotional content (content that primarily advertises or promotes services or products or CDW websites) via SMS/text messaging to a mobile telephone number.

Questions Questions regarding this policy should be directed to the Extranet Help Desk, by sending an email to [email protected] or calling the CDW Ethics Helpline at 1.877.7CDW WAY (1.877.723.9929).

Disciplinary Action Like all our policies, it is important that coworkers live up to these requirements. Failure to do so could lead to disciplinary action, up to and including termination. Additionally, the penalties for violating the CAN-SPAM Act may include civil and criminal liability.

PARTICIPATING IN SOCIAL MEDIA THE CDW WAY (OUR SOCIAL MEDIA POLICY)Introduction Social media has changed the way we connect and communicate with each other. It allows for the real-time exchange of information to large groups. It’s a means for individual “voices” to travel exponentially in public forums. “Saying” something in social media is just like speaking in public or being quoted in the press — it becomes part of the public record and will be available forever. As a result, coworkers must be aware of the potential risks of participating in social media and must understand and follow CDW’s policies on participation. CDW has adopted this policy to help guide our participation in social media and help address those risks.

Applicability CDW considers social media, as defined today, to be any form of communication over the web, including:

• Blogging • Micro-Blogging

• Posting to Online Video, Presentation and Photo Websites • Posting to a Public Wiki/Encyclopedia

• Participating in Online Forums and Discussion Boards • Participating in Any Social Media Network

Social Media tools continue to evolve, so it is your responsibility to check back regularly to make sure you’re up to date.

The policy applies when you discuss or reference CDW in the following ways via social media:

1. When you discuss or reference CDW, its products or services

2. When you discuss or reference customers and/or business partners

3. When you participate in social media using CDW systems or equipment

This policy applies when you are using social media in a way that indicates you are speaking on behalf of CDW or communicating as part of your job responsibilities at CDW. This policy does not apply to purely personal uses of social media or where it is clear that you are not speaking on behalf of CDW or as part of your job at CDW.

Policy You must use good judgment and common sense and adhere to the principles below whenever participating in social media in a manner covered by this policy. Additionally, if you wish to create a CDW-branded account, you need to contact the CDW Social Media Team (email [email protected]) to obtain approval. A CDW-branded account is any social media account that includes the word “CDW” in the handle of the account (i.e., @CDWCorp or @CDW_Collab). Only accounts associated with CDW workgroups (i.e., solutions, segments, regions, etc.), with pre-approval from the CDW Social Media team, can have a branded account.

CDW-branded accounts are considered CDW assets. Individual CDW coworkers shall not create CDW-branded accounts, pages, etc. on social media platforms. You must also provide the CDW Social Media team with your account credentials. This is required in the event you change roles and/or responsibilities within CDW or leave the company entirely.

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As part of CDW’s social media best practices, coworkers are not, under any circumstances, to create social media accounts for one-off events, such as conferences, meetings, webinars and other events. Before you create a CDW social media account, you must contact the CDW Social Media team.

CDW’s Social Media Principles

1. Understand and Follow CDW’s Values and Standards — When you participate in social media, you are held to the values and standards set forth in The CDW Way Code (our code of business conduct and ethics), our External Communications Policy and all other company policies. Make sure you are familiar with and follow the guidance in these documents as you participate in social media. Remember, you are personally responsible for the content of your postings on social media. You can find the aforementioned policies at the CDW Policy Library.

2. Be Transparent. Let People Know You Work at CDW — When participating in social media in a manner covered by this policy, you must clearly identify yourself and your affiliation with CDW. If you have a vested interest in something you are discussing, be specific about what it is. For example, never pretend to be a consumer praising CDW or its products or services via social media. Not only is it dishonest, but it could be illegal.

3. Don’t Pay to Play — Don’t pay for or give a gift to a third party who submits posts discussing CDW and its products or services. The Federal Trade Commission (FTC) regulates these types of arrangements and additional requirements will apply.

4. Speak for Yourself — Make it clear that you are speaking for yourself and not on behalf of CDW or its partners. Include the following statement in your profile: “The opinions I share are my own.” Unless you are specifically authorized to speak on behalf of a group, write in the first person (“I” and “my” rather than “we” and “our).

5. Be Honest, Accurate and Positive — When you share content on social media, be honest and accurate. Do not make statements unless you know they are true. Focus on providing positive, helpful information. Avoid making or repeating negative comments. Do not speculate or deal in rumors. When it comes to our competitors, play nice. Don’t slam the competition.

6. Don’t Share Secrets — Do not post any confidential information concerning CDW, CDW’s coworkers, customers, partners or other business partners. As a publicly traded company, it is very important that you never post information regarding CDW’s financial performance or items that may have or be perceived to have an impact on our financial performance. As detailed in the External Communications Policy, only authorized individuals are permitted to discuss CDW’s financial performance and other material, nonpublic information. Examples of this include:

• Revenue and Profit Numbers • Company Projections and Strategic Plans• Mergers and Acquisitions • New Major Contracts/Customers• Loss of Major Contracts/Customers • Significant Changes in Products or Product Lines• Litigation • Changes in Senior Management

Do not post pricing, spiff or promotional information other than what can be viewed publicly (prior to login) on our websites. If you have any doubt whether information is confidential – assume that it is and don’t post it.

7. Respect Other People’s Stuff — If you want to use information posted on another site in one of your social media posts, don’t just copy it — include a link to it. Do not post trademarked, copyrighted or other protected information of others. This includes the logos and associated intellectual property (IP) of CDW and our partners. It’s important to remember that just because something is posted online doesn’t mean it’s free to use without the owner’s permission or proper credit. If you aren’t sure if something is protected – don’t use it.

8. Respect Others — Don’t include disparaging remarks, slurs or obscenities in your social media posts. Don’t include pornographic material. Show proper respect for topics that may be considered objectionable or inflammatory — such as religion or politics. Communicate as you would if in a face-to-face conversation with someone. Remember that your social media conversations are open for all on the Internet to see.

9. Add Value — Add something meaningful to the conversation. Provide worthwhile information and perspective. Make sure the content you provide is relevant to community members. And be responsive. If someone responds to something you’ve said, follow up quickly (e.g., 24 hours). It helps to monitor for mentions of you to avoid any issues. If you say something inaccurate, don’t take down your post. Admit you made a mistake and provide an update with the correct information.

10. Remember Your Day Job — You want the time you spend on social media to be time well spent. Make sure your manager is supportive of any social media activities you participate in during business hours. Remember that your audience may include your customers and colleagues, so present yourself in a way that will further your personal brand.

11. Think Before You Click — Proofread what you write before you post it. Once you click “submit” or “post”, it will be available permanently for anyone to see. This includes any links you may include in your posts. Make sure you use common sense and apply good judgment to everything you post.



Sharing Photos and Videos on Social Media When it comes to social media, one of the most common activities is to share photos and videos on social media platforms. As a coworker, if you are going to share a photo and/or video on social media, then you need to be aware of the contents of the photo or video. If the photo and/or video contain confidential information concerning CDW, CDW’s coworkers, customers, partners or other business partners, you cannot share that photo online for public consumption. It’s also your responsibility to ensure that anyone included in your photo and/or video has given permission to share their image online.

As social media continues to evolve, there are new apps, like Meerkat and Twitter’s Periscope, that allow for users to live-stream videos from their social media accounts. While these apps allow for real-time sharing of events, they also present several challenges. By following these guidelines, you will help protect yourself from legal liability

• Let people in the area know you are live-streaming an event to your social network(s). This will allow people who don’t want to be filmed to avoid your shot.

• Frame your shots carefully and control the situation. Shoot your footage in a controlled environment. There could be images for rival brands in the background or copyrighted songs playing in the background. When you are shooting live footage, anything can happen and become a part of the live-stream.

• Err on the side of caution. When in doubt, don’t do it. While sharing something in real time may seem exciting, the consequences may outweigh any short-term benefits of live-streaming.

Disciplinary Action Like all our policies, it is important that coworkers live up to these requirements. Failure to do so could lead to disciplinary action up to and including termination.

Questions Contact the CDW Social Media Team or call the Ethics and Compliance Office at 847.419.6160. If you’d prefer more confidential and/or anonymous guidance, contact the Ethics Helpline at 1.877.7CDW WAY (1.877.723.9929) or via the secure online tool located at CDW.ethicspoint.com.

OTHER POLICIESCDW maintains many other policies, including but not limited to the following, which coworkers are responsible for reviewing and ensuring that they understand:

• External Communication and Disclosure Policy — CDW’s Disclosure Policy limits who is authorized to speak with the media, government officials and other third parties on behalf of the Company.

• Corporate Travel and Expense Policy — CDW’s T&E policy outlines processes and procedures for approved business travel and for approved expense reimbursement.

These policies, and others, are available on the Company’s policy library found on The CDW Way Information Center page, which can be reached via the “Values, Standards and Policies” quicklink on the Connect home page. The policies typically list a resource available to assist with any questions, and Coworkers are responsible for utilizing those resources to address any questions they may have. If it is ever not clear who can help with a question,

Coworkers should contact their Coworker Services Business Partner or at 1.877.7CDW WAY (1.877.723.9929) or via the online system found at CDW.ethicspoint.com.

MKT8904 | February 2016



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