Description of the Program

The Code of Ethics for Tech Data Corporation and its subsidiaries is the central feature of the Ethics and Compliance Program. This program explains our fundamental values and shows our associates how to make decisions based upon these values. 

The goals of the program include: 

• Informing associates of the company’s expectations for proper business conduct 
• Providing instruction on relevant laws, regulations and policies affecting associates’ activities 
• Implementing a process for addressing issues and questions involving appropriate business conduct 
• Providing a confidential outlet for associates to report suspected violations of business conduct without fear of retaliation 

Ultimately the reputation and success of Tech Data depend on the individual and collective integrity of its directors, officers, associates and all parties who represent Tech Data around the world. This Code is applicable to all associates and any representative, agent or consultant acting on behalf of Tech Data. 

Our company is ever-changing and operates in a dynamic industry. We cannot anticipate all issues. This Code does not contain answers to every issue or question you may encounter as part of your employment. It is a guide to help you resolve ethical questions, to be read as consistent with the laws and standards of the places in which we do business. As an employee you have a responsibility to ask for assistance when you have questions regarding your own behavior or the behavior of others that appears to violate this Code. In many respects good business ethics is just good business sense. 

Members of management have a special responsibility to follow and support the standards of the Code in word and action. Management is expected to practice an open-door policy by being available to anyone with ethical concerns or questions. The company maintains several confidential communication avenues for raising questions or reporting violations: the "Open Up" forms, "Ask The CEO" on TDnet, the Director of Ethics and Compliance, and an anonymous "Ethics Reporting Hotline" that any employee may call to report their concerns. Employees will not suffer retaliation for raising good faith concerns, questions or complaints. 

The Code will be enforced in the same way at all levels throughout the organization.