Standards, Policies and Laws

Conflicts of Interest 

A conflict of interest occurs when personal interests interfere with your ability to act or make decisions consistent with the best interests of the company. Associates, officers and directors must avoid conflicts of interest and the appearance of a conflict whenever possible. A conflict of interest can occur through a wide variety of circumstances and only a few of the more common situations are described below. If you think you may be in a conflict of interest situation you should disclose the details in writing to your supervisor who shall forward it to his/her vice president for a decision. The vice president will report his or her decision to corporate Human Resources and the General Counsel. Any conflict of interest involving a vice president or higher should be forwarded to Internal Audit and the General Counsel. From there, the suspected conflict shall be reported to the Audit or Governance Committee of the Board of Directors for resolution.

Outside Employment and Activities

Associates may not work for any competitor, customer, distributor or supplier, or companies seeking to be such. Regular, full-time associates may not hold jobs with other employers or engage in outside business – including self-employment or other activities – that adversely affect their job performance or the company's interests. Associates may not work or solicit work for other companies using company assets or while on company time or premises. Officers may not serve on the board of directors of any for-profit entity without the prior approval of the company's Chairman and Chief Executive Officer.

Financial Interests

Associates, officers and directors may not have a financial interest – directly or indirectly – in any competitor, customer, supplier or distributor. This limitation does not prohibit the individual ownership of a non-material interest in a company's publicly traded securities. The extension of credit, or arranging for such extension by the company to executive officers or directors for personal reasons, is prohibited.

Corporate Opportunities

Officers, directors and associates have a duty to advance the interests of the company whenever the opportunity arises. If, in the course of association with Tech Data, they learn of an opportunity that will benefit Tech Data, they should disclose the information to the proper person within the company. Officers, directors and associates should not take for themselves, or any other entity, the benefit of an opportunity without first allowing the company to consider such opportunity.

Gifts and Entertainment

The offer and receipt of gifts and entertainment are an accepted practice to establish and foster valuable business relationships. However, we must exercise good judgment in this practice. Gifts and entertainment are broadly defined to include physical articles, events, trips, services, benefits and other things of value. Gifts may be infrequently exchanged with business associates as long as all gifts and loans of product are in accordance with company policy. Meals, entertainment or social functions should have a legitimate business purpose and a value deemed to be reasonable, customary and proper under the circumstances. Avoid gifts or entertainment that cannot be reciprocated, carry a business obligation, or cause embarrassment to you or the company. Other than inexpensive promotional items with a company's logo, no gifts or entertainment should be offered to government representatives.

Community and Political Activities

Associates are encouraged to be involved with their community, government and charitable organizations. Tech Data observes all laws relating to political activity. The company will not contribute money nor permit use of its assets for any political purpose without the express approval of the Chairman and Chief Executive Officer. With their manager's prior approval, associates may participate in charitable events on company time or with company assets.