Standards of Conduct and Ethics Policy

Zones, LLC and its affiliates ("Company") have established this Standards of Conduct and Ethics Policy ("Policy") to ensure that the rights of the Company, the Company's officers, directors, and employees (together, "Team Members"), and third parties with whom the Company works, including without limitation the Company's customers, service providers, suppliers, vendors, subcontractors, and agents, (together, "Third Parties") are respected. Furthermore, the Company is committed to procuring information technology hardware, software, and services for its customers from a legal and ethical supply chain. Third Parties, and all parties with whom such Third Parties interact, including but not limited to Third Parties' subcontractors, must at all times comply with this Policy and applicable laws, rules, and regulations. Third Parties are expected to have written policies in place and shall provide copies of them to Company upon request for each of the categories listed below, encompassing, at a minimum, the requirements set forth in each section. To the extent that other Company and/or third-party policies and procedures conflict with this Policy, this Policy shall control.

Corporate Citizenship

The Company is committed to doing the right thing, and the reputation, integrity, and success of the Company are based on the honest and ethical conduct of its Team Members and Third Parties. Accordingly, it is important that each Third Party understand the basic principles from which the Company operates:

• Always be truthful.
• Adhere strictly to the letter and the spirit of the law.
• Strive to provide exceptional customer service.
• Be a good corporate citizen.
• Work to promote and sustain a work environment that fosters mutual respect, openness and integrity.
• Be fair in all aspects of the Company's business.

Business Ethics

Conduct that may be disruptive, unproductive, unethical, or illegal will not be tolerated. This Policy does not cover every issue that may arise, but it outlines basic principles about the expectations of the Company for the conduct and ethics of Third Parties.
The following is a non-exhaustive list of conduct that may violate this Policy:

• Falsifying records.
• Engaging in fraud.
• Removing property or data of Company or a third party from any premises, devices, and/or systems without authorization.
• Stealing or attempting to steal property or data of Company or any third party.
• Being habitually tardy or absent.
• Engaging in poor timekeeping, including without limitation failing to log time or inaccurately logging time.
• Fighting or aggressive conduct.
• Being under the influence of intoxicating substances while interacting with the Company or while performing under a contract with Company.
• Using or abusing property, materials, data and/or equipment of Company or a third party without authorization.
• Gambling on premises of Company or a Third Party or utilizing equipment of Company to engage in gambling at any time.
• Sleeping on the job.
• Using offensive or profane language while interacting with Company or while performing under a contract with Company.
• Bringing weapons onto the premises of Company or a Third Party.
• Threatening Company Team Members or any third party.
• Defacing property of Company or a third party.
• Engaging in criminal activity.
• Violating or abusing policies of Company or a third party applicable to Third Party's performance.
• Neglecting and/or failing to perform job duties.
• Bringing the Company into serious disrepute.

The Company may consider a Third Party's performance, prior violation(s) of Company or any Third Party policy, procedures and/or rules, and other relevant circumstances in determining whether to take any action against a Third Party hereunder.

Compliance with Laws, Rules and Regulations

The Company is committed to compliance with all applicable laws, rules and regulations, and it requires all Third Parties to conduct business in accordance with the letter, spirit and intent of all relevant laws, rules, and regulations in all countries in which they and their related entities operate and to refrain from any illegal, dishonest, fraudulent or unethical conduct. Third Parties must conduct its business in compliance with all laws regarding employment, wage, and labor rights and will align with the standards set forth in the Responsible Business Alliance ("RBA") Code of Conduct. Third Parties must familiarize their employees with the basic legal requirements that pertain to such employees' duties and responsibilities.

Human Rights

The Company respects the fundamental human rights of all people, and Company expects that Third Parties will do the same. The Company is committed to a work environment and supply chain that is free from discrimination, harassment, human trafficking, child labor, slavery, and related activities. The Company will not tolerate any activities that support or contribute to discrimination, harassment, human trafficking, child labor, slavery, or related activities, and Company will take steps to ensure compliance with all applicable laws and regulations.

Health and Safety of Workers

The health, safety, and well-being of workers are important priorities of the Company. Third Parties must implement effective health and safety management practices within their business and as part of their daily business operations. Third Parties shall abide by all applicable laws, regulations, and reporting requirements relating to the safety and health of all workers.

Antitrust

Third Parties shall not: (1) fix prices or rig bids with competitors; or (2) exchange current, recent, or future pricing information with competitors.

Anti-Corruption

Third Parties shall not engage in any activity that involves bribes, kickbacks, and/or similar payments ("Improper Payments"), and Third Parties shall never accept or offer any Improper Payments. Facilitating payments (payments made to expedite or secure performance of a routine governmental action like obtaining a visa or customs clearance) are also prohibited, although personal safety payments where there is an imminent threat to health or safety are allowable. Third Parties shall comply with all applicable anti-corruption laws, including without limitation, the Foreign Corrupt Practices Act and the United Kingdom Bribery Act. This section shall apply at all times and even if local law permits any prohibited activity.

Counterfeit Parts

Third Parties must develop, implement, and maintain methods and processes appropriate to their products to minimize the risk of introducing counterfeit parts and materials into products. Third Parties shall have effective processes in place to: (1) detect counterfeit parts and materials; (2) provide notification to recipients of counterfeit product(s) when warranted; and (3) and exclude them from the product.

Media

Third Parties are solely responsible for online posts made by or on behalf of such Third parties or by their agents or personnel. Third Parties should not speak about the Company to the media or in any public forum without advance written consent from the Company's vice president of marketing.

Trade Regulations, Embargoes, and Sanctions

Third Parties shall comply with all applicable trade, economic, and import laws and regulations, including without limitation, sanctions and embargoes applicable to jurisdictions in which they do business. The Company complies with international economic sanctions and embargoes restricting persons, corporations, and foreign subsidiaries from doing business with certain countries, groups, and individuals.

Anti-Boycott Laws

The laws of the United State and many other countries prohibit persons from taking actions or entering into agreements that have the effect of furthering any unsanctioned boycott of a country. Third Parties must comply with all anti-boycott laws applicable in the jurisdictions in which they do business.

Conflict Minerals

Third Parties must determine if their product(s) contain conflict minerals (i.e. tin, tantalum, gold, tungsten, etc.) and if so, such Third Parties must implement supply chain due diligence processes to identify sources of these minerals. Third Parties must also support efforts to eradicate the use of conflict minerals which directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries.

Political Contributions and Charitable Donations

Third Parties shall not make any type of political contribution and/or charitable donation on behalf of Company.

Unauthorized Lobbying

Third Parties shall not undertake any type of lobbying or other similar representative efforts on behalf of the Company without the advance written consent of the Company.

Data Protection & Disclosure of Information

Third Parties must, at all times, protect Company and any Third Party information, electronic data and intellectual property ("Data") with appropriate safeguards and may utilize such Data only within the scope of the Third Party's business relationship with Company. Any transfer of Data must be executed in a way that secures and protects such Data. Third Parties may receive confidential Data only as authorized by a confidentiality or non-disclosure agreement ("NDA") and must comply with such Third Party's obligations in such NDA. Third Parties shall comply with all applicable data protection and security laws and related regulations, in particular with regard to personal data of Zones and any Third Parties, including without limitation Zones customers.

Violations of this Policy

Third Parties must immediately: (1) notify the Company of any violation of this Policy; and (2) remedy any violation of this Policy. A violation of this Policy, including without limitation, a failure to immediately take action to remedy or report a violation may lead to corrective action and/or termination of Company's business relationship and/or contracts with such Third Party. In addition to taking its own actions, the Company may also bring suspected violations of law or regulation to the attention of the appropriate law enforcement personnel. The Company may audit a Third Party to confirm such Third Party's compliance with this Policy, and such Third Party shall fully and timely cooperate in such audit.

Conduct Not Prohibited by This Policy

This Policy is not intended to preclude or dissuade Third Parties from engaging in legally protected activities.

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