Additional Resources

If you have questions about the Ethics Line and how it fits at TD SYNNEX, we have prepared the following resources to help.

FAQs

About the TD SYNNEX Ethics Line

What is the Ethics Line?

The Ethics Line is a confidential reporting channel created by NAVEX to help to report any suspected violation of the TD SYNNEX Code of Conduct, TD SYNNEX policies or applicable laws.

Why do we need a system like the Ethics Line?

TD SYNNEX is committed to acting with integrity and promoting an ethical culture. The Ethics Line reinforces that commitment by providing a channel for current and former co-workers, candidates, board members, and any third-party doing business with or acting on behalf of TD SYNNEX to submit reports 24 hours a day, 365 days a year.

What is the TD SYNNEX approach to reporting and investigations?

TD SYNNEX expects our co-workers and business partners to speak up when they have concerns about illegal behavior or misconduct in our community. We comply with whistleblower laws everywhere we do business, and we strive to maintain a speak up culture where everyone is empowered to be ethical leaders.

To ensure everyone in our broader community is prepared to initiate a report when needed, we publish our internal Speak Up and Non- Retaliation Policy externally for everyone to see. You can find a copy on our TD SYNNEX Governance Page.

The Ethics Line Reporting Process

May I report using either the Internet or the telephone?

Yes. With the Ethics Line, you have the ability to file a confidential or anonymous report via either the telephone or the Internet.

What type of situations should I report?

The Ethics Line system is designed for reporting any suspected violation of the TD SYNNEX Code of Conduct, TD SYNNEX policies or applicable laws.

If I see a violation, shouldn't I just report it to my manager or HR and let them deal with it?

When you observe behavior that you believe violates the TD SYNNEX Code of Conduct, TD SYNNEX policies or applicable laws, we expect you to report it. We’ll listen, and we’ll take action to help. You can talk to your manager, your leadership team, HR, Legal, a local Ethics Advisor, or our Ethics and Compliance department. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. That is why the Ethics Line exists. If you don’t feel comfortable sharing information directly, we would rather you report anonymously than keep the information to yourself.

Why should I report what I know? What’s in it for me?

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct hurts individuals and can also threaten the livelihood of an entire company if left unaddressed.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the Ethics Line secure server to prevent any possible breach in security. The Ethics Line makes these reports available only to specific individuals within the company who are tasked with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every web-site that my PC connects with. Won’t this log identify me as a report originator?

The Ethics Line does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to the Ethics Line is available. In fact, the Ethics Line is contractually committed not to pursue a reporter’s identity, which is why it is so important that you keep track of your own reporting key and password for following-up on any reports you create.

If you feel uncomfortable making a report on your work PC, you can always report by phone.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the Ethics Line system strips away Internet addresses so that anonymity is totally maintained. Plus, the Ethics Line is contractually committed not to pursue a reporter’s identity.

I am concerned that the information I provide the Ethics Line will ultimately reveal my identity. How can you assure me that will not happen?

The Ethics Line system is designed to protect your identity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jane Smith…” or “In my 33 years…”.

At TD SYNNEX, we have zero tolerance for retaliation. We need to hear from you when you have concerns, and we will protect you from retaliation when you speak up for what you believe is right.

Is the telephone toll-free hot line confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the Ethics Line site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish.

Where can I find information about how TD SYNNEX processes my personal data?

If you decide to share your personal data in the context of your report, we will process such personal data as outlined in the Ethics Line Privacy Notice which can be found at the end of this Q&A document.

What if I want to withdraw my consent?

By submitting your personal data as part of reporting a concern using the Ethics Line website or hotline you agree with and consent to TD SYNNEX processing your personal data as outlined in the above TD SYNNEX Privacy Notice and the General TD SYNNEX Privacy Statements. You can withdraw your consent for the future by sending an email to ethicsandcompliance@tdsynnex.com

Do I have any other options to report?

We do encourage you to report your concerns to us through the Ethics Line or any of our other reporting channels. At TD SYNNEX, we are committed to review and manage all reports in a confidential and professional manner, and determine the appropriate action. However, information about external reporting options is available here.

Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

TD SYNNEX expects our co-workers and business partners to speak up when they have concerns about illegal behavior or misconduct in our workplace. All unethical conduct, at any level, ultimately hurts the company and everyone in our TD SYNNEX community. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So, if you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and the TD SYNNEX community to report it.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. The Ethics Line can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

You don’t need to know all the details before you can speak up. Your only obligation is to be honest and to participate in the investigation as needed. This is known as a good-faith report. If your concerns aren’t substantiated, that’s okay. We still appreciate your genuine desire to help, and we’ll still protect you from retaliation.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The Ethics Line system and report distribution channels are designed so that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report on the Ethics Line Web site or through the Ethics Line Call Center, you receive a unique reporting key and are asked to choose a password. You can return to the Ethics Line system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into a “confidential dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All Ethics Line correspondences are held in the same strict confidence as the initial report.

Ethics Line Privacy Statement