Anixter’s Policy

Anixter takes a ZERO tolerance approach to bribery and other forms of corruption, and is committed to acting professionally, fairly, with integrity and in compliance with all applicable anti-bribery and corruption laws wherever it operates.

Your Responsibilities
Anixter expects and requires its suppliers, contractors, integrators, resellers, channel partners, consultants, professional advisors, joint venture partners, custom brokers, freight forwarders, sales agents, and any other parties with whom Anixter does business (“Business Partners” or “you”) to act professionally and ethically at all times in carrying out their services and contractual obligations to Anixter or on Anixter’s behalf to an Anixter customer or any other third party. As a Business Partner, you represent and agree to the following:
1. Compliance with laws. You will comply with all applicable anti-bribery and corruption laws, including, but not limited to, the Foreign Corrupt Practices Act (“Laws”) and will not take any action or permit the taking of any action that may render Anixter liable for a violation of Laws.
2. Improper Payments. You will not promise, offer, give, authorize, request, agree to receive or receive “anything of value” (defined below), directly or indirectly, to or from anyone (including any Public Official or an employee of a commercial enterprise), to improperly influence the behavior of such person for the purpose of assisting Anixter in obtaining or retaining business or securing an improper advantage (e.g., obtaining a contract getting taxes reduced, laws changed, imports cleared, telephone/electricity connected, or permits obtained to conduct business).
3. Facilitation Payments. You will not make facilitation payments on behalf of Anixter to secure or expedite any routine government actions by Public Officials.
4. Meals, Entertainment and Gifts to/from Public Officials. You will not promise, offer, give, authorize, request, agree to receive or receive anything of value to or from any Public Officials anywhere in the world on behalf of Anixter. Anything of value given to a third-party (e.g., family member, significant other, friend, charity, political party) designated by a Public Official with whom Anixter has a potential or existing business relationship, is considered given directly to the Public Official.
5. Meals, Entertainment and Gifts to Persons who are not Public Officials. During the course of performing services on behalf of Anixter, you may promise, offer, give, authorize, agree to receive or receive, anything of value to or from a person who is not a Public Official only if:

a. It is not in the form of cash or cash equivalent (e.g., gift cards, stock, etc.);
b. It is not requested by the recipient or by a third-party on behalf of a recipient;
c. It complies with local law;
d. It complies with the rules and policies on gifts and hospitality of a recipient’s organization;
e. It is pre-authorized by Anixter in writing; and
f. It complies with the other provisions of this Policy.

6. Books & Records. You will keep and maintain books, records and accounts that accurately and fairly reflect the disposition of Anixter’s assets and all transactions that you conduct on behalf of Anixter.
7. Affiliation with Public Officials. If you are a Public Official, or if an officer, director, employee or agent of your business is a Public Official, you are required to immediately disclose this affiliation to Anixter in writing prior to engaging in business with Anixter.
8. Conflicts of Interest. If your family member, or the family member of one of your owners, officers, directors, employees or agents, are related to a current Anixter employee or an agent acting on Anixter’s behalf, you are required to immediately disclose this relationship to Anixter in writing prior to engaging in business with Anixter. For purposes of this paragraph, a family member includes a parent, spouse, sibling, son, daughter, mother-in-law or father-in-law, or brother/sister-in-law.
9. Concerns. You agree to immediately report to Anixter any concerns you may have regarding any unethical or illegal business practice by any Anixter employee or Business Partner by emailing ethics@anixter.com or by using the Anixter Business Integrity Line. See www.anixter.ethicspoint.com for details.

Definitions

“Anything of value” covers just about any form of benefit, which includes, but is not limited to, money, gifts, hospitality, meals and entertainment, tickets to events, promotional expenditure, expenses, services or personal favors, loans, employment offers or promises of future employment, or political or charitable contributions.
“Public Official” is a broad term which includes:
1. An employee, officer, official of, or consultant to:

a. A government at national, state, regional, provincial or local level;
b. A government agency, public authority or other public body;
c. A state-owned or state-controlled enterprise;
d. Groups with special status such as Native American tribes or nations in the US; or
e. An international public organization (e.g, the United Nations or the European Union), and their agencies and other related bodies; or

2. A politician at any level of government, whether they hold political office or not, political candidates, political parties and anyone working for them; or
3. Members of royal or other ruling families.

Termination

Failure to follow this Policy can result in termination of your business relationship with Anixter.

ANIXTER RECOMMENDS THAT ITS BUSINESS PARTNERS READ THE OVERVIEW “UNDERSTANDING ANIXTER’S BUSINESS PARTNER ANTI-CORRUPTION POLICY” IN ORDER TO GAIN A BETTER UNDERSTANDING OF ANIXTER’S BUSINESS PARTNER ANTI-CORRUPTION POLICY. WE PROVIDE THIS OVERVIEW FOR GENERAL INFORMATIONAL PURPOSES ONLY.