Conclusion and Resources

ACTING WITH PROFESSIONAL AND SOUND JUDGMENT

Never Trade on Inside Information

You may become aware of inside information or material nonpublic information about our Company, other companies or our industry in general. We do not trade in securities based on inside information.

How IT's Done ...

Never trade in securities based on inside information.
Never “tip” others who might make an investment decision based on inside information.
Contact the Legal Department if you have questions about whether a transaction would be appropriate given the information you possess.

The CDW Way

Providing inside information is not always as simple as offering a stock tip. For example, if someone calls you and asks you to provide insight about the industry and offers to pay you for consulting time, this could be considered inside information and may expose you and CDW to legal liability. Consult with the Legal Department for help in determining whether something could be considered inside information.

Make the Connection

Inside information is any information about CDW or another company that has not reached the public but would likely be considered important by investors in deciding whether to buy, sell or hold their stock.

Examples include news about CDW’s financial results before the news is formally released; planned acquisitions; planned reorganizations; unreported sales results; planned actions regarding CDW’s stock; and unannounced senior management changes. Inside information also includes nonpublic information about other companies that any coworker receives in the course of their employment at CDW — including nonpublic information about customers, vendors, suppliers and other business partners.

For more information, visit the resource link below:

Insider Trading Policy