Prevent Improper Payments

CDW does not buy business, nor is our integrity for sale. We prohibit the payments of bribes and kickbacks of any kind, whether in dealings with government employees or individuals in the private sector. CDW complies with the United States Foreign Corrupt Practices Act, the U.K. Bribery Act of 2010 and the applicable anti-corruption and anti-money laundering laws of all of the countries in which we do business. 

Making or accepting improper payments subjects both the Company and the individual(s) involved to possible penalties.

How IT's Done ...

  • Never authorize, offer, make or accept an improper payment, such as a bribe or kickback, for any reason.
  • Never hide or try to hide a payment, improper or otherwise.
  • Comply with CDW’s due diligence processes and procedures before entering into agreements or working with third parties.
  • Oversee the work of third parties carefully.

The CDW Way

The CDW Way icon design involving three interlocking rings with a solid center circle.

It is never OK to pay or take a bribe or a kickback. You will not suffer adverse consequences for refusing to pay or take a bribe or kickback, even if it results in the loss of business to CDW. 

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Make the Connection

Remember that a payment is considered improper, no matter the value, if it is offered in an attempt to influence the recipient’s actions. Bribes can come in all shapes and sizes and do not just take the form of cash. Here are some other examples of bribes: offers to provide references, offers to use vacation homes and the promise of future favors. 

CDW also prohibits “facilitation payments” or payments which are paid to an official to prompt them to do their job. If you receive a request for a facilitation payment, contact one of your Ethics and Compliance resources immediately.


For more information, visit the resource link below:

Anti-Corruption Policy