Circuit City 2009 Annual Report Download - page 124

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Exhibit 14
SYSTEMAX INC.
CORPORATE ETHICS POLICY
(REVISED MARCH 2010)
The Corporate Ethics Policy of Systemax Inc. (the “Company”) was prepared to provide the directors, officers, employees and other
representatives of the Company and its subsidiaries (collectively “Company Representatives”) as well as the Company’s shareholders,
customers, suppliers and the general public with a statement of the Company’s commitment to ethical business conduct. This Corporate Ethics
Policy applies to the Company and all of its subsidiaries on a worldwide basis. The Company is committed to acting as a responsible and ethical
corporate world citizen. Company Representatives will conduct Company business with the highest regard for the Company’s ethical and legal
obligations and with the utmost loyalty to its shareholders and customers. It is the duty of all Company Representatives to see that these policies
are followed. Every Company Representative is expected to comply with these policies. Failure to do so may not only harm the Company and
your fellow employees, it will subject you to disciplinary action, including termination of employment under appropriate circumstances.
Summary of Duties for All Company Representatives:
•
Avoid conflicts of interest and potential conflicts of interest between you and the Company.
•
Do not offer or make gifts to customers (unless not of excessive value and unless for a business purpose of the Company). Cash or
cash equivalent gifts of any value are absolutely prohibited.
•
Do not offer or make gifts or payments to or otherwise attempt to bribe or unfairly influence a government official.
•
Do not accept gifts from suppliers, service providers, customers or competitors (unless not of excessive value). Cash or cash
equivalent gifts over $100 are absolutely prohibited.
•
Do not compete with the Company or take personal advantage of Company business opportunities, or have significant interests in
companies the Company does business with.
•
Do not waste or misuse Company assets.
•
Keep all non-public Company information confidential.
•
Deal with all customers, suppliers and competitors fairly.
•
Comply with all laws and government regulations in all countries where the Company does business including laws against non-
competitive practices (antitrust laws), insider stock trading, employment discrimination, bribery and other foreign corrupt practices,
workplace safety laws and export/customs laws.
•
Disclose and record accurately any use of Company funds.
•
Do not falsify, inflate or disguise any accounting record or other business records of the Company.
•
Report all violations of law and/or Company Ethics Policy to appropriate Company officials (see Section 11 below) or to the
Company’s Anonymous Complaint Hotline (see Section 12 below).
Policies:
1.
Loyalty to the Company and its Shareholders:
Company Representatives owe a duty of loyalty to the Company and to its shareholders. The duty of loyalty includes both a duty to protect the
interests of the Company and an obligation to refrain from business conduct that would injure the Company and its shareholders.