ETHICS/CODE OF CONDUCT

Rexel Group Ethics Guide

The Ethics Guide reflects the Rexel Group's commitment to high ethical standards in whatever country the Rexel Group conducts business.

Rexel USA, Inc. Code of Conduct

The Code is based on the Ethics Guide and sets forth the compliance obligations that apply to Rexel USA, Inc. and its subsidiaries and their respective employees and businesses.  The Code includes Compliance Policies  and key Ethical Responsibilities applicable to all Company Employees and to Business Leaders.

California Transparency in Supply Chains Act of 2010 Disclosure

This attachment sets forth the Company's disclosure required by the California Transparency in Supply Chains Act of 2010.

How to Raise A Compliance Concern

This summary explains how any person, whether a Company employee or third party, can raise a compliance concern or question to the Company's ombudsperson.