Ethics and Compliance Program

The Xerox Ethics and Compliance Program is an integral part of our daily business operations and practices. Conducting business with the highest degree of ethical integrity is the job of every employee at Xerox. To facilitate this commitment to integrity we have:

• A global, written code of business conduct available in 19 languages

• A supplemental code of conduct for finance employees

• A specific code of conduct for the board of directors (PDF, 40KB)

• A dedicated Xerox Ethics Helpline to receive questions and complaints, which is accessible from anywhere in the world at any time, and a strictly enforced non-retaliation policy to promote comfort in using the Helpline. Please see How to Contact the Xerox Ethics Helpline (translated into 19 languages) for additional information regarding reporting ethics and compliance concerns.

• The Business Ethics Office tracks all cases from initial reporting to closure, case activity and trends, including the number of matters reported, case categories, outcomes and disciplinary action taken. See Matters Reported to the Business Ethics Office for case trending information.

• An Ethics & Compliance Governance Board comprised of senior executives representing all areas of Xerox business

• Annual global communication of business ethics policy and CEO message on ethics and integrity

• Code of Conduct training required of all employees, including senior management

• An annual ethics certification process that includes all senior managers and officers

The Xerox Ethics and Compliance Program is overseen by the Audit Committee of the Board of Directors. Business Ethics Office is responsible for Xerox’s Ethics and Compliance Program and is led by the Xerox Chief Ethics Officer who also serves and the Chief Legal Officer and Corporate Secretary. The Business Ethics Office has ongoing reporting responsibilities directly to the Audit Committee and our Chief Legal Officer, Corporate Security and Chief Ethics Officer has direct access to the Audit Committee of the Board of Directors, as well as the full Board. The Chief Legal Officer, Corporate Security and Chief Ethics Officer reports directly to Xerox’s Chief Executive Officer.

See below for Xerox Ethics Helpline

See below for the Xerox Ethics Policy Letter

See below for the Non-Retaliation-Policy