Core Values

Xerox Code of Business Conduct

Code of Business Conduct: Connecting with Our Core Values

Our Code of Business Conduct embodies and reinforces our commitment to integrity and helps us resolve ethics and compliance concerns consistent with our core values. Our core values are a set of beliefs beyond compromise. They have been our North Star for over 40 years. They are a part of our heritage and are a part of our future. Connecting with our core values is a shared responsibility.

A Message from Ursula Burns

This updated version of our Code of Business Conduct represents an exciting and innovative way to connect with our core values—the backbone of who we are and all we do at Xerox. The connection with our core values makes it easier to understand our responsibilities. We are committed to being a role model for corporate ethical behavior. This commitment is enabled by the personal actions and accountability of each and every one of us. Our greatest successes over the years have been driven by our allegiance to our long-standing core values. Our reputation rests on what we do and how we act every day. I am looking to each of you to meet or exceed compliance requirements and ethical expectations. Nothing we do is more important than maintaining our personal integrity and our collective financial and business integrity in the name of Xerox. This Code of Business Conduct is a guide. It is not intended to be a compendium of all policies. Use it as a tool to enable dialogues with co-workers and managers and to find the appropriate policies, tools and other resources to help you do the right thing every day.

Ursula Burns Chairman and CEO

2 Code of Business Conduct www.xerox.com/ethics

Table of Contents

2 4 4 4 A Message from Ursula Burns Our Mission Statement Our Core Values 4 Ethical Decision-Making Framework Purpose and Scope 5 Legal and Policy Controls 5 5 6 7 8 Expectation for Compliance Reporting a Concern and Obtaining Guidance Non-Retaliation 13...