Audit Program
To maintain and achieve regulatory compliance, a well-established audit program measures our success in implementing corporate standards and guidelines. To identify environmental, health and safety risks and potential areas of non-compliance, Xerox audits research, manufacturing and service operations on an average of once every three years. Xerox audit teams evaluate operations against Xerox standards, regulations and industry guidelines, and with the assistance of the audit teams, local managers develop action plans to correct deficiencies. Senior management pays particular attention to situations with the potential to pose a high risk of environmental damage, serious injury to employees, or regulatory non-compliance. In 2007, Xerox met its goal of resolution of these issues within 90 days, and has demonstrated that the audit program has become an important mechanism for identifying and correcting performance gaps.

Employee Training and Education
Through training and internal communication, Xerox makes its employees aware of how our operations affect the environment. Manufacturing employees who can have a potential impact on the environment receive training annually on topics such as hazardous waste management, spill prevention and response, recycling and ISO 14001. Customer Service Engineer training covers safety hazards, exposures and processes for risk mitigation. We post our environmental policy in our facilities, and we deploy environmental, health and safety goals for our products through our product development process. Through our ISO 14001 environmental management, employees are routinely involved in identifying the environmental aspects associated with their responsibilities.

We also use our internal Web site to communicate the company’s environmental goals. Employees are encouraged to do their part to reduce environmental impact through programs such as office recycling and our Energy Challenge 2012.

Stakeholder Outreach
Through a variety of means, Xerox communicates with stakeholders about our programs, performance and goals for environmental health and safety. Stakeholders include employees, customers, investors, universities, government agencies and environmental groups. We use their inputs in our reviews and strategy planning. Xerox tracks inquires from customers and other stakeholders and comments through our customer EH&S Support “hotlines” in North America and Europe. We also hear from customers through focus groups, and we hear from the larger community by participating in a number of external organizations.

Integrating Environmental Priorities Into Manufacturing Operations
All of Xerox’s manufacturing operations employ an ISO 14001-conforming environmental management system. This ensures compliance with regulations and Xerox standards, identifies environmental impact and sets objective and performance targets. The ISO 14001 system requires that day-to-day business activities be integrated with environmental planning and program management. It encourages innovative engineering solutions, creative partnerships and employee involvement.

Our major manufacturing operations have been certified to ISO 14001 since 1997. In 2002, we completed the certification of all current manufacturing operations. New plants are scheduled for certification as they become operational.

In 2007, starting with our largest U.S. supplies warehouse operations, Xerox began to expand the adoption of ISO 14001 beyond manufacturing. Our intention is to expand adoption of ISO 14001 to all other U.S. supplies warehouses in 2008 and to additional operations and geographies over the next several years.

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