Finance Code of Conduct
Xerox Corporation's (Xerox or the Company) stated Corporate philosophy is to comply with the highest standards of ethical behavior and the letter and spirit of all applicable laws. Additionally, Xerox is committed to full and accurate financial disclosure in compliance with applicable laws, rules, and regulations and to maintaining its books and records in accordance with applicable accounting policies, laws, rules, and regulations. This policy sets forth the unique stewardship responsibilities of Xerox Senior Financial Management, as defined, Financial Management and Finance staff. The responsibilities in this policy fall within the guidelines established in the Company's business ethics, conflicts of interest and related policies. Compliance with these policies is also implied in the requirements of the Sarbanes-Oxley Act of 2002 and regulatory bodies such as the Securities and Exchange Commission (SEC).
Xerox Corporation and subsidiaries.
The purpose of this code of conduct is to codify standards that are reasonably designed to deter wrongdoing and to promote:
(a) Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
(b) Avoidance of conflicts of interest, including disclosure to an appropriate person or persons identified in this code of any material transaction or relationship that reasonably could be expected to give rise to such a conflict;
(c) Full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in other public communications made by Xerox;
(d) Compliance with applicable governmental laws, rules and regulations;
(e) The prompt internal reporting to an appropriate person or persons identified in this code of violations of the code; and
(f) Accountability for adherence to the code.
Senior Financial Management, Financial Management and their Finance staffs are relied upon by Corporate and operating group management to:
Xerox' shareholders and management look to Xerox' Finance and Control function to prepare and disclose financial data that fairly present Xerox' financial position, results of operations and cash flows in accordance with generally accepted accounting principles, consistently applied.
Minimum Standards: All Financial Personnel
Minimum Standards: Senior Financial Management
Reporting Code of Conduct violations