But guidance comes clearest from Xerox's director of business ethics and compliance, David Frishkorn - a 16-year Xerox veteran with expertise that spans finance, accounting, global business and more. Frishkorn has been asked to speak about ethics by groups such as The Conference Board and Business Ethics magazine, and here he speaks again about Xerox's strong ethics positions and programs.

What's the scope of the Ethics Office's work?
Our office - led by chief staff officer and chief ethics officer Hector Motroni - has worldwide responsibility for ensuring compliance with all company policies and applicable laws as outlined by the Xerox Code of Conduct. We oversee training, awareness and all ethics-related issues for the corporation.

I get to work with every area of the company, including the business groups, corporate security, human resources, office of the general counsel and various experts to establish company standards and procedures that are continually refreshed and promoted within the Xerox population.

What accomplishments in the Office are you most proud of?
There are so many things that come up on a daily basis: detecting and curtailing property thefts and expense report fraud, helping maintain the integrity of our financial reporting, weeding out managers who try to take advantage of their position and power, protecting employees who might feel harassed. But one instance that really stands out in my mind is an employee of an external agency who called with tears in his eyes and apprehension in his voice. He was unable to sleep, losing weight, and experiencing physical issues knowing his employer was defrauding Xerox and our customers. He simply did not know where to turn or what to do. By the end of our conversation, there was genuine relief in his voice and a much clearer perspective and satisfaction that he was doing the right thing. It feels good to help someone get a good night's rest.

How do you conduct investigations?
We take ethical violations seriously and have a deliberate, thoughtful process that defines how investigations are conducted. Our goal is to complete a case within two or three weeks. We oversee the investigation process, so we can recommend improvements to the policies and procedures that are designed to help prevent future violations.

In addition, we have constructed a clear matrix that defines the consequences for various levels of improper actions. The Corporate Executive Board recently cited this "Ethics Responsibility Matrix" as a best practice in a recent business ethics report.

How do you know the ethics messages are getting through?
We conduct random monthly surveys of employees via e-mail to understand what's on their minds. These anonymous surveys are invaluable for spotting trends before they could become ethical issues. We can take the survey results to Xerox's senior leadership team, and collectively plot a course of action that helps resolve the issue before it gets out of hand. In one example, we were seeing an uptick in survey results related to "apathy." In her next employee communiqué, CEO Anne Mulcahy directly addressed the issue by underscoring the credibility of our process and imploring employees that we all have a responsibility to do the right thing and to step up to the plate if we see a problem.

Do employees have a way to report issues or seek help?
Absolutely. We have Ethics Help Lines - toll-free phone numbers - available worldwide to aid employees who need guidance on an issue or who wish to safely report a violation. People can choose to be anonymous, or not. Employees can simply send an e-mail to ethics@xerox.com. We have a strictly enforced non-retaliation policy to promote employees' comfort in speaking up.

What areas most concern you?
Most employees want to do what is right for the company, but I worry they may not know what to do when there are competing interests to determine what is right. Our continual challenge is to ensure that all employees know it is okay to ask for guidance and that they know how to do so.

Any final thoughts for employees?
No matter where you work, respecting the rules and knowing what to expect helps companies safely navigate the troubled waters of an intensely competitive and pressured-filled business world. Being ethical isn't difficult - just do what makes you feel proud.

For more information about business ethics at Xerox, corporate governance and Xerox codes of conduct, visit www.xerox.com/corporategovernance.