Xerox’s Code of Business Conduct embodies and reinforces our commitment to integrity and helps Xerox people resolve ethics and compliance concerns consistent with our core values. Xerox’s core values are a set of beliefs beyond compromise. They are a part of our heritage and future. Xerox’s core values are the key principles that guide our conduct and our relationships. They define how we engage with each other and our customers, how we deliver value and how we behave. They connect us to each other and make our successes possible. Each Xerox employee is accountable for aligning their conduct with our core values.

Key topics of the Code of Conduct include:

• Legal and policy controls.
• How to report concerns and obtain guidance.
• Sales and marketing activities.
• Conflicts of interest.
• Gifts and entertainment.
• Safeguarding and using customer information.
• Controllership.
• Revenue recognition.
• Safeguarding and using company assets.
• Protection of intellectual property and copyrighted material.
• Insider trading and insider information.
• Fair competition and trade practices.
• Bribery and improper payments.
• Money laundering.
• Nondiscriminatory employment practices.
• Health and safety.
• Alcohol and drug misuse.
• Privacy rights of Xerox people.
• Human rights.
• Environmental stewardship.

To view the company’s Code of Business Conduct, visit www.xerox.com/governance.