Our Environment, Health and Safety (EH&S) organization is charged with ensuring company-wide adherence to Xerox’s environment, health and safety policy. The governance model we use to accomplish this task includes clearly defined goals, a single set of worldwide standards and an audit process that ensures conformance to these requirements. Our EH&S governance and policy, adopted in 1991, forms the foundation of our environmental leadership program. For a review of this policy, visit www.xerox.com/environment.

Standards and Programs
Environmental, health and safety standards are our primary tool for ensuring compliance with corporate policies and goals. These worldwide standards establish specific requirements for product safety, materials safety, packaging, design for environment, environmental management and reporting, workplace safety, emergency response and asset protection. We have also established company-wide programs such as Zero Injury, Emergency Preparedness and Energy Challenge 2012 to engage and support employees worldwide.

Supplier Environmental, Health and Safety Management
Xerox extends environmental, health and safety requirements across its supply chain. Since 1998, Xerox has asked its materials and components suppliers to meet specific environmental, health and safety requirements. These requirements were broadened in 2004 to better govern the use of chemicals in Xerox products, parts and supplies throughout the supply chain. The standard, EHS 1001: Xerox Environmental, Health and Safety Supplier Requirements: Chemical Bans/Restrictions and Part Marking, establishes requirements for regulatory compliance, chemical bans and restrictions and parts marking for parts and materials intended for use in electronic products. Further, by adopting the Electronic Industry Citizenship Coalition’s Code of Conduct (click here for information on EICC), Xerox has further strengthened its commitment to ensure that its suppliers are operating according to accepted industry standards for environmental management. Starting in 2003, Xerox extended requirements to companies that provide paper to Xerox for resale. More information on these standards can be found at www.xerox.com/environment.

Audit Program
To maintain and achieve regulatory compliance, a well-established internal 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 to five years. The duration is based on the type of operations and the inherent risks associated with the operations. Xerox audit teams evaluate operations against Xerox standards, regulations and industry guidelines and, with the assistance of the local managers and support staff, 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 2008, 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 impact the environment. As appropriate, employees in manufacturing and other operations 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.

Stakeholder Outreach
Through a variety of means, Xerox communicates with stakeholders about our environment, health and safety programs, performance and goals. Stakeholders include employees, customers, investors, universities, government agencies and environmental groups. Xerox tracks inquiries from customers and other stakeholders and comments through our EH&S “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. Through Xerox’s Thought Leadership program, Xerox conducted 40 sustainability forums with customers in 2008 alone, generating awareness of the importance of sustainability, sharing company best practices and encouraging customers to reduce their environmental footprint by finding “Smarter Ways to Green.” Learn more at www.xerox.com/thoughtleadership.

To advance global efforts to improve our environment, Xerox partners with these private and public organizations:

• Advisory Board of the Center for Sustainable Systems at the University of Michigan
• Advisory Board of Golisano Sustainability Institute at the Rochester Institute of Technology
• Business Roundtable Climate RESOLVE
• Business Roundtable S.E.E. (Society, Environment, Economy) Change
• Business for Social Responsibility
• California’s Climate Action Registry
• New York State Pollution Prevention Institute
• International Leadership Council of The Nature Conservancy
• Organization for Economic Cooperation and Development (OECD) Expert Advisory Group on Sustainable Manufacturing and Eco-Innovation
• The Prince’s May Day Network
• Sustainable Energy Ireland
• U.S. Climate Action Partnership
• U.S. EPA Climate Leaders
• U.S. EPA ENERGY STAR^®
• U.S. EPA WasteWise
• U.S. EPA National Advisory Council for Environmental Policy and Technology Subcommittee on Promoting Environmental Stewardship

Integrating Environmental Priorities in Product Design
Xerox recognizes that the best results – both environmental and financial – are achieved when environmental priorities are considered from the outset of product design. Customer feedback and public policy, along with a forward-looking view of global trends in technology, regulations and ecolabels, have led us to a comprehensive set of standards that encompasses: energy efficiency, chemical management, packaging, parts reuse and recycling, electrical and mechanical safety, ergonomics, electromagnetic emissions, noise, fire resistance and materials safety. Xerox business teams and the EH&S organization review Xerox products at each stage of the “time to market” product development process for conformance with EH&S standards. This is a requirement for the introduction of any new product.

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 objectives 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. warehouse operations, Xerox began to expand the ISO 14001 approach beyond manufacturing. Our largest U.S. supplies warehouse operations have adopted ISO 14001-conforming environmental management systems and have set a goal to reduce solid waste sent to landfills by 25% by 2012.