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Environmental, Health and Safety Governance

The Global Environment, Health, Safety and Sustainability (EHS&S) organization is charged with ensuring company-wide adherence to Xerox's environment, health and safety policy. This organization is led by the Vice President of EHS&S, who reports to the President of Corporate Operations, a direct report to the CEO. The governance model we use to accomplish this task includes clearly defined goals, a single set of worldwide standards and an audit process that validates conformance to these requirements. Our EHS&S governance policy, adopted in 1991, forms the foundation of our environmental leadership program. For a review of this policy, visit www.xerox.com/environment.

The Sustainability Strategy Council has been Xerox’s executive-level organization which championed and guided the corporate environmental sustainability program. Consisting of a senior vice president from each Xerox Business Unit (e.g., R&D, Marketing, Product Development), the Sustainability Strategy Council was responsible for establishing strategic priorities that aligned with corporate goals and sought to ensure that environmental sustainability considerations were integrated into all key business decisions. In 2011, we evolved our environmental sustainability governance structure to align with our progress on the journey toward embedding all aspects of environmental sustainability into business strategy and operational processes. With this transition from strategy to implementation, in 2011 we established an Environmental Sustainability Steering Committee that is chaired by the President of Xerox Global Business and Services Group and includes executive representation from across the business. This committee will now champion and guide the corporate environmental sustainability program. The Steering Committee seeks to ensure that environmental sustainability considerations are integrated into all key business decisions and is responsible for establishing strategic priorities that align with corporate goals.

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 also have 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
As a critical element of supply chain governance, Xerox extends environment, 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, 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. In 2009, through its Socially Responsible Procurement Policy, Xerox formally began extending social responsibility requirements, such as ethics, labor, environmental, health & safety and security controls across its supply chain. More information on these standards can be found at www.xerox.com/environment.

Audit Program
A well-established internal audit program measures our success in implementing corporate standards and guidelines and validates regulatory compliance. To identify environmental, health and safety risks and potential areas of non-compliance, Xerox audits research, manufacturing, engineering and service operations an average of once every three to five years. The frequency of the audits and content 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, beginning in 2010, also evaluated management system performance. With the assistance of the local managers and support staff, action plans are developed and deficiencies corrected. Senior management pays particular attention to situations with the potential to pose a significant risk of environmental damage, serious injury to employees or regulatory non-compliance. In 2010, Xerox met its goal of resolution of these issues within 90 days, and continued to demonstrate 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 and employee safety. As appropriate, employees in manufacturing and other operations receive training annually on topics such as hazardous waste management, spill prevention and response, recycling, ISO 14001 and a variety of other topics. In addition to any regulatory-required safety training, employees are trained on established safe job procedures based upon the job-specific hazards they may encounter and procedures and protective equipment they are expected to use. We post our environmental policy in our facilities, and we deploy environment, health and safety goals for our products through our product development process. Through our ISO 14001 environmental management system, employees are routinely involved in identifying the environmental aspects associated with their responsibilities. In 2010, a significant number of procurement agents participated in training on Xerox corporate sustainability goals to better enable them to implement our Socially Responsible Purchasing Policy, and a broad spectrum of executives gained significant learning through participating in a series of workshops designed to support a scenario planning exercise.

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. Xerox tracks inquiries from customers and other stakeholders and comments through our customer EHS&S Support “hotlines” in North America and Europe. We also hear from customers through focus groups and from the larger community by participating in a number of external organizations. Through our Thought Leadership program, Xerox conducted dozens of sustainability forums with customers and other stakeholders in 2010, generating awareness of the importance of sustainability, sharing best practices in industry, government and academia, 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:

Academia:

• Advisory Board of the Center for Sustainable Systems at the University of Michigan
• Advisory Board of Golisano Institute for Sustainability at the Rochester Institute of Technology
• Advisory Board for American University Center for Environmental Policy

Business:

• Business Roundtable Climate RESOLVE
• Business Roundtable S.E.E. (Society, Environment, Economy) Change
• Business for Social Responsibility
• Sustainability Innovators Working Group
• EcoPatent Commons

Non-Governmental Organizations:

• Environmental Defense Fund Climate Corps
• International Leadership Council of The Nature Conservancy
• The Prince’s May Day Network
• Organization for Economic Cooperation and Development (OECD) Expert Advisory Group on Sustainable Manufacturing and Eco-innovation
• Board of Trustees of Second Nature
• Board of Trustees of Central Western New York Chapter of The Nature Conservancy

Government:

• Sustainable Energy Authority of Ireland
• U.S. EPA ENERGY STAR
• U.S. EPA SmartWay Transport Partnership
• U.S. EPA WasteWise

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. Quarterly status meetings and integration with our newly deployed scorecard promote visibility, best practice sharing and innovation.

In 2007, starting with our largest U.S. supplies 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 25% by 2012. In 2010, our U.S. Equipment Distribution Centers achieved ISO 14001 certification.

Integrating Environmental Priorities into 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 and other stakeholder feedback, along with a forward-looking view of global trends in technology, regulations and ecolabels, has 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 EHS&S organization review Xerox products at each stage of the “time to market” product development process for conformance with EHS&S standards. This is a requirement for the introduction of any new product.

Xerox integrates life cycle thinking into all of our product and service development activities, as well as our innovation activities. Full Life Cycle Assessments (LCAs) – in accordance with ISO 14040 series standards – are conducted for products where a significant technology difference indicates their utility. For example, full peer-reviewed LCAs have been conducted on our solid ink products (8860, 8870 and ColorQube 9200 series), comparing their impacts to comparable xerographic devices. We also utilize a variety of streamlined approaches at various stages throughout our product development processes, starting in our earliest research stages. These approaches are applied to equipment, materials (e.g., toner formulations) and even our service offerings. For example, the Xerox Sustainability Calculator is an LCA-based tool to demonstrate the environmental benefit of optimizing the print infrastructure. We estimate that 65% of our product categories have been comprehended in full LCAs, with nearly all other hardware products and many services undergoing a more targeted evaluation.

In 2009, the product development organization established a series of Common Feature Documents. These define features that should be common across each class of products and are developed in advance of, and as input to, future product and platform planning cycles. Sustainability was one of the first topics developed, and was officially deployed in early 2010. This set of requirements serves as the Design for Environment requirement for equipment.