Suppliers - Supply Chain Transparency

California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act of 2010 became effective January 1, 2012. This California state law requires large retailers and manufacturers to disclose their efforts to eradicate slavery and human trafficking from their supply chain.

Xerox is committed to freely chosen employment which is embedded in our Code of Business Conduct, in our position on labor relations and in our employment practices. Xerox principles are guided by the United Nations Universal Declaration of Human Rights which prohibits slavery, servitude and the slave trade.

To strengthen our approach to supplier-facing sustainability and human rights actions, Xerox started working with the Electronic Industry Citizenship Coalition (EICC) in 2006 and became a member in 2008. The EICC is an organization dedicated to improving social, economic and environmental outcomes in the electronics industry. Xerox has adopted the EICC's Code of Conduct on corporate social responsibility as its code of conduct for suppliers ("Supplier Code of Conduct") and reinforces it annually in a letter to its suppliers. The Supplier Code of Conduct includes labor standards based on recognized principles of international labor and human rights. Freely chosen labor is a primary standard in the Supplier Code of Conduct, prohibiting forced, bonded or indentured labor.

The following highlight our efforts to eradicate slavery and human trafficking from our supply chain:


  • Xerox has implemented a verification process through an internal compliance program with its direct/technology suppliers which utilizes the EICC Code of Conduct.
  • As a part of this compliance program, Xerox conducts initial risk assessments of its suppliers based on objective criteria. For suppliers identified in the initial risk assessment as high-risk, the supplier is required to complete a Self-Assessment Questionnaire annually, which requires the supplier to measure their compliance with the EICC's Code of Conduct. The supplier's responses to the Self-Assessment Questionnaire allow Xerox to identify where possible risks in the supply chain exist. If a supplier's score on their Self-Assessment Questionnaire falls below a passing level, an audit of that supplier is conducted (as more fully described below). The Self-Assessment Questionnaire step also serves to raise suppliers' awareness about the importance of social responsibility topics, clarify Xerox expectations, target areas for review, and document suppliers' assessment of their performance.
  • In addition to the initial risk assessment and Self-Assessment Questionnaire, Xerox procurement professionals and quality assurance engineers routinely conduct on-site visits of suppliers as part of the ongoing supplier verification.


  • As indicated above, if a supplier's score on their Self-Assessment Questionnaire falls below a passing level, the Xerox compliance program conducts an announced review and/or audit. Areas of nonconformance are evaluated as priority, major, minor or areas for review and are addressed through a corrective action process. In addition, Xerox conducts announced reviews/audits of those suppliers identified in the initial risk assessment as high-risk, regardless of their score on the Self-Assessment Questionnaire.
  • All reviews and audits are on-site visits by trained Xerox employees and follow a consistent review and audit process. Xerox utilizes the EICC audit format to address key critical sustainability areas, including but not limited to, labor practices, freedom of association, child labor, forced labor, human rights, and environmental concerns.
  • Since 2010, Xerox has conducted over 300 announced compliance reviews and audits. In 2014, Xerox conducted 31 audits and 41 compliance reviews which represented 30% and 46% of Xerox direct/technology supplier spend respectively.


  • Xerox requires all direct suppliers and critical indirect suppliers to represent and warrant their compliance with all applicable laws and regulations in Xerox agreements for the purchase of products. Similar representations are required by virtue of issuing Xerox purchase orders and other Xerox purchase documents.
  • If it comes to the attention of Xerox that a supplier has violated applicable laws or contract terms and conditions, Xerox analyzes each situation on a case by case basis and determines the necessary course of action (i.e. terminate supplier relationship, instruct supplier to make corrective actions, etc.).
  • Critical direct and indirect suppliers are required to keep some or all of the following business documents on file while conducting business with Xerox:
    • All Xerox Purchase Orders and supplier invoices
    • Multi-National Master Purchase Agreement
    • Confidential Disclosure Agreement
    • Purchase Material Authorization
    • Business Resumption Plan
    • Product Safety and Certification Documents
    • Quality Plan and Quality Inspection Data
    • Restriction of Hazardous Substances (RoHS) compliance form
    • Tool Validation forms and records of the associated Xerox owned tool numbers
    • Electric Industry Citizenship Coalition (EICC) Code of Conduct
    • Multi-National Survey Audit Reports
    • Conflict Mineral Templates

Internal Accountability

  • A Corporate Social Responsibility (CSR) Steering Committee that is chaired by Corporate Office and Direct Report to the CEO. The CSR Steering Committee is supported by the CSR Council, a group of Senior Executives responsible for validating fair operating practices, environment, health & safety, labor, government affairs, reputation & brand, finance & real estate, philanthropy and supply chain & procurement.
  • Xerox has an Ethics and Compliance Program that is an integral part of the daily business operations and practices. To facilitate this commitment to integrity Xerox has:
    • A global, written code of business conduct available in 17 languages
    • A supplemental code of conduct for finance employees
    • A specific code of conduct for the Board of Directors
    • A dedicated Xerox Ethics Helpline and a strictly enforced 'no retaliation policy' to promote comfort in using the Helpline
    • An Ethics & Compliance Governance Board comprised of senior executives representing all areas of Xerox business
    • Annual global communication of business ethics policy and CEO message on ethics and integrity
  • The Xerox Code of Business Conduct seeks to align employee actions and decisions with company's core values and compliance requirements. Our position advocating for human rights and opposing human trafficking is codified in our Code of Business Conduct. All employee violations of the Code of Business Conduct are thoroughly reviewed and investigated on a case by case basis and each incident is treated seriously, fairly and consistently.
  • Xerox provides a variety of channels for employees, suppliers and customers to report suspected ethical violations, including phone, Web, email and postal mail. The Ethics Helpline is available globally 24 hours a day, seven days a week in multiple languages, via toll-free telephone numbers ( and our Web reporting tool (, which supports multiple languages.
  • The Xerox Ethics and Compliance Program is overseen by the Audit Committee of the Board of Directors. The Ethics Office reports directly to the Senior V.P., General Counsel and Corporate Secretary via Xerox Corporate V.P., Deputy Counsel and Chief Ethics Officer, with ongoing reporting responsibilities directly to the Audit Committee. The Senior V.P., General Counsel and Corporate Secretary report directly to Xerox CEO.


All Xerox employees are required to complete the Xerox Code of Business Conduct training and ethics acknowledgement on an annual basis. The training is designed to enhance an employee's ability to recognize and respond to ethical issues, communicate the process and expectations about reporting suspected violations of the Code, and give instructions for obtaining additional guidance should an employee have a question or concerns about Xerox ethics procedures.
Additionally, all Xerox Global Procurement employees are required to complete a Supply Chain Transparency Course annually. The training is designed to aid in the mitigation of human trafficking by building awareness of how human trafficking and slavery manifest themselves in the supply chain.

For more information about social responsibility at Xerox, please visit the Xerox Global Citizenship site.