At Pitney Bowes, integrity matters.

Values and Ethics

Laws and policies change, but one thing that does not change is our commitment to “do the right thing, the right way.” We are committed to maintaining honest, fair and respectful relationships with our employees, our clients and the communities in which we are located. We continually provide education and training for employees not only to ensure that they are aware of the Company’s expectations of conduct, but also to provide them with the tools they need to succeed in an ethical and legally compliant culture. Our training classes, policies, code of conduct, reporting and advice channels and management support provide employees with the guidance they need to be able to do the right thing when faced with difficult choices. Senior management is responsible for modeling expected behaviors and is committed to supporting a thriving culture of integrity. We constantly monitor the performance of our ethics and compliance program to improve its effectiveness.

Code of Conduct

The Pitney Bowes Business Practices Guidelines is our code of conduct. It provides an overview of policies, laws and expectations of conduct for all employees globally. While legally compliant behaviors are the minimum expectation, we expect employees to conduct themselves with the highest ethical standards. We publish the code in two versions: one for employees based in the United States and another for employees based in international locations. We publish the international version in multiple languages, both to reach as many employees as possible in their own language and to accommodate differences in legal requirements and cultural practices.

Ethics and Compliance Review Committee

Our Ethics and Compliance Review Committee meets regularly to monitor and support business and functional unit compliance with regulatory mandates that affect their operations (for example, regulations governing government contracts or disposal of product components). The committee includes senior leaders who span the full range of corporate functions and business units. A separate review committee focuses specifically on ethics and compliance issues related to labor and employment.

Training

Employees have a right to know and understand the behaviors the company expects of them. We communicate our expectations through annual education and training initiatives, which we customize to fit the needs of individual employee groups using a variety of content delivery methods. Each year, we provide foundational or comprehensive training in certain significant compliance topics applicable to all as well as abbreviated training that reviews the highlights of the in-depth courses given the previous year. We also provide refresher communications to remind employees of the essential elements of courses delivered in preceding years. New employees receive introductory compliance training related to their jobs, and are then enrolled the following year in the courses given to the general employee population. This cyclical approach helps employees to keep thinking about key requirements on a regular basis. Our annual training material is available in multiple languages.

In addition to our standard courses, we offer a variety of on-demand training and other regular communications about ethics and compliance. For employees who do not have access to computers, managers provide monthly huddle training on topics covered in our Business Practices Guidelines.

Advice and Reporting Channels

We encourage employees to seek advice in dealing with ethical dilemmas and to report any suspected or actual wrongdoing. Our Ethics Help Line is operated by a third-party administrator 24 hours a day, seven days a week. Employees may call in to the line to report their concerns (anonymously, if permitted by local law) in any of 140 languages or make a report online. Employees may also contact the Global Ethics and Compliance Department in person or through web page reporting, hard copy mail, telephone or confidential email. Employees may also report matters to their manager, or a member of the Human Resources, Legal or Audit departments. Global Ethics and Compliance promptly reviews all claims of potential violations of law or policy and, where appropriate, works with the appropriate stakeholders to investigate claims. If the investigation supports the allegations, we take appropriate and consistent disciplinary action.