Transparency & Ethics

Transparency & Ethics

Ethical business practices

We believe that ethical behavior is critical to Lexmark's Vision, Mission and Values. All Lexmark employees are expected to adhere to the policies set forth in the Lexmark Code of Business Conduct. The Code covers the following topics: personal conduct, conflicts of interest, accounting records, internal controls and audits, complying with laws and regulations, supplier relationships, customer relationships, information concerning others, and corporate social responsibility.

In 2023, 99% of regular, worldwide employees and managers acknowledged their understanding of the 2023 Code of Business Conduct, confirming that they conduct themselves and Lexmark business in accordance with the Code’s requirements. Internal Audit, Human Resources, Legal, Sustainability and other areas review the Code of Business Conduct annually. The Code of Business Conduct is sent directly to all employees annually and is readily available on Lexmark's intranet and, along with other policies related to responsible business conduct.

Employees are encouraged to communicate any critical concern or conflicts of interest to management, legal, internal audit, human resources or the Ethics Hotline/whistle blower. All reported critical concerns and conflicts of interest are presented to the Board of Directors Finance and Audit Committee each quarter.

Lexmark requires targeted anti-corruption and anti-bribery training courses that educate select employee groups about risks of corruption specific to their job functions. 98% of the workforce reviews and acknowledges business ethics and anticorruption training annually. Each of our sites does an annual assessment through Responsible Business Alliance(RBA). This assessment evaluates risk management systems, labor, ethics, health, safety, environmental conditions, identifies gaps, and ensures the systems are in place to prevent violations from occurring in the future. We also do compliance risk audits at our sites periodically and Quality, Environmental and Health and Safety management systems audits annually.

Any officer, director, employee, or agent acting on behalf of Lexmark who violates the Lexmark Code of Business Conduct can be subject to Lexmark disciplinary action, as well as substantial government fines and/or imprisonment.

Preventing corruption

Lexmark business operations are regularly analyzed for risks related to corruption. 100% of our sites had a fraud risk assessment in 2023. Significant entities and processes are specifically identified during the review process. Corruption risk factors are considered in the formation of the Lexmark internal audit plan. The Chief Audit Executive reviews the plan with the Finance and Audit Committee on an annual basis. The company has designed and adopted employee and supplier codes of business conduct that help to mitigate these risks.

The annual audit planning process takes into consideration high-risk fraud areas such as revenue recognition, inventory, receivables, fixed assets, liabilities/disbursements and employee payables. Based on the risk assessment for fraud, Internal Audit evaluates controls in each audited area through test steps designed to address fraud risks.

Lexmark has a zero-tolerance policy towards bribery and corruption among employees and business partners. We terminate business relationships with business partners that operate in an unethical manner. No legal cases regarding corrupt practices were brought against Lexmark or our employees during 2023.

All allegations of employee corruption and fraud are thoroughly investigated by the appropriate business unit in collaboration with Human Resources, Internal Audit, and the Lexmark Legal Department. Results of such investigations determine disciplinary action and whether the incident requires investigation by outside agencies and formal charges. In accordance with the Lexmark zero-tolerance policy toward bribery and corruption, Lexmark will dismiss any employee who commits a nonsystemic, personal-level incident of fraud or dishonesty.

Preventing anticompetitive behavior

Lexmark supports efforts to preserve and foster fair and honest competition in a competitive market system. We take care to ensure that our business practices do not violate competition laws (also known as antitrust, monopoly, fair trade or cartel laws) which prohibit business practices that unreasonably restrict the functioning of the competitive system.

These efforts and our policies ensure that anticompeitive issues do not occur. Lexmark was not the subject of any claims of anticompetitive behavior during 2023.

Monetary fines

Lexmark has not been subject to any significant fines or nonmonetary sanctions for noncompliance of laws and regulations related to accounting fraud, human rights, workplace discrimination, health and safety or corruption during this reporting period.

Political contributions and lobbying

Lexmark is committed to complying with local laws related to the disclosure of political dealings, such as those that require reporting political contributions to the appropriate state or federal political and ethics authorities, and publishing the information on their respective websites. 

From time to time, Lexmark employs the services of remunerated attorney and non-attorney advocates and consultants. These advocates provide Lexmark with legislative monitoring services, guidance on proposed and enacted legislation, and communication of the applicable Lexmark position on legislation to interested parties and stakeholders.

Vision and values

Our employees have defined our vision and values. We live these concepts every day. More than mere words, these statements are truly a framework for how we operate. To learn more about our vision and values, see our Vision and Values page.


Ethics hotline

The Lexmark Ethics Line (1-866-477-2029) is a 24-hour, international toll-free telephone number established to assist Lexmark employees with questions about the Code of Business Conduct or concerns that something improper or a violation of a rule has occurred or might be occurring. A third-party provider operates the Ethics Line. Where local laws allow, the third-party provider of the telephone lines is prohibited from providing a caller’s identity to Lexmark without the caller’s permission. Calls are directed to the Chief Audit Executive and the Chief Legal and Compliance Officer for investigation and review.