CODE OF BUSINESS CONDUCT
2023

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Table of Contents

Letter from the CEO

4

Introduction

5

Lexmark’s Work Environment

6Equal Employment Opportunity

6

Discrimination and Harassment

6

Employee Privacy

6

Personal Conduct

7

Drugs and Alcohol

7

Violent Behavior and Weapons

7

Offensive Behavior

7

Use of Lexmark Time and Assets

8

Travel and Entertainment

8

Handling of Lexmark Confidential Information

8

Recording and Reporting Information

8

Reporting Possible Violations of Laws and Policies

8Disclosure and Use of Confidential and Proprietary Information

9

External Communications

9

Software and Software Services

10

Conflicts of Interest

11

Competing Against Lexmark

11

Supplier Affiliations

11

Business Gifts and Amenities

11

Personal Financial Interests

12

Publicly Traded Securities

12

Closely Held Organizations

12

Employment of Relatives and Related Persons

12

Someone Close to You Working in the Industry

12

Political and Community Service

13

Accounting Records, Internal Controls and Audits

14

Complying with Laws and Regulations

15

General15

Antitrust and Competition Laws

15
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Bribes, Kickbacks or Other Corrupt Transactions

16

Corrupt Transactions and Third-Party Relationships

16

Copyrightable Material

17

CFIUS and United States Government Imposed Communication Restrictions

17

Supplier Relationships

18

Avoid Reciprocal Dealing18

Customer Relationships

19

Premature Disclosure

19

Truth in Advertising

19

Commission for Referrals

19

Relationships with Government Customers

19

Competitor Relationships

20

Fairness in the Field

20

Disparagement

20

Business Contacts with Competitors

20

Information Concerning Others

21

Data Protection

21

Acquiring Information

21

Using Information

21

Information Owned by Others

21

Corporate Social Responsibility

23

Key Contacts

24

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Letter from the CEO
Dear Lexmark Colleague,
As we focus on achieving profitable growth for Lexmark, we must understand that our success is driven not only by ourcommitment to our customers, but also by conducting ourselves ethically, legally and fairly in all of our business dealings.
It is the responsibility of every Lexmark employee to comply with our legal and ethical obligations when dealing with customers,
employees, business partners, competitors and suppliers everywhere in the world. The Lexmark Code of Business Conduct
serves as a guide to ensure that all of our business dealings are conducted with trust and integrity — consistent with our
Vision, Mission and Values.
As a Lexmark employee, you are expected to read, understand and live by this Code of Business Conduct. Since the code
cannot address every situation or issue that could arise in our business environment, you should discuss the code with yourmanager or call the Ethics Line at 1-866-477-2029 if you have questions.
Thank you for taking the time to read the Code of Business Conduct and, more importantly, for conducting your businessdealings in a manner consistent with these guidelines.
Allen Waugerman
President and Chief Executive Officer-4-Introduction
At various times in our careers, each of us will face situations that present ethical and legal questions
related to how we conduct Lexmark’s business. Lexmark’s policy regarding ethical behavior is
straightforward and clear:
We will conduct ourselves ethically, legally and fairly in all our dealings with customers, employees,
governmental entities, business partners, competitors and suppliers everywhere in the world.
While our policy is clear, its application in a specific situation might not be. Lexmark’s Code of BusinessConduct has been developed to assist employees in these situations. The Code sets the standards andpolicies for how we operate in addition to other Lexmark policies and procedures. All Lexmark employees
are personally responsible for reading, understanding and complying with this Code. Any waiver of theCode must be approved by Lexmark’s Ethics Committee, unless otherwise specified. An employee whodoes not comply with the Code is acting outside the scope of his/her employment and may be subject todisciplinary action, up to and including termination of his/her employment with Lexmark. Managers who
condone questionable or improper conduct from their employees who participate in such activity or who failto take corrective action when such matters are brought to their attention, may also be subject to disciplinary
action, up to and including termination of his/her employment with Lexmark. Any reports related to violationsof Lexmark’s Code of Business Conduct will be investigated promptly and corrective action will be taken as
appropriate.
Lexmark operates in many different countries and cultural environments. This Code is meant to apply to
Lexmark, its subsidiaries and employees around the world. If local legal or cultural practices are inconsistent
with the guidance provided in this Code, employees should discuss the appropriate course of action with
their manager, based on the intent and spirit of this Code. Any substantive deviation from this Code due tolocal legal or cultural considerations must be approved in writing by the Ethics Committee.
While any set of policies or procedures cannot answer all possible ethical dilemmas we might encounter,
the Code enables each of us to reach the correct conclusion or identify those situations where we shouldseek guidance from appropriate persons within Lexmark. If you have any questions in interpreting or
applying this Code, it is your responsibility to consult with: your manager, Lexmark’s Human Resources
Department, Lexmark’s Legal Department or the Director of Internal Audit. You may also ask a question byusing the Ethics Line.
An Ethics Committee — co-chaired by the Senior Vice President and Chief People Officer and the Senior Vice
President, Chief Legal and Compliance Officer — has been established to oversee Lexmark’s ethics
program, including the revision and interpretation of this Code.
For purposes of the Code, “Executive Management” refers to the Chief Executive Officer and direct reports
to the Chief Executive Officer.

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Lexmark’s Work Environment
Equal Employment Opportunity
Lexmark is committed to equal employment opportunity. All Lexmark employment-related activities will be
conducted without regard to race, color, age, gender, sexual orientation, gender identity, religion, national
origin, disability, veteran status, or any other characteristic or factor protected by applicable law.
Discrimination and Harassment
Lexmark strives to provide all employees with a healthy, safe and productive work environment.
Harassment or discrimination based on race, color, religion, gender, sexual orientation, gender identity,age, national origin, disability, veteran status or any other characteristic or factor protected by applicablelaw has no place at Lexmark or at any Lexmark activity. This includes, but is not limited to, sales calls, tradeshows, off-site meetings, training events, team-building activities, Lexmark social functions and customeror supplier entertainment activities or events.
If you think you have been the victim of such conduct at Lexmark, or have witnessed it occurring, you havean obligation to report it as soon as possible to your manager or the Human Resources Department. All
complaints of such conduct will be investigated promptly and dealt with appropriately. You will not be
retaliated against for reporting such conduct, and you will not be subject to disciplinary action as long as
you have not engaged in any improper activity.
Employee Privacy
Lexmark is committed to following responsible personal data governance and protection practices andcomplying with applicable law. The only personal data, including medical and benefit information, that
Lexmark collects or maintains is that which is necessary for employment-related business purposes.
Employees responsible for collecting, using, disclosing or maintaining employment-related personal data
must ensure that it is processed in accordance with Lexmark’s Privacy Policy.
Computers, communications equipment, telephones, offices, workspaces, desks, and all other equipment,
facilities, systems, or services provided by Lexmark, and the business information or documents (whether
paper or electronic) created or stored on, by, or in them, are the property of Lexmark. As a result, Lexmark
management has the right to access those assets. Except for small items of a personal nature (such as
pictures and memorabilia), any personal items, files, electronic data, voicemail, email, etc., that you
consider private or personal, data should not be kept in or on equipment, media, services, or facilities
provided to you by Lexmark.
Lexmark has the right, but not the obligation, to inspect and monitor the use of its facilities, data, systems,
services, and equipment to ensure that Lexmark assets are being properly used and that employees arecomplying with Lexmark’s policies and procedures and with applicable laws and regulations.

-6-Personal Conduct
Lexmark’s reputation for maintaining the highest standards of business conduct rests on our daily actions.
Each of us is responsible for acting in the best interests of Lexmark and for conducting ourselves inaccordance with this Code as we engage in any Lexmark activity. This includes, but is not limited to, sales
calls, trade shows, off-site meetings and training events, team-building activities, Lexmark social functions
and customer or supplier entertainment activities or events.
Drugs and Alcohol
The use, possession, manufacture, distribution or sale of drugs or other controlled substances (except
where use is authorized by appropriate medical personnel to treat a bona fide medical condition of theperson possessing them) or alcohol (except where approved by Executive Management) is prohibited on
Lexmark property.
Under no circumstance should you be on Lexmark property, in any Lexmark work environment or engaged
in any activity for Lexmark if you are under the influence of, or affected by, such drugs, controlled
substances or alcohol.
Violent Behavior and Weapons
Violent behavior, or the threat of violent behavior, even if made in jest, is not acceptable conduct. To the
maximum extent permitted by law, Lexmark prohibits your possession of a weapon while you are on
Lexmark premises or when you are engaged in any activity for Lexmark.
Offensive Behavior
Offensive language; racial, ethnic or religious slurs; or other remarks, jokes or conduct which encourage or
permit an offensive work environment or diminish the worth of another person are not acceptable. This istrue even if others do not seem to object.
Corporate Policy Compliance
Complying with Lexmark’s corporate policies and procedures is vital to the ongoing success of ourcompany. Lexmark employees worldwide are expected and directed to comply with all Lexmark corporate
policies. It is each employee’s responsibility to know and understand policy requirements as they apply totheir job
By electronically agreeing to the Code, you are also acknowledging that you understand and will comply
with the IT Security Policy, the Global Lexmark Travel Policy and any applicable local/regional policy
addendums, and the Employee Handbook that is applicable to your geography/location/country.
It is also your responsibility to notify management if you believe a violation of policy, corporate or otherwise,
has occurred. Violations of any Lexmark policies will result in disciplinary action up to and including
termination.
Protecting Lexmark Assets
Each of us is personally responsible for protecting Lexmark assets entrusted to us and for protecting
Lexmark assets in general. You should be alert to any situations or incidents that could lead to the loss,-7-

misuse or theft of Lexmark assets, including Lexmark data and third-party data entrusted to Lexmark.
Use of Lexmark Time and Assets
You may not perform non-Lexmark work or solicit non-Lexmark business on Lexmark premises or whileworking on Lexmark time. Lexmark facilities, systems and equipment are provided solely for the purposeof conducting Lexmark business. You are not permitted to use Lexmark equipment, systems, telephones,
materials, resources or proprietary information for any non-Lexmark business, with the only exception ofvery limited and reasonable use of telephones, computer systems (including e-mail and internet) andprinters for personal matters; however, you will not have any privacy rights in any such use except to theextent required by applicable law. In no case are you allowed to access, store or communicate anything
inappropriate for a professional business environment including, but not limited to, information items orinternet sites of a harassing, offensive, discriminatory, illegal or sexually explicit nature or sites that involve
gambling, copyright infringement, or that otherwise violate Lexmark policy or applicable laws.
You should protect company assets and their efficient use. Theft, carelessness and waste have a direct
impact on Lexmark’s profitability and should be prevented.
Travel and Entertainment
You must ensure that all business travel furthers Lexmark’s interests and that all travel and entertainment
expenditures are reasonable and in compliance with applicable Lexmark policies. You also must exercise
good judgment when traveling on Lexmark business and when organizing and participating in any Lexmark
entertainment activity or event, whether formal or informal. Under no circumstances should you organizeor participate in any Lexmark entertainment activity or event, whether formal or informal, including customeror supplier entertainment activities or events that would violate this Code or any Lexmark policy.
As a representative of Lexmark, you should understand that certain activities and venues are notappropriate for conducting business, entertainment or meetings. This includes businesses such as sexuallyoriented businesses or any other venue or activity that would reflect negatively on Lexmark.
Handling of Lexmark Confidential Information
You should not discuss or communicate Lexmark confidential information with anyone inside or outside of
Lexmark, except Lexmark employees with a legitimate business need to know. In conveying sensitive
information, you should be aware of who might overhear your conversation or view your communication.
When in public locations such as airports, airplanes, and restaurants, you should consider the risk andopportunity for eavesdropping either by overhearing the conversation or other electronic eavesdropping
before you discuss or communicate sensitive information. Sensitive information should only be disclosed
in accordance with Lexmark policy.
Recording and Reporting Information
Accurate and timely information is critical to the effective, efficient and profitable operation of Lexmark. You
must record and report all information accurately and honestly, including but not limited to information
contained in time and attendance reporting, invoices and other accounting reports and documents.
Information must not be organized in a way that is intended to mislead or misinform those who receive it.
Inaccurate or misleading reporting of information to organizations or individuals within or outside Lexmark
is strictly prohibited. Full, fair, accurate, timely and understandable disclosures within reports, documents
and in public communications made by the Company are required. In addition to any disciplinary action you
may face, violation of this provision could lead to civil or even criminal liability for you and Lexmark.
Reporting Possible Violations of Laws and Policies-8-If you become aware of any questionable or improper accounting, financial reporting or auditing matters orof any violation or possible violation of a law, rule or regulation, Lexmark policy, procedure or provision ofthis Code of Business Conduct, you have an obligation to promptly notify a member of your direct
management chain, Lexmark’s Human Resources Department, Lexmark’s Legal Department, the Directorof Internal Audit or the Chief Executive Officer. If you are reluctant to report a possible violation to yourmanager because, for example, he or she might be personally involved, you should report it through oneof the other options listed above or by using the Ethics Line if the options above are not feasible. You may
choose to remain anonymous if you wish when using the Ethics Line and any report will be treatedconfidentially.
A listing of contacts and phone numbers are provided at the end of this document.
You will not be retaliated against for making the report, and you will not be subject to disciplinary action formaking the report as long as you did not participate in the violation. Reasonable efforts will be made toprotect your identity if you so request.
As a Lexmark employee you also have a responsibility to participate and cooperate openly and honestly in
any internal investigation of misconduct or wrongdoing.
Defend Trade Secrets Act of 2016 Notice: Notwithstanding anything in this Code of Conduct or the
Employee Handbook to the contrary, an individual shall not be held criminally or civilly liable under any
Federal or State trade secret law for the disclosure of a trade secret that is made (1) in confidence to a
Federal, State or local government official or to an attorney solely for the purpose of reporting orinvestigating a suspected violation of law; or (2) in a complaint or other document filed in a lawsuit or otherproceeding, if such filing is made under seal. An individual who files a lawsuit for retaliation by an employer
for reporting a suspected violation of law may disclose the trade secret(s) to the attorney of the individual
and use the trade secret information in the court proceeding if the individual files any document containing
the trade secret under seal and does not disclose the trade secret, except pursuant to court order.
Disclosure and Use of Confidential and Proprietary Information
During the course of your employment at Lexmark, you will be exposed to information related to Lexmark’s
operations. This information includes the business, financial, sales and marketing, personnel and services
plans of the business. You may also have access to proprietary information such as: research anddevelopment, design, engineering and manufacturing know-how and processes. This information
represents a valuable Lexmark asset and should be used only in connection with Lexmark business.
Information concerning Lexmark should be considered for internal use only. If you have any doubt about
whether particular information should be shared outside Lexmark with suppliers, business partners,
customers, etc., you should consult with your management prior to any disclosure.
When you create content, you must label the content appropriately in compliance with Lexmark’s DataClassification Policy. Certain information may be classified as confidential or restricted confidential. In thesecases, Lexmark alone is entitled to determine what use may be made of the information and with whom it
may be shared. Your obligation not to disclose confidential information continues even after youremployment with Lexmark ends.
External Communications
Individual employees may not communicate any information related to the Company’s performance orbusiness activities that has not yet been made public through the Global Communications Department.
All inquiries from the media, other than those related to Lexmark’s existing product offerings or routine
operations in non-United States locations, should be directed to Global Communications. In non-U.S.
locations, all communication with the media is to be limited to local senior management or designated public-9-relations representatives. Regardless of location, any inquiries of a potentially negative nature should bedirected to Global Communications. Inquiries from outside attorneys, regulators or government agencies
should be directed to Lexmark’s Legal Department or, in the case of tax matters, VP, Chief Accounting
Officer.
All external communications must be consistent with Lexmark policy, including but not limited to thoseoutlined in the Social Media Policy and this Code of Business Conduct. In addition, no external
communication, including ones made through a personal communication channel such as personal e-mailor any form of online posting, publishing or discussion group, may discredit Lexmark, its products,
employees or business interests.
Software and Software Services
Most software products and services purchased by Lexmark are regulated by some form of licensing or
subscription agreement that describes the terms, conditions and allowed uses of the software and software
services. Lexmark respects copyright laws and observes the terms and conditions of all license andsubscription agreements. All software installed on Lexmark computers or equipment and all software
services for use in Lexmark’s business must be licensed to Lexmark and purchased in accordance with the
IT Security Policy. In addition, you may not install Lexmark licensed software on non-Lexmark computer
systems, without first ensuring the terms of Lexmark’s license agreement allows such usage. You may not
download or otherwise copy any part of a software program for any reason, including development work,
unless Lexmark has obtained the rights to do so.

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Conflicts of Interest
A conflict of interest may arise if you engage in any activity or advance any personal interests at the expenseof Lexmark’s interests. You are expected to avoid situations in which you could be, or appear to be, unduly
influenced by factors which may prevent you from acting in the best interests of Lexmark. You may not
personally take advantage of opportunities that you discover through your use of Lexmark property,
information or through your position with Lexmark. Accordingly, you are required to review your specificsituation with your manager or the Ethics Committee to assess the nature and extent of any concern andhow it can be resolved.
Competing Against Lexmark
You may not engage in any activity or provide assistance to another individual or organization that markets
products or services that compete with Lexmark’s. You must consult with your manager before pursuing
any activity that might create a conflict of interest with Lexmark.
Supplier Affiliations
Generally, without the prior written approval of the Ethics Committee, you may not be a supplier to Lexmark,represent a supplier to Lexmark, work for a supplier to Lexmark or be a member of a significant supplier’s
board of directors while you are an employee of Lexmark. In addition, you may not accept money or benefitsof any kind for any advice or services you may provide to a supplier in connection with its business with
Lexmark.
Business Gifts and Amenities
Except as noted below, neither you nor members of your family may accept or give gifts or gratuities of any
type from or to any supplier, prospective supplier, business partner, channel partner or other customer.
Gifts include merchandise, travel expenses to business meetings or events, entertainment, or any otheritem of value. However, you may give or accept promotional gifts of nominal value (no more than US$75 orits equivalent in other currencies), such as advertising novelties, in the spirit of commercial politeness. You
should consider whether the frequency or timing of any gift might create the appearance of a conflict ofinterest. Gift cards may not be purchased or distributed to employees, contractors, customers, or suppliers. Any
exceptions must be approved by a member of Executive Management. Giving or receiving cash paymentsof any kind is not allowed.
In very limited situations, it may sometimes be necessary to exchange gifts of greater value to avoid
offending the cultural values of a supplier or customer. Any such situation must be reviewed and approvedby a member of Executive Management.
You may give or accept such customary business amenities as meals; provided the expenses involved are
kept at a reasonable level and their acceptance would not embarrass Lexmark if they were disclosed
publicly. Unless Lexmark has specified to the contrary, you may accept promotional premiums anddiscounts offered by transportation companies, hotels, auto rental agencies and restaurants when they are
offered on the same basis to travelers generally.
If you are offered money or a gift, you should decline the offer and inform the party of Lexmark’s gift policy.
If you receive money or a gift, you should inform your manager immediately. Your manager can help you
make appropriate arrangements to return or donate the gift and, where appropriate, remind the giver of
Lexmark’s gift policy.
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Personal Financial Interests
Without the prior written approval of the Ethics Committee, you should not have a financial interest in any
organization that does business with or competes with Lexmark if that interest might cause you to have aconflict of interest, or the perception of a conflict of interest, with Lexmark. Such organizations include
suppliers, competitors, customers and distributors or organizations that remarket Lexmark products orservices.
Publicly Traded Securities
You should not hold a financial interest in a publicly traded company if the combination of your job, theamount of your investment, and the particular company in which you invested when viewed objectively byanother person, could appear to influence your actions as a Lexmark employee.
In the case of a supplier, if you are involved in deciding whether Lexmark does business with that supplier,
you should not have any financial interest in that company.
These guidelines cannot be avoided by acting indirectly through another person or organization.
Closely Held Organizations
Investments in closely held organizations (typically, closely held corporations, partnerships or sole
proprietorships) are likely to cause concern because the ties between closely held organizations and theirinvestors tend to be more significant and extensive than those between other organizations and theirinvestors. For example, there are generally relatively few investors or owners of such companies, giving
each a greater stake in its ownership and a higher likelihood of participating in the company’s day-to-day
operations.
For these reasons, you may not make any investment in a closely held organization that is a competitor,
supplier, distributor or organization that re-markets Lexmark products or services. Exceptions must be
specifically pre-approved by the Ethics Committee.
Employment of Relatives and Related Persons
Lexmark selects employees based upon their qualifications and the needs of the company.
Lexmark recognizes that persons who are relatives of employees or who are in personal relationships with
employees can be a potentially valuable source of qualified candidates. Nevertheless, in both the hiringand management of such persons, Lexmark wishes to avoid conflicts of interest or partiality or theappearance of such. Employees may not manage, supervise or otherwise report to anyone, even with anintermediate manager or managers in between, with whom they have a close personal relationship suchas a relative, domestic partner, romantic partner or cohabitant.
You are required to disclose such relationships, and you should review your specific situation with yourmanager and the Lexmark Human Resources Department to assess the nature and extent of any concern
and how it may be resolved.
Someone Close to You Working in the Industry
If your spouse, another member of your immediate family, or someone else to whom you are close withworks for or is a competitor or supplier of Lexmark, the closeness of the relationship might lead you to
inadvertently compromise Lexmark’s interests or create an appearance of a conflict of interest. Accordingly,
you are required to review your specific situation with your manager and the Lexmark Human Resources
Department to assess the nature and extent of any concern and how it can be resolved.
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Political and Community Service
Lexmark encourages you to be active in the civic life of your community. However, such service might, attimes, place you in a situation that poses a conflict of interest with Lexmark. Depending on your position in
Lexmark and whether you stand to gain personally, the situation might require you to abstain from certain
decisions. Regardless of whether you abstain, you should make it clear that you are a Lexmark employee
to avoid any charge of trying to conceal your association with Lexmark.
Lexmark has adopted a corporate giving policy. The policy describes Lexmark's commitment to thecommunities in which the company operates by providing financial, product and, volunteer assistance forschools and non-profit organizations considered registered charities. Under this policy Lexmark employs
strict criteria in determining eligibility for donations. For instance, Lexmark will not contribute funding or inkind gifts to labor, fraternal, or religious organizations, individuals, or organizations that discriminate on thebasis of race, color, creed, gender, age, sexual orientation, or national origin. Political contributions canonly be made when legal, appropriate and require prior approval by the CEO or Chief Legal and Compliance
Officer. All charitable donations must be pre-approved by Human Resources and should be in accordancewith the Lexmark Corporate Giving Policy, which includes strict criteria for donation eligibility.
Lexmark will not pay you for time spent running for public office, serving as an elected official or
campaigning for a political candidate, unless required by law. You may, however, take reasonable time off
without pay for such activities, if your Lexmark duties permit the time off and your manager approves it.
You also may use vacation time for political activity.
When you participate in community activities or speak publicly regarding community or political issues,ensure that you do so as an individual. Do not speak or act on Lexmark’s behalf unless specificallyauthorized to do so by a member of Executive Management.

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Accounting Records, Internal Controls and Audits
Lexmark is legally required to maintain accounting records that accurately and fairly reflect its financial
activities and to devise and maintain a system of internal control sufficient to provide reasonable assurance
that transactions are appropriately authorized and recorded. Ensuring these requirements are met is a
responsibility shared by each of us.
Lexmark, external auditors, third parties and various governmental agencies routinely conduct audits ofvarious aspects of the Company’s operations. You are not to provide false, misleading or incomplete
information to anyone conducting these audits. If you do so, in addition to any disciplinary actions you may
face, you and/or Lexmark may be subject to civil or criminal liability.

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Complying with Laws and Regulations
GeneralIt is Lexmark’s policy to comply with all applicable laws, rules and regulations. Lexmark is organized under
U.S. law. As a result, its operations are governed primarily by U.S. laws, rules and regulations.
Lexmark operates through subsidiaries, branches and other legal entities in many countries outside the UnitedStates and is subject to the laws, rules and regulations of those countries and jurisdictions as well. Where
there is a conflict between U.S. law and the laws of another country, the issue is to be resolved bymanagement with the concurrence of Lexmark’s Legal Department or, in the case of tax matters, the VP,
Chief Accounting Officer..
All investigations by governmental authorities, other than tax matters, are to be managed by Lexmark’s Legal
Department. Tax matters are to be managed by the VP, Chief Accounting Officer. You are required tocontact Lexmark’s Legal Department or the VP, Chief Accounting Officer as soon as possible regarding
an inquiry from any governmental authorities or from other parties who have filed, or expressed theirintention to file, a lawsuit involving Lexmark.
Antitrust and Competition Laws
The purpose of competition laws (also known as antitrust, monopoly, fair trade or cartel laws) is to preserveand foster fair and honest competition within a competitive market system.
Under these laws, Lexmark may not enter into agreements with other companies (whether formal orinformal) that unreasonably restrict the functioning of the competitive system. Examples include
agreements or communications between Lexmark and:●●●a competitor to charge the same price for a product or to divide or allocate
markets or customers;
a supplier which limits or controls the supplier’s production or prohibits the
supplier from selling to a Lexmark competitor; ora distributor which prohibits the distributor from handling competitive
products.

These and other agreements that could limit competition are highly questionable, if not illegal, and must be
reviewed with Lexmark’s Legal Department.
A formal agreement with a competitor need not exist to violate these laws. A general discussion followedby common action can be enough to show an implied agreement. In an investigation, every communication,
written or oral, is subject to extreme scrutiny. You must not engage in any communication with a competitor
that could result in price-fixing, bid-rigging (including complementary bidding), allocation of customers ormarkets, boycotts or production limits to restrain trade.
To ensure that Lexmark complies with these laws, all contracts, arrangements and questionable situations
should be reviewed by Lexmark’s Legal Department, except for standard contracts and practices alreadyapproved by Lexmark’s Legal Department (such as standard sales and purchasing agreements andpractices).

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Bribes, Kickbacks or Other Corrupt Transactions
All employees, officers and directors of Lexmark or any of its affiliates, channel partners, service providers,
suppliers, intermediary agents, joint ventures, or third parties acting as a representative, agent, or adviser
to Lexmark or any of its affiliates, must comply fully with applicable anti-corruption laws, including applicableprovisions of the Foreign Corrupt Practice Act.
You are prohibited under any circumstances from directly or indirectly offering, giving, soliciting or receiving
any form of bribe, kickback or other corrupt payment, or anything of value to or from any person ororganization (“corrupt transactions”), including government agencies, individual government officials,
private companies and employees of those private companies except as provided for under the anticorruption policy or this document.
The Foreign Corrupt Practices Act (the “FCPA”) applies to U.S. individuals and companies, including theircontrolled international subsidiaries.
The FCPA anti-bribery provisions prohibit payment of a bribe to a foreign official. The FCPA defines a bribe
as anything of value given or offered to a foreign official to influence an act or decision to obtain, retain or
direct business or to secure any improper advantage. "Anything of value" is not limited to cash.
Foreign officials include: (i) a non-U.S. official or non-U.S. political party, party official or candidate forpolitical office; (ii) an employee of a government-owned company, such as a national utility company; and(iii) an officer or employee of a public international organization, such as a United Nations agency.
The FCPA contains special provisions for expediting payments made to secure routine governmental action.
No such payments may be made without the advance approval of Lexmark’s Legal Department. Any suchpayments must be recorded as an expediting payment in the accounting records of Lexmark.
Any officer, director, employee, agent or stockholder acting on behalf of Lexmark who violates the FCPA
may be subject to substantial fines and/or imprisonment, in addition to any Lexmark disciplinary action heor she may face. If convicted, Lexmark may also be subject to substantial fines.
Corrupt Transactions and Third-Party Relationships
Corrupt offers, promises and payments made through channel partners, service providers, intermediaryagents, joint ventures, or third parties are also prohibited.
Therefore, it is important to conduct due diligence on such partners or agents, and not disregard or ignore
facts which indicate a probability that a corrupt payment may occur. The purpose of due diligence is toensure, to the extent possible, that Lexmark retains only reputable and honest agents, representatives andpartners.
In addition, contracts with agents or third-party representatives and joint venture partners should, to theextent possible, include provisions to mitigate the risk of potential corrupt transactions.
Boycotts and Export Controls
Lexmark’s and its non-U.S. subsidiaries’ ability to export and sell products and services in certain countries
and to certain entities is restricted by U.S. and other laws and regulations. In addition, Lexmark is prohibitedfrom participating in boycotts against other countries which are considered friends of the United States.
U.S. law requires that Lexmark report the receipt of any boycott requests to the U.S. Government. If you
become aware of a boycott request or have any question as to whether a proposed transaction may violate
the export control laws, you should consult with Worldwide Import and Export Compliance or with local
management responsible for export compliance.

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Copyrightable Material
In most cases, the copyrights in employee-generated works of authorship, such as manuals and computer
programs, are automatically owned by Lexmark through operation of law. In other cases, title to the
copyrights is given to Lexmark by contractual provisions. Lexmark’s policy is to limit the reproduction or
distribution of copyrighted material within Lexmark to only that material for which the copyright is owned byor appropriately licensed to Lexmark. To ensure that material not owned by Lexmark is appropriately
licensed, Lexmark may request a license from the owner of such material before permitting the material tobe placed into or on any Lexmark owned distribution channel, including, but not limited to, any corporate email or intranet system. If there is a question of ownership, you should consult your manager before you
distribute material through any distribution channel.

CFIUS and United States Government Imposed Communication Restrictions
The Committee on Foreign Investment in the United States (CFIUS) is an inter-agency committee of the
U.S. Government that reviews transactions that could result in control of a U.S. business by a foreign
person or foreign company, to determine the effect of such transactions on the national security of theUnited States.
In November 2016, Lexmark was purchased by a consortium of Chinese based investors led by Apex
Technology Co. (now Ninestar Corporation) and the private equity firms PAG Asia Capital and Legend
Holdings.
As a result of this purchase, there are several very important, U.S. government-imposed rules about how
Lexmark’s employees and contingent workers may interact with consortium employees, contingent
workers and affiliates. The U.S. government recognizes the synergies that can be achieved by allowing
Lexmark and the consortium to work together on select projects. Unless your management team tells youthat you will be working on one of these projects and you receive approval notification from Lexmark’s
Security Officer, you should not have any contact with anyone from the consortium or its affiliatecompanies.
The vast majority of our employees will have no interaction with members of the consortium, and while
you need to understand these rules, they generally won’t impact your day-to-day activities. For that
handful of employees who will have interactions, you will need to understand the rules prior to any futureinteractions.
You should report to your manager and to the Lexmark Security Officer at security.officer@lexmark.com ifanyone associated with the consortium attempts to contact you for any reason if you are not approved toengage with the consortium. Do not initiate or accept phone calls, meeting invitations, texts, emails, or
instant messages (e.g. WeChat) to or from any person associated with the consortium companies unless
you are working on an Approved Business Relation (ABR), are listed on Lexmark’s Approved
Communications List, and have completed specific training on the process and rules for communicatingwith members of the consortium. You should also report to your manager and to the Lexmark Security
Officer if anyone associated with the consortium attempts to contact you outside of these policies andguidelines.

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Supplier Relationships
You must treat all suppliers fairly. It is essential that suppliers competing for Lexmark’s business haveconfidence in the integrity of our selection process. In deciding among competing suppliers, you should
weigh all the facts impartially. Whether or not you are in a position to influence decisions involving theevaluation or selection of suppliers, you must not exert or attempt to exert influence to obtain special
treatment on behalf of a particular supplier. Suppliers are to be selected in line with Lexmark’s sourcing
strategy and on the basis of a supplier’s ability to satisfy Lexmark’s requirements, which include quality,
price, continuity of supply, capacity, reliability and technology.
To prevent any perception of unfairness, former employees will generally not be allowed to act as a supplieror supplier’s representative for a period of one year after such person’s employment with Lexmark has
ended.
Suppliers should never be used as a means to circumvent Lexmark policy or the law.
Avoid Reciprocal Dealing
Seeking reciprocity is contrary to Lexmark policy and may be unlawful. You may not imply or tell aprospective supplier that your decision to purchase its products or services is conditioned on the supplier’s
agreement to purchase Lexmark products or services or on the supplier’s not purchasing the products orservices of a competitor (or actually imposing such a reciprocal obligation). To avoid allegations ofreciprocal dealing, do not tell a prospective customer that Lexmark deserves the customer’s businessbecause Lexmark purchases products or services from that customer. This does not mean that a Lexmark
customer is precluded from being a Lexmark supplier. It simply means that Lexmark’s decision to buy
products or services from a supplier must be made independently from that supplier’s decision to purchase
Lexmark products and services. Bartering arrangements are allowed only when approved by a member of
Executive Management.

- 18 -Customer Relationships
Lexmark extends appropriate terms to each type of customer. For example, distributors, dealers and end
users purchase certain Lexmark products or services under different terms. However, within each category,
Lexmark endeavors to conduct its business so that all customers who are procuring in similar quantities
and under similar business conditions are treated in a similar manner.
Lexmark will compete vigorously in bidding for government and commercial business. If circumstances
require modified pricing or service terms, the modifications must be specifically approved by an appropriate
level of management.
Premature Disclosure
In most circumstances, Lexmark does not disclose unannounced offerings (including products, prices,
terms and conditions) to a customer or prospective customer that have not been disclosed to customers
generally. Exceptions must be approved by a member of Executive Management.
Truth in Advertising
It is Lexmark’s policy to avoid any misstatement of fact or misleading impression in any of its advertising,literature, exhibits or other public statements. All statements made in support of our products and services
should be true statements that can be supported to the satisfaction of a reasonable person. In addition, anyomission of fact, wrongful emphasis or use of illustrative material that would tend to mislead a reader,
listener or viewer is to be avoided. No claim, comparison or other statement of fact should be included in a
message without having sufficient evidence to support it.
Commission for Referrals
When authorized by Lexmark, sales and marketing employees may refer customers to third-party suppliers
such as Lexmark authorized remarketers, third-party software organizations or financing organizations.
However, you may not accept any fee, commission or other compensation for this activity from anyone
other than Lexmark.
Relationships with Government Customers
What is acceptable practice in a commercial business environment may not be acceptable (and may
possibly be illegal) when dealing with government customers. Therefore, you must be aware of and adhere
to the relevant laws and regulations in each country governing relationships between government
customers and suppliers.
For example, the following activities (whether conducted directly or indirectly) are not permitted when
dealing with U.S. Government customers and may be prohibited in other countries as well:●●●discussing or offering employment or business opportunities which could
personally benefit procurement officials;
offering or providing gifts or gratuities; or
soliciting or obtaining proprietary or source selection information.

Furthermore, Lexmark may be prohibited from hiring former government employees who participatedpersonally and substantially on behalf of the government in procurement activities. You should consult with
Lexmark management and the Lexmark Legal Department before you take any steps to hire such a person.
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Competitor Relationships
Fairness in the Field
If you work in a sales or service activity, Lexmark expects you to compete vigorously and effectively, but
most of all, fairly. You should not take unfair advantage of anyone through manipulation, concealment,
abuse of privileged information, misrepresentation of material facts or other unfair-dealing practices.
Disparagement
It is Lexmark’s policy to sell products and services on their merits, not by disparaging competitors, theirproducts or services. False or misleading statements and innuendoes are improper. You may not makecomparisons that unfairly cast the competitor in a bad light. Such conduct only invites disrespect from
customers and complaints from competitors.
In short, in all your business dealings you should stress the advantages of Lexmark products and services
and be sure that all comparisons are fair and accurate.
Business Contacts with Competitors
Because many companies have multiple relationships with Lexmark, you should be aware that a company
with whom you are dealing, such as a supplier or a customer, may also be a Lexmark competitor. Such
relationships require extra care. It is also inevitable that you, other Lexmark employees and competitors
will from time to time meet, talk and attend the same industry or association meetings. Usually, thesecontacts are perfectly acceptable as long as the requirements of this Code of Business Conduct are
followed.
Acceptable contacts include sales to other companies in our industry, purchases from them, participationin approved joint bids, and attendance at business shows, standards organizations and trade associations.
But even these contacts require caution.
In all contacts with competitors, you should not discuss pricing policy, terms and conditions, costs,
inventories, research and development activities, marketing and product plans, market surveys and studies,
production plans and capabilities, financial performance or any other proprietary or confidential information.
Collaboration or discussion of these subjects with competitors can be illegal. If a competitor raises such a
subject, even lightly or with apparent innocence, you should object, stop the conversation immediately andtell the competitor that you cannot discuss these matters under any circumstances. If necessary, you should
leave the meeting.
In summary, disassociate yourself and Lexmark from participation in any possibly illegal activity withcompetitors; and confine your communication to what is clearly legal and proper. Finally, report any incident
associated with a prohibited subject to Lexmark’s Legal Department as soon as possible.

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Information Concerning Others
Data Protection
Lexmark is committed to following responsible personal data management and protection practices for all
personal data collected from external sources, including customers, prospective customers, business
partners and other third parties. Employees and those business partners and suppliers who manage anduse such data on our behalf are required to do so in compliance with Lexmark’s Privacy Policy andapplicable law.
Acquiring Information
In the normal course of business, you may acquire information about many other organizations, including
competitors. Doing so is a normal business activity. Lexmark gathers this kind of information for such
purposes as extending credit and evaluating suppliers. Lexmark also collects information on competitorsfrom a variety of legitimate sources to evaluate the relative merits of its own products, services andmarketing methods.
There are, however, limits to the ways that information, especially information about competitors, may be
acquired and used. You should not employ illegal or unethical means to acquire a competitor’s trade secrets
or other confidential information. Lexmark does not condone any illegal practices to acquire suchinformation, including stealing, burglary, wiretapping and bribery. Solicitation of, or accepting confidential
data from a competitor’s employees, from Lexmark employees who were previously employed bycompetitors or from Lexmark customers is also prohibited. You may not misrepresent for whom you workor who you are to obtain competitive information or utilize others to undertake activities that would be
unacceptable if pursued by you.
You should not examine information designated as confidential, such data about products or proposals
prepared for customers, business partners, or suppliers unless access to this information is required to doyour job.
Using Information
Information about other companies and their employees should be treated with sensitivity and discretionand not disclosed unless authorized or legally mandated. Other companies are rightly concerned about
their reputations and the privacy of their employees. When using sensitive information, you should use it in
the proper context and make it available only to other Lexmark employees with a legitimate business needto know. In presenting such information, you should disclose the identity of the organization or individuals
only if necessary. If disclosure is not necessary, you should present the information in the aggregate or bysome other means.
Information Owned by Others
Other organizations, like Lexmark, have intellectual property they want to protect as do individuals.
Sometimes they are willing to disclose their confidential information for a particular purpose. If you receive
another party’s confidential information, it is important that you proceed with caution to avoid Lexmark being
accused of misappropriating or misusing someone else’s confidential information.
To avoid the risk of Lexmark being accused of misappropriating or misusing someone's confidential or
proprietary information (whether written or oral), you should determine whether the information actually is
confidential or has restrictions placed on its use. If written information is labeled trade secret, confidential,
proprietary, or restricted, or if you have any other reason to believe that Lexmark may not be free to use or- 21 -

disseminate the information without restrictions, review it with your manager or Lexmark’s Legal
Department and, if appropriate, ask the other party.
The same precaution applies to oral information. If, before entering into a meeting or a conversation, you
think that the information you are about to hear might be considered confidential, you should first establish
clearly in writing that it is not confidential and that its use is unrestricted.
You may only agree to receive confidential information or information that has use restrictions (whether
written or oral) after the terms of its use have been formally agreed to in writing by Lexmark and the otherparty. Any such agreement should be reviewed by Lexmark’s Legal Department. Once another party’s
confidential information is legitimately in your hands, you may not use, copy, distribute or disclose that
information unless you do so in accordance with the terms of that agreement.

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Corporate Social Responsibility

Lexmark is committed to acting responsibly in the global community. Consistent with this commitment, as
a company and as individual Lexmark employees, we must strive to operate in a manner that demonstrates
Lexmark’s respect for human rights, safety standards and environmentally sound business practices.
Promoting Human Rights
Lexmark strives to assure the fair and equitable treatment of our employees and those of our suppliers byprotecting workers’ rights and promoting safe and ethical working conditions. As a Lexmark employee you
have the right to freely chosen employment and freedom of association. In this regard, Lexmark does notuse forced labor, indentured labor, or child labor. Lexmark is committed to compliance with laws regulating
wages, hours and working age.
Ensuring Product Safety
Lexmark Product Safety Programs focus on compliance with worldwide safety and health regulations andlaws. As part of this commitment, Lexmark tests our products in laboratories accredited by third-party
agencies. As part of these efforts Lexmark’s Product Safety teams are tasked with investigating reported
safety incidents and taking appropriate action.
Providing a Safe and Healthy Workplace
The health and safety of our employees is a priority. Lexmark offers workplaces that pursue the safe useof equipment, situations and practices and has developed written programs that focus on legal andregulatory compliance. Should an unsafe working condition or other safety issue occur, you have an
obligation to promptly report it directly to your management or to your Environmental, Health and Safety
team.
Protecting the Environment
Lexmark is committed to preserving and protecting our natural resources and practicing pollution prevention
in the design of our products and services, and in the operation of our facilities. You are encouraged to
discover effective and eco-friendly ways of helping our customers and safeguarding the environment. Yourideas and efforts should seek new ways to deploy cost-effective best practices for energy conservation,
wise water use, and waste reduction through reuse and recycling.

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Key Contacts
Ethics Line: 1-866-477-2029 (toll-free)*
Online: https://secure.ethicspoint.com/domain/media/en/gui/27207/index.html* International access numbers for the Ethics Line are available at the website above.

President and Chief Executive Officer
Allen Waugerman
Tonya Jackson Senior Vice President and Chief People Officer
Brent Lambert, Senior Vice President and Chief Legal and Compliance Officer
Lexmark Legal Services Department
Neill Kahle (NA, LAD and AP)
Kai Wagener (EMEA)
Human Resources Department
Sheri Evans Depp (U.S. and Canada)
Elodie Fresnel (EMEA)
Jennifer Loh (Asia Pacific)
Monica Estrada (Latin America)
Chief Audit Executive, Director Compliance & Security
Trisha Hayes
Data Protection Officer

Chad Talbott
Vice President, Chief Accounting Officer

Ron Vonderhaar
Vice President, Global Marketing
Matthew Dollus
Worldwide Import and Export Compliance
Brad Fruth- 24 -