Visa Code Of Business Conduct And Ethics

We Honorthe CodeWe Foster a Cultureof IntegrityWe Speak UpWe Safeguard Our Assetsand InformationWe Work Openly and HonestlyDo Your Part — Speak UpCooperateIf you are asked to do something that makesyou feel uncomfortable, or you see or suspectactivity that goes against our Code, the law or ourvalues, let someone know. Choose the reportingchannel that feels right for you. Optional channelsfor raising a concern include:Be sure to cooperate in any misconduct investigation.Failure to cooperate or interfering with aninvestigation may result in disciplinary action,up to and including termination. Human Resources The Compliance Department or theBusiness Conduct OfficeWe Connectthe WorldResourcesWhat Happens Aftera Concern is RaisedWe act decisively to do what’s right. Your manager or upper-level managerWe Upholdthe LawNo retaliationWe do not tolerate retaliation against anyone whoparticipates in an investigation or raises a concernin good faith. Retaliation may result in disciplinaryaction, up to and including termination. The Legal Department Our Confidential Compliance Hotline(see next page for more information)accessible 24/7 in multiple languagesVisa Code of Business Conduct and Ethics 7Our goal is to ensure a safe and respectfulenvironment where everyone can comeand do their best work. When we learn of apotential violation of the Visa Code of BusinessConduct and Ethics or other Visa policy by VisaStaff, a confidential, professional investigationis conducted. We address misconduct througha formal resolution process, and confirmedviolations of our Code and other companypolicy may result in corrective action, up toand including termination of employment.NoteNothing in this Code or in any Visa policyprevents you from communicating directlywith government agencies or law enforcementabout actual or potential violations of lawsor regulations. You do not need the priorpermission of Visa’s Legal Department toengage in such communications, nor doyou need to inform the company aboutsuch communications.

We Honorthe CodeWe Speak UpWe Foster a Cultureof IntegrityWe Safeguard Our Assetsand InformationWe Upholdthe LawWe Connectthe WorldConfidential Compliance HotlineThe Confidential Compliance Hotline, operated by athird party, lets you share your questions, concerns orcomments online or by phone, 24 hours a day, sevendays a week. You may report anonymously, wherepermitted by local law. Keep in mind that anonymousreports are more difficult to investigate — identifyingyourself may expedite and ensure thorough reviewfor the resolution of your concern.Note that Visa’s processes incorporate local laws andregulations related to the reporting and treatment ofconcerns through the Hotline and inform staff fromaffected countries where applicable. Make a call: 1-888-289-9322 (see directory for thephone number in your country). If you wish toremain anonymous, you may indicate so whenmaking your report. Whether anonymous or not,you will receive a unique password for follow-upsvia the Hotline portal.In whatever way you choose to contact us, yourconcern or question will be addressed promptly,and your identity will be kept confidential to thefullest extent possible.For guidance on the Code of Business Conduct andEthics or questions involving employee conduct,contact the Business Conduct Office to submit aninquiry or complaint. You may also make an inquiryor a report through Visa’s Confidential Hotline(online or call in). Contact the Hotline here.ResourcesHow do I find the correct Hotlinenumber in my country?You may contact our Hotline from anylocation by going online or by phoneusing the instructions below:1Use the international toll-freedialing codes web page2Select the country from whichyou are calling3Dial the toll-free number4Dial the Hotline number:1-888-289-9322 (see directory forthe phone number in your country)Visa Code of Business Conduct and Ethics 8

We Honorthe CodeWe Speak UpWe Foster a Cultureof IntegrityWe Safeguard Our Assetsand InformationEveryone’s ResponsibilitiesManager-Specific ResponsibilitiesWe are all accountable for our actions and honorour commitment to act ethically and in compliancewith the law.Managers have additional responsibilities and serveas role models. Managers are expected to:Here are just a few ways we demonstrate ethicsin every situation: We lead by example. Be a role model for others andsupport your team so they can follow your lead. We inspire others. Create a work culture thatinspires employees to act with integrity and speakup with concerns. We are always honest in our business dealingsinternally and externally. We are committed to complying with the Code,company policies and all laws and regulations. We seek guidance from managers or othercompany resources when needed (refer toResources for whom to contact). We report suspected violations of the Code,Visa policies or the law. Keep an open door — Encourage your teammembers to come to you with questions andconcerns. Be available and listen. Help them makesound decisions in their work. Do not tolerate retaliation — Never retaliateagainst members of your team for sharing concernsor asking questions and take swift action to protectemployees from retaliation by others. Escalate concerns — Promptly report anybehavior you suspect is unethical, illegal, violatesour Code or policies or goes against the way we dobusiness. However, you should not investigate theconcern yourself.Even those in leadership roles sometimes need help.If you are not sure of the proper course of action, seekguidance. Help your team find answers if they raise aconcern that you cannot resolve. You can access theEthical Manager’s Toolkit here. We encourage open communication, includinga Speak Up culture to raise concerns without thefear of retaliation.Visa Code of Business Conduct and Ethics 9We Upholdthe LawWe Connectthe WorldResources

We Honorthe CodeWe Speak UpWe Foster a Cultureof IntegrityWe Safeguard Our Assetsand InformationWe Foster a Cultureof IntegrityPromoting a culture of integrity requiresall of us to demonstrate respect, ethicalbehavior, good business judgment andtrust. This shared commitment is integralto protecting our company.Visa Code of Business Conduct and Ethics 10We Upholdthe LawWe Connectthe WorldResources

We Honorthe CodeWe Speak UpWe Foster a Cultureof IntegrityWe Safeguard Our Assetsand InformationWe Upholdthe LawWe Connectthe WorldResourcesWe Respect Each OtherWe create a culture of inclusion where everyone is treated with dignity and respect.Harassment and DiscriminationWe value the individual differences, experiencesand capabilities of each employee. Our collectivestrength — enhanced by the diverse backgroundsand perspectives of our worldwide teams —makes Visa a better place to work and a better businesspartner for our clients and merchants. We are stronglycommitted to equal opportunity in all employmentdecisions and promote a culture where everyoneis treated with dignity and respect. Maintainingan inclusive environment also involves removingbarriers experienced by employees with disabilities byproviding reasonable accommodations when needed.Visa prohibits any form of harassment or discriminationbased on a protected class: race, color, sex, sexualorientation, gender identity or expression, creed,religion, age, marital status, national origin, ancestry,pregnancy, medical condition, veteran status,citizenship, physical or mental disability and any othercharacteristic unrelated to job requirements protectedVisa Code of Business Conduct and Ethics 11by law. Discrimination or harassment based ona protected class may take the form of written orverbal, actions or visual such as photos or videos.If you see, suspect or experience harassmentor discrimination, report it to your manager,AskHR, Human Resources or through theConfidential Hotline (1-888-289-9322).What Would You DoWhat if your manager is the one discriminatingagainst you? Where do you turn?All Visa employees have the right to a positive workenvironment free of harassment and discrimination.If you feel your manager or anyone is discriminatingagainst you or harassing you, seek help by reportingit to Human Resources, Legal and Compliance, theBusiness Conduct Office or the Confidential Hotline(1-888-289-9322).

We Honorthe CodeWe Speak UpWe Foster a Cultureof IntegrityWe Safeguard Our Assetsand InformationRespect at WorkRelationships at WorkRelativesClose personal relationshipsVisa also recognizes that on occasion, employeesmay become involved in a close personal relationship(defined as dating or a romantic or sexual relationship).To ensure all potential conflicts of interest have beenaddressed, disclosure of the relationship to HR isrequired even if the employees are peers, work onWe Connectthe WorldResourcesClose Personal RelationshipsConduct, including speech, that is disrespectful of Visa staff or others involvedwith Visa could lead to corrective action, up to and including termination.Visa recognizes that there will be times when theemployment of relatives may occur in the workplace.Such relationships may result in conflicts of interest,potential bias or favoritism or adversely affect the abilityof Visa to operate effectively. Therefore, you are requiredto advise Human Resources or AskHR immediately ifyou are aware of the employment, or pendingemployment, of a relative.We Upholdthe Lawdifferent teams, have different functional roles or workin different locations. You may disclose using AskHR.This is a confidential process to help Visa assess anyorganizational impact from the relationship.Under no circumstances may an employee ina management or supervisory position have aclose personal relationship with an employee orcontingent worker whom they supervise (directlyor indirectly) or whose terms or conditions ofemployment they may influence.If you are unsure whether a relationship needsto be disclosed, contact Human Resources or theBusiness Conduct Office to discuss in confidence.For additional information on this topic, please seethe Employee Handbook.Visa Code of Business Conduct and Ethics 12 A disclosure to HR is required fordating, romantic or sexual relationshipsbetween employees. Under no circumstances may an employeein a management or supervisory positionengage in a close personal relationship withan employee or contingent worker in thesame reporting line or whom they supervise(directly or indirectly) or whose termsor conditions of employment they mayinfluence as per the HR Employee Handbookand Code of Business Conduct and Ethics.Remember Immediately report anyone with a weaponto Global Security and Safety

We Honorthe CodeWorkplace ViolenceWe are committed to providing a safe and secureworking environment. Report any activity or behaviorthat appears to be intimidating or violent or threatensthe security or safety of our employees.We Speak UpWe Foster a Cultureof IntegrityWe Safeguard Our Assetsand InformationAlcohol may be provided at some company events onVisa premises with advance approval from an ExecutiveCommittee member. At these events, we are still actingas representatives of Visa; use good judgment.Protecting Employee PrivacyRemember — Visa employees, consultants,contractors and guests are prohibited from bringingany kind of weapon into any Visa facilities (except forauthorized law enforcement officials), irrespective ofany local laws that may permit such action. If you seesomeone with a weapon in a Visa facility, reportit immediately to Global Security and Safety.Visa respects the confidentiality of employee information.As with consumer and client information, we takemeasures to protect our employees’ personal records andinformation. Only those with appropriate authorizationmay access employment records, and they may do soonly for legitimate legal or business purposes. You havecertain rights to access your own records.Reporting a Safety Incident: If you need to report asafety hazard, injury or work-related illness, pleasenotify Safety@visa.com, phone 1-571-439-7111or toll-free 1-855-544-VISA (8472).If you mistakenly receive the personal information ofother Visa employees, you should contact the VisaSecurity Incident Response Team (VSIRT) immediately anddo not access or use the data.Alcohol and Drug UseFreedom of AssociationAlcohol and drugs can impair your ability to performyour job and place others at risk. Visa employeesare prohibited from using, selling, possessing orbeing under the influence of alcohol, marijuana,illegal drugs or any illegal substance on our propertyor while working on our behalf. Prescription andover-the-counter medicine is permitted if you takeit according to your doctor’s instruction and you areable to safely perform your job.Visa recognizes employees’ right to freedom ofassociation and collective bargaining.We Upholdthe LawWe Connectthe WorldResourcesWhen requested, Visa will provide reasonableaccommodations to employees with disabilitiesand will continue to work with vendors to improvethe accessibility of our internal tools. Our productand development teams should consider accessibilityas a key requirement to avoid creating barriers to usefor our users with disabilities.If you require an accommodation due to a disability,consult with Human Resources, or if you have aquestion about procuring or building accessibleproducts, consult with Visa’s Accessibility Team.As with consumer and clientinformation, we take measures toprotect our employees’ personalrecords and information.Find out moreAccessibility and Accommodations Integrity and Respect at Work Insite PageAs part of our efforts to maintain an inclusive workplacefor our employees and increase financial inclusion forour customers, Visa is committed to improving theaccessibility of our tools and products. Harassment and Discrimination PolicyVisa Code of Business Conduct and Ethics 13 AskHR Employee Handbooks Working with Employee Relations

We Honorthe CodeWe Speak UpWe Foster a Cultureof IntegrityWe Safeguard Our Assetsand InformationWe Upholdthe LawWe Connectthe WorldResourcesWe Avoid Conflicts of InterestVisa has a Conflict of Interest Policy to help us avoid conflicts of interest and theappearance of conflicts between our personal interests and those of Visa. Avoidingconflicts of interest is an important way we can demonstrate our commitment toVisa’s Code of Business Conduct and Ethics and support our strong ethical culture.As Visa employees, we share a common interest inprotecting our company. We are transparent in ourbusiness dealings and avoid situations that put ourpersonal interests in conflict with those of Visa orlead others to question our business or professionalobjectivity. If you become aware of a potentialconflict, you have an obligation to disclose it.At right are some situations commonly associatedwith potential conflicts and that must be disclosedper the Conflicts of Interest Policy. It is impossible tooutline all potential conflicts of interest, so we mustuse good judgment in our day-to-day activities: Outside employment, including self-employment,consulting activities even if they are not in thepayments space, or involvement in any start-upventures, including starting your own business(e.g., early stage start up) or engaging Visa staffin such a venture. Advisory board, Board of Directors or equivalentfiduciary roles for a residential, charitable, not-forprofit, religious, or social organization, or as part of yourofficial Visa job duties (e.g. sitting on the Board of a Visaentity or partner), or you wish to serve on a Board forany entity owned or controlled by you or your family. Unpaid professional activities for any paymentservice or related company or entity that has arelationship with Visa.Visa Code of Business Conduct and Ethics 14Continued on next page

We Honorthe Code Close relative who works for any organization thathas a relationship or competes with Visa in any way. Previous employment with a Visa businesspartner, where you are now involved in decisionsregarding that organization. Financial interest or investment (as owner, partner or stockholder) of 1% orgreater of the total outstanding shares of anypublicly traded company. (either directly or through an investment/venture fund where you have investmentcontrol or influence over investment decisions)in a private company/startup in a paymentservice or related company or entity that has arelationship with Visa. Relationships with government officialsor offices that have influence over matters thatcould affect Visa business. Prior government employmentWe are transparent in our businessdealings and avoid situations thatput our personal interests in conflictwith those of Visa or lead others toquestion our business objectivity.We Speak UpWe Foster a Cultureof IntegrityWe Safeguard Our Assetsand InformationWe Upholdthe LawWe Connectthe WorldResourcesCommercial BoardsAdditional requirements exist for serving on an advisoryboard, Board of Directors or equivalent fiduciary oradvisory role for organization types not covered underthe Conflict of Interest Policy (e.g., most for profitentities). For these situations, employees at a job level ofSVP or higher will be allowed to seek such roles if certaineligibility and approval requirements are met as statedin the External Board, Advisory or Equivalent RolesPolicy. Commercial board service by VPs and below is notpermitted unless an exception is granted by theCEO and Chief Legal and Administrative Officer of Visa.RememberIf you have any additional questions or concernsregarding your conflict of interest disclosure obligations,either under the Conflict of Interest Policy orExternal Board, Advisory or Equivalent Roles Policy,please contact the Business Conduct Office. Conflict of Interest Policy Become familiar with situations that maypresent a conflict of interest Know when to disclose an outside activityfor approval Seek help if you are unsure whether asituation creates a conflict of interestFind out more External Board, Advisory or EquivalentRoles Policy Conflict of Interest Disclosure Form Anti-Bribery PolicyAvoid situations that could: Impair objectivity in performing Visa job duties Travel and Expense and Purchasing CardProgram Policy Cause or create a perception of favoritism tooutside organizations or individuals Political Participation, Lobbying andContributions Policy Interfere with your ability to perform Visa job duties Create actual or potential harm to Visa’s businessor brand reputationVisa Code of Business Conduct and Ethics 15

We Honorthe CodeWe Speak UpWe Foster a Cultureof IntegrityWe Safeguard Our Assetsand InformationWe Safeguard OurAssets and InformationBy safeguarding our physical assets,intellectual property and confidential businessinformation and maintaining accurate financialrecords according to established guidelines,we ensure Visa’s continued success.Visa Code of Business Conduct and Ethics 16We Upholdthe LawWe Connectthe WorldResources

We Honorthe

Visa is committed to complying with applicable laws . in every decision we make, and in every action we take. This includes: Upholding the highest standards for government . work, including procurement rules. Not doing business with sanctioned governments, jurisdictions, individuals and entities. Complying with Visa