Code of Business Ethics and Conduct Introduction

The Paychex Code of Business Ethics and Conduct organizes a set of Company standards for proper business conduct so that all of our employees can gain a better understanding of the way Paychex wishes to conduct business. Paychex maintains a strong belief in the value of ethical behavior. The trust and confidence of the public, our stockholders, our clients and our own employees is a critical asset that benefits all.

All members of the Paychex Board of Directors, all Officers, and all Paychex employees (collectively referred to as "employees" throughout this Code), are expected to read and understand this Code of Business Ethics and Conduct. Each of us is personally responsible for making sure that our business decisions and actions comply at all times with the letter and spirit of this Code.

In addition, each of us has a duty to report behavior on the part of others that appears to violate this Code or any other compliance policy or procedure of Paychex. Ethical concerns, questions or complaints may be raised with your immediate supervisor, Human Resources, or submitted directly to the Audit Committee as outlined within this Code. All concerns, questions, and complaints will be taken seriously and handled promptly and confidentially. No retaliation will be taken for raising any concern, question or complaint in good faith.

If at any time you have any questions about the Paychex Code of Business Ethics and Conduct, or your own application of these ethics, contact your supervisor, manager, or Human Resources for further assistance.

For more information about Paychex Investor Relations, please contact:

Terri Allen
Paychex Investor Relations
911 Panorama Trail S.
Rochester, NY 14625
585-383-3406

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