Code of Business Ethics and Conduct Reporting Corporate Misconduct, Complaints, Concerns

Anyone who has a concern about the conduct of a Paychex executive or other officer, or about the Company's accounting, internal accounting controls or auditing matters, may communicate that concern directly to the Audit Committee Chairman of the Paychex Board of Directors.

Employees may use a toll-free number published on the Company's Web site to initiate this communication. The toll-free number (1-866-494-3161 extension 400) is established and coordinated by a confidential and independent third party service. Prior to engaging the Audit Committee Chairman, the employee should consider using the Paychex Problem Solving Policy (refer to the employee handbook) to communicate a complaint or concern.

  • The Audit Committee Chairman will receive all complaints or concerns relating to corporate misconduct and internal controls or auditing matters and may designate a person within Paychex to assist with the investigation.
  • The status of all complaints will be reported on a quarterly basis to the full Audit Committee and, if the Committee so directs, to the full Board.
  • The Audit Committee may request the retention of outside counsel or other advisors, for any complaint addressed to it.
  • A complaint may be submitted on an anonymous basis. However, it will be more difficult to investigate the complaint if the Audit Committee or the designee is unable to discuss the matter with the employee or employees involved.
  • The Audit Committee will designate a person to maintain a confidential filing system for the retention of all complaints or concerns as well as the final determination of the investigation. Only members of the Audit Committee and their designees have access to these files.

Any employee of the Company may not directly or indirectly terminate, demote, suspend, threaten, harass, or otherwise discriminate against an employee who has provided information or otherwise assisted in any investigation regarding corporate misconduct.

All retaliation complaints relating to financial misconduct and internal control or accounting matters should be directed to the Audit Committee Chairman. The Chairman may notify the Internal Audit Manager or Human Resources to handle the complaint. The complaint must be true or believed to be true and must provide a sufficient amount of detail to support the claim of retaliation and proceed with an investigation. Based on the all information collected, the appropriate disciplinary action will be taken including possible termination.

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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For more information about Investor Relations, contact Terri Allen at:

585-383-3406 
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