Visa 2008 Annual Report Download - page 325

Exhibit 14.1
Code of Business Conduct and Ethics
Introduction
This Code of Business Conduct and Ethics (this "Code") applies to all of the directors, officers and employees of Visa Inc. and its subsidiaries and affiliates
(the "Company") and covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic principles to
guide the way we conduct our business. All of our directors, officers and employees must conduct themselves accordingly and seek to avoid even the
appearance of improper behavior. The Code should also be provided to and followed by the Company's agents and representatives.
If a law conflicts with a policy in this Code, you must comply with the law; however, if a local custom or policy conflicts with this Code, you must comply
with the Code. If you have any questions about these conflicts, you should ask your manager how to handle the situation. In addition, the Company maintains
more detailed policies and procedures for many of the topics covered by this Code. Directors, officers and employees of the Company are responsible for
knowing and abiding by these more detailed policies and procedures, which are contained on the Company's internal website.
Those who violate the standards in this Code will be subject to disciplinary action, up to and including termination of employment. If you are in a situation
which you believe may violate or lead to a violation of this Code, follow the guidelines described in Section 17 of this Code.
1. Compliance with Laws, Rules and Regulations
Obeying the law, both in letter and in spirit, is a fundamental obligation we must respect in all of our activities. All officers and employees must obey the laws
of the cities, states and countries in which we operate. Although not all employees are expected to know the details of all these laws, it is important to know
enough to determine when to seek advice from managers or other appropriate personnel.
From time to time, the Company will hold information and training sessions to promote compliance with laws, rules and regulations.
2. Conflicts of Interest
Directors, officers, and employees have an obligation to avoid conflicts, and the appearance of conflicts, between their own interests and their responsibilities
to the Company or its clients. A "conflict of interest" exists when a person's private interest interferes in any way with the interests of the Company. A conflict
situation can arise when a director, officer or employee takes actions or has interests that may make it difficult to perform his or her Company work
objectively and effectively. A conflict situation may also arise when a director, officer or employee, or a member of his or her family, receives improper
personal benefits as a result of his or her position in the Company. Loans to, or guarantees of obligations of, employees and their family members may
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