Visa 2008 Annual Report Download - page 331

Code of Ethics for Senior Financial Officers
The CEO and all senior financial officers (including the CFO, the principal accounting officer, controller, and any persons performing similar functions) of
Visa Inc. or its subsidiaries (collectively, the "Company") are bound by the provisions of the Company's Code of Business Conduct and Ethics and are also
subject to the following additional specific policies:
1. The CEO and all senior financial officers are responsible for full, fair, accurate, timely and understandable disclosure in the periodic reports required to
be filed by the Company with the United States Securities and Exchange Commission and in other public communications made by the Company.
Accordingly, it is the responsibility of the CEO and each senior financial officer promptly to bring to the attention of the Board of Directors any
material information of which he or she may become aware that could affect the disclosures made by the Company in its public filings or otherwise
assist the Board of Directors in fulfilling its responsibilities.
2. The CEO and each senior financial officer shall promptly bring to the attention of the Audit and Risk Committee any information he or she may have
concerning (a) significant deficiencies in the design or operation of internal controls which could adversely affect the Company's ability to record,
process, summarize and report financial data or (b) any fraud, whether or not material, that involves management or other employees who have a
significant role in the Company's financial reporting, disclosures or internal controls.
3. The CEO and each senior financial officer shall promptly bring to the attention of the General Counsel or the CEO and/or, as appropriate, to the Audit
and Risk Committee or the Board of Directors, as applicable, any information he or she may have concerning violations of the Company's Code of
Business Conduct and Ethics and of these additional policies by any management or other employees who have a significant role in the Company's
financial reporting, disclosures or internal controls.
4. The CEO and each senior financial officer shall promptly bring to the attention of the General Counsel or the CEO and/or, as appropriate, to the Audit
and Risk Committee any information he or she may have concerning evidence of a material violation of the securities or other laws, rules or regulations
applicable to the Company and the operation of its business, by the Company or any agent thereof, or of violation of the Code of Business Conduct and
Ethics or of these additional policies.
5. The CEO and each senior financial officer shall promptly bring to the attention of the General Counsel or the CEO and/or, as appropriate, to the Audit
and Risk Committee or the Board of Directors, as applicable, any material transaction or relationship that arises and of which he or she becomes aware
that reasonably could be expected to give rise to an actual or apparent conflict of interest between personal and professional relationships.
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