Ethics

Office Depot is committed to the highest standards of ethics and transparency in its operations. We believe organizations that remain loyal to their beliefs and have mechanisms in place to fulfill these goals build a foundation for long-term sustainable success.

The Global Compliance Office provides education and training to build awareness of our ethical business practices and compliance policies among our associates worldwide. Our compliance team’s efforts reach every global market each year through a combination of instructor-led and computerbased Code of Ethical Behavior and the Anti-Corruption and Bribery training along with and awareness communications. In 2013, the Global Compliance Office conducted ethics and compliance training in 17 countries to reinforce our commitment to doing what is right. Our ethics and compliance program was further strengthened through live instructor-led Anti-corruption and Bribery Policy training to associates in six markets.

In addition, Office Depot conducted numerous other trainings on topics such as Anti-Harassment, Anti- Money Laundering, and Insider Trading to further exemplify our commitment to compliance initiatives and educating our associates on the laws in which we must operate under. We also expanded the reach of our Whistleblower Program and Financial Compliance Policy to include our global operations.

Office Depot regularly evaluates our internal compliance programs against industry standards and validates their effectiveness by engaging outside legal, audit and ethics compliance partners in this evaluation.

Office Depot Hotline

The Hotline is our global ethics and compliance communications forum for associates to voice their concerns or report violations pertaining to financial integrity or our Company policies. Operated by an independent and impartial third party, our Global Compliance Office administers the program to ensure that concerns are thoroughly investigated and routed to the correct investigation team.

We offer an international case reporting solution available in 20 languages via phone and Web, and our domestic hotline program enables associates to anonymously text concerns on ethics matters. Office Depot’s reporting mechanisms are designed in accordance with local data privacy requirements, allowing all global associates to communicate any violations of the law, our Code of Ethical Behavior or other relevant Company policies.

OfficeMax: Leadership in Ethical Business Practices

Our focus on integrity has led OfficeMax to be named as one of 2013’s World’s Most Ethical Companies by Ethisphere Institute. This honor is based on our code of ethics, sustainable business practices, corporate citizenship, and nominations from senior executives, industry peers, suppliers and customers. It’s the second consecutive year OfficeMax has received the ethics award.

OfficeMax was also honored with Ethisphere Institute’s Ethics Inside Certification (EIC) for 2012-2013, as a result of our strong ethics and compliance program, culture of ethics, reputation and leadership, corporate citizenship and responsibility initiatives, and governance systems.
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As part of our strong compliance program, OfficeMax trained associates globally on our Code of Business Conduct. This course served as the foundation of our ethics program and was one of the many compliance courses offered to our associates in 2013. Through the use of computer-based training and the support of our executive leadership team, we were able to train our associates throughout all levels of our organization which demonstrated our commitment to upholding company values and global compliance initiatives.

OfficeMax Tipline

The OfficeMax Tipline was our independent hotline program staffed by an outside company with operators capable of communicating in more than 100 languages. This program created a selfgoverning way for associates to voice their concerns about violations with applicable laws, internal policies, and circumstances of dishonesty or theft within the company. We value the voice of our associates and offered this program with the capability for the reporter to remain anonymous. We investigated all reports to the fullest extent possible in an effort to ensure our workplace was free from conflicts and retaliation.