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Office Depot Corporate Disclosure in adherence to California Transparency in Supply Chain Act

The California Transparency in Supply Chains Act of 2010 (SB 657) (the "Act") is effective in the State of California as of January 1, 2012. The general purpose of the Act is the elimination of slavery and human trafficking in product supply chains and providing transparency to consumers so that they may make educated purchasing decisions. The Act requires companies to disclose their efforts in ensuring that their supply chains are free of slavery and human trafficking. Office Depot fully supports these efforts and seeks to ensure that throughout our supply chain, high standards of safety, quality and human rights are upheld. We continuously look at ways to enhance our processes and address such global concerns. Specific to our efforts to ensure and verify the absence of slavery and human trafficking in our direct supply chain, we undertake the following measures:

Since the implementation of Office Depot social and vendor compliance program in 2003, Office Depot has made value-based management the framework around which our global business strategy is constructed. In doing so, we have committed to uphold the highest ethical, social and environmental standards in the conduct of our business and the operation of our supply chain. Accomplishing this commitment requires a comprehensive set of policies and programs integrated throughout our business operations.

Office Depot's Supplier Guiding Principles is an important part of our corporate responsibility framework. Our underlying principles provide guidelines and standards for our business partners engaged in the manufacturing, assembly, and distribution operations of our products. We intend to work only with reputable suppliers and manufacturers who will lawfully produce our goods through fair and honest dealing, in decent working conditions without exploitation and with regard to the environment. Office Depot is committed to managing a consistent, effective and comprehensive monitoring system that allows us to measure the progress and achievements of our social and vendor compliance policies and programs.


Supplier Verification and Certification:

Office Depot enters into trade vendor purchasing agreements or purchase order terms and conditions with each of our direct suppliers. Such agreements require our suppliers to comply with all applicable laws and regulations, as well as adhere to certain supplier guiding principles, including prohibitions on forced or child labor, slavery and human trafficking. Our supplier guiding principles also require our direct suppliers to certify that the materials incorporated into our products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. Commencing in 2012, annual certification is required of our suppliers.

Office Depot works closely with its suppliers through a continuous process improvement approach to enhance our supply chain business model as well as address any potential issues within the supply chain. This process includes on-boarding supplier assessments and audit protocols.


Audits:

Suppliers and their factories producing Office Depot's private label and direct import products are selected for a vendor compliance audit. These audits are performed or evaluated by an independent third party to verify compliance with the Office Depot Supplier Guiding Principles and social and vendor compliance policies and programs. All of our private label and direct import product suppliers are expected to meet our requirements as a condition of doing business with Office Depot.

The audits are conducted within an announced "audit window" by an approved third party audit firm. The third party auditors are required to maintain certain levels of experience and corresponding credentials to ensure that compliance issues are detected and immediately communicated. Office Depot has remediation and continuous improvement processes in place in the event of findings that are not consistent with Office Depot's standards and principles. In the event of less than satisfactory findings, Office Depot works closely with the applicable supplier to implement a Corrective Action Plan (CAP). The corrections of the detected findings are validated during a re-audit, which is typically conducted within six to twelve months depending on the audit grading. Office Depot has a zero tolerance policy for the presence of forced labor and child labor as well as other critical principles. In the event any zero tolerance finding is uncovered, we require the supplier to take immediate corrective action or be subject to termination.


Accountability:

All of Office Depot's associates and suppliers are expected to conduct business ethically and in accordance with all applicable laws and regulations. Office Depot's associates are further required to comply with Office Depot's Code of Ethical Behavior and failure to act accordingly will result in corrective action, including the possibility of termination of employment. Any Office Depot supplier that fails to comply with applicable laws or ethical business practices may be subject to immediate business suspension or termination.


Training:

Office Depot continuously develops and enhances our training programs for our associates. We provide regional training to our associates and our associates are required to acknowledge and adhere to our Code of Ethical Behavior, which includes compliance with all applicable laws where Office Depot conducts business. Additionally, we are in the process of enhancing our associate training for our associates who are directly responsible for our supply chain management on mitigating risks of slavery and human trafficking and anticipate such training to commence in early 2012.