At Staples, we strive to work with suppliers who treat their workers with dignity and respect, adhere to applicable laws and regulations, and make their products in an environmentally sustainable manner. Accordingly, we require each supplier providing us with Staples Brand Products, Direct Import Products and/or Contracted Manufacturing Products to comply with the following Supplier Code of Conduct (“our Code”).* We strongly recommend that our other suppliers comply with our Code or similar standards:

Forced Labor: Suppliers shall not use forced labor, whether in the form of prison labor, indentured labor, bonded labor, or otherwise.

Child Labor: Suppliers shall not employ people younger than 14, or the minimum age for completing compulsory education in the country of manufacture, whichever is higher.

Harassment and Abuse: Suppliers shall treat every employee with respect and dignity, and shall not subject any employee to physical, sexual, psychological, or verbal harassment or abuse.

Nondiscrimination: Suppliers shall not subject any person to discrimination in employment (including hiring, salary, benefits, advancement, discipline, termination, or retirement) on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin.

Health and Safety: Suppliers shall comply with applicable environmental laws and regulations and provide a safe and healthy working environment to prevent accidents and injury to health occurring within or arising out of the course of work, or as a result of the operation of employer facilities.

Freedom of Association and Collective Bargaining: Suppliers shall recognize and respect the right of employees to freedom of association and collective bargaining.

Wages and Benefits: Suppliers shall pay employees at least the minimum wage required by local law, or the prevailing industry wage if no minimum wage law applies, and shall provide legally mandated benefits.

Hours of Work: Suppliers shall not require employees to work more than the local legal limit and employees should be granted at least one day off in every seven–day period. Employees should not be required to work more than 60 hours a week except in extraordinary business circumstances.

Overtime Compensation: In addition to their compensation for regular hours of work, suppliers shall compensate employees for overtime hours at the applicable premium rate in their country. In countries that have not established premium overtime rates, suppliers shall not pay employees less than their regular hourly rate for overtime hours.

Monitoring and Compliance

To ensure compliance with our Code, Staples regularly monitors the factories producing Staples Brand Products, Direct Import Products and/or Contracted Manufacturing Products through a series of scheduled and unscheduled audits and visits by third parties and Staples personnel. We seek relationships with suppliers that are committed to manufacturing such products under fair and safe labor conditions and sound environmental practices. If we determine that a particular factory does not comply with our Code, we typically strive to work with the supplier to develop and implement an appropriate corrective action plan. Nevertheless, depending upon the circumstances, Staples may elect to end its relationship with a supplier that produces Staples Brand Products, Direct Import Products and/or Contracted Manufacturing Products at any time for failing to adhere to our Code.

Updated 8/22/2005

Posted 10/11/2005

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* Staples Brand Products are products, including all labeling and packaging, which are marked with a brand name belonging to Staples or one of its affiliates or subsidiaries. Direct Import Products are products for which Staples or one of its affiliates or subsidiaries is the importer of record. Contracted Manufacturing Products are products in connection with which Staples or its affiliates or subsidiaries owns tangible or intangible property used in the production process, such as molds, equipment, patents, etc.