Supplier Guiding Principles
IV. Bribery and Corruption
Compliance, including but not limited to, matters involving import, export, bribery and corruption concerns
Supplier represents and warrants to Office Depot that all Products supplied have been or shall be produced,
packaged, labeled, shipped and documented in compliance with all applicable laws of the respective country in
which the goods are produced, packaged and shipped, and all other applicable federal, state and local laws,
regulations and administrative rules or orders, including but not limited to those involving or enforced by U.S.
Customs and Border Protection. Supplier further represents and warrants that it is in compliance with all laws, rules
and regulations that are applicable to its relationship with Office Depot including, but not limited to, U.S. laws
regulating prohibition of bribery, anti-terrorism, asset controls and corruption, as well as applicable import or export
laws, regulations and administrative rules or orders. Suppliers are required to notify Office Depot in advance of any
conflicts of interest which may impact the Supplier’s ability to meet compliance requirements. This includes any
relationships with foreign officials or a non-U.S government agency. Supplier shall notify Office Depot immediately
in the event of circumstances or changes that would or may affect Supplier’s ability to remain in compliance with
Office Depot’s compliance standards.
Conflict of Interest: Suppliers should avoid actions that may result in conflicts of interest, which include offering or
providing personal gifts, favors, personal travel expenses, lodging, or other housing, services of any kind, excessive
meals and entertainment, or any other thing of value to Office Depot associates.
Anti-Corruption
Supplier must maintain the highest standards of moral and ethical conduct at all times. Supplier shall not engage in
any form of corrupt practices including, without limitation to, extortion, fraud, impersonation, false declarations or
bribery. Bribes, implied or offered, with the intention of obtaining or retaining a business or other improper
advantage are not to be offered or accepted.
Gifts and Hospitality
Supplier must adhere to the following Office Depot policies regarding gifts and hospitality to help alleviate any
perception of impropriety:
Office Depot associates are not to accept gifts of more than $50 USD in value and Supplier may not offer such
gifts. There are no exceptions.
Office Depot associates are not permitted to purchase items directly from Supplier.
Supplier is to immediately report to Office Depot any inappropriate requests or solicitations made by Office Depot
associates. Suppliers may do so by reporting to Office Depot’s hotline at www.odhotline.com
Suppliers must keep a written account of all payments (including meals, entertainment, gifts or items of value)
made on behalf of Office Depot.