Ethical Conduct

Our Code of Ethics defines our ethics policies and procedures globally. We highlight and reinforce awareness of these standards through communications from senior managers and ethics staff, ethics training, a global independent ethics reporting and help line, proper investigation and enforcement procedures, and internal monitoring and auditing controls. These actions help maintain and enhance a culture of accountability and integrity.

Code of Ethics

Staples' Code of Ethics covers the following major topics:

Training

We launched our ethics training program in 2005. Our training covers key aspects of our Code that all associates need to know, including real–world ethical dilemmas that associates might face, and provides information on the many ways associates can get help and report concerns. We are committed to continually improving our ethics training to ensure that it resonates with associates across the organization and addresses key risks.

Seeking Advice and Reporting Concerns

Associates have many ways to seek guidance on ethical issues they face and report concerns. We encourage associates to speak with their manager or another member of management if they feel comfortable, or they can contact our ethics team, contact HR, or file a report through our independent third party reporting and help line. Available to all Staples associates globally via phone or the Internet, this tool enables associates to file issues confidentially and anonymously if they choose, outside of company channels. Regardless of how an ethics issue comes to our attention, we maintain a strict policy of no retaliation for concerns raised in good faith.

• Ethical Conduct
• Supplier Responsibility
• Staples Soul Main

• Code of Ethics (PDF)
• Supplier Code of Conduct (PDF)
• Ethics Section - 2006 Staples Soul Report (PDF)
• 2006 Staples Soul Report (PDF)

• Corporate Governance