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Responsible Sourcing

Staples is committed to providing our customers with top-quality products at a reasonable price, that are also manufactured responsibly. That means we expect workers making Staples® Brand Products to be treated fairly and with dignity and respect, and that the products themselves are made in an environmentally sustainable manner. In addition, we demand adherence to any and all appropriate international and U.S. laws, regulations and industry standards applicable in the countries where Staples operates.

Staples® Supplier Code of Conduct

To establish clear guidelines for responsible operation, we developed the Staples Supplier Code of Conduct to help ensure that every relationship we enter – whether it’s with a supplier, factory or vendor – consistently operates in accordance with Staples’ requirements. The Supplier Code of Conduct (or its equivalent) is included as an appendix to each manufacturing agreement, and each supplier is required to comply with its provisions and post the Code in all factory locations manufacturing Staples® Brand Products.

In general, the Code is based on international social accountability standards and contains 10 specific areas of conduct which that are each evaluated during on-site audits. The Code is regularly reviewed and reinforced as business needs and requirements change.

Social Accountability Audits

The Director of Product Quality oversees supplier auditing to ensure compliance with the Supplier Code of Conduct. All audits are carried out by external, independent third parties. The Director of Product Quality works closely with the Vice President of Product Development, Sourcing and Quality, who is in charge of producing goods, and with the Director of International Supply Chain, who is in charge of shipping goods from the supplier to the end destination and maintaining compliance with all security provisions. Both individuals report up to the SVP for the Staples® Brand Group.

All suppliers in “at-risk” geographies are required to be audited prior to starting production and are recertified every year. For example, Staples currently designates the following countries as “at-risk” in accordance with industry assessments: Argentina, Bangladesh, Brazil, China, Egypt, India, Indonesia, Japan, Malaysia, The Philippines, South Korea, Taiwan, Thailand and Vietnam. Each audit is designed to allow the factory to demonstrate adherence to our Code through on-site verification by a trained auditor. The auditor conducts employee interviews and document reviews to substantiate factory operating practices, and rates the factory on a point scale.
A summary of the audit sections and requirements can be found here.

Certain requirements are deemed “Critical” to create minimum standards for each supplier to consistently achieve. Suppliers failing to meet the minimum requirements are required to sign a Letter of Commitment, which states their intent to continuously improve and requests a probationary period to implement the necessary changes. They are also required to complete a Corrective Action Plan (CAP) documenting the steps they will take and the timeline for the necessary improvements. Suppliers who meet the minimum requirements but have violations in other areas receive a conditional pass and may also be required to submit a CAP. All CAPs must be approved prior to Staples’ continuing business with the supplier. Follow-up audits are scheduled at regular intervals to ensure suppliers stay on track while on probation and when all CAP plans have been implemented.

Social Accountability Audit and Corrective Action Process

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Results of 2015 Audits

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29 inactive suppliers (no Staples® Brand Products are currently being produced there)

Staples did not sever ties with any factories in 2015

*A total of 295 Social Accountability audits were carried out at 244 factories, as some locations were audited more than once.

**Suppliers on probation must complete corrective action to continue working with Staples. In addition to scheduled factory inspections, Staples conducts short-notice and unannounced audits.

California Transparency in Supply Chains Act

Staples is committed to providing our customers with top-quality products at a reasonable price that are also manufactured responsibly. Staples expects all workers, with an emphasis on those who make Staples® Brand products, to be treated fairly and with dignity and respect, and the products themselves are made in an environmentally sustainable manner. In addition, Staples requires its third-party vendors who supply products for resale, and suppliers who manufacture Staples® Brand products, to comply with applicable international (in the countries in which the parties are doing business) and U.S. laws, regulations and industry standards.

In accordance with the California Transparency in Supply Chain Act, below you will find information regarding the efforts Staples is taking to eradicate slavery and human trafficking from our supply chain, while maintaining social accountability and supply chain transparency.

Verification

Staples is committed to fair labor practices throughout our supply chain. To establish clear guidelines for responsible operation, we developed the Staples Supplier Code of Conduct (“Code”) to help ensure that every relationship we enter — whether it’s with a vendor of third-party products or a supplier of Staples® Brand products — consistently operates in accordance with Staples’ standards. Compliance with the Code (or its equivalent) is required in each manufacturing agreement, and each supplier manufacturing Staples® Brand products is required to post the Code in all factory locations. For all other products, Staples strongly recommends that its vendors comply with the Code (or a similar code of its own). In either case, Staples has the right to terminate its relationship with its vendors or suppliers if Staples finds that such vendors or suppliers are violating anti-slavery or human trafficking laws or the Code, respectively.

In general, the Code is based on international social accountability standards and contains 10 specific areas of conduct, including the prohibition of forced and child labor. All areas of conduct are annually assessed during on-site audits conducted by a third-party auditor who identifies and verifies that suppliers are not at risk for violating any anti-slavery or human trafficking laws. The Code is regularly reviewed and reinforced as business needs and requirements change.

Audits

All factories of Staples’ suppliers in “at-risk” geographies are required to be audited and certified prior to the start of production, and rectified every year thereafter. Staples evaluates risk annually, and currently designates the following countries as “at risk,” in accordance with industry assessments: Argentina, Bangladesh, Brazil, China, Egypt, India, Indonesia, Japan, Malaysia, South Korea, The Philippines, Taiwan, Thailand and Vietnam. Factories are deemed certified when they meet Staples’ standards. Each audit is designed to allow the factory to demonstrate adherence to our Code through an on-site assessment, conducted by an independent third-party auditor. Factories are given notice of a 2-week timeframe in which Staples will conduct the audit, without specific notice of which day or time. The auditor conducts assessments, by interviewing workers and facility management, reviewing documents and inspecting facilities, including dormitories where present, to substantiate factory operating practices. The auditor then rates the factory on a point scale.

Certain Staples standards are marked “critical” and create minimum standards for each supplier to consistently achieve. Suppliers that fail to meet the minimum standards are required to sign a Letter of Commitment stating intent to improve, request a probationary period to implement necessary changes and complete a Corrective Action Plan (CAP), approved by Staples, to document when improvements can be expected. Suppliers who meet the minimum requirements but have violations in other areas receive a conditional pass and may be required to submit a CAP. In order to ensure that suppliers maintain social accountability and compliance with our stringent requirements, follow-up audits are scheduled and conducted at regular intervals for suppliers on probation and for those implementing a CAP. If a factory fails to demonstrate progress on implementing corrective action, we terminate the relationship.

In 2015, a total of 295 audits were carried out at 244 locations identified as “at-risk” factories, as some locations were audited more than once. As a result, 204 were deemed certified and the remaining 40 were put on probation and obligated to complete the necessary corrective actions. Staples did not sever ties with any of its suppliers or factories.

Certification

As mentioned above, our Code (or its equivalent) is included in each manufacturing agreement, and each supplier is required to comply with its provisions, which serves as a self-certification.

To ensure that our contractors and suppliers respect and enforce our company Code and standards, we respond in a manner commensurate with the nature and extent of the violation, upon any discovery of a violation of our Code, as referenced above. See our Conflict Minerals Policy to understand other initiatives we take to support human rights.

Internal Accountability

The Director of Product Quality oversees supplier auditing to ensure compliance with the Code. All audits are carried out by external, independent third-parties. The Director of Product Quality works closely with the Vice President of Product Development, Sourcing and Quality, who oversees the production of goods, and with the Director of International Supply Chain, who is responsible for shipping goods from the supplier to the end destination and maintaining compliance with all security provisions. Both individuals report to the SVP for the Staples® Brand Group. All these people maintain supervision over production and shipping and ensure that suppliers maintain compliance with our Code, which supplements our other supervisory procedures, described above in more detail. Furthermore, any supplier that fails to comply with applicable laws or ethical business practices may be subject to immediate business suspension or termination.

Training

Staples provides employees and management, who have direct responsibility and interaction with supply chain management, training on fair labor practices and human trafficking and slavery, particularly with respect to mitigating risks within the supply chain. We train these employees on our Code, manufacturing agreements and auditing procedures annually, while highlighting their importance to our business, supplier factory workers and consumers. Furthermore, we encourage anyone who becomes aware of any violations of the law, Code or any other requirements (such as our Code of Ethics) to immediately notify their management, human resources office or global ethics office; to visit StaplesEthicsLink.com to file a report; or to contact their region’s toll-free ethics hotline.

What suppliers must do when failing to meet minimum code requirements:

  • Sign a Letter of Commitment stating an intent to improve
  • Request a probationary period to implement changes
  • Complete a Corrective Action Plan to document when improvements can be expected

If a factory fails to demonstrate progress on implementing corrective action, we end the relationship.

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