Commitment to Safer Chemical Management

Office Depot and its subsidiaries are committed to be environmental stewards that support healthy communities and help our customers do the same. As part of this stewardship, we support the responsible use of chemicals in compliance with all laws and regulations, and we will work toward reducing and eliminating chemicals of concern beyond those legal requirements. This commitment extends to all the products we sell, including private and other brands, the packaging for those products, and the manufacturing processes for those products. We seek to phase out chemicals of concern and improve the general management of chemicals.

Office Depot seeks to promote safer chemical management through transparency about chemicals in the products we sell, reducing and eliminating chemicals of concern, and advancing safer alternative formulations in the products we sell and their packaging. In collaboration with our vendors and suppliers, Office Depot strives to identify the presence of chemicals of concern in products and packaging and to support innovations that result in an orderly transition to safer alternatives.

To have the most widespread, positive impact on our customers, community, and company, we have a prioritized approach toward applying these standards throughout all products, beginning with our private brands. Office Depot places a high level of importance on implementing these policies throughout the entire company, including corporate, retail, service and distribution aspects of the business. We are establishing quantifiable goals for reducing and eliminating chemicals of concern in the products we sell and their packaging, and we have created a Beyond Restricted Substances List (BRSL) identifying chemicals that we restrict or limit. As specified in the list, the current BRSL restricts or limits per- and polyfluoroalkyl substances (PFAs), flame retardants (both halogenated and organophosphate), and essentially all known regulated phthalates. The BRSL also restricts specified antimicrobials and solvents. We intend to evaluate and increase the chemicals listed on our BRSL by 10 to 20% in 2021 and further each year thereafter by adding additional chemicals identified in Office Depot’s Priority Chemical List.

Office Depot also encourages innovations to work toward safer alternatives to chemicals of concern, beginning with the Priority Chemicals. In 2021, Office Depot also intends to add to its assortment to increase the number of disinfectants that are free of quaternary ammonium compounds (“quats”) and sodium hypochlorite.

Office Depot uses the WERCSmart solution (WS) to help manage our understanding of chemicals in the products supplied by vendors. We use the WS offered by Underwriters Laboratories (UL) to help manage our understanding of chemicals in the products supplied by vendors. Since 2014, Office Depot has required all vendors and suppliers to register their products and formulations with WS. WS assesses each registered product to support Office Depot’s objectives.

Private brand products: 

For our private brand products, Office Depot requires each product to comply with state and federal chemical requirements and continuously looks for safer chemical practices. Our BRSL and identification of additional chemicals that we are working to add to the BRSL are intended to help focus our efforts and those of our suppliers during the implementation of this policy. The lists identify both specific chemicals and chemical classes that are priorities for safer alternatives innovation.

• We have Private Brand Operating Guidelines, which include chemical testing requirements and increasingly rigorous standards. This ensures we are holding our brands to the highest standard and being transparent with our practices.

• Using our professional partners and internal team of quality assurance engineers, we ensure that our private brand vendors are complying with Office Depot’s Quality Manual and safer chemical practices. We test for chemicals of concern in all new private brand products before acquiring them, and we continue testing those products for chemicals of concern biannually.

• We encourage private and national brand suppliers to lead on sustainable chemistry by leveraging third party certifications that assess and recognize leadership in line with the principles of green chemistry and safer substitution.

• We require our private brand suppliers to comply with chemical safety restrictions set forth in state and federal requirements, but we believe those requirements are a starting point, not an ending point. In addition to testing for restricted substances under all state and federal requirements, including California’s Safe Drinking Water & Toxic Enforcement Act, we are developing requirements to go beyond state and federal regulatory compliance, and our BRSL already shows certain areas where we impose chemical restrictions beyond those required by law.

• We work with factories that produce our private brand products on improving and educating them on their chemical management processes and the importance of taking precautions regarding chemical use.

Relationships with our vendors, suppliers, and other partners:

To keep this commitment consistent throughout all aspects of our business, we coordinate with our vendors, suppliers, and other partners to emphasize the importance of adhering to our guiding principles. We will work with suppliers to encourage the incorporation of sustainable chemistry principles in the design of products sold in our stores. By providing access to educational and informational tools, our vendors and suppliers understand our standards and align with our values regarding Office Depot’s chemical footprint. 

• For hazardous materials, we utilize the WERCs system by UL to gather all necessary information to safely abide by shipping regulations. Our distribution and transportation teams work together and share the WERCs resource to gain greater awareness of our environmental impact within the industry and the actions we are taking to create a safer environment.

• By partnering with an industry leader in hazardous waste disposal, Office Depot is eliminating hazardous waste sent to landfills. Our retail and supply chain facilities are required to accumulate and dispose of hazardous waste within the regulatory time frames and utilize proper disposal methods.

Sustainability Through Office Depot’s GreenerOffice™ Program: 

We have taken our customers’ concerns into consideration when creating our environmental policies and we want to support our customers in their environmental priorities.

Office Depot’s Greener Purchasing Program is a six-step process that helps us transition customers to reach their greener purchasing goals. We have created a web portal dedicated to helping customers identify, evaluate, and purchase products that are environmentally friendly, including use of safer chemicals.

Through Office Depot’s GreenerOffice™ Program, we created icons for our greener product assortment to showcase the attributes that are important to us and our customers. These icons, along with third-party eco labels, assist our customers in making purchasing decisions that are safer for the environment. These icons fall into three areas of impact: Use of Safer Chemicals & Avoid Exposure; Save Energy & Avoid Emissions; and Save Resources & Avoid Waste. Along with our other businesses that are also wholly-owned subsidiaries of The ODP Corporation, Office Depot has assembled more than 19,000 products in our assortment with green attributes, and we are committed to decreasing the company’s environmental impact through waste diversion programs, greener packaging, transportation innovations, and product solutions that extend throughout the lifecycle. Because of this program, in 2019, 28% of customer purchases were greener products, and over 20% of company sales were products with greener attributes.

Safer Chemicals in Cleaning Products:

Office Depot is committed to reducing and providing alternatives to chemicals of concern in cleaning products we sell, including cleaning chemicals, hand soaps, hand sanitizers, and air fresheners. Specifically, Office Depot aims for cleaning products to account for 40% of the BRSL in 2021. To promote public transparency, we provide the Safety Data Sheets for all cleaning products online with each product listing at www.officedepot.com. Almost all our private brand cleaning products are eco-conscious, meaning they have one or more meaningful eco-attributes or eco-labels providing third-party assurance for the environmental claims on the labels. Our private brand floor and glass cleaners are certified bio-based and bear the “Safer Choice” ecolabel showing the product meets U.S. EPA Safer Product Standards. All Office Depot private brand cleaning products are sourced from a single supplier, which facilitates coordination and transparency regarding product requirements.

Safer Chemicals in Paper Products:

Office Depot has been actively working for more than 15 years to reduce and eliminate chemicals of concern in paper products. As part of our continuous improvement in this area, we have nearly succeeded in 100% eliminating BPA from all thermal paper. During Q1 2021, we intend to communicate with any remaining suppliers of thermal paper that Office Depot will only purchase thermal paper that is BPA-free. Office Depot is committed in 2021 to evaluate thermal paper with the goal of offering thermal paper free of other phenolics of concerns, such as BPS, BPF, and BPC.

We are committed to sourcing, using and selling paper products that reduce our impact on the world’s forests. We published our first Environmental Paper Policy in 2004 and revised it in 2013. We then updated and replaced it in 2019 with our current Greener Purchasing Policy for Paper Products. This policy applies to 100% of office copy paper and marketing paper purchased or sold by Office Depot.

We remain committed to using recycled fiber, supporting responsible forestry certification, increasing supply chain transparency, and growing markets for greener paper products. Our current Greener Purchasing Policy for Paper Products promotes our sustainability goals by helping avoid paper products from illegal sources, forests being actively converted to non-forest use, High Conservation Value forests (unless Forest Stewardship Council (FSC) certified or progressing to FSC), genetically modified or engineered trees, or forests where harvesting is documented to negatively impact human rights or labor rights.

Recycling program:

Through our E-waste, and Ink and Toner Cartridge Recycling Programs, we work with the most qualified electronics and toner recycling partners and aspire to the highest industry standards. Our recycling goal is to ensure products and components are reused, recycled and/or disposed of properly and that chemical risks are managed responsibly. Forty-five percent of our waste was recycled in 2019, and along with our other businesses that are also wholly-owned subsidiaries of The ODP Corporation, 204 metric tons of waste were diverted from landfills. In 2019 and through the third quarter of 2020 combined, Office Depot recycled over 6 million pounds of ink and toner cartridges and approximately 8.9 million pounds of e-waste for customers.

A systematic and transparent approach will result in the greatest value for our business and our stakeholders. We will utilize our management programs and policies to effectuate and sustain our continued commitment to chemical management. We will continue to measure our progress and strive for strategic improvements to develop better options for our customers, communities, and company.

Chemical Reduction Through Disposal of Potentially Hazardous Materials:

Potentially hazardous materials occur in our daily lives far more frequently than most people realize, and Office Depot works to reduce and eliminate chemicals of concern through proper disposal of products and materials containing such chemicals. Our employees are trained to recognize the following types of products and dispose of them through designated channels in our facilities, rather than in ordinary trash or down the drain:

• Aerosols, Flammables, and Combustibles (acetone, isopropyl alcohol, etc.)

• Oxidizers (bleach, chlorine, etc.)

• Corrosive Acids and Bases (ammonia, etc.)

• State Regulated/Toxic Materials

• Universal Waste – Types of products:

o Fluorescent Light Bulbs

o Household Batteries

o Small Electronic Devices: any item that contains a circuit board or uses AC power or batteries

o TVs and Video Displays: including computers, monitors, laptop computers and other devices with video screens