5C culture Compliance & Ethics The ODP Corporation’s Global Compliance Department is committed to providing education, training, and awareness to the Company’s associates around the world with respect to the Company’s ethical business practices and related compliance policies. Every business decision we make must be consistent with our 5C Culture and high ethical values, otherwise we will not move ahead, regardless of how great the benefit may be. These values are integral to our success and are non-negotiable. The ODP Corporation’s Code of Ethical Behavior guides expectations of how we should act towards one another as well as maintaining compliance with the laws that govern our business. It is the foundation upon which our related policies, trainings and ethical decisions are established. All our associates are expected to comply with our Code of Ethical Behavior. CODE OF ETHICAL BEHAVIOR 8. INTRODUCTION GOVERNANCE PLANET PEOPLE PROSPERITY SASB INDEX 8. INTRODUCTION GOVERNANCE PLANET PEOPLE PROSPERITY SASB INDEX