Data Security The ODP Corporation is committed to creating and maintaining high standards of data security. To that end, we have a comprehensive approach to data security and risk mitigation. This includes vigorously protecting customer personally identifiable information (PII) and company confidential information. The foundation of our data security program aligns with the internationally recognized ISO/IEC 27001 industry security standard . We deploy a multi-faceted, defense in-depth data security program led by our Chief Information Security Officer and implemented by a team of trained cybersecurity professionals to address data security risks, vulnerabilities, and to protect company assets. Through the use of people, process, and technology (tools), The ODP Corporation actively identifies risks and applies risk mitigation and treatment to each risk based on its defined policies and procedures. The ODP Corporation complies with all applicable laws, rules, and regulations pertaining to collection, storage, protection, and destruction of PII and confidential information including Sarbanes Oxley (SOX) and the California Consumer Privacy Act (CCPA). We also comply with applicable industry security standards including the Payment Card Industry Data Security Standard (PCI DSS). Our technology systems and security program are subject to regular audits by our Internal Audit team and our independent auditor / public accounting firm. Cyber security updates are provided to the Board of Directors through quarterly updates to the Audit Committee. Our robust security programs include multi-factor authentication protocols , firewalls , and anti-virus/anti- malware software . We maintain a security operations center to monitor our Security Information and Event Management (SIEM) system. We conduct ongoing risk assessments, internal and external penetration tests, phishing simulations, and maintain a bug bounty program. We maintain a comprehensive global training and awareness program on relevant information security topics and company policies in order to help our company associates and contractors extend our security mission throughout their day-to-day responsibilities and help them make sound computing decisions. The ODP Corporation is committed to creating and maintaining high standards of data security. 11. INTRODUCTION GOVERNANCE PLANET PEOPLE PROSPERITY SASB INDEX 11. INTRODUCTION GOVERNANCE PLANET PEOPLE PROSPERITY SASB INDEX