Global Code of Business Conduct and Ethics

lululemon 2023
Contents
We comply with all laws, and in doing so we
01 contribute to healthy communities

02 We preserve our integrity by avoiding conflicts of interest

We are all responsible for fostering a respectful

03

Global Code of Business Conduct and Ethics

and inclusive workplace

04 Our culture promotes a happy, healthy, and fun life

05 Personal responsibility is the path to success

06 Questions, concerns & assisting with investigations

07 Reporting a violation of the Code and non-retaliation

08 Reporting a violation of the Code through the Integrity Line

09 Training and certification

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Message from Calvin
At lululemon, we take ethics and integrity seriously, which plays a critical role in achieving our
purpose to elevate human potential by helping people feel their best.

As we grow to be a truly global brand, we will continue to operate in markets that have a broad
range of cultural nuances and business practices which vary across each market and context.
Our behaviour should remain aligned to a clear and consistent Code of Conduct that outlines
our unwavering commitment to conducting our business ethically and is rooted in our values of
personal responsibility, inclusion, connection, courage, and fun.

The Code, in tandem with our IDEA commitments (Inclusion, Diversity, Equity and Action) and
Impact Agenda, reflects the diversity of the global communities in which we operate and sets the

Global Code of Business Conduct and Ethics

conditions for us to create positive change in building a healthier, thriving and more equitable future
together with our guests, partners, and communities. Our responsibility, as individuals, as leaders
and as a company, is to create a truly diverse and inclusive culture, and remove barriers to equity to
foster belonging.

The Code contains information, resources, and tools that empower us to act ethically and in
compliance with the law. While our Code is thorough, we know that it may not address every ethical
instance we may face in our day-to-day situations. Each of us must take personal responsibility to
use common sense and judgment in our personal conduct and act in accordance with the Code.

If you have questions about the Code, or if you have concerns about possible ethical violations
in the workplace, I urge you to speak immediately with your leader and/or your People & Culture
Partner, or utilize the other resources listed in the Code.

Upholding our Code demonstrates the strength of our culture and our values. I look forward to
continuing to build the future of lululemon, together.

With gratitude,

Calvin McDonald
Chief Executive Officer

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Global Code of Business Conduct and Ethics
Our code is grounded
in our values.
We are guided by our values in everything we do.

The Code applies to all lululemon employees, ambassadors, contractors,

officers, and directors.

To reach our business and personal goals, we must practice the highest
integrity. This means that we respect each other, our guests and all laws,
customs, and cultures. In this spirit, we support a workplace environment
that neither pressures nor encourages anyone to compromise our
company’s values or standards of conduct.

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01. We comply with all laws, and
in doing so we contribute to healthy
communities.
We are all expected to comply with the law. This includes not only following the laws of our home
market, but also complying with local laws when visiting different markets or transacting business with
individuals, organizations, or guests located in a different market. Be particularly aware of the following
key laws that have an impact on our business:

Anti-corruption and Anti-bribery

It is never appropriate to offer or accept bribes, kickbacks, or any other type of improper preferential
benefit. Likewise, we do not allow vendors or other individuals or organizations to offer or accept
any bribes or kickbacks on our behalf. A bribe can include giving or receiving any item of value (e.g.,

Global Code of Business Conduct and Ethics

money/cash, cash equivalents such as gift cards, gratuities, gifts, kickbacks, unauthorized rebates,
meals, entertainment, products, trips, favours, offers of employment, loans, contributions, or donations)
to/from a person or entity to improperly influence any act or decision to obtain or retain business or
to secure any advantage for lululemon, or otherwise improperly promote our business interests in any
respect.

We do not tolerate corruption, and we must always operate with integrity regardless of local custom or
industry practice. Conducting business the right way and with integrity not only helps us obey the law,
but it also strengthens our relationships with local communities and our partners. Please refer to our
anti-corruption and anti-bribery policy on our company intranet site for more information.

FAQ: What is a bribe?

Bribery is offering to give or giving money or anything else of value, directly or indirectly, to improperly
influence another person to do something for you that they would otherwise not have done. For
example, making a payment directly to a customs official to “assist” with getting products released
into a country would be a bribe.

FAQ: What is a kickback?

A kickback is a form of bribery where money or something of value is given in exchange for services
rendered. For example, cash, gifts, or favors given to a procurement officer for awarding a contract
would be a kickback.

FAQ: Could it still be a violation of the Code to give gifts when they are local custom and
expected as a part of doing business?

Yes. Our policies regarding gifts and entertainment set out in the Code and anti-corruption and anti-
bribery policy apply equally in all countries regardless of any perceived local customs/practice.

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Import-Export and Trade Laws

We transfer products, supplies, and raw materials to and from countries all over the world every day.
In so doing, we must comply with all laws, rules, and regulations that govern these activities. These laws
may include export controls, customs laws, and trade sanctions.

Insider Trading Laws

We may not buy or sell shares of lululemon stock (or securities of other companies) if we know of
material information that has not been made public. Material information is any information that would
influence a reasonable investor’s decision to buy or sell stock. Examples of “material information”
include consolidated sales figures, the departure of an executive, or a significant issue with a key
supplier. Trading in shares while in possession of non-public material information is a serious violation of
securities law as is providing non-public material information to someone who may trade in our shares.
Never provide material non-public information to other people, including family members or friends as
it may enable them to improperly buy or sell securities using confidential information. Please refer to
our Insider Trading Policy for more information. Members of our board of directors, executive officers,
and certain other employees have additional restrictions on trading in lululemon securities, which are

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outlined in our Insider Trading Policy.

Competition Laws

We compete hard but play fairly. Fair dealing laws and antitrust laws protect industry competition by
generally prohibiting agreements between competitors that seek to manipulate prices or unfairly impact
competition. We must not attempt to make any anticompetitive agreements, such as agreements to
fix prices or production. In addition, we must not disclose competitive and non-public information to
competitors, suppliers, or distributors.

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02. We preserve our integrity by
avoiding conflicts of interest.
Covered Relationships

We should not influence, appear to influence, or have any real or apparent involvement with any
employment-related or business-related matters that involve a covered relationship. A covered
relationship may exist inside or outside of the Company and includes:

• a person who is a member of our household or with whom we have a close personal
relationship with.

• a person or organization with whom we or our close personal relation has or seeks a business,
employment, contractual or other financial relationship with.

Global Code of Business Conduct and Ethics

For example, employees may not influence or have any involvement with employment-related decisions
that involve a relative.

In addition, we may not have any involvement with vendors that involve a covered relationship, including
being a party to the selection of the vendor.

Gifts and Business Entertainment

Providing and receiving modest gifts or entertainment may foster long term business collaboration
provided that they are reasonable and appropriate for the situation, not offered to improperly influence a
business decision, and are permissible under the law. Gifts and entertainment should always be in good
taste and considered a courtesy. When determining what is reasonable and appropriate, consider the
cumulative value of gifts given or received over the course of the relationship. Gifts and entertainment
for government officials are prohibited without prior written approval from the Legal department. Please
contact Employment Policy & Compliance or the Legal department for more information.

Political Activities

At lululemon, we work to ensure everyone has a sense of belonging. Political activities should be kept
separate from work activities. It is inappropriate to use company resources (including time, property,
or equipment) in furtherance of personal political activities or to display personal political messages
(on buttons, clothing, and other paraphernalia) at work. Any political activities being conducted
on lululemon’s behalf must be approved and conducted in accordance with internal policies and
procedures.

FAQ: What is a conflict of interest?

A conflict of interest may exist whenever one’s ability to exercise good judgment and/or successfully
fulfill the duties of their role can be called into question because of an actual or perceived benefit
or incentive to them or to a person or organization with whom they have a covered relationship. An
example of a conflict of interest would be considering hiring a relative’s company to perform services for
lululemon.

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Business Opportunities

We may not take advantage of business opportunities that we learn about through our work with
lululemon or direct any such opportunities to another individual or organization, unless lululemon has
already been offered and declined the opportunity. We may not use company property or information to
compete with lululemon.

Outside Employment and Other Potential Conflicts of Interest

lululemon is passionate about supporting our people to achieve their goals, inside and outside of work.
However, we must ensure that we do not provide services to another for-profit business that may
appear to conflict with our duties to the company without prior written approval from People & Culture,
unless otherwise allowed under the terms of employment or local law. Never provide services to or be
an employee of a competitor while employed by lululemon. When unsure whether something might be
considered a conflict of interest or perceived as a conflict of interest, ask your people leader, your People
& Culture partner or contact Employment Policy & Compliance.

Director Conflicts

Global Code of Business Conduct and Ethics

Board members have a duty to avoid actual or potential conflicts of interest in the performance of their
duties as directors of lululemon. A director should not have any interests that would materially impair
their ability to (1) exercise independent judgment or (2) otherwise discharge the fiduciary duties owed
as a director to lululemon and its stockholders. Each director must independently evaluate their own
current and planned actions, positions, and interests to determine whether or not an actual conflict of
interest, or the appearance of a conflict of interest, is or may be present.

If they determine that a conflict of interest or the appearance of a conflict of interest does or will exist,
the director must avoid such action, position, or interest.

Prohibition of Loans

lululemon may not directly or indirectly, make a loan to an executive officer or director of lululemon or
guarantee any loan or obligation on behalf of an executive officer or director.

FAQ: What if I am unsure as to whether a conflict of interest exists?

It is important to understand that it is the appearance of influence that triggers a conflict of interest, not
whether a person has actually been influenced. If uncertain about a potential conflict of interest, seek
guidance from your people leader or contact your People & Culture partner or Employment Policy &
Compliance.

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03. We are all responsible for fostering
a respectful and inclusive workplace
We stand for humanity, diversity, and empathy. We strive to provide an environment that creates the
conditions for all employees to excel, be creative, take initiatives, feel a sense of belonging, and seize
opportunities. Teamwork and collaboration help us to leverage our diverse backgrounds, talents, and
ideas for innovative and fresh solutions. Our commitment to inclusive behaviour and ethical conduct,
aligned with our values of inclusion and personal responsibility, govern how we interact with guests,
vendors, colleagues, and members of the public at all times.

Extend courtesy and respect to all individuals, respect the property of others, act fairly and honestly,
and take steps to understand local laws and customs wherever we operate.

We do not tolerate racism, discrimination, harassment or hate. The diversity of our workforce is a
critical asset that helps us achieve our goals. We are committed to providing equal opportunity in all

Global Code of Business Conduct and Ethics

aspects of employment and will not tolerate discrimination on the basis of race, color, creed, age, sex,
sexual orientation, gender identity or gender expression, national origin, religion, body size, family status,
marital status, medical condition, physical or mental disability, military service, pregnancy, childbirth
and related medical conditions, or any other legally protected status. We will not tolerate harassment or
unlawful behaviours of any kind, including derogatory comments or conduct based on sexual orientation,
race, ethnicity, or any other protected status.

We believe everyone has the right to be well, to live free from all forms of bullying and harassment,
and to be treated with respect and appreciation. We do not tolerate violence, bullying, or harassment
in our workplace. Bullying and harassment includes any inappropriate conduct or comment by a person
towards a worker that the person knew or reasonably ought to have known would cause that worker to
be humiliated or intimidated.

Examples of bullying and harassment include but are not limited to deliberately impeding or undermining
a person’s work, excluding, or isolating a person socially, cyber-bullying, and spreading malicious rumours
or gossip.

Bullying and harassment does not include any reasonable action taken by an employer or supervisor
relating to the management and direction of workers or the place of employment. Reasonable direction
or management includes performance management, corrective action, or instruction provided to assist
an employee in their development or advancement.

Sexual harassment will not be tolerated.

Sexual harassment is a form of discrimination. We strictly prohibit sexual harassment in the workplace.
Sexual harassment can occur between any two people, regardless of their gender or sexual orientation.
Sexual harassment may include but is not limited to sexually suggestive gestures, unwelcome leering or
staring, or the making of sexual advances or repeated invitations after a previous advance or invitation
has been refused.

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04. Our culture promotes a happy,
healthy, and fun life.
Environmental Stewardship

Because environmental health is the foundation for personal health, we are passionate about reducing
our environmental impact. At a minimum, we are expected to follow all environmental rules and regulations
established by local, regional, or national authorities.

Workplace Safety

Our people’s wellbeing is our top priority. lululemon promotes and maintains a safe and healthy work
environment that complies with all relevant laws, rules, regulations, and policies, as well as our own standards
and guidelines. Through our Vendor Code of Ethics, we also require our supply chain partners to agree to
maintain safe and healthy workplace facilities.

Global Code of Business Conduct and Ethics

Labour Practices

lululemon, and any other individual or organization working with us, must comply with all labour and
employment standards laws, rules, regulations, and policies in the jurisdictions where we or they operate.

We will not use forced or involuntary labour, child labour, or engage in human trafficking—nor will we tolerate
any other individual or organization who engages in such practices. We are committed to a responsible
supply chain, and all vendors must agree to uphold our ethical standards of production and adhere to our
Vendor Code of Ethics.

Workplace Culture

We are a team of committed people who care deeply for each other, believe anything is possible, and
relentlessly pursue our growth together.

People leaders should help foster a supportive, inclusive, and legally compliant workplace environment.
They must always demonstrate their personal commitment to the Code and ensure the same from their
employees. Thus, people leaders should exercise care when appointing an individual to a position of
authority and responsibility.

Respect for Our Guests and Others

Guest relationships, as well as relationships with other third parties in our communities, are critical to our
success. In meeting guests’ needs, we are committed to conducting business with integrity and according
to all applicable laws, rules, and regulations. Guests will be served without regard to race, color, creed, age,
sex, sexual orientation, gender identity or gender expression, national origin, religion, body size, family status,
marital status, medical condition, physical or mental disability, military service, pregnancy, childbirth and
related medical conditions, or any other legally protected status.

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05. Personal responsibility
is the path to success.
Protecting lululemon’s Assets

We all have a responsibility to protect lululemon’s assets from improper use or disclosure. This includes,
among other things, protecting all non-public information from disclosure, including our trade secrets,
design information, information about our suppliers, contracts, and manufacturing processes, guest
information, financial information and employee and pricing data, as well as not reproducing licensed or
internally developed software for personal use. We also don’t permit unauthorized photography or video
recording of any nature in our stores, the SSC, the DCs or any other lululemon property.

Intellectual Property

Intellectual property (IP) is one of our most valuable assets. IP includes our trademarks, copyrights,

Global Code of Business Conduct and Ethics

patents, and trade secrets. To provide the best products and experiences to our guests, we must always
protect our IP. Never disclose our IP to any third party outside of lululemon unless they are contractually
required to maintain confidentiality. Disclosure of our IP could result in severe damage to lululemon so
it must be safeguarded. We respect the IP rights of others and do not tolerate the unauthorized use of
anyone else’s IP or confidential information. To use someone else’s IP (including their names, images, or
likenesses), there must be appropriate consent. If unsure, reach out to the Legal department.

Personal Use of Technology and Other Assets

Personal use of lululemon’s assets, including our technology, during work time, should be minimal
and should not interfere with job performance or otherwise violate the Code. It is never appropriate
to use our technology, including email or intranet, to send or access potentially offensive or
inappropriate content.

FAQ: Can I use the Company’s computers, phones, printers, and copy machines at the office for my
consulting business so long as it is after hours?

No. Using lululemon’s resources for a consulting practice in this fashion is more than incidental use
of company assets and is not permitted.

Privacy

Employee and guest privacy is important. We should always respect the privacy of personal information
whenever we collect, maintain, or transfer information and ensure that we comply with all applicable
guest and employee privacy policies.

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FAQ: Can I use product strategy information that a friend of mine at a competitor accidentally sent
me to develop lululemon’s strategy?

No. If confidential information is received under unusual circumstances, send the information back to the
owner and delete all copies of it on our system. Do not share the information with any other employees.

Data Security and Data Protection

Keeping data safe preserves the trust that exists between lululemon and our employees, guests, and
business partners. Data security involves following all relevant company policies and being mindful
to protect passwords, user IDs, access cards, and encryption or authentication keys. Any actual or
suspected disclosure of data must be immediately reported to Information Security and the Legal
department. Examples of a data breach include the loss or theft of a USB stick containing company data,
leaving work devices unlocked or in an unsecure place (e.g. laptop computer or mobile phone), leaving
work product in a public place or even in lululemon property accessible to the public (e.g. on the bus,
or visible through the window of a parked car, in unsecure garbage or recycling bins, on whiteboards in
unsecure conference rooms.) It is important that we treat employee, guest, and business partner data
with respect. We handle data consistent with local data protection and privacy laws and Regulations.

Global Code of Business Conduct and Ethics

Accurate Records

We must follow our system of internal controls and disclosure controls and ensure that corporate
records and all securities filings are timely, legitimate, and accurate. Creating false or misleading records
is prohibited, and all financial accounts, reports, and records are expected to be fair, accurate, and
appropriately authorized.

Document Retention

We are expected to comply with all records management policies and legal hold notices. These policies
apply to retention and destruction of all records created by lululemon, including, but not limited to, hard
copies, electronic files, emails, instant messages, video, and backup tapes.

Speaking on lululemon’s Behalf

Unless specifically authorized to do so, one cannot speak publicly on lululemon’s behalf or publicly
disclose proprietary or confidential information about lululemon, including on social media. Those
permitted to speak on our behalf must be truthful, accurate, and respectful in their communications
and maintain any duty of confidentiality.

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06. Questions, concerns and
assisting with investigations.
Questions

Speak to your people leader, or People and Culture if there are questions about the Code. If unsure
what to do in a certain situation, speak up and ask for help.

Waivers

Waivers or exceptions to the Code for any employee will be granted only in advance and under
exceptional circumstances by the Legal department. A waiver of the Code for any executive officer
or member of our board of directors may be made only by the board of directors or a designated
committee of the board.

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Consequences for Violating the Code

Violation of any law or the Code is a serious matter. Any employee, contractor, director, or officer who
compromises or violates any applicable law or the Code may be subject to disciplinary action, up to
and including, termination of employment, loss of employment-related benefits, and, if applicable,
criminal or civil proceedings.

Cooperating in Investigations

lululemon will conduct a prompt, thorough and objective investigation into any potential violations
of the Code. You may be asked to cooperate or provide information as part of an investigation. Full
cooperation and assistance are required and any failure to do so will be considered a violation of the
Code.

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07. Reporting a violation of the Code
and non-retaliation.
Reporting Violations

If you suspect that there has been a violation of the Code, report it through the following channels:

• your people leader • the integrity line; or

• another people leader • Our Audit Committee Chair:
• your People and Culture partner Chair, Audit Committee
1818 Cornwall Avenue
• any member of the Legal department.
Vancouver, British Columbia V6J 1C7
• anyone on our Senior Leadership team. [email protected]

Global Code of Business Conduct and Ethics

Investigation Process

lululemon has an internal investigation process and will conduct a prompt, thorough and objective
investigation of complaints. Any complaint received will be considered, and if necessary, investigated
by our internal independent investigation team (Employee Relations) or an impartial third-party on the
basis of the information provided and in accordance with applicable law.

Government Investigations

Nothing in the Code precludes an employee from reporting a violation of law to a government agency
or cooperating in a government investigation.

Non-retaliation

We will not tolerate retaliation against, or unfair treatment of, any employee who makes a report in
good faith about a violation or possible violation of applicable law or the Code, or who participates in
any investigation conducted internally or by a government enforcement agency. Any employee who
believes he or she has been retaliated against should promptly report it to one of the resources listed
in the Code.

FAQ: What does non-retaliation mean?

Any action that might deter a reasonable person from engaging in protected activity, including making
a good faith concern regarding a work experience or a violation or possible violation of applicable law
or workplace policy, or who participates in an investigation of a complaint. Similarly, any person who
reasonably reports any possible violation of local, regional, state, or federal laws or regulations will be
protected by the Company with regard to that concern. The protection continues even if the report is
ultimately unsubstantiated.

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08. Reporting a violation of the Code
through the Integrity Line
If you are not comfortable discussing your concern with any of the above resources, you can contact our
Integrity Line to report your concern in a confidential manner. Reporting procedures in each country are
consistent with local laws and policies. Where applicable, information about all Integrity Line reports is
provided to the Legal department and the chair of the Audit Committee.

Our Integrity Line is operated by a third party with trained staff who gather information related to your
concern. If you wish to remain anonymous, you are able to do so.

You can contact our Integrity Line by phone (available 24 hours, 7 days a week) using the phone
numbers listed in the tables on pages 16 below. For those countries with access numbers, you must first
dial the appropriate access number based on your country and if applicable, your provider, and then
when prompted, you must enter the 844-toll free number. Instructions for calling the Integrity Line are

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also available online at Ethics Points. You may also complete an Integrity Line report online at Ethics
Points.

All reports of violations will be addressed consistent with our policies and procedures.

Any people leader or other individual who receives a report of a violation or a possible violation should
refrain from conducting any independent investigation, and promptly forward the report to the Legal
department, who will advise on next steps.

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Integrity Line Numbers

Market Access Numbers (Dial this number first) Toll Free Number

North America N/A 1-877-217-4665 OR 844-676-8048

Australia 1-800-551-155 844-676-8048
China N/A 400-601-3075
France Telecom: 0-800-99-0011
0-800-99-1011
0-800-99-1111
France 400-601-3075
0-800-99-1211
Telecom Development: 0805-701-288
Paris: 0-800-99-0111

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Germany 0-800-225-5288 844-676-8048
Hong Kong SAR 800-93-2266 844-676-8048
India 000 800 919 0229 844-676-8048
Ireland 1-800-851-349 844-676-8048

KDDI: 00-539-111
Japan NTT: 0034-811-001 844-676-8048
Softbank Telecom: 00-663-5111

Macau SAR 00-800-111 844-676-8048

Malaysia 1-800-80-0011 844-676-8048
Netherlands 0800-022-9111 844-676-8048
New Zealand 000-911 844-676-8048
Norway N/A 844-676-8048
SignTel: 800-011-1111
Singapore 844-676-8048
StarHub: 800-011-0001
Dacom: 00-309-11
ONSE: 00-369-11
South Korea Korea Telecom: 00-729-11 844-676-8048
US Military Bases – Dacom: 550-2872 US
Military Bases – Korea Telecom: 550-4663

Sweden 020-799-111 844-676-8048

Switzerland 0-800-890011 844-676-8048
Taiwan 00-801-102-880 844-676-8048
Thailand 1-800-018-142 N/A
UK 0-800-89-0011 844-676-8048
Vietnam 1800 462587 844-676-8048

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09. Training and Certification
Training

You may be required to complete annual compliance training. If asked to do so, completion of the
training is required and any failure to complete such mandatory training in a timely manner could
result in disciplinary action.

Certification

On an annual basis, you will be asked to acknowledge your commitment to the Code. In addition,
you will be asked to confirm that you are not aware of any unreported violations of the Code. This
acknowledgement must be completed.

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