MODERNSLAVERY
STATEMENTFISCAL 2022

MODERN SLAVERY STATEMENT FISCAL 2022

INTRODUCTION
The Modern Slavery Act 2015 (UK) and othersimilar measures require businesses to disclose
information relating to their efforts to assess andaddress the risks of modern slavery (including
forced labor and human trafficking) in theiroperations and supply chains.
This Modern Slavery Statement by Peloton Interactive, Inc.
on behalf of all our affiliates, including Peloton Interactive UK
Limited (Peloton Interactive Inc. and all subsidiaries collectively
referred to as Peloton within this Statement), has beendeveloped as part of our commitment to respect human rights
worldwide. This statement covers Peloton’s fiscal year ended
June 30, 2022, unless otherwise stated.
Peloton is committed to upholding, promoting, and protecting
human rights, and we strive to operationalize this commitment
in our own workplace and with partners throughout our supply
chain. We are committed to a policy of zero tolerance for all
forms of modern slavery, and actively work to ensure that ourbusiness and supply chains are free from modern slavery. This
statement articulates our current approach to implementing a
program to realize our commitments in this area.

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MODERN SLAVERY STATEMENT FISCAL 2022

BUSINESS STRUCTURE
AND OPERATIONSAs of November 1, 2022, we have approximately 3,825

GENERAL BUSINESS INFORMATION

located in the United States. Internationally, we have employees

Peloton is the largest interactive fitness platform in the world,in Australia, Canada, Germany, Ireland, Taiwan, and thepioneering connected, technology-enabled fitness, and theUnited Kingdom. We have hired and may continue to also hirestreaming of immersive, instructor-led boutique classes to aadditional seasonal employees, primarily in our showrooms,

community of approximately 7 million Members. We operate atduring the holiday season.

EMPLOYEES
employees globally. The majority of Peloton’s employees are

the intersection of fitness, technology, and media, and provide
equipment, proprietary networked software, digital fitness andOPERATIONS

wellness content, and apparel for our Members around theWe operate retail locations across the United States, the United

world. Our global headquarters is in New York City, and we

Kingdom, Canada, Germany, and Australia. We also produce

operate across the United States, the United Kingdom, Canada,original programs, primarily from our production studios inGermany, and Australia.

New York City and London. As noted in Peloton’s 2022 Annual
Report on Form 10-K, our suppliers are primarily based in

Our Members can access the brand’s immersive content

various locations in Asia and North America. The components

through Peloton’s connected fitness equipment, which provides

used in our products are sourced either by us, directly, or on ouraccess to a wide variety of fitness disciplines. Businesses andbehalf by our contract manufacturers. For the financial year

enterprises can also access select Peloton products and theended June 30, 2022, we manufactured and assembled ourplatforms for their teams and customers through Peloton’s

products in-house, as well as through third parties primarily

Corporate Wellness program and Peloton Commercial.

in Asia. In July 2022, we announced a shift to third-party
manufacturing partners for 100% of our products and expanded
an ongoing relationship with a long-established Taiwanesemanufacturing partner.

MODERN SLAVERY RISK
The majority of our employees are professional andadministrative staff, particularly within the United States andEurope. The nature of their work, in addition to their location,leads us to believe that there is a low risk of modern slavery
within our business.
However, due to our global scope, risks of modern slavery are
primarily relevant to an extended supply chain. To address theserisks, Peloton has multiple corporate policies and due diligenceprocesses that form the backbone of our overall human rightsof Conduct. Peloton employs a third-party global sanctions
and trade compliance diligence platform to assist in regulatory
screening and due diligence efforts. We maintain an ongoing
review and qualification process for prospective suppliers; once
onboarded, suppliers are audited, as needed.
Peloton did not identify any instances of modern slavery
within its operations during the fiscal year ended June 30,
2022. As detailed below, Peloton continues to develop policies
and procedures that reflect our ongoing commitment to theprotection of human rights and the elimination of all forms ofmodern slavery.

approach. These policies include Peloton’s Code of Conduct,
Reporting Policy, Procurement Policy, and the Supplier Code2MODERN SLAVERY STATEMENT FISCAL 2022

POLICIES
CODE OF CONDUCT
Peloton’s Code of Conduct establishes our values and a set of
guiding principles for putting those values into practice. The
Code makes clear that Peloton employees and partners are
expected to operate with the highest possible standards ofhonest and ethical business conduct. The Code of Conduct
requires all employees to understand the legal and regulatory
requirements, as well as Peloton’s policy commitments,that apply to the business and encourage employees to askquestions and speak up about potential violations and concerns.
The Code of Conduct also establishes Peloton’s commitment
to fair and honest treatment of others, including employees,customers, business partners, suppliers, vendors, and other

SUPPLIER CODE OF CONDUCT
Peloton’s Supplier Code of Conduct (SCoC) establishes thecompliance and ethics standards expected of all of Peloton’s
direct and indirect suppliers, who are required to monitor theirown suppliers, contractors, and subcontractors for compliancewith the SCoC.
The SCoC, among other things, explicitly requires that suppliers
comply with applicable laws regarding human rights, including
any rights of workers to exercise their lawful rights of freeassociation; protections for young workers; provision of safeand healthy work environments; and the right of workers tobargain collectively. This includes a prohibition against modern
slavery in any form, including human trafficking and the use of
any type of involuntary or forced labor. The SCoC directs that

service providers.

all persons engaged in labor on behalf of our suppliers, or anyPROCUREMENT POLICY

Suppliers must meet or exceed all applicable wage and hourEstablishing the criteria and guidance for the acquisitionof goods and services, the Procurement Policy requires
adherence to the Code of Conduct by all suppliers and theiragents. Additionally, Peloton’s Sourcing & Procurement teamis responsible for overseeing the commercial relationships
between Peloton and its suppliers, which includes ensuringthat all aspects of the relationships are held to the highest
ethical and professional standards. As part of Peloton’ssustainability commitments, suppliers are expected to conduct
their business in a safe, sustainable manner, consistent with allapplicable laws.

of their customers, must be at least 16 years of age and older.
laws, including those relating to minimum wage, overtime, andany associated legally mandated benefits.
Suppliers are additionally required to create and maintainrecords to demonstrate compliance with the SCoC, and musttake corrective actions to promptly remedy any identified
noncompliance. Additionally, suppliers must allow employees
and/or agents of Peloton full access to facilities upon request,
including without limitation, records demonstrating compliancewith the requirements of the SCoC. Failure to comply with theSupplier Code will result in a business review of the supplier
relationship, up to and including termination of the supplier’s
business relationship with Peloton.

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MODERN SLAVERY STATEMENT FISCAL 2022

DUE DILIGENCESUPPLIER SCREENING
In assessing potential and existing suppliers, Peloton uses athird-party global sanctions and trade compliance diligenceplatform to screen global government lists of sanctioned,
specially designated, and restricted parties, including entities
known to use modern slavery, convict, and/or child labor.
We monitor these lists on an ongoing basis as a part ofcontinuing due diligence.
ESG SUPPLIER ASSESSMENTS
In June 2022, Peloton launched an ESG Supplier Assessment

This assessment covers multiple topics, including generalcompany information and corporate social responsibility/
ESG issues. The ESG Assessment includes sections specificallyaddressing forced labor policies and procedures, child labor
policies and procedures, migrant workers, recruitment, andgeneral worker safety.
SUPPLIER AUDITS
Peloton seeks to maintain a global supplier auditing program
to enable Peloton or a trusted agent to conduct an audit of thesupplier’s facility, manufacturing procedures, quality controls,systems and tools, books and records, and other documents.
Currently, Peloton conducts audits on an as-needed basis.

via a third-party platform with a small subset of suppliers.

GRIEVANCE AND REPORTINGMECHANISMS

Peloton also makes available to employees, contractors, andPeloton maintains a Reporting Policy that sets forth Peloton

reporting of suspected violations of applicable laws or

employees’ duty to report in good faith any known or suspectedviolations of laws, including violations of Peloton’s Code ofConduct, Supplier Code of Conduct, and other policies. The
Reporting Policy clarifies that this reporting responsibility
includes reporting concerns received from persons outsideof Peloton and concerns regarding third parties who provide
services to Peloton, such as contractors or suppliers.

suppliers an ethics hotline and online reporting tool maintainedby an independent third party that allows for anonymous
policies, and other compliance concerns, including concerns
about human rights, employment practices, and modernslavery. These tools are made available in several languages,including Chinese, English, French, German, Italian, Japaneseand Spanish.
Peloton prohibits retaliation of any kind against anyone whoraises a good faith concern under the Reporting Policy or whoassists with an investigation into potential violations.

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ONGOING EFFORTS
As preventing and addressing modern slavery risks in ourbusiness and supply chains is an ongoing process that requires
long-term planning and vigilance, Peloton is committed tocontinuously enhancing its human rights protection efforts.
Peloton will also reassess its risk profile should it expand into
new markets and continue monitoring any modern slavery risks
throughout its supply chain.
At Peloton, we will continue to evolve our approach in the next
fiscal year and beyond, by:> Further building our capacity and approach to supplierengagement, including resources to enhance knowledge ofhuman rights issues (including modern slavery) and humanrights standards.

> On an annual basis, evaluating an increasing number ofsuppliers with an ESG Assessment and introducing a
supplemental Modern Slavery Act Assessment via the same
third-party platform. This additional questionnaire will request
information regarding assessment and management ofmodern slavery risk, information on due diligence processes,
certification of direct suppliers, organizational policies, andemployee/supplier trainings. This will help Peloton assess theefficacy of due diligence programs and supplier policies inaddressing potential risks of modern slavery.
> Continuing to build human rights protections and standards
into our Supplier Code of Conduct.
In closing, Peloton will continually seek to strengthen humanrights protections in our operations and supply chain alike andwill continue to seek progress on these global issues throughcollaborative action.

Pamela Thomas-Graham
Chairperson, Nominating, Governance, and Corporate
Responsibility Committee Peloton Interactive, Inc.
Board of Directors
December 15, 2022
For and on behalf of Peloton Interactive, Inc.
This statement was executed and approved on December 15,
2022 by the Nominating, Governance and Corporate
Responsibility Committee of the Board of Directors of Peloton
Interactive, Inc. and a link to this statement shall be placed on thehomepage of the Peloton website for the United Kingdom https://www.onepeloton.co.uk/ in accordance with Section 54 of theUK Modern Slavery Act, as well as on the website for the UnitedStates https://www.onepeloton.com/ in accordance with theCalifornia Transparency in Supply Chains Act.

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