At lululemon, we take ethics and integrity seriously. We’re responsible to show up as our best selves with one another and to act in a way that’s respectful and in line with our values.

As we grow to be a truly global brand, we will continue to operate in countries that have a broad range of cultural business practices. Therefore, it’s important that we are all guided by a clear and consistent Code of Conduct that outlines our unwavering commitment to conducting our business ethically.

Living the principles in our Code will enable us to deliver on our purpose—to elevate the world by realizing the full potential within every one of us. The Code, in tandem with our Impact Agenda, helps set the conditions for us to create positive change in building a healthier, thriving future together with our guests, partners, and communities.

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 choice we face in business. Each of us must use common sense and judgment in our personal conduct as we 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 P&C Business Partner, or utilize the other resources listed in the Code.

Upholding our values and living into our Code of Conduct is the ultimate display of personal responsibility. The example that we all set each day shapes who we are for the world, and I look forward to continuing to build the future of lululemon, together.

With gratitude,

Calvin McDonald
Chief Executive Officer

Founded in 1998, lululemon’s purpose is to elevate the world by realizing the full potential within every one of us.

Community matters to us, and our community’s shared values are reflected in the Code of Conduct and Ethics.

To reach our business and personal goals, we must exemplify the highest integrity. This means that we respect our fellow employees and guests and all laws, customs, and cultures. In this spirit, we support a workplace environment that neither pressures nor encourages any employee to compromise their ethical values or standards of conduct.

Wherever the Code refers to an “employee,” it also includes all contractors, officers and directors.

Employees are expected to comply with all laws. This includes not only following the laws of your home country, but also complying with local laws when visiting a different country or transacting business with individuals, organizations or guests located in a different country. In particular, be aware of the following key laws that impact our business:

Anti-corruption

It is never appropriate to offer or ac- cept bribes, kickbacks, or any other type of improper preferential bene- fit. Likewise, we do not allow vendors or other individuals or organizations to offer bribes or kickbacks on our behalf. A bribe can include giving or receiving any item of value (e.g., money/cash, cash equivalents such as gift cards, gratuities, gifts, kick- backs, unauthorized rebates, meals, entertainment, products, trips, favors, 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 have zero tolerance for corruption and we must always operate with integrity regardless of local custom or industry practice. Doing business the right way not only helps us obey the law, but it also strengthens our relationships with local communities and our partners. Please refer to our anti-bribery policy on our company intranet site for more information.

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.

FAQ: What is a bribe?

Bribery is giving money or anything else of value to another person so that they will do something for you. A “kickback” is a form of bribery where money or something of value is given in exchange for services rendered. For instance, making a payment directly to a customs official to “assist” with getting products into a country would be a bribe.

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

Yes. Our policies regarding gifts and entertainment set out in the Code apply equally in all countries regard- less of any perceived local customs/ practice.

Insider Trading Laws

Employees may not buy or sell shares of lululemon stock (or securities of other companies) if they know of material information that has not been made public. Material in- formation 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. You should never provide material non-public information to other people, including your 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 out- lined 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. Employees must not attempt to make any anticompetitive agreements, such as agreements to fix prices or production. In addition, employees must not disclose competitive and non-public information to competitors, suppliers, or distributors.

lululemon recognizes the dignity of the individual, respects and trusts each employee, promotes self-development, and values diverse perspectives and ideas. At the same time, an employee’s personal interests must not improperly influence (or appear to influence) the performance of their duties with lululemon. Employees should avoid any situation that may create, any perceived, apparent or actual conflicts of interest, including:

Personal Relationships

You should not participate in any business decision that could benefit an individual with whom you have a close personal relationship. For example, employees may not influence or have any involvement with employment-related decisions that involve a relative.

In addition, employees may not have any involvement with vendors who are a relative, including being a party to the selection of the vendor.

Gifts and Business Entertainment

Political Activities

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 situation in which a person has a private or personal interest that appears to influence their official duties at lululemon. An example of a conflict of interest would be considering hiring a relative’s company to perform services for lululemon.

Business Opportunities

You may not take advantage of

business opportunities that you learn about through your work with lululemon or direct any such opportunities to another individual or organization, unless lululemon has already been offered and declined the opportunity. Employees may not use company property or information to compete with lululemon.

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.

Outside Employment and Other Potential Conflicts of Interest

Employees must ensure that they do not provide services to another for-profit business that may appear to conflict with their duties to the company, unless otherwise allowed under the terms of their employment or local law. Never provide services to a competitor while you are employed by lululemon. If you’re not sure whether something might be considered a conflict of interest or perceived as a conflict of interest, ask your manager, your People & Culture partner or contact People Practices.

Director Conflicts

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

• 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

If he or she determines that a conflict of interest or the appearance of a conflict of interest currently does or will exist, the director must avoid such action, position or interest.

Prohibition of Loans

lululemon may not directly or indirect- ly, 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 you are at all uncertain about a potential conflict of interest, seek guidance from your manager/supervisor or contact your people & culture partner or People Practices.

Mutual Respect

We strive to provide an environment that allows all employees to excel, be creative, take initiatives, find new ways to solve problems, and generate opportunities. Teamwork helps us to leverage our diverse backgrounds, talents, and ideas. Our high standards for professional and ethical conduct 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 under- stand local laws and customs wherever we operate.

Non-Discrimination

The diversity of our workforce is a tremendous asset that helps us fulfill our mission. We are committed to providing equal opportunity in all aspects of employment and will not tolerate discrimination on the basis of age, race, color, national origin, religion, sex, gender identity or expression, sexual orientation, family status, marital status or any other protected status. We will not tolerate harassment or unlawful behaviors of any kind, including derogatory comments or conduct based sexual orientation, race or ethnicity.

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 includes sexually suggestive gestures, unwelcome leering or staring, and the making of sexual advances or repeated invitations after a previous advance or invitation has been refused.

Hostility, Violence, Bullying and Harassment is Prohibited

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 deliberately impeding or undermining a person’s work, excluding or isolating a person socially, cyber-bullying, and spreading malicious rumours or gossip that are not true.

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.

Reporting

We encourage our workforce to take reasonable steps to prevent bullying, harassment, and discrimination from occurring in our workplace. To this end, employees are required to report any instance of workplace bullying, harassment, or discrimination. De- tailed information on reporting and investigation procedures is set out in our Employee Handbook, pramana.

The Company strictly prohibits any form of retaliation against any individual who makes a good faith report of violence, harassment and/or discrimination, or who participates in an investigation of such reports.

Labour Practices

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

If an employee is unsure or not clear on local labor and employment standards, they should contact People & Culture or their manager. We will not use forced or involuntary labor, child labor, or engage in human trafficking—nor will we tolerate any other individual or organization who en- gages in such practices. We are commit- ted 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

Managers and supervisors should help foster a supportive, inclusive and com- pliant workplace environment. They must always demonstrate their personal commitment to the Code and ensure the same from their employees. Thus, man- agers should exercise care when appoint- ing 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, 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 gender, race, ethnicity, sexual orientation, physical or mental dis- ability, age, pregnancy, religion, veteran status, national origin or any other legally protected status.

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

Workplace Safety

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 require our supply chain partners to agree to maintain safe and healthy workplace facilities.

FAQ: Can I use product strategy informa- tion that a friend of mine at a competitor accidently sent me to develop lululemon’s strategy?

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

Assets

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, patents and trade secrets. You must always protect our IP and make sure you never disclose it to any third party outside of lululemon unless they are contractually required not to disclose the information. 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. If you want to use someone else’s IP (including their names, images or likenesses), you must have appropriate consent to use it. If you’re not sure, reach out 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.

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.

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 dis- closure of data must be immediately reported to Information Security and Legal. 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. your 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.

Accurate Records

You 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

You 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, you 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.

Questions

You can speak to your manager, your People and Culture Partner or any member of the legal department if you have questions about the Code. If you’re not sure 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.

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. Your full cooperation and assistance is required and any failure to do so will be considered a violation of the Code.

Reporting Violations

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

• your manager
• another manager
• your People and Culture partner
• any member of the legal department;
• anyone on our Senior Leadership team;
• the integrity line; or
• Our Audit Committee Chair: Chair, Audit Committee 1818 Cornwall Avenue

Vancouver, British Columbia V6J 1C7 auditcommittee@lululemon.com

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?

Anyone who in good faith reports a possible violation of the Code or assists in the investigation of a reported violation will be protected by the Company. Similarly, any person who reasonably reports any possible violation of local, regional, state, or federal laws or regulations will be protected by the Company. The protection continues even if the report is ultimately unsubstantiated.

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. All Integrity Line reports are 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 and 17 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 also available online at www.lululemon.ethicspoint.com. You may also complete an Integrity Line report online at www.lululemon.ethicspoint.com.

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

Any manager 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.

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 violations of the Code. This acknowledgement must be completed.