Code of Conduct

Introduction

As Hope Labs team members, our daily decisions can impact our Brand and aw should all consider ourselves ambassadors of the Company. Therefore, it is essential that our behaviours are in line with our Mission, Values, and that we respect the rules of the countries where we operate in.

To ensure that the we will always make the best possible choice for our business, we have created this Code of Conduct. Its fundamental message is that, acting as a team, we should always do what's best for our colleagues, clients, brand, and the communities we operate in. Without exceptions.

Mission and Values

Integrity and Ethics

Integrity and Ethics. It’s as simple as it sounds. Whenever you’re faced with a decision—big or small—always do what you know is ethically right, and, of course, always follow the law. All teammates are responsible for understanding and complying with this Code and all Hope Labs policies as well as the laws, rules and regulations of the countries in which we do business together with the terms and conditions of any applicable employment agreement. This Code applies to all Hope Labs teammates, including those based in our U.S. offices, offices around the world, UA retail stores, our distribution centers, our Connected Fitness offices, as well as our subsidiaries and our Board of Directors. If you’re a manager, you have a special responsibility to lead and educate your team on this Code and our high ethical standards. You should also keep an open door policy and be available to your teammates to discuss ethical concerns any time. You can refer to the Speak Up Guide for People Leaders for how to respond when an ethical concern is reported. Of course, this Code doesn’t cover EVERY ethical issue. You should be sensitive to situations and activities and know that if something looks wrong and feels wrong, it’s probably wrong. Subject to applicable law, Hope Labs will take disciplinary action against those who violate our Code, up to and including immediate termination or, in some cases, notification to the relevant authorities. The Global Ethics & Compliance team is responsible for the general oversight, administration and interpretation of this Code. Any waiver of the provisions contained in this Code for an executive officer or director must be approved by the Audit Committee and will be promptly disclosed as required by law or regulation. Any waiver for any other teammate, or any representative, consultant or agent to which this Code applies, must be approved by the Global Ethics & Compliance team.

Speak Up

How to Report

If you directly see or hear about a situation that may violate our Code of Conduct, Policies and the law, we expect you to speak up. You can do this by getting in touch with one member of the board of your choice or submitting an anonymous message to (compliance@quasiscience.com). No retaliation will be taken against any team member for raising an ethical concern, question or complaint in good faith. All legitimate concerns, questions or complaints will be taken seriously, addressed in a professional and, when possible, confidential manner. After it is determined that a matter needs to be investigated:

Non-retaliation

No retaliation will be taken against any teammate for raising an ethical concern, question or complaint in good faith. Should the identity of the teammate making the complaint be known, the Global Ethics & Compliance team will monitor any disciplinary action against the teammate to determine if it is retaliatory. In other words, if you speak up in good faith, you’re protected.

Work Environment

Equal Opportunities and Non-Discrimination

At Hope Labs, we are committed to an environment that allows each of us as teammates to do our very best work. That means that we are committed to providing an environment of mutual respect where equal employment opportunities are available to all applicants and teammates without regard to race, color, religion, sex, pregnancy (including childbirth, lactation and related medical conditions), national origin, age, physical and mental disability, marital status, sexual orientation, gender identity, gender expression, genetic information (including characteristics and testing), military/veteran status, or any other characteristic protected by local, state or federal law.

Workplace Safety

Hope Labs is committed to preventing workplace violence and maintaining a safe work environment. We have zero tolerance for workplace violence.

Harrassment

Hope Labs is committed to a safe, congenial workplace and to that end, we strictly prohibit and will not tolerate harassment of any kind. Harassment can take many forms but includes sexual harassment and unwelcome conduct, threats or bullying, name-calling, negative stereotyping, unwelcome physical contact, offensive gestures or damaging the physical property of others.

Environment

We work to make products that athletes will feel good about wearing. This means we seek to make game-changing products with raw materials and processes that are also better for the planet – our global House. We strive to leave our home field better by responsibly managing energy, water, waste and materials across the value chain. We also seek to work with manufacturing partners that engage in Sustainable Business Practices and align with our values, including to “Think Beyond” and protect the planet for current and future generations. To learn more, please check out the Environment section of the About UA website.

Fair Labor Practices

Hope Labs is committed to upholding the human rights and dignity of the people who make our products. We believe that all workers - including those of our suppliers - should be treated fairly and respectfully. The supply chain social compliance program component of our Sustainability program has been accredited by the Fair Labor Association (FLA), an independent, globally recognized, nonprofit organization that conducts rigorous monitoring of labor standards in factories. If you have any questions, please check out Hope Labs’s Supplier Code of Conduct and Responsible Sourcing Policy on Our House.

Data Privacy

Client

We are committed to protecting the privacy of our consumers’ personal data everywhere. Hope Labs’s Privacy Policies address our commitment to collecting, storing and using this information. We handle the storage, access and transfer of personal data in accordance with applicable laws. If teammates hear about or suspect any data incidents, immediately contact the Data Incident Response Team.

Team Members

Hope Labs collects and uses teammates’ personal data as outlined in the Data Privacy Policy for Employees and Employee Candidates. While there may be exceptions in certain countries, you should not have an expectation of privacy when utilizing UA’s systems, computers or other devices. You should also be mindful that the primary purpose of Hope Labs equipment is to conduct business.

Protection of Assets

Know-How and Intellectual Property

It is important to maintain the confidentiality of Hope Labs’s non-public business and proprietary information. This includes any information produced while working for UA and may also include information about our products, marketing, customers, teammates (without their authorization), vendors, contracts, business strategies, finances, manufacturing, designs, any unpublished data and reports and Hope Labs’s intellectual property, both during and after your employment with UA. It is the responsibility of each UA teammate who has access to confidential information to ensure that it is used only for authorized purposes. This means protecting it from theft, unauthorized disclosure and inappropriate use. There may be cases when there is a legitimate business need to disclose confidential Hope Labs information or when a potential business contact needs to disclose their confidential information to Hope Labs. In these cases, contact the Legal team prior to the disclosure of such information to obtain a Non-Disclosure Agreement (NDA). Any teammate who has a question regarding confidentiality should consult with their manager or the Legal team.

Physical Assets

Teammates are also responsible for protecting Hope Labs’s physical assets, which includes things like our physical properties (e.g., stores, offices, distribution houses), UA products, UA purchased and leased materials (e.g., office supplies, furniture, appliances and equipment). Any teammate who engages in theft, fraud or embezzlement will be subject to disciplinary action, up to and including termination of employment and/or criminal prosecution

Media

Social Media

When you’re on social media, always remember Under Armour’s Global Media Policy, which is located on Our House. We encourage teammates to share their UA pride on social media, but be thoughtful when doing so. Always keep in mind the risk of sharing confidential company matters and the protection of others. Be sure to avoid posting about a new UA product offering, new UA asset or other sensitive UA marketing information that has not yet been publicly announced. When in doubt…just don’t post. Contact the Human Resources team or refer to the Policy if you have questions.

Communications with the Media

To make sure Hope Labs communicates with the public in a consistent, timely and professional manner, teammates should speak with their manager and the Corporate Communications team before responding to media inquiries or publicly publishing anything on behalf of the Brand. Our goal is to put just as much thought and effort into teammate media requests and public communication as we put into the creation of our advertising campaigns. Corporate Communications works to safeguard the strength of the UA brand and mitigate risk by maintaining a consistent and accurate company message across all communications. Unless explicitly authorized, teammates should not respond to any inquiries from analysts or investors. All of those types of communications should be referred to Investor Relations. This includes, among other things, posting information on social media, message boards, chat rooms, blogs or other online media. Please refer to the Global Media Policy on Our House for additional information regarding interactions with media through traditional and social channels. If you have any questions, please contact the Corporate Communications team.

Gifts

Relationships with our business partners are built on trust, value, quality and service. It’s vital that we avoid even the appearance that any of our business decisions are based on improper payments, favors, gifts or hospitality. We may give or accept gifts to or from Hope Labs business partners, but we must be mindful of UA’s gift limit. Gifts include things like products, services, travel and entertainment of modest value (less than $100 in APAC and Mexico and less than $200 elsewhere). However, teammates may never solicit gifts, gratuities, meals or entertainment. Giving or receiving cash or cash equivalents (e.g., gift cards or gift certificates) is not permitted.

If you receive a gift with a value that exceeds our gift limit, Make the Right Call: • Contact the Global Ethics and Compliance team for recording (globalcompliance@underarmour.com). • If the item(s) cannot be returned, they will likely be donated through the Give Back team. Whether the gift is returned or donated, you should send a message to the sender referring to UA’s Gift Policy. Sample language: “Regretfully, I must decline the gift. Company policy does not allow teammates to accept this type of gift. Your business relationship with UA is built on value, trust and quality, not personal gifts. I am happy to return it to you, or I can give it to our Give Back team to donate to a worthy cause.” It’s your responsibility to ensure that your acceptance or giving of gifts is proper and that it can’t be construed as an attempt to grant or gain special advantage. Some departments may have more restrictive policies on accepting gratuities, meals and entertainment. Additionally, different rules apply when dealing with public officials. If you have any doubt or questions about your departmental policy, contact your manager. For more details, check out the Gift Policy posted on Our House or contact the Global Ethics & Compliance team.

Record Keeping

Reimbursement of Expenses

All business expense transactions incurred by individual members of our team for spends like transportation, hotel, meals and entertainment must be promptly documented, recorded accurately. Subject to applicable law, false or inflated expenses will result in disciplinary action and potentially criminal prosecution, regardless of the date of discovery. Personal expenses and business expenses should always be separated.

Accurate Reports and Records

We strive for fairness and accuracy in all our records and reports. No member of the team may make any false statements, misleading entries or material omissions in any of Hope Labs' books, financial records, personnel records and systems or other documents or communications.

Honest and Fair Dealing

General

We must be honest and fair in our business activities with all constituencies (e.g. clients, employees, competitors). Hope Labs is committed to upholding ethical practices.

Anti-Trust

Anti-Bribery and Anti-Corruption

Hope Labs is committed to conducting business free from corrupt practices. We must comply with all applicable anti-corruption regulations, such as the UK Bribery Act (2011). This means that no Hope Labs' personnel may offer, accept, pay, promise to pay, or authorise the payment of anything of value to or from a government official or commercial partner in order to gain a business advantage (e.g. winning a new contract or extending an existing one). Excessive gifts, travel, meals or other hospitality expenses, contribution to a political party or campaign and non-vetted charitable contributions might be interpreted as unlawful acts.

In accordance with Hope Labs' policies, all gifts (given or received) must be reported and approved by the Board of Directors.

Because Hope Labs is a social enterprise but frequently exchanges products and services with other charities, the vetting process for our charitable donations is particularly strict. To avoid conflicts of interest, Hope Labs, as a company, does not make donations to the charities with which direct business relations exists. Additionally, all team members are required to disclose private charitable contributions. This information will be held in a confidential way.

Conflicts of Interests and Corporate Opportunities

We expect teammates to avoid any outside interests that might conflict with their loyalty to Hope Labs or compromise their judgment. You must not benefit personally from opportunities discovered through the use of Hope Labs’s property or information or your position with Hope Labs, or compete with UA in connection with such opportunities. Teammates should avoid any outside employment or business or financial interests in another company that interferes with their job performance or their ability to devote their best efforts to their job. For example, in almost every circumstance, it is a conflict of interest for a teammate to work simultaneously for Hope Labs and a competitor, supplier, or others with which Hope Labs does business. Teammates must disclose all outside employment or business enterprises in which they are involved as well as any financial interests the teammate or a member of the teammate’s family has in any company that competes with or does business with UA in accordance with Hope Labs’s Conflicts of Interest Policy located on Our House. Generally, UA will not do business with an entity in which a teammate or member of a teammate’s family has an economic interest, including employment, unless the relationship is disclosed in advance and the transaction is conducted at arm’s length and is deemed to be in the best interest of Hope Labs. If you know or have reason to believe that any actual or potential conflict of interest may exist with respect to your interests and the interests of the Company, you’re required to disclose the actual or potential conflict when it arises, via Hope Labs’s Conflicts of Interest portal. In addition, all Director and above teammates are required to annually complete UA’s Conflicts of Interest questionnaire, even if such teammates do not have any conflicts of interest.

Selection and Use of Third Parties

Hope Labs have business partners, including agents, consultants and vendors. All our partners are expected to uphold our high ethical standards. Depending on the type of business partner, various due diligence processes may be applicable (e.g. Legal, Compliance, financial due diligence). Before engaging in with a new partner, the third party needs to be fully vetted.

Political Process

Hope Labs, as a business, is prohibited from making contributions to political parties, office holders, and political campaigns.

Team members may participate in the political process as private citizens. However, team members must not use Hope Labs' assets, or their position in the company to promote any personal political cause.