Last Updated: July 29, 2025

1.0 Purpose

Peloton is committed to maintaining a professional, ethical, and respectful work environment. This policy outlines the standards of behavior expected from all employees, contractors, and representatives of Peloton.

1.1 Mission Statement

To provide energy data management solutions that enable our customers to maximize productivity, while pursuing relentless improvement in our products and services.

1.2 Vision Statement

The Peloton Platform will be the world’s Energy Data Management system.

2.0 Scope

This policy applies to all directors, officers, employees, agents, consultants, contractors, subcontractors, vendors, and other workers at Peloton (collectively referred to as “representatives” in this policy).

3.0 Our Values

• Ownership: We take full ownership of our work—our tickets, projects, products, and accounts. We deliver as promised and are forthcoming when we fall short. We trust our teammates to do the same and hold ourselves accountable for continuous improvement.
• Teamwork: We treat everyone with kindness and foster collaboration. We embrace diversity, support team cohesiveness, and value open dialogue and constructive feedback as a path to better decisions. We celebrate wins together and communicate with empathy and clarity.
• Boldness: We challenge the status quo with courage. We ask analytical questions to uncover the true problem before acting, and we embrace innovation and brave thinking to drive meaningful progress.
• Integrity: We are loyal to our team and transparent in our interactions. We communicate openly, own and fix our mistakes, and commit fully to decisions. Trust and credibility are built through honesty and consistency.
• Mindful Growth: We pursue improvement with intention. We consider the impact of every decision and feature—not just for growth’s sake, but to deliver meaningful value to our customers and our team.

4.0 Commitment to Ethics

• Open-Door Policy: Peloton maintains an open-door policy to encourage open communication, feedback, and discussion on any matter of importance. Representatives are encouraged to raise concerns about conflicts of interest, harassment, discrimination, bribery, workplace violence, or any code of conduct violations with any manager, including executive management, at any time.
• Fair Treatment: Treat everyone fairly and with mutual respect. Avoid unethical practices.
• Legal Compliance: Comply with all legal regulations and standards. Maintain confidentiality.

5.0 Raising Issues and Concerns

Peloton representatives have a responsibility to report concerns related to harassment, discrimination, anti-bribery, anti-corruption, and workplace violence. Representatives are required to adhere to Peloton's Code of Conduct policy and report any violations to Human Resources or the Compliance Officer immediately upon becoming aware of such violations. Peloton will not retaliate against anyone who, in good faith, reports violations or suspected violations, or assists in an investigation of a reported violation.

Please provide detailed information about your complaint or concern, as Peloton's investigation depends on the quality and details of the information provided. All properly reported violations will be promptly investigated, and violators may face disciplinary action, including termination. Legal violations will be reported to law enforcement authorities. Peloton will maintain confidentiality in good faith reports and take reasonable steps to protect anonymity, subject to applicable laws.

To report a concern, please contact Human Resources or reach out to Peloton's Compliance Officer.

Human Resources

• Email: hr@peloton.com
• Phone: +1.587.674.8237
• Mail or In-person: HR Manager; 3300, 525 8th Ave SW, Calgary, AB T2P 1G1

Compliance Officer

• Email: compliance.officer@peloton.com
• Phone: +1.403.801.5890
• Mail or In-person: Compliance Officer; 3300, 525 8th Ave SW, Calgary, AB T2P 1G1

6.0 Ensuring a Safe and Respectful Workplace

Creating a safe and supportive environment is extremely important to us. Everyone is entitled to work in an inclusive environment that is free from unlawful discrimination, harassment, and violence.

Peloton has zero tolerance for discrimination, harassment, or violence from any source internal or external. Representatives should report any inappropriate situations to their supervisor, Human Resources, Compliance Officer or executive management.

Equal Opportunity Employment: Peloton is an equal opportunity employer. We prohibit unlawful discrimination in employment based on gender, race, color, creed, religion, age, citizenship, sexual orientation, gender identity, gender expression, genetic information, marital status, pregnancy, national origin, ancestry, physical or mental disability, military or veteran status, or any other protected class under applicable laws. Discrimination based on perceived characteristics or associations are prohibited.

Harassment: Peloton is committed to maintaining a respectful workplace, free from all forms of harassment.

• Harassment includes unwelcome conduct based on a person’s protected characteristic that affects their employment opportunities, work performance, or creates an intimidating, hostile, or offensive working environment. Examples include slurs, negative stereotyping, threatening acts, pranks, jokes, and hostile written or graphic material.
• Sexual harassment includes unwelcome sexual advances, requests for sexual favors, and other conduct of a sexual nature, such as displaying sexually suggestive material, unwelcome flirtations, suggestive comments, verbal abuse of a sexual nature, sexually-oriented jokes, crude or vulgar language or gestures, graphic or verbal commentaries about an individual’s body, display or distribution of obscene materials, physical contact such as patting, pinching, or brushing against someone’s body, or physical assault of a sexual nature.

Respectful Communications: Peloton representatives are expected to communicate and interact with each other respectfully, regardless of differences in opinions. Be mindful of remarks on culture, politics, religion, health, and sexual orientation, as these topics are sensitive and can easily have negative or unintended effects on people. Do not call out or shame people for their lawful, personal beliefs, activities, or statements on moral, political, or social issues. Peloton representatives are expected to comply with this Code of Conduct policy during their interactions with peers, management, clients, customers, Peloton’s business contacts, and on Peloton’s community forums like Slack, Teams, and Zoom.

This policy also extends to public statements that relate to or impact Peloton, its reputation, or its representatives, including social media posts using personal accounts. It is everyone’s responsibility to create a healthy and inclusive workplace environment, where all communication and interactions are marked by dignity and respect.

7.0 Health & Safety

Peloton strives to provide a safe, healthy, and sanitary work environment. Representatives are responsible for helping to maintain a safe and healthy workplace for everyone by following safety and health rules and practices when sick, and promptly reporting accidents, injuries, and unsafe equipment, practices, or conditions. This responsibility extends to customer sites, where our Peloton representatives will follow all applicable Health and Safety guidelines.

Maintaining a physically safe environment may involve on-site video surveillance, access card protocols, vigilance against tailgating, reporting suspicious behavior to law enforcement, and aiding law enforcement during investigations.

Representatives should also be alert to early warning signs of violence, such as intimidating behavior, physical assault, destruction of property, and threats, and take appropriate actions, including notifying Human Resources and contacting law enforcement when necessary.

Our Peloton representatives will follow the Health and Safety guidelines when on customer sites.

8.0 Drugs & Alcohol

Peloton is committed to maintaining a safe and healthy work environment. Substance abuse is strictly prohibited as it is incompatible with the health and safety of our representatives. While alcohol may be available at our offices and corporate events, representatives are expected to use good judgment. Consumption of alcohol should never lead to impaired performance, inappropriate behavior, endangerment of oneself or others, or violation of the law.

Representatives must always behave appropriately, promoting Peloton’s interests and reputation. Alcohol consumption should be moderate to avoid intoxication that could lead to abusive, harassing, improper, or illegal conduct.

Driving a vehicle on Peloton business, including transporting other representatives, while under the influence of alcohol, cannabis, non-medical or illegal drugs, or other controlled substances is strictly prohibited. Peloton has a zero-tolerance policy for driving under the influence.

No representative should feel pressured to consume alcohol at any event. To ensure safety, Peloton may monitor alcohol consumption at events and provide taxi chits or online vouchers such as Uber Vouchers for safe transportation home. If a representative appears to be excessively intoxicated and may drive, Peloton may take steps such as preventing the representative from driving, calling a family member, removing vehicle keys, or contacting the police.

If a representative is impaired, they should not return to work activities. The general rule is that if a representative feels they cannot drive, they should not return to work.

Illegal and non-medical legal drugs in our offices or at sponsored events are strictly prohibited.

9.0 Confidential Information and Intellectual Property

• Confidential Information: Protect all confidential information belonging to Peloton, its customers, and third-party vendors. Only share confidential information with those who need it for their job.
• Intellectual Property: Safeguard Peloton’s intellectual property and avoid inappropriate or unauthorized disclosures. Report any security incidents immediately.

10.0 Compliance with Law

• Legal Compliance: Understand and follow the laws and regulations that apply to your work. Deal honestly, ethically, and fairly with suppliers, customers, competitors, and representatives.
• Anti-Corruption: Never bribe anyone or accept bribes for any reason. Follow all applicable laws regarding gifts and entertainment.
• Modern Slavery: Never engage in or tolerate any form of modern slavery. Follow all applicable laws on modern slavery.

11.0 Training and Awareness

Peloton provides regular training to all representatives on respectful workplace behavior, including harassment and violence prevention. This includes onboarding and annual refreshers. Training is reviewed regularly to ensure effectiveness and compliance.

12.0 Enforcement

Any representative found to have violated this policy may be subject to disciplinary action, up to and including termination for just cause.