Supplier Code of Conduct & Supply Chain Transparency Statement

SUPPLY CHAIN TRANSPARENCY STATEMENT

The California Transparency in Supply Chains Act of 2010 and the United Kingdom Modern Slavery Act require certain businesses to provide public disclosures regarding efforts to eradicate slavery and human trafficking from their supply chains. Such disclosure is intended to provide consumers with information that will allow them to make more informed decisions about the goods they are purchasing. As outlined in this Code, Fitbit takes reasonable steps to help ensure slavery and human trafficking (as such phrase is defined in section 54, UK Modern Slavery Act 2015) is not taking place in any part of its supply chain or otherwise as a part of its own business. Upon request, Fitbit will provide a statement of the steps it has taken, together with such other information a requestor may reasonably require in order to enable it to prepare a slavery and human trafficking statement in accordance with section 54, UK Modern Slavery Act 2015.

C-TPAT

To the extent a supplier transports goods for Fitbit into the United States, the supplier must comply with the C-TPAT (Customs-Trade Partnership Against Terrorism) security procedures on the US Customers website at www.cbp.gov (or other website established by the US government for such purpose).

LABOUR

We believe all workers in our supply chain deserve a fair and ethical workplace. Workers must be treated with dignity and respect and our suppliers must uphold certain standards of human rights. The labour standards set forth in this Code must be applied to all types of workers, including temporary, migrant and student. Those labour standards are:

Prevention of Involuntary Labour and Human Trafficking - All work must be voluntary. Involuntary labour, slavery or trafficking persons is not allowed.

Prevention of Underage Labour - Suppliers may only use workers who are at least 15 years of age or the applicable minimum legal age, whichever is higher. Furthermore, workers under the age of 18 shall not perform work that is likely to jeopardise their health or safety, including night shifts and overtime. Fitbit does support the development of legitimate workplace apprenticeship programmes that comply with applicable laws and this Code.

Working Hours - Suppliers must follow all applicable laws and regulations with respect to working hours, overtime and days of rest. Even if allowed under applicable laws and regulations, a work week must not exceed 60 hours, including overtime, and workers must take at least one day off every seven days, except in emergencies or unusual situations.

Wages and Benefits - Compensation paid to workers must comply with applicable wage laws, including those related to minimum wages, overtime hours and legally mandated benefits. Suppliers may not withhold wages as a disciplinary measure. Additionally, for each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify their compensation is accurate.

Humane Treatment - Harsh or inhumane treatment is not permitted. This includes sexual harassment or abuse, corporal punishment, mental or physical coercion or verbal abuse, nor is there to be any threat of such treatment. Policies and procedures in support of these requirements shall be clearly defined and communicated to workers.

Non-Discrimination - We are committed to a workplace that is free of harassment and unlawful discrimination. Suppliers must not discriminate against any worker based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered military veteran status, protected genetic information or marital status. In addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

Freedom of Association and Collective Bargaining - In conformance with local law, suppliers shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

HEALTH AND SAFETY

We believe a healthy work environment is core to a company whose mission it is to help people lead healthier, more active lives. Therefore, our suppliers are required to maintain a work environment that meets the health and safety standards set forth in this Code. Workers must always have the right to refuse unsafe work and report unhealthy working conditions. Those health and safety standards are:

Occupational Health, Safety and Hazard Prevention - Worker exposure to potential safety hazards must be identified, assessed and controlled through proper design, engineering and administrative controls, preventative maintenance, safe work procedures and ongoing safety training. Where these hazards cannot be adequately controlled by these means, workers shall be provided with appropriate personal protective equipment, as well as educational materials about risks associated with these hazards. Reasonable steps must also be taken to remove pregnant women/nursing mothers from working conditions with high hazards, remove or reduce any workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments, as well as include reasonable accommodation for nursing mothers.

Emergency Prevention, Preparedness and Response - Suppliers must identify, evaluate and manage occupational health and safety hazards through a prioritised process of hazard elimination, engineering controls and/or administrative controls. Such plans and procedures must focus on minimising harm to life, the environment and property.

Workplace Injury and Illness - Prevention, management, tracking and reporting of occupational injury and illness shall be supported by appropriate procedures and systems. These procedures and systems should encourage workers to report incidents, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes in order to facilitate return of workers to work.

Industrial Hygiene - Worker exposure to chemical, biological and physical agents is to be identified, evaluated and controlled. When hazards cannot be adequately controlled by such means, workers are to be provided with, and use, appropriate, well-maintained, personal protective equipment. Protective programmes shall include educational materials about the risks associated with these hazards.

Physically Demanding Work - Worker exposure to hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.

Machine Safeguarding - Production and other machinery must be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazards to workers.

Sanitation and Workplace Conditions - Workers are to be provided with access to clean toilet facilities, potable water, as well as sanitary food preparation, storage and eating facilities. Where dormitories are provided, the dormitories must be maintained clean and safe, including, providing for appropriate emergency exits, hot water for bathing and showering, adequate heat and ventilation and reasonable personal space, as well as reasonable entry and exit privileges.

Health and Safety Communication - Suppliers must provide workers with appropriate workplace health and safety training in their main language. Health and safety related information shall be clearly posted in the facility or another place readily accessible by workers. We recognise that ongoing worker input and education is essential to identifying and solving health and safety issues in the workplace and require that our suppliers seek that on a regular basis.

ENVIRONMENTAL

We recognise that we can’t help change peoples’ lives without ourselves working closely with our suppliers to minimise any adverse effects our manufacturing operations may have on the community, environment and natural resources. Therefore, we require our suppliers to meet the environmental standards set forth in this Code. Those environmental standards are:

Environmental Permits and Reporting - All required environmental permits, approvals and registrations are to be obtained, maintained and kept current by suppliers and their operational and reporting requirements are to be followed.

Pollution Prevention and Resource Reduction - The use of resources and generation of waste of all types by our suppliers are to be minimised or eliminated at the source or by practices such as modifying production, maintenance and facility processes, or by other means.

Hazardous Substances - Suppliers must implement a systematic approach to identify, manage and reduce chemicals and other materials posing a hazard to humans or the environment, including that such chemicals are to be identified, labelled and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

Solid Waste Management - Suppliers shall implement a systematic approach to identify, manage, reduce and responsibly dispose of or recycle solid waste (non-hazardous).

Air Emissions Management - Air emissions that pose a hazard to the environment are to be characterised, routinely monitored, controlled and treated as required prior to discharge. Suppliers shall conduct routine monitoring of the performance of their air emission control systems.

Material Restrictions - Suppliers are to adhere to applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labelling for recycling and disposal.

Water Management - Suppliers shall implement a water management programme that documents, characterises and monitors water sources, use and discharge, seeks opportunities to conserve water, and controls channels of contamination. All wastewater is to be characterised, monitored, controlled and treated as required prior to discharge or disposal. Suppliers shall conduct routine monitoring of the performance of their wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

Energy Consumption and Greenhouse Gas Emissions - Suppliers are to track and document energy consumption and greenhouse gas emissions. Suppliers are to look for cost-effective methods to improve energy efficiency and to minimise their energy consumption and greenhouse gas emissions.

ETHICS

We believe that underpinning the standards discussed above is the need to uphold the highest standards of ethical conduct in all business dealings. Therefore, we require that our suppliers meet the standards of business ethics set forth in this Code. Those ethical standards are:

Business Integrity - Suppliers must have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement.

No Improper Advantage - Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorised, given or accepted, either directly or indirectly through a third party. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

Disclosure of Information - All business dealings should be transparently performed and accurately reflected on Suppliers’ business books and records. Furthermore, Suppliers must accurately disclose such information as required under applicable laws.

Intellectual Property - Intellectual property rights are to be respected, including that the transfer, use and storage of confidential information is to be done in a manner that reasonably protects intellectual property rights and confidentiality.

Fair Business, Advertising and Competition - Standards of fair business, advertising and competition are to be upheld.

Protection of Identity and Non-Retaliation - Programme that ensures the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained, unless prohibited by law. A formal process by which personnel are able to raise any concerns without fear of retaliation is to be communicated to workers.

Responsible Sourcing of Minerals - Suppliers shall have a programme that reasonably assures that the tantalum, tin, tungsten and gold in the products they manufacture do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Suppliers shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to us upon request. Fitbit’s policy on the responsible sourcing of minerals is available at fitbit.com/legal.

Privacy - Suppliers must take reasonable measures to protect the privacy of personal information of everyone it does business with, including suppliers, customers, consumers and its employees. At a minimum, suppliers must comply with all applicable privacy and information security laws and regulations when personal information is collected, stored, processed, transmitted and shared.

MANAGEMENT SYSTEM

We believe that paramount to a Supplier ensuring its compliance with the standards set forth in this Code is the implementation by Supplier of a management system designed to identify and mitigate operational risks related to this Code and seek continual improvement of its business operations. Core to any such management system are the following elements:

Company Commitment - Statements affirming Supplier’s commitment to compliance and continual improvement, endorsed by executive management, including translations to local language.

Management Accountability and Responsibility - Tasking senior executives with ensuring implementation and ongoing review of the management system.

Legal and Other Requirements - A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.

Risk Assessment and Management - A process to identify the legal, compliance, environmental, health and safety, security, labour practices and ethics risks associated with a supplier’s operations. Suppliers must determine the relevant significance for each risk and implement appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.

Improvement Objectives - Written performance objectives, targets and implementation plans to improve the Supplier’s performance in achieving those objectives.

Training - A programme for training Supplier’s workforce to implement Supplier’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.

Communication - A process for communicating clear and accurate information about its policies, practices, expectations and performance to workers, suppliers and customers.

Worker Feedback, Participation and Grievance - Ongoing processes to assess employees’ understanding and to obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.

Audits and Assessments - Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.

Corrective Action Process - Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

Documentation and Records - Creation and maintenance of documents and records to help ensure regulatory compliance and adherence to company requirements along with appropriate confidentiality to protect privacy.

Supplier Responsibility - A process by which each supplier communicates the requirements of this Code to its suppliers and to monitor its suppliers compliance to this Code.