MODERN SLAVERY POLICY
Last Updated: April 19, 2024
1.0 PURPOSE
This policy establishes Peloton’s commitment to ethical practices and the prevention of modern slavery within our business and supply chains. It outlines our responsibilities and those of our representatives in observing and upholding our position on modern slavery and provides guidance on identifying and reporting related concerns.
2.0 scope
This policy applies to directors, officers, employees, agents, consultants, contractors, subcontractors, vendors, and other workers at Peloton (collectively referred to as “Representatives” in this policy).
3.0 POLICY
3.1 Definition and Commitment
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour, human trafficking, and child labour. All these forms have one thing in common: they involve the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to prevent modern slavery in our business and supply chains.
3.2 Transparency and Supply Chain Standards
We commit to transparency in our business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all our Representatives and, as part of our contracting processes, and we expect that our suppliers will hold their own suppliers to the same standards.
4.0 Policy Oversight and Management
- The Compliance Officer is responsible for ensuring this policy complies with our legal and ethical obligations, and that Representatives comply with it.
- The Compliance Officer has primary responsibility for implementing this policy, monitoring its use and effectiveness, addressing any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
5.0 Representative Responsibilities and How to Raise a Concern
- You must read, understand, and comply with this policy.
- Preventing, detecting, and reporting modern slavery in any part of our business or supply chains is everyone’s responsibility. Avoid any activities that might lead to or constitute a breach of this policy.
- Notify the Compliance Officer as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur in the future.
- Raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains.
- If you are unsure whether an act, the treatment of workers, or working conditions within any part of our supply chains might constitute modern slavery, report your concerns to the Compliance Officer.
- We encourage openness and will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken. No one shall suffer any detrimental treatment for reporting in good faith their suspicion that modern slavery is or may be taking place in any part of our own business or supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you must notify the Compliance Officer as soon as possible.
6.0 COMMUNICATION
This policy and information on the risks our business faces from modern slavery in its supply chains are communicated to Representatives as part of the onboarding and orientation process. Representatives are required to read and acknowledge this policy annually. Additionally, Peloton will provide specific training programs on modern slavery and trafficking to relevant employees, including those involved in supply chain management and procurement. These training programs will be conducted periodically to ensure awareness and understanding of modern slavery risks and prevention measures.