Sleep Number : Code of Business Conduct

CODE OF BUSINESS CONDUCT

APRIL 2024

Date of Issue: April 2024

I ACKNOWLEDGE AND UNDERSTAND THAT THIS CODE OF BUSINESS CONDUCT DOES NOT CREATE AN EXPRESS OR IMPLIED CONTRACT OF EMPLOYMENT BETWEEN THE COMPANY AND ME. I AGREE AND ACKNOWLEDGE THAT I AM AN AT-WILL EMPLOYEE, MEANING THAT I CAN QUIT OR BE TERMINATED AT ANY TIME, FOR ANY LAWFUL REASON OR NO REASON. I AGREE AND ACKNOWLEDGE THAT THIS AT-WILL RELATIONSHIP CANNOT BE ALTERED AND THAT NO CONTRACT CAN BE FORMED REGARDING ANY TERM OR CONDITION OF EMPLOYMENT UNLESS IT IS IN WRITING AND SIGNED BY THE PRESIDENT OF THE COMPANY. I ALSO AGREE AND ACKNOWLEDGE THAT THIS IS THE FIRST PAGE OF THE CODE OF BUSINESS CONDUCT PUBLICATION GIVEN TO ME.

This Code is a general statement of policy, to be modified, applied and interpreted by Sleep Number at its discretion. Sleep Number reserves the right to vary from any provision in this Code in its complete discretion. This 2024 version of the Code replaces all previous versions of the Code.

Signature_________________________________________________________________________

Print Name _______________________________________________________________________

Date_____________________________________________________________________________

Code of Business Conduct Certification­

I hereby certify that I have received a copy of the Code of Business Conduct of Sleep Number (the "Company"), that I have had an opportunity to read the entire Code and understand its contents.

I acknowledge that I have an opportunity to ask questions of my manager, Human Resources or a representative of the corporate offices regarding the Code of Business Conduct. I also acknowledge that I have participated in the annual Code of Business Conduct training and that I have had an opportunity to ask questions regarding the presentation and the subjects covered by the Code.

I further certify that I am presently not aware of any criminal conduct or any other conduct that would violate Sleep Number's Code of Business Conduct on the part of the Company, its Company Team including all officers, directors, team members, agents or representatives or that if I am aware of such conduct I have reported it through one of the avenues listed below. I also pledge to promptly report, through one of the avenues listed below, or by using the toll-free Ethics and Integrity hotline [phone] or online at sleepnumbercorporation.ethicspoint.com, any good faith suspicion of non-compliance with this Code,

or if I experience or witness any unlawful discrimination, harassment, or retaliation during the course of my employment.

Signature_________________________________________________________________________

Print Name_______________________________________________________________________

Date_____________________________________________________________________________

If you have any questions regarding the Code of Business Conduct, please contact:

1. Your manager;
2. Your Human Resources representative;
3. The Chief Legal and Risk Officer;
4. Any member of the senior management team.

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Sleep Number Team,

Integrity is foundational to our culture - it's what drives us to do the right thing, even when it's a challenge. Integrity, along with our other values, guides us to live our code of ethics every day, underlining our commitment to our purpose of improving the health and wellbeing of society through higher quality sleep.

It's our responsibility to uphold our strong ethics for all our stakeholders - customers, team members, communities, suppliers and shareholders. Our values of Passion, Integrity, Innovation, Courage and Teamwork are our

compass and guide our decisions. Putting our values at the forefront of our interactions reflects our beliefs and furthers our commitment to create and sustain a workplace culture of inclusion and belonging where every team member feels empowered to reach their full potential.

Every team member is expected to always act with integrity and treat others with respect. We are all responsible for conducting our business with the highest ethical standards in accordance with the standards outlined in our Code of Business Conduct. Completing the annual training supports a safe, healthy, respectful workplace we can all be proud of. Modeling this behavior and having a good understanding of these practices is an expectation we have of all our team members.

Thank you for continuing to show integrity in every interaction - doing the right thing on behalf of all our stakeholders. This is who we are, and we are grateful for how you exemplify this commitment every day as we improve more lives.

Sleep well,

Sam Hellfeld

EVP, Chief Legal and Risk Officer and Secretary

My Sleep Number® setting is 65

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Table of Contents
Code of Business Conduct Certification	4
What's the Right Thing to Do?	8
• Right by Our Customers
• Right by the Company
• Right by Our Fellow Team Members and Business Partners
• Right by Our Shareholders
• Right by You
Right by Our Customers	9
Honesty in Our Communications - Marketing and Advertising Compliance	9
Fair Competitive Landscape - Compliance with Antitrust Laws	9
Protecting Our Customers' Privacy	10
Applies in All Countries	10
Right by the Company	11
Our Obligation to Comply with the Law	11
Conducting Business Internationally	12
Compliance with Governmental Investigations	12
Integrity in Decision Making	13
Avoiding Conflicts of Interest	13
Protecting Sleep Number Assets	14
Fair and Honest Relationships with Business Partners
(Including Restrictions on Gifts and Entertainment)	14

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Table of Contents
Business, Travel and Entertainment Expenses	16
Electronic Communications	16
Protecting the Company's Confidential Information	17
Political Activity and Contributions	19
Contacts with the News Media	19
Right by Our Fellow Team Members and Business Partners	20
No Discrimination or Harassment or Retaliation − Treating Everyone with Respect	20
Maintaining a Healthy and Safe Work Environment	21
Protecting Our Fellow Team Members' Privacy	21
Protecting Our Business Partners' Confidential Information	22
Fair and Honest Relationships with Business Partners	22
Right by Our Shareholders	23
Integrity and Accuracy in Financial Reporting	23
Integrity and Accuracy in Public Disclosures	23
Compliance with Accounting and Internal Control Procedures	23
Contract Review and Approval	23
Cooperation with Audit Procedures	24
No Exceptions	24
Insider Trading	24
Right by You	25
Your Obligation to Understand and Comply with the Code	25
Reporting Possible Incidents of Noncompliance	25
Zero Tolerance for Retaliation	26
Disciplinary Matters	27
Exceptions or Waivers	27

Sleep Number team members are employed at will. No policy or provision in this Code of Business Conduct ("Code") is intended to create a contract between Sleep Number and any team member, or to limit the rights of the Company and its team members to end the employment relationship at any time and for any lawful reason, with or without notice or cause. This Code is a general statement of policy, to be modified, applied and interpreted by Sleep Number at its discretion. Sleep Number reserves the right to vary from any provision in this Code in its complete discretion. This 2024 version of the Code replaces all previous versions of the Code.

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What's the Right Thing to Do?

Sleep Number Corporation ("Sleep Number" or the "Company," which includes all of its subsidiaries) requires strict adherence to the letter and the spirit of all laws applicable to the conduct of its business, and demands high standards of integrity and sound ethical judgment from the Company Team including all officers, directors, team members, agents and representatives acting on behalf of the Company. In other words, we all have a responsibility to do the right thing:

• Right by Our Customers
• Right by the Company
• Right by Our Fellow Team Members and Business Partners
• Right by Our Shareholders
• Right by You

We must rely on the individual judgment and diligence of each team member to maintain Sleep Number's standard of honesty and integrity - to do the right thing. Each of us is responsible for reading, understanding and complying with this Code of Business Conduct (the Code). While the Code provides general guidance to help us do the right thing, no set of guidelines can cover all situations. If you encounter a situation where interpretation of the Code is unclear, or you have an ethical question or problem, the best course of action is to discuss it with someone. Consult with your manager, a Human Resources representative, any member of senior management or the Company's Chief Legal and Risk Officer. Anyone contacted with a request for assistance shall take every practical and reasonable measure to ensure that the team member's relationship with the Company shall not be adversely affected as a result of the request. No team member will be subjected to retaliation of any kind because he/she/they has reported a violation of this Code of Business Conduct.

Confidential help is also available through the Company's independently administered Ethics and Integrity hotline. To use the Company's Ethics and Integrity hotline, call 1-833-596-3092 or online at sleepnumbercorporation.ethicspoint.com. It's confidential, toll-free and available 24 hours a day. You may leave your name or remain anonymous.

You should also refer to your Team Member Handbook and policy documents developed by different departments, which contains other Company policies that apply to your conduct as a team member of the Company.

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Right by Our Customers

Honesty in Our Communications − Marketing and Advertising Compliance

It is unlawful and against Company policy to make false, deceptive, or misleading claims regarding the products and services offered by Sleep Number or to make false, deceptive, or misleading statements regarding the products or services offered by our competitors. All claims regarding Sleep Number's products or services, or the products or services of our competitors, must be properly substantiated in accordance with applicable guidelines established by the Federal Trade Commission or other authorities of competent jurisdiction. All marketing and advertising materials and content must also conform to Sleep Number's style guide in order to assure that our intellectual property is properly used and protected, and to avoid the misuse of any other party's intellectual property. To ensure compliance with these guidelines and requirements, Sleep Number team members, agents and representatives may only use, mail, circulate or publish marketing or advertising materials and content that have been approved by the corporate Marketing Department.

The corporate Marketing Department must approve all discounts, contests, sweepstakes, giveaways, drawings and other promotional offerings made available to our customers or related to our products or services. Local marketing programs must conform to guidelines provided by the corporate Marketing Department. All team members, agents and representatives must conduct and administer all such discounts, contests, sweepstakes, giveaways, drawings and other promotional offerings strictly in compliance with the rules and guidelines established by the corporate Marketing Department.

Fair Competitive Landscape - Compliance with Antitrust Laws

Sleep Number's policy is to comply fully with U.S. federal and state antitrust laws and with the antitrust laws of other countries as applicable. This policy applies to Sleep Number's relations with its competitors and its relations with its distributors and dealers carrying Sleep Number products. Sleep Number determines its marketing policies independent of its competitors, distributors or dealers.

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No Sleep Number team member shall enter into any understanding or agreement with any competitor concerning or affecting prices or involving division of territories, allocation of customers or a boycott of any customer or supplier, or any activity that may reduce or eliminate competition in violation of applicable antitrust laws. Sleep Number team members are not authorized to nor shall they enter into an agreement to control the resale prices of any distributor or dealer and shall comply with applicable antitrust laws concerning non-price relations with a distributor or dealer.

Sleep Number team members, agents and representatives shall strive to avoid any conduct that might even appear to violate antitrust laws. No Sleep Number team member is authorized to permit the departure by any other team member from Sleep Number's policy of compliance with antitrust laws. Sleep Number team members, agents and representatives should avoid discussions with competitors involving projected sales, revenues and expenses, production schedules, inventories, unannounced products or services, pricing strategies, marketing plans or proprietary Company information. These guidelines also apply to informal contact you may have with competitors, including those at tradeshows or meetings of professional organizations. If a competitor attempts to discuss such topics, please do not engage in the conversation, and promptly report the issue to Sleep Number's Chief Legal and Risk Officer.

The following are examples of possible violations of antitrust laws. If you encounter any situation involving such matters, you must bring it to the attention of the Company's Chief Legal and Risk Officer:

• Agreements between competitors to set or fix prices, allocate markets or customers, limit production or quality, or boycott a customer or supplier; or
• Agreements with customers to control resale prices, require tie-in sales (requiring the purchase of one product as a condition to selling another), require reciprocal dealings or restrict marketing territory.

Before engaging in any conduct that a team member believes may be subject to antitrust laws, the team member shall seek the advice of the Company's Chief Legal and Risk Officer. Any Sleep Number team member having reason to question whether the conduct of any other team member is in compliance with antitrust laws shall promptly report the matter to the Company's Chief Legal and Risk Officer.

Protecting Our Customers' Privacy

It is imperative that we maintain the confidentiality of our customers' confidential or personally identifiable information, including, without limitation, credit card information (credit/debit card numbers, expiration dates, CVV/CVC2s or PINs), Social Security numbers, addresses and telephone numbers. Inadvertent disclosure of such information could compromise the credit or privacy of our customers and could expose the Company to significant risk of fines, penalties or damages. Each of us has an obligation to take all reasonable precautions to avoid placing this information at risk. If you believe, or reasonably suspect, that any of our customers' confidential information has been compromised in any way, please contact the Legal Department immediately.

Applies in All Countries

Sleep Number conducts business internationally and the standards described above, or variations thereof, as well as numerous other laws, will apply to our relationships with our customers in other countries. Please refer to the following section under the heading Right by the Company − Conducting Business Internationally for more information regarding our obligations to comply with foreign laws.

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