Sleep Number requires strict adherence to the letter and the spirit of all laws applicable to the conduct of its business and demands the same from our Vendors. We expect a high standard of integrity and sound ethical judgment from our own team members and expect the same from our Vendors. We all have a responsibility to “do the right thing.” Toward that end, this Code of Business Conduct for Vendors is intended to address several key areas: Labor and Human Rights, Health and Safety, Sustainability and Ethics.


The Sleep Number Code of Business Conduct for Vendors (“Code”) applies to all suppliers or companies that manufacture product or supply goods or services to Sleep Number, including the affiliates and subsidiaries of such companies. The Code also applies to any permitted supplier sub-contractors for which the supplier shall be responsible for such compliance. Any supplier who utilizes the services of sub-contracts shall identify such sub-contracts to Sleep Number prior to their engagement on Sleep Number’s behalf. Hereinafter, all of the aforementioned suppliers, companies, sub-contractors and individuals shall be referred to as Vendors. This Code is not all inclusive. At a minimum, however, we require that all Vendors meet the standards expressed herein.


Sleep Number and its designated agents including, in some cases, external auditors, can audit Vendor to ensure compliance with the standards of the Code of Business Conduct. Factories and employer provided housing, if any, can be inspected, and employees can be interviewed as part of the process. If permission to conduct an audit is denied, consequences up to or including termination of our agreement may occur. Further, Sleep Number reserves all rights to require Vendors to self-certify their compliance with the Code in writing at any time. Vendors are urged to retain all documentation that they feel is necessary in order to demonstrate their compliance with this Code over time. Vendors will communicate the requirements of this Code to their employees and sub-contractors. Vendors shall make the Code readily accessible to their employees and subcontractors in their local language.


Full commitment to the principles and standards of the Code is a condition of doing business with us. Notwithstanding any contractual provision otherwise, the failure of a Vendor to comply with both the spirit of the Code as well as the letter of any applicable federal, state, local, provincial or international law, rule or regulation will result in the termination of the Vendor’s relationship with Sleep Number and any of its subsidiaries or affiliates for cause. The continued provision of products, goods or services by the Vendor to Sleep Number after receipt of this Code evidences the Vendor’s agreement to the requirements contained herein.


Vendors must uphold the human rights of its workers and treat them with dignity and respect.

Fair Treatment: Vendors will treat their employees with dignity and respect and no employee shall be subject to physical, sexual or psychological harassment or physical or mental abuse, corporal punishment, mental coercion, physical coercion, or unreasonable restrictions on freedom of movement.

Non-Discrimination: Vendors will not discriminate against any worker in hiring or employment practices including salary, benefits, advancement, discipline, termination, or retirement on the basis of age, race, religion, creed, gender, sex, sexual orientation, gender identity and/or expression, genetic information, ancestry, marital status, status with regard to public assistance, military or veteran status, or any other characteristic protected by law.

Work Environment: Vendors will provide their employees with a safe and healthy workplace that is in compliance with all applicable laws and regulations regarding health and safety standards. At a minimum, employees shall be provided reasonable access to potable water and sanitary facilities, fire safety, and adequate lighting and ventilation. These standards apply to both the employees’ work environment and any Vendor provided housing.

Involuntary Labor and Human Trafficking: Vendors will not use any involuntary, forced or slave labor, whether prison, bonded, indentured, or otherwise. All work must be voluntary and workers shall be free to leave work or terminate their employment. Employees will not be required to surrender any government-issued identification, passport or work permit as a condition of employment. Vendors shall be responsible for compliance with this Code and with any applicable law, rule or regulation by any person, entity or agency it may direct, employ or utilize in the provision of employees to its facilities.

Underage Labor: Use by Vendors of any child labor is strictly prohibited. The minimum age for employment shall be either 15 years of age, the minimum age for employment in that country, or the age for completing compulsory education in that country, whichever is higher. Provided such juvenile’s employment is consistent with the foregoing, any juvenile so employed by a Vendor must not perform work likely to jeopardize their health, safety or morals and must be carried on consistent with ILO Minimum Age Convention No. 138.

Wage, Benefits, and Working Hours: Vendors shall pay all workers at least the minimum wage required by applicable laws and regulations and provide all legally mandated benefits. Vendors shall not make deductions from wages for disciplinary purposes. Employees will be paid timely by Vendors and provided with sufficient written information to understand the basis upon which they are being paid. Vendors shall comply with applicable wage and hour labor laws and regulations governing worker compensation and working hours.

Freedom to Associate: Vendors will respect the rights of their employees to associate, organize and bargain collectively in a lawful and peaceful manner without penalty or interference. If a specific country’s laws restrict the freedom of employees to associate, Vendors will allow employees to raise job-related grievances without penalty or retaliation.

Speaking Up: Vendors encourage employees to report their questions, concerns, suggestions, or complaints to someone who can address them properly.


Vendors must provide a safe and healthy workplace for its employees.

Injury Prevention: Vendors shall endeavor to eliminate physical hazards to its employees where possible. Where such hazards cannot be eliminated, Vendors shall provide appropriate physical safeguards to reduce the possibility or severity of physical injury to employees. Appropriate personal protective equipment shall be provided. Employees are free to raise safety concerns or refuse unsafe working conditions without fear of discipline or reprisal until their concerns are addressed.

Emergency Preparedness: Vendors will anticipate, identify and assess potential emergency situations and prepare the necessary emergency plans and response procedures to address such situations. Vendors shall provide employees with appropriate training and hold regular drills as necessary to ensure employee preparedness in the case of an emergency.

Communications and Training: Vendors will provide its employees with appropriate health and safety information and training including written health and safety information and warnings appropriate to the work that the employee performs. Vendors shall comply with all laws and regulations regarding the communication of the presence of and training for the safe handling of any hazardous substances used in the workplace.


Vendor shall conduct its business in a way that demonstrates its continuous commitment to sustainability.

Environmental Issues: Vendors shall commit to complying with any law, rule or regulation relating to the environmental impact of their designs, manufacturing processes and waste emissions.

Hazardous Substances: Vendors will comply with any hazardous and restricted substances directive as may be published by Sleep Number from time to time. Additionally, Vendors will comply with all applicable laws, rules or regulations prohibiting or restricting the use or handling of specific substances and will disclose any substances which fall under the Safe Drinking Water and Toxic Enforcement Act of 1986, also known as California Proposition 65. A list of Proposition 65 substances can be found at This list is updated quarterly, and the Vendor is responsible for monitoring any and all updates and notifying Sleep Number of any changes to their previous disclosures.

Conflict Minerals: Vendors represent and warrant that any and all parts or components manufactured on behalf of or sold to Sleep Number will comply with all applicable laws, rules, regulations and standards pertaining to sourcing or components or raw materials, including the Organization for Economic Cooperation and Development’s (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the Supplement on Tin, Tantalum, and Tungsten. Vendors will not use, nor will their subcontractors use, conflict minerals whose obtainment is linked to human rights violations.

Recycling: Vendors will comply with all applicable labeling laws and regulations related to the recycling and disposal of its products.

Solid Waste Disposal: Vendors shall manage and dispose of non-hazardous waste generated from its operations as required by applicable laws and regulations.

Environmental Permits and Reporting: It is the Vendor’s responsibility to obtain, maintain and keep current all required environmental permits and registrations and follow the operational and reporting requirements of such permits.

Reduction and Conservation: It should be the Vendor’s intent to reduce or eliminate, to the greatest extent practicable, the waste and emissions its operations generate (solid waste, wastewater, air emissions, etc.). Vendors should also be aware of the natural resources which its operations consume and strive to conserve as much natural resources as is practicable given the Vendor’s business operations.


Vendors shall conduct its business in a way that demonstrates its commitment to the highest standards of ethical conduct.

Business Integrity: Corruption, extortion or embezzlement, in any form, is strictly prohibited. Vendors shall, at all times, maintain their compliance with the Foreign Corrupt Practices Act (FCPA), any international anti-corruption conventions and any applicable anti-corruption laws and regulations in the countries in which they operate. Vendors shall not offer or accept any bribes or other means to obtain an undue or improper advantage. Vendors shall abide by all fair competition and antitrust laws applicable in their country of operation.

Confidentiality: Except as otherwise required by law, Vendors shall maintain the confidence of the information entrusted to it and shall not use such information for any purpose other than furthering the relationship with Sleep Number. Vendors shall take steps to ensure their other customers do not come in contact with Sleep Number’s confidential information including its products, specimen, prototypes or manufacturing processes to the extent such are specific to Sleep Number.

Conflicts of Interest: It is essential for Vendors to avoid any improper influence or even the appearance of improper influence in the manner in which it conducts its business. This includes avoiding relationships, personal or professional, which could or reasonably appear to compromise Vendor and Vendor’s employees’ responsibilities and ability to make sound, impartial and objective business decisions in connection with Vendor’s relationship with Sleep Number. This includes any situations where Vendors are dealing with Sleep Number team members.

Gifts and Entertainment: Gifts of modest or reasonable value, or primarily of an advertising or promotional nature, and are customarily offered to others having a business relationship are generally acceptable. Gifts and entertainment given to create an unfair business advantage are prohibited.


endors shall inform Sleep Number immediately in the event of Vendor’s non-compliance with this Code.


Vendors shall have a process for identifying, monitoring and understanding the laws and regulations that are applicable to its business and its operations. Vendors shall maintain a process to ensure that any documentation or records related to their compliance with applicable laws, rules and regulations are created and maintained sufficiently to document such compliance as well as with this Code.


Any questions Vendors may have regarding this Code of Business Conduct may be directed to Sleep Number’s Legal Department at