ANTITRUST POLICY 2021

Contents
 Antitrust Policy
Adopted Effective as of: June 23, 2021

This policy applies to all officers, directors and employees of Purple Innovation, Inc. and its
subsidiaries (collectively “Purple”).

I. Introduction

As set forth in its Code of Ethics, Purple strives to adhere to the highest standards of ethical conduct
including compliance with applicable governmental laws, rules, and regulations. Further, its Code of Ethics
prohibits seeking competitive advantage through unlawful or unethical business practices and requires fair
dealing with suppliers and competitors. Purple seeks to avoid even the appearance of impropriety in the
actions of its directors, officers, and employees.

Accordingly, this Antitrust Policy ("Policy") outlines our commitment to integrity and explains the specific
requirements and prohibitions applicable to our operations under antitrust laws, including, but not limited to,
the US federal laws and international laws governing anti-competitive behavior. Purple strictly prohibits all
forms of antitrust behavior and will take all necessary steps to ensure that antitrust violations do not occur
in its business activities.

Antitrust laws are intended to prevent artificial restrictions on free and open competition in the marketplace.
The laws declare certain kinds of business conduct illegal as restraints of trade or as creating (or potentially
creating) monopolies. The prohibited conduct includes price-fixing and bid-rigging, division of customers or
markets among competitors, and, in some cases, agreements among competitors to refuse to deal with
other competitors, customers, or suppliers.

Aside from the US antitrust laws, the Company may also be subject to other non-US antitrust laws, in
addition to the local laws of the countries in which the Company conducts business. This Policy generally
sets forth the expectations and requirements for compliance with those laws, as well as U.S. laws.

II. No Price Fixing

Purple will establish its own prices and terms without any direct or indirect agreement with competitors.
Purple will not agree with any competitor to restrict production or sales, or to take actions that have the effect
of raising, lowering or stabilizing the price of any product or service. In addition to pricing and terms, Purple
shall not agree with competitors on promotions, bids, discounts, or quotas.

Price fixing does not prohibit Purple from matching competitors’ pricing and terms so long as there is no
agreement or coordination with competitors.

III. No Market Allocation

Purple will not make any agreements, arrangements, or understandings with competitors to divide territories
 or assign customers.

IV. No Bid Rigging

In any circumstance where Purple is engaged in a competitive bid environment, Purple will not agree with
any competitor to any arrangement that limits competition (including agreeing in advance on who will win
the bid, agreeing not to bid, agreeing to take turns on winning bids, or any joining with competitors in a joint
effort in order to limit competing bids).

V. Sharing/Seeking Confidential Information

Purple officers, directors, and employees will never seek commercially or competitively sensitive information
from a competitor. Employees who join Purple from a competitor are prohibited from bringing with them any
information belonging to their former employer or any tangible items that contain such information.

Purple employees can seek competitive intelligence from Purple’s own resellers but must never ask a
reseller to violate a nondisclosure agreement or to reveal a trade secret. A Purple employee who receives
a competitor price list from a reseller should note on the document the source and the date received.

VI. No Unlawful Price Discrimination

Antitrust laws prohibit certain discrimination in prices or promotional allowances offered to competing
resellers. Purple will not engage in price discrimination that poses a reasonable probability of significant
harm to competitive processes either in the Purple reseller’s own market or in downstream markets. This
means that Purple will not sell to favored customers at low prices that allow them to undersell direct
competitors with the same intent. This Policy does not prevent Purple from choosing to meet a price that a
competitor is offering to a Purple reseller, but you must never contact the competitor for verification of the
competitor’s price.

The antitrust laws do not prohibit charging different prices to different end-users. Examples of permissible
price differences include coupons, age discounts (where not prohibited by state laws), occupational
discounts, consumer rebates, seasonal discounts, and consumer discounts for buying multiple products.

VII. No Tying Arrangements

Where Purple may have a dominant market position in one product, Purple will not require customers to
purchase a second, less-desirable product in order to obtain the first product. This does not prevent Purple
from offering bundled packages of products, as long as each product is also available for sale separately.

VIII. Trade Associations

Before attending a meeting of a trade association whose meetings you have not attended before, a Purple
employee must first check with the Purple legal department, which will determine whether the trade
association has an antitrust compliance policy, has antitrust counsel, and has a good reputation for antitrust
compliance.

No Purple employee attending a trade association meeting will ever discuss with competitors any pricing,
pricing strategies, markets, customers, volumes, or any other nonpublic information. This includes not only
 the formal meetings but also conversations in the hallway or at social gatherings.

The Purple employee must receive a written agenda before attending a trade association meeting – and
then must make sure that the agenda does not include inappropriate topics. If a trade association meeting
veers into an inappropriate area, the Purple employee must object to discussing the topic and ask the
meeting to move onto a permissible topic. If the discussion continues, then the Purple employee should
announce his or her intention to leave the meeting and ask that the departure be noted in the minutes. The
Purple employee should promptly inform the Purple legal department, so that it can determine whether any
further action is necessary.

IX. No Unlawful Restraints in Employment Markets

Antitrust laws also prohibit employers from making agreements with each other where the sole purpose is
to limit their ability to solicit, recruit, or hire each other’s employees. This does not preclude Purple from
having noncompete or nonsolicit agreements between itself and its own employees (although these have to
be reasonable and enforceable under applicable state law). This also does not preclude Purple from having
no-hire clauses as part of an otherwise legitimate agreement (such as in the sale or purchase of a business,
or the creation of a joint venture with another company). Any kind of contractual restriction on Purple’s
ability to recruit, solicit, or hire potential employees must be reviewed by the Purple Legal Department.

X. Compliance

Company officers, directors, and employees must be familiar with this Policy and perform their duties in
compliance with this Policy. Those who violate this Policy are subject to disciplinary action, up to and
including termination of employment. To ensure that all Company officers, directors, and employees are
thoroughly familiar with the provisions of this Policy and applicable antitrust laws, the Company will provide
training and resources as appropriate.

Any Company officer, director, or employee who suspects that this Policy may have been violated must
immediately notify the Company as specified in the section below entitled "Reporting Policy Violations". Any
officer, director, or employee who, in good faith, reports suspected legal, ethical, or Policy violations is
protected under Purple’s policy prohibiting retaliation. When in doubt about the appropriateness of any
conduct, the Company requires that you seek additional guidance before taking any action that may subject
the Company to potential antitrust liability.

XI. Duty to Cooperate

The Company may at times undertake a more detailed review of certain activities. As part of these reviews,
the Company requires all officers, directors, and employees to cooperate with the Company, outside legal
counsel, or other Company consultants. The Company views failure to cooperate in an internal review as a
breach of your obligations to the Company, and will deal with this failure severely in accordance with any
 local laws or regulations.

XII. Questions About the Policy

If you have any questions relating to this Policy, please contact Purple's Legal Department.

XIII. Reporting Policy Violations

To report potential violations of this Policy, immediately notify the Company by using Purple’s Ethics Hotline
or contact the Legal Department, Internal Audit, Human Resources, or any Purple executive not involved in
the potential violation.