Compliance Reporting Policy

This Compliance Reporting Policy (this “Policy”) is directed to each employee, officer, director, independent contractor, customer or vendor of WEGMANN automotive USA, Inc. (the “Company”). Consult with the Company’s Director of HR at 615-849-4454 if you have any questions about this Policy.

Policy Overview
The purpose of this Policy is to reinforce the business integrity of the Company by providing a safe and reliable means for employees and others to report concerns they may have about conduct at WEGMANN automotive. Whether you are an employee, an officer or director, an independent contractor, or someone who does business with us, we ask that you bring to light good faith concerns regarding our business practices. By following this Policy, you can raise concerns, confidentially and anonymously if desired, and free of any retaliation, discrimination, or harassment.

We ask that you follow this Policy to report good faith concerns regarding any of the following (collectively, “Violations”):

Suspected violations of our WEGMANN Group Code of Ethics for WEGMANN automotive USA
Suspected violations of any other Company policies or procedures.
Questionable accounting, violations of internal accounting controls, or any other auditing or financial matters, or the reporting of fraudulent financial information.
Any other suspected violations of law, fraudulent activities, or unethical conduct.

Nothing in this Policy is intended to prevent anyone from reporting information to law enforcement agencies when an employee has reasonable cause to believe that the violation of a federal or state statute has occurred. A report to law enforcement, regulatory, or administrative agencies may be made instead of, or in addition to, a report directly to WEGMANN automotive. If requested, we also ask that you provide truthful information in connection with an inquiry or investigation by a court, an agency, law enforcement, or any other governmental body.

If you are a WEGMANN automotive employee or officer, please note that if you are aware of a potential Violation and do not report it according to this policy, or if you knowingly provide false or deliberately misleading information, you may be subject to disciplinary action, up to and including termination of your relationship with the Company.

Reporting and Investigation
We encourage you to promptly take one or more of the following actions if you have any concern regarding a Violation or potential Violation:

Discuss the situation with your manager.
If you are uncomfortable speaking with your manager or believe your manager has not properly handled your concern, contact the VP of Operations or CFO.
If you do not believe your concern is being adequately addressed, or you are not comfortable speaking with one of the above-noted contacts, report your concern using our reporting hotline by phone at 615-893-9839 or by email at compliancereporting @wegmann-automotive.com. Receipt of the report will be acknowledged to the sender within a reasonable period following receipt if the sender supplied contact information for response.

All reports of a Violation will be taken seriously and will be promptly and thoroughly investigated. The specific action taken in any particular case depends on the nature and gravity of the conduct or circumstances reported and the results of the investigation. With respect to any Violation confirmed by the Company’s investigation, the Company will take corrective action proportionate to the seriousness of the offense. Reasonable and necessary steps will also be taken to prevent any further Violation.

Confidentiality
Information disclosed during the course of the investigation will, to the extent practical and appropriate, remain confidential, except as may be reasonably necessary under the circumstances to facilitate the investigation, take remedial action, or comply with applicable law. For any Violation not reported through an anonymous report, we will advise the reporting party that the Violation has been addressed and, if we can, of the specific resolution. However, due to confidentiality obligations, there may be times when we cannot provide the details regarding the corrective or disciplinary action that was taken.

No Retaliation
WEGMANN strictly prohibits and does not tolerate unlawful retaliation against any employee for reporting a Violation or suspected Violation in good faith or otherwise cooperating in an investigation of a suspected Violation. All forms of unlawful retaliation are prohibited, including discipline, threats, intimidation, or other adverse actions. Any such retaliation will result in disciplinary action, up to and including termination of employment or any other working relationship with WEGMANN automotive.

Bringing any alleged retaliation to our attention promptly enables us to honor our values, and to promptly and appropriately investigate the reported retaliation in accordance with our policies and procedures. If you observe or have been subject to any conduct that you believe constitutes retaliation for having made a report in compliance with this Policy or for having participated in any investigation relating to an alleged Violation, please immediately report the alleged retaliation to the Director or HR. If, for any reason, you do not feel comfortable discussing the alleged retaliation with these people, please report the alleged retaliation through the reporting hotline by phone at 615-893-9839 or online at compliancereporting@wegmann-automotive.com. WEGMANN automotive will directly and thoroughly investigate the facts and circumstances of all perceived retaliation and will take prompt corrective action, if appropriate.

Modification
The Company expressly reserves the right to modify the provisions of this Policy at its discretion.