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Supplier Code of Conduct

Wheels highly values the contributions of its suppliers, consultants, vendors and contractors and their respective employees, agents, representatives and subcontractors (collectively, “Suppliers”).  Our Suppliers are important stakeholders who enable Wheels to consistently deliver exceptional service to our clients.

Wheels is committed to working with its Suppliers with honesty, integrity, fairness and a commitment to doing what’s right.  We firmly believe we should manage our relationships with our Suppliers as business partners and for the long term.

Wheels believes it is of paramount importance to conduct business in full compliance with all applicable laws and regulations.  Wheels expects each of its Suppliers to share its commitment to honesty, integrity and fairness, and to conduct its business in full compliance with all applicable laws and regulations.  We expect our Suppliers to comply with both the spirit and the letter of the law and to apply the highest ethical standards in the conduct of their businesses.

In addition, all our Suppliers are expected to treat everyone with whom they have contact with respect, integrity, kindness and fairness, including all Wheels personnel, and all personnel of our clients, vendors and advisors.

Wheels, Inc. is committed to an environment where open, honest communications are the expectation, not the exception. We want you to feel comfortable in approaching any member of management about instances where you believe violations of policies or standards have occurred.

In situations where you prefer to place an anonymous report, you are encouraged to use our third-party hotline provider, EthicsPoint. You can use this hotline to provide positive suggestions and stories about our culture, to ask for guidance related to policies and procedures, or to submit concerns regarding potentially unethical behavior involving Wheels or any of Wheels’ employees, Suppliers, clients, vendors and advisors.

Ethicspoint Supplier Hotline: 844-989-3011

Online Reporting:  www.wheelssuppliers.ethicspoint.com