Whistle Blower Policy

Sasser Family Holdings, Inc. and Subsidiaries (the "Company") has established a long term vision of being a leading global transportation asset services & investments provider, delivering superior customer service and expertise in order to help our customers better serve their customers.

The Company is committed to providing a workplace conducive to open discussion of our business practices and is committed to complying with the laws and regulations to which we are subject. Accordingly, the Company will not tolerate conduct that is in violation of such laws or regulations. Each employee has the responsibility to promptly report any suspected misconduct, illegal activities or fraud, including any questionable accounting, internal accounting controls, and auditing matters, or other violations of federal and state laws or regulations (collectively "Misconduct") in accordance with the provisions of this policy. Any other third party, such as vendors, customers, service providers, advisors, or competitors and any shareholder also may report, under the procedures provided in this policy, a good faith complaint regarding Misconduct. In order to facilitate the reporting of communications regarding alleged Misconduct, the Audit Committee of the Board of Directors has established the following policies and procedures for (i) the receipt, retention, and treatment of complaints received; and (ii) the confidential, anonymous submission by employees of the Company of concerns regarding any suspected misconduct, illegal activities, or fraud, including any questionable accounting, internal accounting controls and auditing matters, or other violations of federal and state laws or regulations.

1. Reporting of Concerns or Complaints Regarding Misconduct.

Taking action to prevent problems is part of the Company's culture. If you observe possible unethical or illegal conduct by any employee, you are encouraged to report your concerns. Employees and others involved with the Company are urged to come forward with any such information, without regard to the identity or position of the suspected offender(s).

Employees and others may choose any of the following modes of communicating suspected violations of law, regulation, or other wrongdoing, as well as any concerns regarding questionable accounting or auditing matters (including deficiencies in internal controls):

  • Report the matter to your supervisor; or
  • Report the matter to the Company’s CEO, COO, CFO, or President; or
  • Report the matter to the Chairman of the Audit Committee or any other member of the Audit Committee.
  • If your situation requires that your identity be protected, please submit an anonymous report directly to the Chairman of the Audit Committee.

Audit Committee Chair:
Mr. Jeffery W. Taylor
c/o Cole Taylor Bank
9550 W. Higgins Road
Rosemont, IL 60018, USA
+01 (1) 847 653 7720

2. Confidentiality

The Company will treat all communications under this Policy in a confidential manner, except to the extent necessary (a) to conduct a complete and fair investigation, or (b) for review of Company operations by the Company's Board of Directors, its Audit Committee, and the Company's independent public accountants.

3. Retaliation

Any individual who in good faith reports a possible violation of any of the Company's policies, missions, values or of laws or regulations or any Misconduct, as defined, including any concerns regarding questionable accounting or auditing matters, even if the report is mistaken, or who assists in the investigation of a reported violation, will be protected by the Company. Retaliation in any form against these individuals will not be tolerated. Any act of retaliation should be reported immediately and will be disciplined appropriately.

Specifically, the Company will not discharge, demote, suspend, threaten, harass, or in any other manner discriminate or retaliate against any employee in the terms and conditions of the employee's employment because of any lawful act done by that employee to either (a) provide information, cause information to be provided or otherwise assist in any investigation regarding any conduct, law, rule, or regulation, including any provision of Federal law relating to the fraud against shareholders, or (b) file, cause to be filed, testify, participate in, or otherwise assist in a proceeding filed or, to the employee's knowledge, about to be filed relating to an alleged violation of any such law, rule, or regulation.

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