Vendor
Code of Conduct

updated: 06/2024

WilsonHCG
Vendor Code Of Conduct
Welcome to working with WilsonHCG, Inc! The Company is proud to present the following Vendor Code of
Conduct. This Vendor Code of Conduct is part of WilsonHCG’s wider environmental, social, and governance(“ESG”) initiatives. The Company’s ESG initiatives aim to address the challenges and opportunities of ourchanging world. By taking care of the environment, we reduce our carbon footprint and contribute to a moresustainable future. By caring for our people and communities, we foster a culture of diversity, inclusion, andengagement, which enhances our innovation and performance. By adhering to high standards of governance,
we ensure transparency, accountability, and ethical conduct in all our decisions and actions.
WilsonHCG, Inc (“we”, “us”, “our”) and its affiliates (WilsonHCG) are committed to the highest standards ofservice quality and business integrity. WilsonHCG requires all of its vendors and suppliers (“Vendor”, “you”,“your”) and employees to conduct themselves with the highest standards of honesty, fairness, and integrity,
complying with all applicable laws and avoiding the appearance of impropriety. We also strive to be an asset
to the community and society at large by supporting social, cultural, intellectual, environmental, and economic
initiatives, while improving the quality of life of our workforce and their families at the same time and we expect
our Vendors to do the same.
This Vendor Code of Conduct (“Code”) outlines our expectations when engaging in providing products
and services to WilsonHCG. Vendors are expected to act in accordance with this Code, including aligning
guidelines, policies, and practices, and communicating and enforcing the Code provisions throughout theorganization’s own vendors.
Vendors must act with integrity and are expected to demonstrate a commitment to legal, ethical, safe, fair, andenvironmentally responsible business practices.
We are an inclusive culture and do not believe discrimination in any form should be tolerated. Vendors are
expected to demonstrate a commitment to inclusive business practices, including without limitation diversity intheir workplace.
Vendor shall ensure that its employees, subcontractors, agents, and third parties assigned to provide services
to WilsonHCG consistently with this Vendor Code of Conduct. Additionally, WilsonHCG may require Vendor
to immediately remove any Vendor employee or representative that acts inconsistently with this or any otherWilsonHCG policy. Failure to adhere to this Code of Conduct will result in disqualification from consideration
for future business with WilsonHCG and may result in termination of existing business. Vendors may contact
WilsonHCG’s Legal Department at legal@wilsonhcg.com for questions relating to its obligations
under this policy.

2| WilsonHCG Vendor Code of ConductEthics& ComplianceVendor shall comply with all laws, regulations, and policies applicable to it and its
dealings with WilsonHCG, including employment laws prohibiting discrimination andharassment. If this Code of Conduct or any other applicable WilsonHCG policy conflicts
with applicable law, applicable law will govern such conflict to the extent it is impossible
for Vendor to comply with both the law and the policy. If this Code of Conduct conflicts
with any other applicable WilsonHCG policy, this Code will govern to the extent it is
impossible for Vendor to comply with both policies.

International Trade Compliance
You must conduct business in strict compliance with all applicable laws and regulations governing (a) the export,
re-export and retransfer of goods, technical data, software, and services; (b) import of goods; (c) economic sanctions
and embargoes, and (d) U.S. antiboycott requirements.

Ethics and Compliance Program
Commensurate with the size and nature of your business, you must have management systems, tools andprocesses in place that (a) ensure compliance with applicable laws, regulations and the requirements set forth in
this Code; (b) promote an awareness of and commitment to ethical business practices, including, without limitation,
the expectations set forth in this Code; (c) facilitate the timely discovery, investigation, disclosure (to WilsonHCG andothers, as appropriate) and implementation of corrective actions for violations of law, regulations or the expectations
set forth in this Code; and (d) provide training to your employees on compliance requirements, including the
expectations set forth in this Code.

Business Integrity
Vendors to WilsonHCG are expected to operate in compliance with all applicable laws and regulations of thecountries, states, and localities in which they operate. This includes laws and regulations related to ethical businesspractices, quality, labor and employment practices, as well as health, safety, and environmental protection. Suppliers
are also expected to conform their practices to generally accepted industry standards, obtain and maintain all
applicable permits, licenses and registrations, and operate in accordance with permit limitations and requirements
at all times.

Unfair Business Practices
WilsonHCG is committed to competing fairly and in compliance with the antitrust and competition laws in every
country where it does business. Vendor shall comply with all applicable fair business, advertising, and antitrustcompetition laws; Vendor shall not fix prices, rig bids, allocate customers or markets, or exchange current, recent, or
future pricing information with Vendor’s competitors.

Legal & Customer Requirements
Vendors shall identify and comply with applicable laws, regulations, standards and relevant customer requirements.

3| WilsonHCG Vendor Code of Conduct

Your Obligations
as Business Partners
If your contract with WilsonHCG prohibits you from assigning, delegating, or
subcontracting your obligations, we expect you to strictly comply with this prohibition.
If your contract with WilsonHCG permits you to assign, delegate, or subcontract yourobligations or procure products or services from others that will be incorporated in
products or services acquired by WilsonHCG from you, we expect you to carefully selectyour business partners and perform due diligence, audit, and oversight to prevent anddetect misconduct. You must flow down the principles set forth in this Code to thesebusiness partners and we will hold you responsible for ensuring compliance by yourbusiness partners.

Government Procurement
In some cases, our partners are assisting us with fulfilling government contracts. Accordingly, and whereverapplicable, we recognize that the requirements related to government contracts are generally stricter than those
governing our commercial contracts. It’s important that you recognize that, too, and comply with all contractual
terms and obligations. Remember, your contractual obligations also apply to the vendors and subcontractors who
provide services or perform work on our government contracts.
Vendors must take special care to comply with the unique and special rules that apply to contracting with the U.S.
Government. If you support a WilsonHCG contract with the U.S. Government, you must at all times follow the U.S.
Government’s rules for competing fairly, honor restrictions applying to U.S. Government employees (e.g., receipt ofgifts and employment), deliver products and services that conform to specifications, laws, and regulations, adhere
to government accounting and pricing requirements, claim only allowable costs, ensure the accuracy of datasubmitted and comply with all other applicable U.S. Government requirements.

Gifts, Gratuities Travel, & Entertainment
Vendors shall not directly or indirectly provide any gift, travel, entertainment, political contribution, or charitable
donation of any value to a WilsonHCG employee or any third party on behalf of WilsonHCG. Vendor may offer a
WilsonHCG employee a gift, travel, or entertainment only if it is: (a) appropriate (no cash or cash equivalents or otherexcluded gift type), does not create an actual impropriety or a perception of impropriety, and complies with all laws,
regulations, and policies for all parties), (b) of reasonable value, and (c) with full transparency of its value.

Conflicts of Interest
A conflict of interest arises when a WilsonHCG employee’s personal interest interferes with the best interests of
WilsonHCG. It may occur when an employee or a family member or friend receives a personal benefit as a result of
the employee’s position with WilsonHCG. Vendor shall disclose to the WilsonHCG Ethics Office (ethics@wilsonhcg.
com) all relationships that have the potential to create a conflict of interest or the appearance of a conflict of interest.
Vendor shall correct any actual or perceived conflict of interest as directed by WilsonHCG.

Accuracy of Records and Submissions
Vendors must maintain books and records that accurately and completely reflect all transactions related to
WilsonHCG business and each of your submissions to WilsonHCG, its customers, and regulatory authorities mustbe accurate and complete. You must never make an entry in your books and records to alter, conceal, or destroy any
document to misrepresent any fact, circumstance, or transaction related to WilsonHCG business.
Accordingly, WilsonHCG expects vendors to provide honest and accurate invoices. Invoices should be itemized,
quote the PO number (where relevant), be supported by appropriate documentation and comply with all otherrequirements as set out in the relevant contract(s). Invoices may not be split to circumvent approval requirements.
4| WilsonHCG Vendor Code of ConductFraud Prevention
In carrying out duties for WilsonHCG and in your general business conduct, you must not initiate, participate or
assist in fraudulent or dishonest activities. Such activities include, but are not limited to: theft, embezzlement
or misappropriation of WilsonHCG funds or property, or the property or funds of others; falsification, misuse, or
unauthorized removal of client or WilsonHCG records; false representation or concealment of information.

Insider Trading
Federal and state laws prohibit trading in securities by anyone with material information not available to the public.
Vendor’s interactions with WilsonHCG may result in Vendor having access to material, nonpublic information about
WilsonHCG or another company (including WilsonHCG’s customers, suppliers, and other business partners). Vendor
shall not engage in any action to take advantage of that information, including buying or selling Vendor’s or thatcompany’s securities or sharing that information with others.

Bribery
Bribery is offering or making a payment (or payment in kind) and/or offering/promising a gift to influence a decision
dishonestly or to induce or reward a person for improper performance of any relevant function or activity. This
includes both private and public bribery.
WilsonHCG does not tolerate corruption or bribery in any form and we expect our vendors to fully comply withrequirements of all applicable anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices
Act and the UK Bribery Act.
Vendors will not directly or indirectly give, offer, or accept anything of value to obtain or retain business or favored
treatment, to influence actions or to obtain an improper advantage for WilsonHCG, itself, or any third party. This
includes any benefit, fee, commission, dividend, gift, cash, gratuity, services, consideration or any inducements ofany kind to any WilsonHCG representatives, officers, agents or employees of WilsonHCG.
Furthermore, vendors will ensure the same of any affiliates, retained agents, subcontractors, intermediaries or workers.
This prohibition extends not only to public officials, candidates for office, and workers of state-owned enterprises, butalso to workers or officers of counterparties, clients/customers, suppliers, any agent of the aforementioned parties,
or any other person with whom the firm does or anticipates doing business.
All purchases made by WilsonHCG will be made on the basis of price, quality, and service, and WilsonHCG willdeal with its vendors fairly, honestly and openly. WilsonHCG employees are required to conduct all business andinteractions with vendors in strict compliance with the applicable provisions of WilsonHCG Code of Conduct.

Anti-Corruption
WilsonHCG is committed to doing business with integrity and in compliance with the highest anti-corruption
standards. Corruption violates the public’s trust, threatens economic and social development, and hurts fair trade.
WilsonHCG shall comply with the U.S. Foreign Corrupt Practices Act, all similar anti-corruption and bribery laws inother countries. Vendors shall not engage or attempt to engage in bribery, extortion, or embezzlement. Suppliershall conduct itself with honesty, fairness, and high ethical standards, avoiding even the appearance of impropriety
in all its business interactions worldwide.

Antitrust Law
WilsonHCG competes fairly and expects our partners to share our unwavering commitment to conducting business
and winning with integrity. Comply with all antitrust and global competition laws wherever you operate, and neverenter into any agreement that unlawfully restricts competition. Further, vendors must abide by fair business practices,
including truthful and accurate advertising.

Anti-Money Laundering
WilsonHCG abides by all laws designed to deter criminal enterprise, prevent terrorism and protect the national
security of the companies where we do business. Exercise good judgment when dealing with customers orother business partners to prevent inadvertent use of WilsonHCG’s business activities for money laundering or
terrorist financing.

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Tax Evasion & the Facilitation of Tax Evasion
WilsonHCG takes a zero-tolerance approach to our vendors committing or facilitating tax evasion. Vendors (andeach of their subcontractors) are expected to have policies and procedures in place to prevent employees and otherassociated persons from committing or facilitating tax evasion.

Unauthorized Lobbying & Speaking to the Press
Vendor shall not undertake any type of lobbying or other similar representative efforts on WilsonHCG’s behalf before
any kind of government entity, official, body, or representative without the express written consent of WilsonHCG.
Suppliers shall make no statements to the press about or on behalf of WilsonHCG unless expressly authorized to
do so by WilsonHCG.

Confidential Information
Proper management of confidential information and personal data is critical to the success of both WilsonHCG
and Vendors. WilsonHCG vendors must protect all WilsonHCG information, data (including personal data), andintellectual property or technologies with appropriate safeguards. Vendors may receive our confidential information
only as authorized by a confidentiality or non-disclosure agreement and must comply with their obligations not
to disclose the confidential information, not to use the information except as permitted by the agreement, and toprotect the information from misuse or unauthorized disclosure. This requirement prevails beyond contract expiry
or termination.

Intellectual Property Rights
WilsonHCG’s intellectual property is among its most valuable assets and WilsonHCG is committed to protecting
it. WilsonHCG’s intellectual property includes: brands, logos, slogans, domain names, business names, andother identifying features used to identify WilsonHCG and its products or services; software, scripts, interfaces,
documentation, advertising and marketing materials, content (such as website content) and databases; trade
secrets, ideas, inventions, systems and business processes; and confidential information, as addressed above insection (VI)(L) “Confidential Information” of this Code.
Vendors shall comply with all applicable intellectual property rights and laws. As business partners supporting
WilsonHCG’s efforts, suppliers shall respect WilsonHCG’s intellectual property rights, protect WilsonHCG’s trade
secrets and confidential information, and safeguard customer information. Vendors shall manage technology andknow-how in a manner that protects intellectual property rights. Accordingly, the Vendor shall only use information
technology and software that it has acquired or licensed legitimately and shall use them only in accordance with theterms of such licenses. Vendor shall not transfer any of WilsonHCG’s technology, proprietary information, or trade
secrets without prior written consent from WilsonHCG’s Legal Department.
Accordingly, Vendors must use WilsonHCG’s intellectual property only as required to provide services to WilsonHCG.
Intellectual property created while carrying out the duties of your engagement with WilsonHCG, or using any
WilsonHCG resources, is owned by WilsonHCG, unless otherwise specified in any written agreement between you
and WilsonHCG. You shall provide assistance as requested by WilsonHCG, both during and after engagement or
appointment, in connection with its attempts to evidence, register or enforce its rights in such intellectual property,
including the rights afforded by trademarks, copyrights and patents. WilsonHCG may require you to waive or assign
all rights, title and interest in such intellectual property to WilsonHCG.

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Use of WilsonHCG
and Affiliates Names and Logos
WilsonHCG prohibits suppliers’ use of WilsonHCG or any affiliate companies’ name orlogo for any purpose without express written authorization. This includes, but is not
limited to: public announcements, press releases and media activity, advertising,endorsements, customer or client listings and photographs of WilsonHCG and its
companies’ aircraft, buildings, equipment and branded products in supplier publications.
As a general rule, WilsonHCG and its companies will not permit the use of their names
for media, advertising and marketing purposes, however any such requests should besent to: marketing@wilsonhcg.com.

Social MediaYour personal communications should not identify WilsonHCG or your engagement to provide products or services
to WilsonHCG. Do not use WilsonHCG letterhead, envelopes, fax cover sheets, or other communication materials
containing WilsonHCG’s name, logo or trademark for your personal communications unless you are authorized
to do so by WilsonHCG. In particular, in any personal communication with politicians, public officials, industry or
professional associations, the media or the general public, you should not lead people to believe that you are
expressing the views of WilsonHCG. Public Communications and Social Media You shall not comment or provide
information relating to WilsonHCG’s businesses with respect to any products and/or services you provide in publicforums (including internet chat rooms, bulletin boards, blogs, social and business networking sites) unless you are
specifically authorized to do so by WilsonHCG. You should not make any statements on behalf of WilsonHCG.

Privacy & Data Protection
Vendor shall respect the reasonable privacy and confidentiality expectations of everyone with whom it does
business and shall appropriately protect all data that may come into its possession because of its relationship with
WilsonHCG, including data relating to WilsonHCG and WilsonHCG employees, customers, and partners. Vendor
shall comply with WilsonHCG’s instructions and with applicable privacy, data protection, and security laws andregulations when personal, confidential, proprietary or other sensitive information is collected, stored, processed,transmitted, or shared. Vendors shall use WilsonHCG-provided information technology and systems only forbusiness-related purposes authorized by WilsonHCG.
Data and information may only be disclosed to the extent necessary for it. In case of doubt, consultation must
be sought. Vendors shall comply with all applicable data protection laws and regulations, as amended fromtime to time. Vendors shall provide all employees who come into contact with such data or information with theappropriate training pursuant to the relevant data protection laws and regulations and require them to keep thedata and information confidential. Declarations of compliance are to be submitted to WilsonHCG or its Legal
Department upon request at privacy@wilsonhcg.com. Additional information about WilsonHCG’s privacy policy canbe found here.

Supply Management System
Vendors are expected to have a management system that ensures they comply with applicable laws, regulations,and WilsonHCG policies, conform to this Code of Conduct and identify and reduce risks related to this Code. The
system should also promote continuous improvement and compliance with changing laws and regulations.

Supplier Diversity
Vendors shall engage socially and economically different categories of vendors through inclusive sourcing processes
that promote equal opportunities.

7| WilsonHCG Vendor Code of Conduct

Communication
WilsonHCG Vendors are expected to assist WilsonHCG in enforcing this Code of Conduct by communicating its
principles to their supervisors, officers, employees, suppliers, and third parties through their respective supply chain.
Vendors may direct questions or comments about this Code of Conduct to legal@wilsonhcg.com.

Management Systems
Vendors to WilsonHCG are expected to manage their activities systematically in order to maintain business continuity,
meet the standards set forth in this document and to improve their operations continually.

Anonymous Reporting & Reporting Misconduct
We expect Vendors to provide their employees and Vendor’s business partners with access to adequate reporting
channels to raise legal or ethical issues or concerns, including, without limitation, reports of a violation of this Codeby Vendor or Vendor’s business partners, without fear of retaliation, including opportunities for anonymous reporting.
In the event that you become aware of misconduct related to WilsonHCG business undertaken by any WilsonHCG
employee, any of your employees, or any employees of your business partners, we expect you to promptly
notify WilsonHCG. You may contact WilsonHCG at legal@wilsonhcg.com, or if you prefer to contact WilsonHCG
anonymously, please submit your feedback on this form.
Vendors must promptly investigate reports of legal or ethical issues or concerns.

Emergency Preparedness & Response
Vendors shall identify and assess emergency situations in the workplace and any company-provided living quarters
and minimize their impact by implementing emergency plans and response procedures.
Additionally, Vendors should minimize the impact to life, environment, and property of emergency situations andevents through the implementation and testing of emergency plans and response procedures.

Commitment & Accountability
Vendors shall demonstrate senior management commitment and accountability through policies, objectives andformal processes, to the concepts described in this document by allocating appropriate resources.

Risk Management
Vendors shall have mechanisms to determine and manage risks in all areas addressed in this Code. To that end,
Vendors should provide resources, including competent personnel and appropriate infrastructure, to manage risks
and ensure conformance to this Code.

Documentation
Vendors shall implement processes to develop, maintain and control documents and records necessary todemonstrate conformance with these expectations and compliance with applicable regulations.

Training & Competency
Vendors shall have a training program that achieves an appropriate level of knowledge, skills, and abilities inmanagement and workers to address these expectations.

8| WilsonHCG Vendor Code of ConductAdditional
Considerations
Continual Improvement
Vendors are expected to continually improve by setting performance objectives, executing implementation plans
and taking necessary corrective actions for deficiencies identified by internal or external assessments, inspections,and management reviews.

WilsonHCG’s Global Human Rights Policy
WilsonHCG committed to conducting our business in accordance with the highest ethical standards and incompliance with all applicable laws, rules, and regulations. We expect our vendors to share our principles anduphold our standards and for each to develop policies and programs as appropriate to ensure that all workers
understand and adhere to these standards.
WilsonHCG recognizes its responsibility to protect human rights.
Examples of such rights are articulated in internationally recognized standards, including the Universal Declarationof Human Rights, and the International Labor Organization (ILO) Core Conventions. Our position is reflected in our
Human Rights Statement and our actions in the countries in which we do business. We expect our vendors to have
similar policies and practices that apply to all workers, suppliers, and their supply chains, including migrant andtemporary workers.

Non-Discrimination
Vendors shall provide a workplace free of harassment and discrimination. Vendors must treat their existing andprospective employees and business partners fairly, based only on merit and other factors related to your legitimate
business interests, and without regard to race, religion, color, age, gender, gender identity or expression, sexual
orientation, national origin, marital status, veteran status or disability.

Military Veteran Hiring Practices
The veteran hiring landscape has transformed over the past few years, which means companies, including
WilsonHCG Vendors, need to constantly evolve their veteran hiring practices to match the changing veteran talentmarket and the changing needs of veterans.

Accomodations
Vendors shall make reasonable accommodations for disabled employees and applicants, as required by law.
Accordingly, Vendors shall provide assistance or changes to a position or workplace that will enable a qualified
employee to do his or her job despite having a disability. Vendors shall provide these accommodations so that
employees with disabilities can enjoy the benefits and privileges of employment equal to those enjoyed by similarlysituated employees without disabilities.

Fair Treatment
Vendors must treat all workers fairly and ethically with respect and dignity. Vendors may not subject workers tocorporal punishment, physical, sexual, psychological, or verbal harassment or abuse. Vendors may not use monetaryfines to discipline employees. In addition, WilsonHCG Vendors must provide an environment that allows employees
to raise concerns without fear of retaliation.

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Freedom of Association
Open communication and direct engagement with workers to resolve workplace and compensation issues is
encouraged. Vendors shall respect the rights of workers, as set forth in local laws, to associate freely, join or not joinlabor unions, seek representation and join workers’ councils. Workers shall be able to communicate openly withmanagement regarding working conditions without threat of reprisal, intimidation or harassment.

Child Labor
Vendor must ensure that child labor is not used in the performance of your work, whether or not related to
WilsonHCG business. The term “child” refers to any person under the minimum legal age for employment where thework is performed.

Forced Labor & Human Trafficking
Vendors shall not use any form of slave, bonded, forced, involuntary prison labor or engage in human trafficking or
exploitation. Employment should be freely chosen and employees free to leave after reasonable notice is served.
WilsonHCG suppliers should not retain employees’ identification papers or travel documents such as Passports,
Identification Cards and Work Permits as a condition of employment.
WilsonHCG does not tolerate slavery, forced labor, or human trafficking in any form and WilsonHCG will not knowingly
work with vendors who engage in these practices or permit their subcontractors to engage in these practices.
We expect our vendors to fully comply with requirements of applicable slavery, forced labor and human trafficking
laws, including without limitation the UK Modern Slavery Act 2015.
All work must be performed under and in accordance with contracts that have been entered into voluntarily. Vendors
must not use involuntary labor of any kind, including prison labor, debt bondage, or forced labor by governments.
Vendors must not engage in practices associated with forced labor. These practices, identified by the International
Labour Organization (ILO), include withholding of wages, retention of identity documents, and restriction of movement.
Vendors should put into place measures that ensure workers are not exploited by third-party labor providers, suchas recruiters or agencies. Such measures include caps on or elimination of recruitment fees; provision of contracts
to all workers in their native language or other language which they are able to understand; elimination of deposits
paid by workers to vendors or recruiters to secure jobs. Additionally, vendors must not engage in or support humantrafficking and are encouraged to implement due diligence measures to ensure that no human trafficking exists
within their extended supply chains.

Hiring & Employment Practice
Vendors’ hiring practices must include verification of workers’ legal right to work in the country and ensure that
all mandatory documents, such as work permits, are available. In addition, a written contract should be madeavailable to each worker that clearly communicates the conditions of employment in a language understood by
the employee. WilsonHCG Vendors must not discriminate against employees in hiring, promotion, and salary or
performance management on the basis of race, color, gender, religion, nationality, age, disability, political affiliation,
union membership, sexual orientation, maternity or marital status of the employee. WilsonHCG Vendors are expected
to support diversity and equal opportunity in their workplaces. The Vendor shall not require employees to undertake
pregnancy or medical tests, except where required by local law or in relation to workplace health and safety, andshall not discriminate based on results.

Compensation & Working Hours
Vendors should provide wages and benefits that meet or exceed the requirements of local law. At a minimum,
vendors should pay workers regularly and timely, the legal minimum wage, the prevailing industry wage, or thewage negotiated in an applicable collective agreement, whichever is higher. All other types of legally mandated
benefits must be provided as required by law, including, as applicable, paid leave, pension, statutory insurance,
health benefits, maternity leave, parental leave, family care leave, and childcare benefits. All overtime work mustbe performed and compensated in accordance with the law and the individual’s employment contract or otherapplicable contract or collective agreement.

10| WilsonHCG Vendor Code of ConductHealth & Safety
Vendors must provide workers with a safe and healthy work environment and should proactively put in placemeasures such as policies, procedures, education, and communication that support accident prevention andminimize health risk exposure for all employees. Where appropriate the supplier shall provide personal protective
equipment together with training on its benefits and use.
Where provided, workers’ living quarters should be clean and safe and meet the same health and safety standards
as those that apply in the workplace.

Environmental Responsibility
Vendors shall operate in an environmentally responsible and efficient manner, and they shall minimize adverse
impacts on the environment. Suppliers are encouraged to conserve natural resources, to avoid the use of hazardous
materials where possible and to engage in activities that reuse and recycle.

Environmental Authorizations
Vendors shall comply with all applicable environmental regulations. All required environmental permits,
licenses, information registrations, and restrictions shall be obtained, and their operational and reporting
requirements followed.

Waste & Emissions
Vendors shall have systems in place to ensure the safe handling, movement, storage, recycling, reuse or managementof waste, air emissions and wastewater discharges. Any waste, wastewater or emissions with the potential to
adversely impact human or environmental health shall be appropriately managed, controlled and treated prior torelease into the environment.

Animal Welfare
Where applicable, vendors agree to treat animals humanely, including with minimal stress and pain. Alternatives toanimal testing should be used whenever possible.

Compliance with this Code
Vendors must ensure that WilsonHCG has the right to assess their business partners’ compliance with the
expectations set forth in this Code in performing work for WilsonHCG, including on-site inspection of facilities andreview of associated books, records, and other documentation. Vendors must ensure that their business partners
will provide WilsonHCG upon request with additional information and certifications evidencing compliance.
In the event of any wrongdoing, you will fully cooperate with any related investigation conducted by WilsonHCG.
Vendors will ensure that their business partners also fully cooperate if such an investigation involves theirperformance. Vendors (and their business partners) must correct any non-conformances identified duringassessments. WilsonHCG does not assume any duty to monitor or ensure compliance with this Code, and Vendors
acknowledge and agree that they are solely responsible for full compliance with this Code by Vendor’s directors,
officers, employees, representatives, and business partners.
For questions or concerns about this Code, including its application to specific circumstances in connection withyour organization’s performance of work for WilsonHCG, or suspected failures by your organization to satisfy these
expectations in performing work for WilsonHCG, please contact WilsonHCG at legal@wilsonhcg.com, or if you prefer
to contact WilsonHCG anonymously, please submit your feedback on this form.

Transparency & Disclosure
Vendors to WilsonHCG are expected to make reasonable efforts to publicly disclose topics and goals thatare important to the organization’s impact on the environment and social issues (e.g., on a website or publicly
available report).

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Monitoring & ComplianceWilsonHCG may engage in monitoring activities to confirm a Vendor’s compliance with this Code, including on-site
assessments of facilities, use of questionnaires, review of available information or other measures necessary toreview supplier’s performance. WilsonHCG may disqualify any potential supplier or terminate any relationship with acurrent supplier that has failed to conform to these Standards.
Vendors’ implementation of and adherence to these principles can be demonstrated by reference to their own Codeof Conduct or corporate policy which contains comparable standards. Should a Vendor not have such standards inplace, the Vendor is expected to undertake compliance with this Code of Conduct.
This Code sets forth our expectations for current and future Vendors. We expect all new and existing Vendors tomeet our minimum expectations and to aspire to make continuous improvements to their businesses as notedherein across ethical, human and labor rights, Vendor diversity and inclusion and environmental areas. Any facts
or circumstances which are likely to lead to your inability to meet the requirements and expectations of this Codeshould be reported immediately to your WilsonHCG relationship manager. In line with the WilsonHCG Business
Integrity Program, we provide our people and the public with various channels through which integrity concerns canbe raised without reprisal. If you encounter what you believe to be any potential integrity concerns, including but notlimited to violation of local laws or regulations, or this Code, or unethical behavior, you may report your concerns via
the methods outlined above.
WilsonHCG has established conduct standards for its business-related practices that are set out in our BusinessConduct Guidelines. These WilsonHCG Business Conduct Guidelines (“Guidelines”) reflect our commitment to ourvalues of honesty, integrity, respect, and responsibility. WilsonHCG expects that its vendors will share and embracethese values as well as our commitment to regulatory compliance.
While Vendors are independent entities from WilsonHCG, the business practices and actions of a Vendor, when
conducting business with or on behalf of WilsonHCG, may significantly impact and reflect upon our Company.
Because of this, WilsonHCG expects all Vendors and their employees, agents, and subcontractors to follow our highethical standards set forth in these Guidelines, while they are conducting business with us or on our behalf.
It is the responsibility of our Vendors and representatives to understand and adhere to WilsonHCG’s expectations.
Vendors should notify a member of WilsonHCG management if and when any situation develops that causes the
Vendor or representative to operate in a way that may be in conflict with WilsonHCG’s expectations. WilsonHCG
may request the removal of any Vendor or representative who behaves in a manner that we consider to be acting
inconsistent with these Guidelines or any WilsonHCG policy.

12| WilsonHCG Vendor Code of Conduct