Sierra’s Code of Ethics

1. Overview

The Sierra Auto Finance (“Sierra”) Code of Ethics (“the Code”) applies to all employees in every role. The code is not a novel, arbitrary creation but, rather, a positive reinforcement of the honest behavior that Sierra employees already demonstrate. It is intended to emphasize the highest standards of integrity throughout all levels of the organization. Sierra Auto Finance expects its employees to act in accordance with this code at all times as well as to identify, pursue and correct any deviation from its spirit.

2. Ethical Statements

A. We are honest with our customers, our partners and ourselves about our duties, our practices, and our words.

B. We follow the direction of our management team, but resolve to speak up if we disagree with where we’re heading.

C. We treat one another with respect, resolving differences of opinion with maturity and sensitivity to opposing views.

D. We hold ourselves accountable for our mistakes, and expect others to do the same. If our judgement is at fault, we will find a way to make it right.

E. We are unwavering in our mission to guard the privacy of our customers, protecting their personal information at every level of the organization.

F. We condemn discrimination in all its forms while practicing fairness in lending, servicing, hiring, and in the treatment of our colleagues.

G. We avoid conflicts of interests so that we can make principled decisions based on facts and circumstances, not opinions or personal bias.

H. We know and respect the laws, codes, and regulations that govern us and remain informed on changing regulations that could affect the way we do business.

I. We create policies and procedures that help us deliver on lawful responsibilities and seek out paths that are more efficient so that our methods can be improved.

J. We are stewards of the code, and report violations when see them.