Modern Slavery Act2015 Statement

ESG:

Introduction

Modern slavery is a criminal offence and a violation of human rights. The Modern Slavery Act 2015 defines modern slavery to include slavery, servitude, forced or compulsory labour and human trafficking.

Beacon Rail Lux Holdings S.a r.l. (together with its direct and indirect subsidiaries, “Beacon”) is committed to com batting and ensuring that risks of modern slavery occurring within its business or within its supply chain are addressed. Beacon delivers that commitment by implementing policies and integrated systems that cover modern slavery risks, as set out below.

Beacon takes a zero-tolerance approach to modern slavery. This statement sets out the means by which Beacon implements and enforces this approach to minimise the risk of modern slavery taking place within its organisation or supply chain.

Beacon’s organisation

Beacon is a rail rolling stock leasing company serving the UK and European marketplace.

The purpose of Beacon is to provide the leading rail leasing service to passenger and freight train operators. Safety is central to everything it does. Beacon is committed to the wellbeing of all its employees where health and safety is part of the everyday conversations within the business, one of Beacon’s company-wide annual objectives is to “ensure safety is central to everything we do”.

Beacon has an industry leading management team with extensive rail asset management expertise and capital markets experience, enabling it to meet the equipment needs of its customer base, and, following the acquisition of Mitsui Rail Capital Europe in September 2023, employs 168 professional, engineering and support staff across the offices in Luxembourg, Amsterdam, London, Madrid, Munich and Frankfurt.

The supply chain of Beacon includes rolling stock manufacturers, asset maintenance providers and customers who take Beacon’s rolling stock on lease.

Beacon’s approach

The purpose of Beacon is to provide the leading rail leasing service to passenger and freight train operators. Safety is central to everything it does. Beacon is committed to the wellbeing of all its employees and the communities it operates in, and health and safety is part of its everyday work conversations. Beacon also recognises the importance of managing environmental, social and governance (“ESG”) factors effectively, as part of the context for and its approach to investment in rolling stock. In 2023, for the fourth year running, Beacon was awarded 5 Stars in the Global Real Estate Sustainability Benchmark (GRESS). As Beacon’s approach to address and mitigate the risk of modern slavery continues to evolve, it will seek to align it with its ESG commitments and develop an integrated approach across these issues.

In relation to its own business operations, Beacon maintains robust employment policies and procedures. Beacon seeks to enable its people to perform well, feel motivated and thrive in a safe and positive work environment. Given these internal controls, small operational and premises footprint and the jurisdictions in which it operates, Beacon considers the presence of modern slavery in its own business operations to be low risk.

Each year, Beacon delivers mandatory compliance training to its board and employees to ensure that its people are aware of the health, safety, quality and environmental risks in the business, and understand how best to manage the risks associated with each of these areas. One of the mandatory compliance training courses focuses specifically on modern slavery. Beacon also encourages its people to raise concerns and provide appropriate protection for whistle-blowers.

In order to assess and address risks of modern slavery and human trafficking in its supply/value chain, Beacon takes the following approach:

• Due diligence is conducted on all new vendors. Beacon tailors the nature and extent of the due diligence carried out on various areas/units of its business and supply chain depending on the geographical location of those operations, and the potential level of risk of modern slavery, human trafficking and other breaches of human rights in those locations;

• Beacon ensures, including through contractual obligations and its vendor questionnaire, that its suppliers are aware that it is unwilling to work with them unless they comply with the Modern Slavery Act 2015 and have and adhere to policies which are sufficient to ensure that their supply chains are free from modern slavery and address salient risks; and

• Beacon carries out audits and inspections on various parties in its supply chain to ensure that the high standards it adheres to are reflected in the operations of its business partners.

It is the policy of Beacon to remain fully compliant with all laws that apply to it, including the Modern Slavery Act 2015 and all other laws, regulations and directives in relation to modern slavery and human trafficking. Beacon has stringent policies in place to ensure the proper oversight, where applicable, of the construction, manufacturing and maintenance of its assets.

Monitoring performance

eacon is committed to continuing to evolve its approach to address and mitigate the risk of modern slavery in conjunction with, and as an important part of, the development of its broader ESG approach. In particular, Beacon will seek to continue to raise awareness of modern slavery obligations and risks throughout the business, and communicate its commitment to addressing the risk of modern slavery to its business partners and evolve its risk­based understanding and approach concerning potential sources of modern slavery risk.

The management of Beacon carry out regular inspections, reviews and audits to ensure that these policies are complied with and are adequate to ensure that the business is complying with the high standards which it sets for itself, as well as those imposed by law. Beacon will continue to monitor the effectiveness of the measures identified above to identify any areas in which it needs improvement, and to implement such improvements as soon as possible.

Legal references

This statement is made under section 54 of the Modern Slavery Act 2015 and constitutes Beacon’s slavery and human trafficking statement for the financial year ending 31 December 2023.

Board approval

This statement was formally approved by the Board of Beacon on 11th March 2024.

Adam Cunliffe
Chief Executive Officer
March 2024

Keith Howard
Chairman
March 2024