Modern Slavery Act2015 Statement

ESG

Introduction

Beacon Rail Lux Holdings S.à r.l. (together with its direct and indirect subsidiaries, “Beacon”) is committed to combatting modern slavery and ensuring that risks of modern slavery within its business and supply chain are addressed. Beacon takes a zero-tolerance approach to modern slavery. This statement sets out how Beacon implements and enforces this approach to minimise the risk of modern slavery within its organisation and supply chain.

Structure and Business

Beacon is a rail rolling stock leasing company serving the UK and European marketplace, and safety is central to everything it does. Beacon is committed to the wellbeing of all its employees, and health and safety form part of everyday discussions 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 and employed 154 professional, engineering and support staff as at 31 December 2025 across offices in Luxembourg, Amsterdam, London, Madrid, Munich and Frankfurt.

Beacon recognises the importance of managing environmental, social and governance (“ESG”) factors effectively as part of its approach to investment in rolling stock. Beacon’s broader ESG framework, including external benchmarking such as GRESB and EcoVadis, supports its approach to identifying and managing sustainability risks, including human rights risks. As Beacon’s approach to addressing and mitigating the risk of modern slavery continues to evolve, it will seek to align it with its broader ESG commitments and develop an integrated approach across these areas.

Supply Chain

Beacon’s supply chain includes rolling stock manufacturers, asset maintenance providers and customers (including lessees and operators) operating across multiple jurisdictions in both the United Kingdom and continental Europe. Beacon recognises that the risk of modern slavery may vary across different parts of its supply chain depending on the nature of the activities involved and the geographical locations of its suppliers and other business partners. Beacon accordingly takes a risk-based approach to assessing and managing modern slavery risk across its supply chain, as set out further below.

Policies in Relation to Modern Slavery

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

Beacon ensures, including through contractual obligations, that its suppliers are aware that it is unwilling to work with them unless they comply with applicable modern slavery laws and regulations and adhere to policies designed to mitigate the risk of modern slavery in their supply chains and address relevant risks.

Due Diligence Processes

In order to assess and address risks of modern slavery and human trafficking in its supply 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 across 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 human rights issues in those locations.

Beacon may carry 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.

Where concerns are identified through the due diligence or audit process, Beacon assesses those concerns on a case-by-case basis and takes appropriate remedial action. Beacon will only engage with suppliers who support its zero-tolerance approach to modern slavery or who are taking verifiable steps towards compliance.

Risk Assessment and Management

Beacon takes a risk-based approach to identifying and managing the risk of modern slavery across its business and supply chain. In assessing risk, Beacon takes into account:

• the geographical location of its suppliers and business partners and the prevalence of modern slavery risk in those jurisdictions;
• the nature of the goods and services procured; and
• the nature of the working practices involved in the relevant parts of its supply chain.

On the basis of its due diligence and risk assessment processes, and having regard to the jurisdictions in which it operates, Beacon considers the risk of modern slavery in its own business operations to be low. Beacon continues to monitor and review this assessment on an ongoing basis.

Training and Awareness

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 these risks. One of the mandatory compliance training courses focuses specifically on modern slavery.

Beacon also encourages its people to raise concerns and provides appropriate non-retaliation protection for whistle-blowers via an anonymous telephone line operated by an independent third party.

Beacon is committed to continuing to raise awareness of modern slavery obligations and risks throughout the business, and to communicating its commitment to addressing modern slavery risks to its business partners.

Monitoring Effectiveness

Beacon carries out regular inspections, reviews and audits to ensure that its policies are complied with and are adequate to maintain the high standards 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 for improvement, and to implement such improvements as soon as possible.

To support this commitment, Beacon will, in the next financial year, seek to use the following steps as key indicators of effectiveness:

• undertake the annual review of Beacon’s Modern Slavery Statement;
• confirm with all new employees that they have read and understood Beacon’s Modern Slavery Statement;
• continue to promote employee awareness and understanding of modern slavery risks, including through Beacon’s internal communications and online training system;
• continue to engage suppliers that conduct their business in compliance with all applicable laws and regulations, including those relating to anti-slavery;
• continue to monitor the dedicated channel of communication for reporting of any concerns related to modern slavery;
• continue to monitor developments in legislation relating to modern slavery; and
• continue to support industry initiatives to combat modern slavery.

Legal References

This statement is made under section 54(1) of the Modern Slavery Act 2015 and constitutes Beacon’s Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2025.

Board Approval

This statement was formally approved by the Board of Beacon on 22^nd May 2026.

Adam Cunliffe
Chief Executive Officer
Date:    28^th May 2026

Keith Howard
Chairman 
Date:    28^th May 2026