CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

The California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers that do business in California to publicly disclose their efforts to eradicate slavery and human trafficking from their supply chains. WillScot strives to engage suppliers that comply with all applicable laws regarding forced labor and human trafficking. WillScot requires suppliers, through our purchase order contracts where possible, to operate ethically and within the bounds of all local laws and regulations. WillScot fully supports the intent of the California Transparency in Supply Chains Act of 2010.

Verifications of Supply Chain. WillScot has a code of conduct for our suppliers (“Supplier Code of Conduct”) of which a primary tenet is adherence to all relevant laws and regulations, including a primary tenet of the policy which states that “Suppliers must not participate in human trafficking, use forced, involuntary or slave labor.” WillScot is continuing to develop processes to verify, evaluate and address supply chain issues related to human trafficking and slavery.

Audit. WillScot does not have a self- or third-party plan for auditing our suppliers to evaluate their compliance with sustainability and social responsibility goals, including those directly related to human trafficking and slavery.

Supplier Certification. Through our Supplier Code of Conduct, suppliers are asked to certify that the materials in their products comply with the laws and regulations of the countries where they are sold, including those related to the prohibition of forced labor and human trafficking. WillScot is in the process of developing a certification for that specifically requires supplier compliance with the California Transparency in Supply Chain Act.

Accountability. WillScot is committed to ethical and socially responsible conduct in the workplace. Upon hire, WillScot requires all employees to read and acknowledge our Employee Handbook which contains our Code of Conduct. Our Code of Conduct states that we expect our employees to “respect and obey the laws of the cities, states and countries in which we operate and avoid even the appearance of impropriety."

Training. WillScot is in the process of developing training on supply chain risks related to forced labor and human trafficking for our sourcing, supply chain and other personnel with direct responsibility for supply chain management.