Whistleblower Reporting

As part of the Mitsubishi HC Capital Group (the "Group"), CAI International, Inc. ("CAI") adheres to the "Mitsubishi HC Capital Group Code of Ethics" clarifying fundamental values and ethics to be shared across the Group as basic guidelines for all the officers and employees, including all persons working in the Group. Every officer and employee of the Group must follow this Code of Ethics.

1.Establishing Trust

Fully recognizing the weight of our social responsibility and public mission, we aim to establish the unshaken trust of society through complete information management and sound and proper business activities, including the timely and appropriate disclosure of company information.

2.Customer-Oriented Approach

Consistently taking a customer-oriented approach and having good communication, we offer products and services that best meet customers' needs to obtain customers' satisfaction and support.

3.Strict Compliance with Laws and Regulations

We strictly adhere to all applicable laws and rules (including social, industry, and company rules) and undertake appropriate and sincere corporate activities in line with social norms. We also respect internationally accepted standards as a corporate group operating globally.

4.Respect for Human Rights and the Environment

Respecting the personality and character of each other and emphasizing conservation of the global environment that is the shared asset of humankind, we pursue harmony with society.

5.Exclusion of Anti-Social Elements/Money-Laundering Prevention

We take a resolute stance against anti-social elements that threaten the order and safety of civil society. In compliance with all applicable laws and regulations related to preventing money laundering, we take every possible measure to block money laundering and terrorist financing.

CAI expects employees, and encourages customers, vendors, investors and other parties, to raise any concerns about potential failures to adhere to the Code of Ethics or any applicable law or regulation. Employees and third parties have access to CAI's Complaints Hotline, managed by Digital Media Innovations, LLC ("Notified"), for employees or third parties to report any conduct inconsistent with the Code of Ethics or applicable law. Notified will direct all Complaints Hotline reports to CAI's Compliance Department for investigation and further processing.

The Complaints Hotline can be accessed at: https://www.whistleblowerservices.com/cap