UK Modern Slavery Act Statement

CSI Leasing, Inc (“CSI” or the “Company”) is issuing this statement in compliance with the UK Modern Slavery Act of 2015.  This statement covers the Company’s fiscal year ending December 31, 2022.   While subject to annual periodic review, this statement remains effective for subsequent years unless or until withdrawn or amended by the Company.

The Company

CSI Leasing, Inc. is a multinational company with subsidiaries in over twenty countries throughout the world, including the United Kingdom. CSI is a wholly-owned subsidiary of Tokyo Century Corporation, a publicly traded Japanese company.  CSI’s primary business is leasing information technology and other types of equipment to corporate customers.

Supply Chain

CSI’s supply chain consists primarily of established and reputable information technology and other equipment manufacturers and their authorized resellers. The business is primarily office-based with the main supply chain categories comprising technology, financial and other professional services.

In most cases, CSI’s leasing customers select the type of equipment they want to lease and the supplier of that equipment.  CSI sources office equipment and office supplies for the Company’s internal operations from various vendors throughout the world.

Based on the sector and supply chain profile, the risk of modern slavery or human trafficking is considered to be relatively limited.

Policies and Processes

CSI is committed to ensuring that there is no modern slavery or human trafficking within the Company or its supply chain. This Statement affirms its intention to act ethically in all business relationships.

The following policies set out the approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in the business:

• Compliance Reporting Policy – CSI encourages its employees, customers and other business associates to report any concerns related to its direct activities or its supply chains.
• Code of Business Conduct – A compliance framework, incorporating Anti-Money Laundering and Anti-Bribery and Corruption policies, includes procedures for detecting, mitigating and managing the risks of financial crime, including those potentially linked to human rights violations.

Employees are required to report any suspicion of a violation of the policies.

Due Diligence Processes

The Company undertakes due diligence when considering taking on new customers/suppliers, and regularly reviews its existing customers/suppliers. The Company’s due diligence process includes checking for negative news and government watchlists, building long-standing relationships and making clear our expectations of business associates.

CSI performs a compliance check against government watch lists and negative news, including allegations that the company has engaged in human trafficking or modern slavery.

Training

To maintain awareness and ensure a level of understanding of the risks of modern slavery and human trafficking in the business, we provide training on our compliance policies during the onboarding of new employees as well as periodic ongoing training for all employees.

CSI Leasing, Inc. does not tolerate any form of human trafficking or modern slavery. CSI is committed to ensuring that the Company does not knowingly or indirectly support any illegal activities. On behalf of the Board of Directors, this statement is approved for publication on CSI’s website.

Stephen G. Hamilton

Chief Executive Officer and Chairman of the Board