TRINITY INDUSTRIES INC

Disclosure Controls and Procedures

We maintain disclosure controls and procedures designed to ensure that we are able to collect and record the information we are required to disclose in the reports we file with the SEC, and to process, summarize, and disclose this information within the time periods specified in the rules of the SEC. Our Chief Executive and Chief Financial Officers are responsible for establishing and maintaining these procedures and, as required by the rules of the SEC, evaluating their effectiveness. Based on their evaluation of our disclosure controls and procedures that took place as of the end of the period covered by this report, the Chief Executive and Chief Financial Officers concluded that these procedures are effective to 1) ensure that we are able to collect, process, and disclose the information we are required to disclose in the reports we file with the SEC within the required time periods and 2) accumulate and communicate this information to our management, including our Chief Executive and Chief Financial Officers, to allow timely decisions regarding this disclosure.

Internal Controls over Financial Reporting

During the three months ended June 30, 2024, the Company implemented a new core accounting platform, which included changes to the Company’s general ledger, accounts payable, accounts receivable, and fixed assets accounting processes. As a result of this implementation, we modified certain existing internal controls over financial reporting and implemented new controls and procedures related to the new financial system.

Except as noted above, during the period covered by this report, there were no other changes in our internal controls over financial reporting (as defined under the Exchange Act Rule 13a-15(f)) that have materially affected or are reasonably likely to materially affect the Company’s internal control over financial reporting.