Sunbelt Rentals Holdings, Inc.

Our Board has adopted a Code of Conduct (the “

Code

”), which applies to all Sunbelt directors, officers, and employees. The Code is based on a fundamental principle — our expectation to do what is right and to act with integrity — and is designed to promote honest and ethical conduct, compliance with applicable laws and regulations, and accountability throughout the organization.

The Code requires compliance with standards relating to conflicts of interest, protection of company assets and confidential information, accurate recordkeeping, fair competition, anti-bribery and corruption, insider trading, and appropriate public communications. It also establishes expectations for lawful and ethical interactions with customers, suppliers, business partners, and government entities.

The Code emphasizes Sunbelt’s commitment to a safe, respectful, and inclusive workplace and to responsible corporate citizenship. It includes standards addressing health and safety, human rights, fair labor practices, environmental stewardship, and community engagement. The Code provides multiple avenues for reporting concerns, including a confidential compliance hotline, and prohibits retaliation against individuals who raise concerns in good faith. Any waiver of the Code for directors or executive officers may be granted only by the Board (or a committee thereof).

The Code, which is reviewed periodically by our Nominating Committee, requires our employees to know and follow the Code, Sunbelt’s policies and the laws and regulations applicable to our business. Our employees are expected and encouraged to report any violations or suspected violations of the Code. We have published the Code on our website in the “Governance Documents” section at

https://ir.sunbeltrentals.com/governance/governance-documents

, where we intend to disclose any future amendments to or waivers of our Code requiring disclosure under applicable law and NYSE listing standards.