This Code does not supersede, change or alter existing company policies and procedures. Certain principles referred to in the Code are the subject of formal policies that have been adopted by the company. GATX also has a separate Code of Ethics applicable to its senior officers, which may contain standards of conduct applicable to those officers that may be stricter than those in this Code.

Only the Board of Directors, or a Board committee to which such responsibility has been delegated, may waive any applicable provision of this Code for a senior officer or director of the company. Any such waiver will be disclosed promptly to shareholders.