Modern Slavery Statement

ANTI-HUMAN TRAFFICKING AND  ANTI-MODERN SLAVERY STATEMENT

1. STATEMENT SUMMARY

DEA TopCo LP and its direct and indirect wholly owned and/or controlled subsidiaries (collectively, the “Company” or “Digital Edge”) expects its directors, officers, employees, and third-party business partners to comply with all applicable laws, rules, and regulations and to follow all internal Company policies, observing the highest ethical standards in the conduct of their duties and responsibilities.

Human trafficking and modern slavery are violations of fundamental human rights. Though there are many manifestations, they are all intended to exploit vulnerable persons for the gratification or commercial gain of others. The Company is committed to ensuring that human trafficking and modern slavery never play a part in our workplace or in our supply chain.

Though the Company is not currently subject to the UK Modern Slavery Act of 2015 or the Australian Modern Slavery Act of 2018, the Company believes it is best practice to address modern slavery risks in our business and supply chain. This Anti-Human Trafficking and Anti-Modern Day Slavery Statement (the “Statement”) reflects the Company’s determination to ensure that human trafficking and modern slavery play no part in the conduct of our business or in our supply chain.

2. STATEMENT APPLICATION

This Statement is applicable to the Company’s worldwide operations. This Statement sets forth the Company’s commitment to combatting human trafficking and modern slavery and clearly communicates the ethical conduct we expect from our employees (including our contingent workers, agents, contractors, and consultants providing services on behalf of the Company) as well as from all our business partners.

III. ORGANIZATIONAL STRUCTURE, BUSINESS, AND SUPPLY CHAIN

Headquartered in Singapore, Digital Edge is a trusted and forward-looking data center platform company, established to transform digital infrastructure in Asia. Through building and operating state-of-the-art, energy-efficient data centers rich with connectivity options, the Company aims to bring new colocation and interconnect options to the Asian market, making infrastructure deployment in the region easy, efficient and economical. Digital Edge has operations in Singapore, Hong Kong, China, Korea, Japan, India, Indonesia and the Philippines with a total of 15 data centers across eight metros. The Company is in the process of advancing plans for further metro and geographic expansion in the Asia Pacific region.

The Company provides space, power, HVAC and related data center (including connectivity) services to our customers. In order to do so, the Company must design and construct data centers, outfit the space with appropriate equipment and utilities, and provide appropriate functional support and oversight. Thus, the Company’s supply chain contains a variety of suppliers, ranging from local to global. While the Company’s equipment and infrastructure is often manufactured, supplied, and maintained by global suppliers and providers, the Company also uses local support as needed for construction, security, maintenance, operation, and functional support.

IV. POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING

The Company will use all available tools to avoid human trafficking and modern slavery. Such tools include our Governance Programs, our Code of Conduct, our Business Partner Code of Conduct, our Third Party Due Diligence Policy and Procedures, our Whistleblower Policy, our contracting terms and conditions and our training programs. The Company has a zero-tolerance policy for any instances of human trafficking or modern slavery, and we demand the same opposition from all who work for or with us.

V. RELEVANT DUE DILGIENCE PROCESSES 

Digital Edge recognizes that the third parties we engage in our day-to-day business are essential to our success and reflect who we are as a company. Consequently, we strive to ensure that we only deal with third parties who are reputable and who are prepared to abide by our same standards of business conduct. The Company has therefore adopted a Third Party Due Diligence Policy and Procedures and carries out risk based due diligence on all third parties with whom we interact.

The objective of our Third Party Due Diligence Policy and Procedures is to promote compliance by Digital Edge and our third-party business partners (“Third Parties” or “Third Party”) with the Company’s various policies, including our Code of Conduct, Business Partner Code of Conduct, Trade Sanctions Policy, Anti-Money Laundering, Anti-Bribery & Anti-Corruption Policy, and this Statement, as well as all applicable laws, rules and regulations to which we are subject. These requirements minimize the risks associated with engaging and working with Third Parties.

VI. RISK ASSESSMENT AND MANAGEMENT

Understanding our modern slavery risk is critical to targeting our actions and partnerships to prevent and address the issue. Although the Company does not operate in an industry sector with a high risk of human trafficking and modern slavery, we acknowledge there are risks with regard to our indirect supply chain as well as certain geographic locations in which we operate. The risk is particularly high when any unskilled, temporary, or outsourced labor is involved. The Company has adopted a Risk Management Policy that helps assess, monitor, and mitigate these risks. We assess the potential human rights risks of our supply chains by considering the origin of our suppliers and by understanding and monitoring their approach to modern slavery as part of our supplier on-boarding process. We actively engage with our direct suppliers and thoroughly scrutinize their management systems as it relates to their upstream suppliers.

VII. KEY PERFORMANCE INDICATORS

We regularly assess our supply chain to determine whether any element may be of higher risk than previously assessed and/or requires us to undertake a physical audit. This is a continuous process. We are committed to physical inspections when our risk assessment determines it to be sensible. Our evaluation starts when a supplier is on-boarded and helps identify any high-risk suppliers. Suppliers are then subject to an on-going assessment process against a range of criteria, including compliance with our ethical standards and corporate values. Key suppliers are reviewed more frequently by the Legal Department and, if required, external advisors.

We may also determine to conduct reviews and investigations on an ad-hoc basis, particularly if issues are raised by whistleblowers or on our ethics and compliance hotline.

VIII. TRAINING ON MODERN SLAVERY AND TRAFFICKING

The Company has published our Code of Conduct and Business Partner Code of Conduct which set forth our expectations of ethical conduct from everyone performing services for or on behalf of the Company. These codes are publicly available on the Company’s website and adherence to these Codes is a pre-condition to continued association with the Company. Consistent with these codes, we expect all employees and Third Parties who work for us or on our behalf to ensure that human trafficking and modern slavery are never a part of the Company’s supply chain or workplace.

Company employees and business partners undergo periodic training to ensure compliance with these codes. Annual trainings are provided live and online and are available in multiple languages. Employees are required to certify compliance with and recommit to the Code on an annual basis. In addition, the Company has adopted a Whistleblower Policy and maintains a helpline to address questions or concerns related to such Codes; the Company enforces a zero tolerance, non-retaliation policy that protect our employees when they raise a concern thereunder.

EFFECTIVE DATE: March 2022