ESG Policy

Introduction

At Digital Edge, we are committed to upholding the highest standards of corporate responsibility guided by our core values of Respect, Innovation, Grit, Excellence, and Responsibility. Our Environmental, Social, and Governance (ESG) policy embodies these values through three fundamental pillars: Respect for Resources, Respect for People & Communities, and Respect for Transparency. These pillars are integral to serving our mission to build the foundation for the world’s digital future, helping organizations to grow sustainably and empowering the populations they service.

Purpose

The purpose of our ESG Policy is to integrate ESG principles into our business operations, guiding our actions towards sustainable development, positive societal contributions and ethical practices. This policy ensures we operate responsibly and transparently, creating long-term value for our stakeholders while meeting their expectations and contributing progressively to the environment and society.

Overview of ESG Policy

This policy is designed with a focus on the principles and strategies pertaining to ESG material topics at Digital Edge. The subsequent sections are organized as follows:

• Implementation and Accountability: The roles, responsibilities, and training necessary to ensure effective policy execution and continuous improvement.
• Respect for Resources: Our focus on sustainable resource use, pollution prevention, climate change mitigation, and biodiversity protection.
• Respect for People and Communities: Our dedication to upholding human rights, fair labor practices, diversity and inclusion, community engagement, and health and safety.
• Respect for Transparency: Our commitment for ethical conduct, transparency, board diversity, and robust risk management.
• Conclusion

Applicability

The ESG Policy (“Policy”) is applicable to DEA TopCo LP and DEA TopCo II LP and its wholly owned and/or controlled direct and indirect subsidiaries, associates and joint ventures (hereafter, “Company,” “Digital Edge,” “our,” “us,” or the “we”), including permanent, fixed term or temporary or part-time employees and other third parties performing work for or on the Company’s behalf on a dedicated basis, including contingent workers, casual workers, contractors, probationers, trainees, apprentices, vendors, consultants, agents and representatives of the Company (collectively, “Company Representatives”).

Implementation and Accountability

This section outlines the framework for embedding our ESG policy into all aspects of our business. It covers the roles and responsibilities, integration into business processes, and continuous training needed for effective execution. Additionally, it details our performance monitoring and reporting systems, third-party assessments and audits, stakeholder engagement practices, and mechanisms for continuous improvement and accountability.

Implementation

The implementation of our ESG Policy is a collaborative effort that involves all levels of the Company, from the ESG Steering Committee to individual employees. The following structures and processes are in place to ensure effective implementation:

Roles and Responsibilities:

1. 1. ESG Steering Committee: The ESG Steering Committee, comprising senior leaders including C-suite executives and Heads of Functions, is responsible for overseeing the implementation of the ESG Policy. The committee meets at least quarterly to provide strategic direction and identify priorities, integrate ESG considerations into business decisions, champion sustainability efforts across the Company, review progress against KPI metrics and address challenges.
   2. ESG Director: Leads the development and execution of the ESG strategy, coordinates with different departments, and ensures that ESG initiatives align with the Company’s overall mission and objectives.
   3. Heads of Functions: Implement ESG initiatives within their respective departments, track performance against ESG targets and KPI metrics, and report progress to the ESG Steering Committee.
   4. Employees: Engage in ESG activities, adhere to ESG policy and procedures, contribute to achieving the Company’s sustainability goals and enable the suppliers, consultants, agents and contractors to comply with this ESG policy

Training and Awareness:

Regular training sessions and workshops are conducted to raise awareness about ESG principles and practices. Employees are encouraged to participate in ESG initiatives and to integrate sustainability into their daily operations.

Integration into Business Processes:

ESG considerations are integrated into core business processes, including strategic planning, risk management, procurement, and operational procedures. This ensures that ESG principles are embedded in all aspects of our operations.

Accountability

Ensuring accountability is critical to the success of our ESG Policy. The following mechanisms are in place to monitor, evaluate, and report on ESG performance:

Performance Monitoring and Reporting

1. 1. ESG Metrics: Key performance indicators (KPIs) related to ESG goals are established and monitored regularly. These metrics cover areas such as Health and Safety, GHG emissions, energy and water consumption, diversity and inclusion, and community engagement.
   2. Regular Reporting: Progress on ESG initiatives is reported to the ESG Steering Committee and Board of Managers quarterly. A voluntary annual ESG report is also publicly published to provide transparency to stakeholders, including investors, customers, and the community.

Third-Party Assessments and/or Audits

Independent third-party assessments and/or audits are conducted at [minimum annually to evaluate] the effectiveness of our ESG program and to ensure compliance with relevant standards and regulations. Findings from assessments and/or audits are used to identify areas for improvement and to refine ESG strategies.

Stakeholder Engagement:

Regular engagement with stakeholders, including employees, customers, investors, suppliers, and community members, helps to ensure that our ESG initiatives meet their expectations and address their concerns. Feedback from stakeholders is used to support continuous improvement through identification of performance challenges and opportunities.

Continuous Improvement:

We are committed to continuously improving our ESG performance. This involves regularly reviewing and updating the ESG Policy, setting new targets, and adopting best practices in sustainability.

Accountability Mechanisms:

Clear accountability mechanisms are established to ensure that responsibilities for ESG implementation are clearly defined and adhered to. Performance reviews and incentive programs are aligned with ESG objectives to encourage and reward contributions to sustainability goals.

Respect for Resources

We are dedicated to sustainable practices that minimize our environmental impact. By focusing on reducing greenhouse gas emissions, optimizing energy and water management, renewable energy transitions, promoting circular economy initiatives, and conserving biodiversity, we strive to manage resources efficiently and responsibly. Our commitment to these efforts ensures that we respect and protect our natural surroundings, contributing to a more sustainable and resilient future.

Principle 1: Driving Greenhouse Gas (GHG) Emissions Reduction

We take a proactive approach to reducing greenhouse gas emissions by prioritizing measurement, energy efficiency, renewable energy adoption, and collaborative efforts. Our commitment to combating climate change is evident through regular emissions measurement and reporting, setting ambitious science-based reduction targets aligned with international climate objectives like the Paris Agreement and Science Based Targets initiative, deliberate selection of efficient cooling systems and infrastructure optimization, as well as seeking to transition to renewable energy sources. While carbon offsets can complement our emissions reduction initiatives, they are not a substitute and are used selectively and strategically to further mitigate our remaining carbon footprint, especially for emissions that are challenging to eliminate.

Principle 2: Optimizing Energy Efficiency through Sustainable Design

In line with our dedication to sustainability, we prioritize integrating eco-friendly practices into the design of our data centers to improve energy efficiency. By focusing on sustainable design principles, we aim to reduce our environmental footprint while enhancing operational efficiency. This includes meticulous site selection processes, adoption of modular designs to maximize flexibility and scalability, utilization of sustainable construction methods and materials, pursuit of green building certifications to validate our commitment to sustainability, and continuous optimization of our Power Usage Effectiveness (PUE) metric to ensure efficient energy consumption.

Principle 3: Championing Responsible Water Management

In alignment with our commitment to responsible water management, our Company has established principles and strategies to address water constraints and stress regions, effectively. We prioritize influencing water considerations during the design phase, conserving water resources, minimizing usage, and implementing sustainable water management practices. By embracing these principles, we aim to reduce our environmental impact, promote water stewardship in the communities where we operate, and contribute to a more sustainable future.

Principle 4: Fostering Sustainability with Circular Economy Practices

In our commitment to sustainability, we embrace the principles of the circular economy to minimize waste, maximize resource efficiency, and promote the continuous use and reuse of materials within our data center operations. By adopting and exploring circular economy strategies, such as prioritizing resource conservation, extending product life through maintenance and refurbishment, designing for material circularity, establishing closed-loop systems for resource management, and fostering collaboration and innovation, we aim to progressively transition towards a regenerative model that ensures long-term environmental and economic resilience.

Principle 5: Promoting Biodiversity Conservation for Environmental Resilience

In our commitment to sustainability, we recognize the vital importance of biodiversity for the health of our ecosystems and the well-being of our communities. By embracing biodiversity-driven initiatives, such as habitat protection, sustainable site development, native species promotion, pollution prevention, and stakeholder engagement, we strive to uphold our responsibility to protect and enhance biodiversity within and around our data center sites. These efforts contribute to protect and enhancing natural habitats, promote species diversity, and contribute to the resilience of our environment.

Respect for People & Communities

Through robust health and safety standards, equitable human capital management, and initiatives fostering diversity, equity, and inclusion, we aim to cultivate a workplace culture that values and respects every individual. Additionally, our commitment extends beyond our Company, to actively engage with and support the communities in which we operate, nurturing positive relationships and contributing to their sustainable development.

Principle 6: Empowering Communities through Collaborative Engagement

This principle underscores our commitment to fostering strong, positive relationships with the communities where we operate. Our strategies – including community engagement and collaboration, transparency and communication, social responsibility and contribution, respect for community rights and interests, and long-term relationship building – are designed to ensure mutual benefit, support local development, and maintain open, transparent communication. By actively engaging with, and contributing to, our communities, we aim to build trust, address local needs and shared challenges, enhance our social impact as well as foster mutually beneficial partnerships that extend beyond the operational lifespan of the datacenter.

Principle 7: Advancing Diversity, Equity & Inclusion in Workplace

Digital Edge is unwavering in its commitment to cultivating a diverse, equitable, and inclusive environment, both internally, and within the communities we engage with. Through our Company’s principles and strategies, we strive to ensure that every individual, irrespective of their background, is provided with equal opportunities and is esteemed and respected. We endeavor to foster a culture that nurtures innovation, collaboration, and fairness, where all of our employees feel valued and respected.

Principle 8: Weaving Health and Safety into Daily Affairs

At Digital Edge, we are dedicated to prioritizing health and safety as a cornerstone of our organization. Our commitment is unwavering in ensuring the well-being of our employees, customers, visitors, contractors, and stakeholders. Through a proactive approach, we seek to continuously improve our safety practices by fostering a culture of safety, implementing robust work systems, managing risks effectively, providing regular training, conducting audits, and seeking feedback. Our principles include prioritizing preventive measures, continuously improving health and safety protocols, engaging employees in safety initiatives, complying with regulations while aiming to exceed industry standards, and maintaining transparency and accountability in all health and safety practices and incidents.

Principle 9: Fueling Success through People Empowerment and Well-Being

Our Company is guided by the principle of human capital management that prioritizes’ employee’s well-being, talent development, and fair compensation. We are committed to creating a supportive work environment that fosters growth and well-being for all of our employees through initiatives focused on training, engagement, and competitive rewards. By investing in our workforce and promoting a culture of empowerment, we aim to cultivate a high-performing and engaged team that drives our collective success.

Respect for Transparency

Respect for Transparency underscores our commitment to ethical conduct, accountability, and open communication. Upholding business ethics, maintaining a responsible supply chain, and ensuring transparent economic performance are integral to our corporate governance framework. We prioritize customer privacy and data security, adhering to strict data protection protocols and business continuity measures to safeguard stakeholder interests. Through transparent reporting and engagement with stakeholders, we strive to foster trust and accountability in all our endeavors.

Principle 10: Ensuring Resilient Business Continuity and Operations

At Digital Edge, safeguarding the integrity and availability of critical data infrastructure is paramount to our ESG commitment. We adhere to core principles and strategic frameworks to ensure robust Business Continuity practices. Our approach emphasizes proactive risk mitigation, redundancy planning, and rapid response protocols to mitigate potential disruptions. By integrating these principles into our ESG policy, we uphold our responsibility to maintain operational resilience, safeguard data integrity, and minimize environmental impact, thereby ensuring the continuity of our business operations.

Principle 11: Upholding Business Ethics with Integrity and Transparency

We are committed to principles of Business Ethics that uphold integrity, transparency, and accountability, promote ethical conduct in all our operations, ensure compliance with legal and regulatory requirements, and foster a culture of honesty and responsibility. To uphold the highest standards of integrity and accountability, we have developed comprehensive strategies, several policies including our code of conduct aimed at fostering ethical conduct, ensuring compliance with anti – corruption and anti- bribery laws, and promoting a culture of transparency and responsibility.

Principle 12: Safeguarding Customer Privacy & Data Security

Our steadfast commitment to safeguarding customer’s privacy and data security encompasses a multi-faceted approach. We prioritize the protection of personal and sensitive information, ensuring compliance with relevant regulations and industry standards. Through transparent and responsible data management practices, we aim to build trust with our customers. To achieve these objectives, we implement robust cybersecurity measures and comprehensive strategies designed to fortify customer privacy, thwart unauthorized access, and uphold adherence to stringent regulations and standards. By maintaining a proactive stance on security and continuously enhancing our practices, we strive to provide a secure environment for customer data, reinforcing our dedication to data protection and customer trust.

Principle 13: Elevating Economic Performance for Sustainable Growth

As part of our commitment to Economic Performance principles, we strive for sustainable growth that creates long-term stakeholder value, by delivering high-quality products and services, fostering innovation, building positive relationships, and creating job opportunities while minimizing environmental and social impacts. We implement green finance principles and frameworks, and support investments in sustainable projects for a low-carbon economy. By seeking to consider Internal Carbon Pricing (ICP), we assess the financial impact of our carbon footprint to align financial decisions with environmental responsibility. Through responsible investments that prioritize ESG factors, we contribute to long-term sustainable development.

Principle 14: Enhancing Sustainability through Responsible Supply Chain Practices

We prioritize Responsible Supply Chain management, emphasizing ethical sourcing processes, sustainability, labor rights, and environmental stewardship. Our strategies center on ethical practices, transparency, and supplier collaboration to uphold high social and environmental standards. We select partners committed to fair labor practices, human rights, and environmental sustainability, conducting due diligence for supply chain compliance. We work with suppliers focusing on environmental sustainability, reduced emissions, resource conservation, and circular economy principles.

Questions

If you have questions or are concerned about any aspect of this Policy, you may contact:

1. Naz Ghouse, ESG Director, at naz.ghouse@digitaledgedc.com
2. Or email the Company’s ESG Department at esg@digitaledgedc.com.

Conclusion

Digital Edge is deeply committed to advancing ESG principles as integral components of our business operations. Through the development and implementation of this comprehensive ESG policy, we have outlined our commitment to sustainable practices, ethical conduct, and responsible stewardship of resources. We recognize the importance of balancing economic growth with environmental protection, social equity, and strong governance practices to ensure the long-term success and resilience of our Company.

As we move forward, we remain dedicated to upholding the principles and strategies outlined in this policy, fostering transparency, accountability, and continuous improvement in all aspects of our business. We invite our stakeholders to join us on this journey towards a more sustainable and inclusive future, where we can collectively make a positive impact on our planet and communities.

Date: 1 October 2024