Code of Ethics and Business Conduct

Data4 Values

Being Entrepreneurial

Being Entrepreneurial means and implies that:

• At Data4 everyone has a role to play; each person counts. The company’s strong growth supports an entrepreneurial approach: we dare to do more, and we naturally integrate innovation and customer needs.
• As entrepreneurs, we give meaning to our mission and have a vision that guides us to set efficient goals for our company.
• We are responsible for our actions and we are motivated by healthy But we are also team players who know how to move in the same direction.

Taking Responsibility

Taking Responsibility means and implies that:

• We are passionate about people, society, the environment and our corporate
• Our business is the pillar of the digital world. Therefore, we feel responsible for our actions that enable digital growth and the digital transformation of society. All of our actions are carried out with a responsible approach to the environment, both in our day-to-day behaviour and in our strategic decisions.
• We demonstrate integrity and respect in our relationships with colleagues, customers and suppliers. We are trustworthy and transparent; we are constructive and allow everyone to question or challenge our fear.
• We are professional and responsible in demonstrating ownership. We strive for quality and excellence in what we do.

Demonstrating Adaptability

Demonstrating Adaptability means and implies that:

• All organisations operate in an environment of uncertainty and unexpected problems. As many of our clients have attested, we’ve embedded agility in our DNA to be able to react more quickly. But it’s not just about being responsive: it’s also about being open to change and anticipating new trends in order to have the ability to maintain effectiveness in a changing environment and adjust to the new requirements of our customers and projects.
• Having adopted adaptability as a differentiating value, we want to be the players who act in our industry. We want to learn and improve continuously and challenge the status quo.

Data4 Code of Business Conduct

What is the Code of Business Conduct?

The Code of Business Conduct (hereinafter also “the Code”) is a set of principles and values that guides the actions of the Data4 Group (hereinafter referred to as „Data4„, “the Group” or “the Company”).

Data4 is aware that its success depends on the creation of a system of internal and external relations based on the fundamental principles and values of integrity, professionalism, ethics and honesty.

The diffusion of these principles and values within the Company, and their application in all daily activities, allows Data4 to maintain its reputation as a professional and reliable business partner.

The Code of Business Conduct comprises five sections: the first four sections lay out the rules and principles that define Data4’s character. Every Data4 employee, supplier, consultant, agent and partner must respect these rules and principles in every action and decision they take. The fifth section addresses the expectations and procedures for reporting a violation of these rules and principles.

The Code of Business Conduct is approved by the Data4 Board of Directors; thus, all substantive changes must be approved by the Board.

Who Does the Code of Business Conduct Apply To?

Everyone who works for, with or on behalf of Data4 must comply with the Code of Business Conduct. This includes all directors, officers, employees and temporary workers[1] based in every country. The Code also applies to third parties, such as suppliers, consultants and agents, when acting for and on behalf of Data4.

Hereinafter, all persons to whom the Code of Conduct applies will be referred to as „Data4 People” collectively and, „Data4 Person” individually.

In order to ensure that all Data4 People comply with the principles and rules contained within the Code of Business Conduct, the Group promotes its circulation and awareness.

It is the responsibility of each individual to be familiar with and understand the Code of Business Conduct, and to promote a culture of ethics and quality in the workplace. If any Data4 Person has a question about the content or application of the Code of Business Conduct, they should contact Data4 HR Department for clarification and explanation.

What Happens in the Event of a Violation?

Possible violations of the principles and rules contained within this Code may be internally investigated by Data4 and, as such, may result in disciplinary actions being taken.

Data4 undertakes to provide for and impose – with consistency, impartiality and uniformity – sanctions proportionate to the respective violation(s) of the Code. Such sanctions will be issued in accordance with the laws and labour regulations in place in the relevant country.

If you’re an employee, it could result in a reprimand or other disciplinary action, including the termination of your employment at the company for cause.

In more serious cases, Data4 reserves the right to refer the matter to the competent civil or criminal authorities, which could result in substantial fines, penalties and/or imprisonment.

Finally, all Data4 People are expected to co-operate with the implementation of the Code by reporting any violations, or suspected violations, of which they become aware (see Section 5 for the procedures on reporting a violation).

1.   Ethical Conduct

The integrity and reputation of a company is based on the daily conduct of all its people. Therefore, it is vital that everyone is aware of the impact of its actions and actively seeks to support and maintain the culture of ethics that inspires the Data4’s business.

For this reason, all Data4 People are expected to conduct themselves in a respectful, professional and law-abiding manner at all times.

1.1.  Respect for the Individual

Be committed to our respectful work environment free from discrimination[2], violence[3] and harassment[4].

Data4 is committed to promoting equal opportunities and diversity in the workplace. We value diversity, equity and inclusion, and we should all do our part to maintain our respectful work environment where everyone feels safe, included and productive. The company does not tolerate workplace discrimination, violence or harassment. All directors, officers and employees must work to ensure that the company is a safe and respectful environment where high value is placed on integrity, fairness and respect. For more information on the company’s commitment to its positive work environment, refer to the company’s Positive Work Environment Policy.

Respect towards others means not only refraining from any hostile, intimidating or offensive attitudes or behaviours, but also treating others with kindness. Every employee should feel comfortable in the workplace and has the right to not be subject to negative behaviours, direct or indirect, which may interfere with her/his work and/or negatively impact on her/his dignity or self- esteem.

Therefore, the Company expressly prohibits all Data4 People from engaging in any disrespectful verbal, non-verbal or physical conduct or harassment for any reason.

Examples of disrespectful behaviour or harassment:

• harassment based on a person’s physical characteristics;
• harassment based on a person’s sex or sexual orientation;
• provocative or intimidating attitudes;
• bullying;
• unwanted sexual gestures or offensive attitudes;
• excessive and unwelcome

We want to create a culture of reporting when it comes to discrimination, violence and harassment, as reporting is essential for us as a company to stamp out these behaviors. While we reserve the right to take corrective action if you knowingly make a false accusation about an innocent party, you will not face retaliation for making a good faith report or assisting in the investigation of a report.

You have a duty to report discrimination, violence and harassment.

If you experience or become aware of what you believe to be discrimination, violence or harassment, you are expected to report it in accordance with the “Reporting Potential Code Violations” section of the Code and/or in accordance with the Positive Work Environment Policy. Reports of discrimination, violence or harassment will be taken seriously and investigated. If you are found to be discriminating against, acting or threatening to act violently towards, or harassing any individual at Data4, or if you knowingly condone the discrimination of, violence towards, or harassment of another individual, you will face corrective action up to and including termination without notice and for cause. We want to create a culture of reporting when it comes to discrimination, violence and harassment, as reporting is essential for us as a company to stamp out these behaviors. While we reserve the right to take corrective action if you knowingly make a false accusation about an innocent party, you will not face retaliation for making a good faith report or assisting in the investigation of a report.

1.2.  Meritocracy

Meritocracy is the fundamental value on which Data4 bases all choices related to its employees. Data4 provides equal opportunities to all its employees and all qualified applicants for employment. Valuing the merits and performance of employees creates a fair and diverse workplace; encourages professional development; and facilitates high standards by inspiring everyone to reach their potential.

Everyone at Data4 should be aware that any decision relating to personnel selection; benefits or bonuses; career advancement; or professional assignments depends solely on the employee’s professional qualifications, skills and performance.

1.3.  Professionality

Data4 requires its People to behave professionally at all times, respecting their own role and that of other people.

Behaving professionally means respecting the ethical principles contained within this Code in every situation; carrying out one’s duties with dignity; and respecting the highest professional standards.

The behaviour of the individual is important, as it determines the image that third parties have of the Group and, therefore, its credibility and success.

Data4 People will dedicate all the professional capacity and effort necessary for the proper performance of their duties. In particular, People may not provide, on their own account or for third parties, to companies or entities other than Data4, professional services similar or equivalent to those provided by Data4 or that may involve a conflict of interest with them, unless authorized by Data4.

1.4.  Conflicts of Interest

A ‘conflict of interest’ exists when a person’s private interests interfere or conflict in any way with the

interests of Data4.

Everyone has an obligation to do what is right for Data4 when carrying out their work. This obligation includes avoiding situations that create a conflict between personal interests and the interests of the Company.

Transparency and awareness are essential to avoid conflicts of interest.

It is important that every Data4 Person is able to recognise potential conflicts of interest and to behave appropriately.

Occasionally in the ordinary course of business, conflicts of interest may arise. When faced with a conflict of interest, it is very important to disclose it as soon as possible to the relevant manager, or to the Board of Directors if the conflict arises at senior management level. Such disclosure is necessary in order to obtain all necessary approvals and adhere to any restrictions that may be imposed.

Here are some examples of situations presenting a potential conflict of interest:

• doing business with friends or relatives;
• working for other companies;
• investing in competing companies;
• using company information for personal

Specifically, Data4 People will dedicate all the professional capacity and effort necessary for the proper performance of their duties. In particular, Data4 People may not provide, on their own account or for third parties, to companies or entities other than Data4, professional services similar or equivalent to those provided by Data4 or that may involve a conflict of interest with them, unless authorized by Data4.

2.   Compliance with Laws, Rules, Regulations and Policies

Being an ethical and honest company also means respecting the law and being committed to compliance with applicable laws, rules, regulations and policies. As a global company, we must comply with the law wherever we do business. Data4 People have a responsibility to understand and comply with all laws and regulations that affect their work.

In the event a local law, custom or practice conflicts with the Code you must adhere to whichever is most stringent. If you know of any of our practices that may be illegal, you have a duty to report it. Ignorance of the law is not, in general, a defense to breaking the law. We expect you to make every reasonable effort to become familiar with the laws, rules, regulations and policies affecting your activities and to comply with them. If you have any doubts as to the applicability or interpretation of any of the above, you should obtain advice from the Group’s Legal Department.

2.1.  Anti-Bribery and Anti-Corruption

Data4 strictly complies with the applicable anti-bribery laws and regulations of each country in which it operates. Furthermore, in order to operate in full compliance with the highest international standards, Data4 also acts in accordance with the UK Bribery Act and the US Foreign Corrupt Practices Act (FCPA).

We value our reputation for conducting business with honesty and integrity. We do not pay bribes in furtherance of our business, either directly or indirectly, and you are not permitted to pay bribes on our behalf or authorize others to pay bribes on our behalf. This commitment comes from the highest levels of management and you must meet this standard.

The issue of corruption is strongly felt at Data4, which is constantly striving to combat any corrupt practices that may occur within the Group.

To this end, Data4 has carried out a bribery risk assessment to identify and assess the risk of bribery offences being committed, as a preventative measure. The Company conducts due diligence on third parties with whom it does business in order to ensure that they too are acting in full compliance with applicable anti-bribery and anti-corruption legislation.

Data4 has adopted appropriate procedures and policies (inter alia, the ABC Program and ABC Policy) to prevent such events and promotes the communication and training of all employees in matters related to anti-bribery and anti-corruption.

A bribe is defined as ‘anything of value’ that is, directly or indirectly, offered, promised, given or received with the intention of improper influence the decision of a Data4 Person or its counterpart (or an employee, agent or consultant more generally) and, in so doing, securing an improper or unfair advantage in promoting, enhancing, obtaining or retaining business. It is not necessary that the bribe holds a high economic value; the purpose for which it is given is most important, as this amounts to corrupt intent and may take many other forms, including gifts, travel, hospitality, political contributions, charitable donations, employment opportunities, internships, and secondments. Facilitation payments[5] are also a form of bribe and are therefore not permitted. For further details, refer to company’s Anti-Bribery and Corruption Policy.

Therefore, anything of value offered or received from persons who have a business relationship with the company are generally acceptable, if the gift or entertainment is modest in value, appropriate to the business relationship, and does not create an appearance of impropriety. No cash or cash equivalent payments should be given or received and must meet these specific criteria:

• all gifts must be reasonable, bona fide, and directly related to the promotion, demonstration, or explanation of products or services, or related to the performance of a contract between Data4 and the other party;
• all gifts must comply with the relevant applicable local law and with all Data4 policies;
• no gift should be offered for the purpose of securing an improper business

All Data4 People must ensure that any gift that may be offered or received in connection with their work is transparent, properly disclosed in business and accounting records, and permitted by law and internal policies. If the gift is for a public official, the Data4 Person must always receive prior approval from its supervisor.

Employees who do not comply with these requirements may be required to reimburse the company for the value of any gifts or benefits they make or receive on behalf of the company. Violations can result in severe consequences for you and/or the company, including findings of violations of laws, disciplinary action by Data4 (up to and including dismissal for cause), and related civil penalties. For further details, refer to relevant Guideline for the Giving/Receipt of Gifts, Meals & Other Entertainment, and the Making/Soliciting of Charitable Donations applicable in your jurisdiction.

Anyone who becomes aware of an alleged or actual violation of these rules has a responsibility to report it immediately, in accordance with the Whistleblowing Policy adopted by Data4.

2.2.  Data Protection

Data4 guarantees that processing activities will be carried out in strict compliance with European and national laws and regulations related to the protection of personal data (“Privacy Legislation”). In particular, Data4 only processes personal data for legitimate purposes, duly communicated in advance to the data subjects to whom the personal data belongs. Unless specifically authorised, personal data collected cannot be processed for purposes other than those originally agreed.

Furthermore, taking into account the different levels of compliance; the costs of implementation; and the nature, scope, context and purpose of processing – as well as the various risks to the rights and freedoms of the data subjects – Data4 guarantees that technical and organisational measures will be implemented to ensure appropriate levels of security.

Data4 guarantees that the rights of all data subjects under Privacy Legislation will be upheld.

The Group requires all Data4 People to comply with Privacy Legislation. This includes the processing of personal data of: employees, customers, suppliers, partners, stakeholders or any other data subject whose personal data is collected or processed by Data4.

Every Data4 Person is responsible for maintaining the confidentiality of all personal data that is processed and ensuring that personal data is never passed on to unauthorised third parties.

2.3.  Insider Information and Securities Transactions

Data4 expressly prohibits the purchase or sale of company shares by anyone in possession of non- public information or material; in other words, information about the Company that has not been publicly disclosed (also called ‘insider information’).

Information is ‘non-public’ when it has not been communicated to the general public and/or the general public has not been made aware of such information. Insider material refers to any ‘material’ which, when read or consulted, could influence the reasonable investor’s decision regarding the sale or purchase of shares, or affect the price of shares in any way.

Likewise, anyone with access to other companies’ insider information – including Data4 customers or suppliers – may not buy or sell that company’s securities.

Any Data4 Person who shares insider information with a third party, who then executes transactions based on that information, will be held liable for said illegal transactions and punished under the applicable law(s).

2.4.  Anti-Money Laundering

Data4 is aware of the central role of companies in the fight against money laundering. The Group is committed to implementing anti-money laundering measures, also with a view to prevent the financing of terrorism.

Therefore, it is explicitly forbidden for all Data4 People to:

• purchase, replace or transfer money, goods or other utilities with knowledge of their criminal origins – or, to carry out any transaction which serves to conceal the illegal origin of said money or goods;
• replace or transfer money, goods or other utilities deriving from a crime – or carry out any transaction which hinders the identification of their criminal origin;
• use in economic or financial activities money, goods or other utilities with knowledge of their criminal origin;
• carry out any activity with money or goods with the intention or with the knowledge that they will be used, directly or indirectly, in whole or in part, for the commission of any of any terrorist or criminal activity.

Anyone who becomes aware of circumstances, activities or events which may be an indicator of money laundering or terrorist financing, has a responsibility to immediately report it.

2.5.  Accounting and Tax Compliance

Data4 maintains company books, records and accounts with a reasonable level of detail, to accurately and fairly represent all its transactions. Records are maintained and updated in the timeframe and manner required by law and internal policies.

Data4 People involved in these activities must never, under any circumstances, keep inaccurate, false or misleading records – even if such failure could reasonably be expected to have no detrimental effect. Each Data4 Person is obliged to comply with the applicable tax and fiscal laws, as well as work within the generally accepted guidelines.

The Company has adopted control and prevention measures with the aim of preventing civil and/or criminal offences. Any wilful misrepresentation of – or misinformation regarding – the financial accounts and reports shall be regarded as a violation of this Code. As such, appropriate legal action – whether civil and/or criminal – will be instigated.

Data4 is committed to complying with all economic sanctions imposed with respect to certain entities and countries, including economic sanctions imposed by the UN, the EU and other jurisdictions in which Data4 operates.

2.6.  IT Security

Due to the increasing interconnection of different communication systems, and the integration of software layers to improve management and efficiency, Data Centers are increasingly confronted with information and data security issues.

The data center has evolved from a real estate asset – whose primary function was to provide customers with permanent and secure access to the data hosted in its buildings – into an ultra- connected asset, open to the outside world. The same security requirements, however, must be maintained.

This evolution of IT infrastructures requires that Data4 takes into account the new risks linked to physical safety and security, as well as the security of information and information systems.

Security is of the utmost importance. It is a necessary condition for the business and ensures a relationship of trust between Data4, its customers and its strategic partners. It also allows Data4 to guarantee continuity and quality service.

The security objectives of DATA 4 have been defined as follows:

• to ensure the physical safety/security of infrastructure;
• to ensure the availability of infrastructure;
• to ensure the availability, confidentiality and integrity of data;
• to ensure traceability and auditability of actions and access to IT systems and

With these objectives in mind, Data4 has put in place organisational and technological measures to ensure high standards of IT security. These include:

• measures allowing access only to authorised users, with authentication systems based on the principle of minimum privilege;
• the integrity of exchanged data;
• protection of computer and telematic systems from malicious software attacks;
• controls on the network infrastructure;
• an adequate security incident management

These objectives are achieved not only through the adoption of organisational and technological measures throughout various corporate processes (which aim to protect assets and the integrity of information) but also through Data4 People, who must play an active role in the correct usage of IT resources.

3.   Business Relationships

Data4 believes that a company’s success is underpinned by the way it relates to its business partners and how it chooses to conduct its business activities.

Only an open, transparent, and equal-opportunities company can aspire to excellence in its industry.

For this reason, Data4 believes it is essential that all of Data4 People are aware of, and abide by, the principles and rules listed below.

3.1.  Fair Competition

Data4 fully supports the development of the open market and promotes the liberalisation of the market.

Data4 People are expected to avoid any behaviour that may equate to improper business practice. As such, the following conduct is strictly prohibited:

• seeking the proprietary information of others;
• possessing secret trade information, obtained without the owner’s consent;
• asking past or present employees of other companies to share another company’s proprietary information;
• collaborating with competitors to divide markets, opportunities, offerings or geographic

Fair competition must also apply to suppliers, with whom Data4 is committed to behaving in a fair and honest manner, regardless of where they are located or the type of products or services they provide.

Data4 undertakes open and fair procurement, in which suppliers are selected on a competitive basis, and establishes mutually beneficial relationships based on close co-operation and clear communications.

3.2.  Confidentiality

Data4 makes every effort to ensure the protection of confidential information, whether it concerns the Company, its customers, partners, suppliers or third parties.

Any data, information, documents or reports acquired or processed during the course of work must be treated as strictly confidential. More generally, information that is not available to the public and that relates to a company’s business, strategies, projects, customers and/or partners should be considered confidential.

Every Data4 Person is obliged to only use the confidential information, acquired in the course of their work, exclusively within the limits and for the purposes authorised. Privileged information shall also be safeguarded to prevent disclosure to third parties.

3.3.  Innovation

The daily work of every Data4 Person must be centred on customer satisfaction, with the goal of

providing the best service possible and always acting in the customer’s best interests.

Data4 strives to keep its finger on the pulse of technological advances by spearheading innovative projects and opening up to new technologies (ex : technologies that could help Data4 reducing its environmental footprint). Thanks to this adaptability and desire to move forward, Data4 is able to understand the changing needs of its customers and meet the requirements of an evolving society.

3.4.  Security of Company Information and Assets

Each Data4 Person is responsible for the proper, appropriate and correct usage of the assets provided by the Company. Everyone is responsible for ensuring the integrity and protection of assets from theft, misuse, sabotage, loss or damage.

Intangible assets – such as brand, reputation and the intellectual property of the Company – must also be protected by all Data4 People.

Data4 works to foster, through the application of advanced technologies, quality management and technical standards as well as the highest levels of process safety and infrastructural integrity throughout the asset lifecycle.

In addition, Data4 monitors the operating conditions of assets and requires that any situation which may represent a danger if not adequately controlled is reported.

All Data4 People must comply with the following rules:

• devices provided for the performance of work duties must be used with care and within the limits allowed by internal procedures, avoiding loss or deterioration;
• data and information must only be consulted by authorised Persons and used if it is necessary for the performance of business activities;
• the use of the services and software provided by Data4 must be limited and installing unauthorised software, or modifying the pre-existing configurations on Company IT systems, must be forbidden;
• respect all intellectual property rights of Data4 (copyright, patents, trademarks);
• security incidents must be immediately reported (even if only suspected) in accordance with Data4’s applicable internal procedures.

3.5.  Responsible Relationships with Suppliers and Business Partners

Data4 shares its values and integrity with its suppliers, as well as its commercial and industrial partners, in order to build relationships based on maximum transparency.

In addition to professionalism, Data4 requires its suppliers and partners to commit to and share its principles and values, and to operate in line with its high standards of respect for the law and human rights.

For this reason, Data4 implements quality selection and monitoring processes to qualify its suppliers and partners, based on the principles of transparency and integrity.

On the basis of the general principles of transparency and integrity, Data4 asks its suppliers to share its CSR values via the “Supplier CSR Charter” available on our website or on request.

3.6.  Co-operation with Authorities and Institutions

Data4 promotes and supports dialogue and active co-operation with international, national and local authorities and institutions, committing to the establishment of relations with authorities based on the principles of fairness and transparency.

For this reason, all Data4 People are prohibited from:

• making, inducing or facilitating false statements or incomplete statements (which omit relevant details) to authorities and institutions;
• entertaining relations with authorities and institutions outside the limits or parameters of their function and position;
• improper use of the Data4 name in personal interactions with political parties, movements and committees.

4.   Social Responsibility

Data4 is committed to operating responsibly in the social environment in which it does business. In particular, the Company highly values respect for human rights, health and safety at work, the environment and national interests.

Data4 also supports and seeks to uphold the Global Compact of the United Nations.

4.1.  Human Rights and Modern Slavery

Data4 supports and respects the protection of all human rights worldwide.

The Group is committed to upholding the fundamental human rights of its employees and stakeholders, in line with the United Nations Guiding Principles on Business and Human Rights (UNGP) and the OECD Guidelines for Multinational Enterprises. Data4 also applies to its activities the principles of economic, social and environmental sustainability as outlined in the United Nations Sustainable Development Agenda.

Data4 requires its suppliers and partners to adhere to these same high standards. Data4 requires all its People to respect fundamental human principles such as:

• respect for minorities, diversity and equal opportunities as well as the elimination of discrimination in employment;
• the eradication of harassment and physical or mental abuse in the workplace.
• operating with leading health and safety practices to support the goal of zero serious safety incidents;
• striving to ensure that the interests, safety and well-being of the communities in which we operate are integrated into our business decisions;
• freedom of expression and opinion;
• respect for workers and prohibition of practices such as human trafficking, slavery and servitude, forced labour and child labour;
• freedom of association and collective bargaining;
• data privacy;
• protection of the

We strive to embed these standards into all of our core business activities, including training, communications, contracts and due diligence processes set out in our ESG Due Diligence Guidelines and Vendor Management Program. These practices extend to our interactions with our key suppliers and other business partners. For more information about our business practices and systems and controls to safeguard against modern slavery and human trafficking, please refer to the company’s Anti-Modern Slavery and Human Trafficking Policy.

4.2.  Health and Safety

Data4 strives to provide its employees with a safe, healthy, clean and secure work environment and asks them for their co-operation in maintaining a safe and healthy workplace. Every Data4 Person should:

• comply strictly with all occupational, health and safety laws and internal procedures;
• not engage in illegal or dangerous behavior, including any acts or threats of violence;
• not possess, distribute or be under the influence of drugs while on company premises or when conducting company business; and
• not possess or use weapons or firearms or any type of combustible material in the company’s facilities, or at company-sponsored functions.

For this purpose, Data4 has organised and regulated its activities in accordance with the applicable national laws of the countries in which it operates, as well as in keeping with international standards, to create a health and safety system that provides for:

• the assessment of all health and safety risks related to the activities carried out by its employees or by third parties in its interests;
• the adoption of a systematic approach to eliminate the risks at the source if possible, or to minimise them;
• the adoption of the best technologies and working methods, oriented towards continuous improvement;
• the adoption of an information and training program for

If you or someone you know is in immediate danger of serious bodily harm, first call local law enforcement authorities and then report the incident in accordance with the “Reporting Potential Code Violations” section of the Code and/or in accordance with the Positive Work Environment Policy.

4.3.  Environmental, Social and Governance (“ESG”) Management

Our ESG policy outlines our approach to ESG which is based on the following guiding principles:

4.3.1.           Mitigate the impact of our operations on the environment:

1. Strive to minimize the environmental impact of operations and improve efficient use of resources over time.
2. Support the goal of net zero greenhouse gas (GHG) emissions by 2050 or sooner.

4.3.2.           Strive to ensure the well-being and safety of employees:

1. Foster a positive work environment based on respect for human rights, valuing diversity, and zero tolerance for workplace discrimination, violence or harassment.
2. Operate with leading health and safety practices to support the goal of zero serious safety incidents.

4.3.3.           Uphold strong governance practices:

1. Operate to the highest ethical standards by conducting business activities in accordance with our Code of Business Conduct and Ethics.
2. Maintain strong stakeholder relationships through transparency and active engagement.

4.3.4.           Be good corporate citizens:

1. Strive to ensure the interests, safety and well-being of the communities in which we operate are integrated into our business decisions.
2. Support philanthropy and volunteerism by our employees.

Our ESG Due Diligence Guideline incorporates the Sustainability Accounting Standards Board (SASB) engagement guide to assist investment teams in conducting a comprehensive review of material ESG factors for all investments under consideration. The ESG Due Diligence Guideline is required to be considered in all diligence work performed as part of Data4’s ESG approach. Our Vendor Management Program also incorporates ESG considerations where applicable.

4.4.  Corporate Citizenship

Data4 is committed to good corporate citizenship. This includes complying with all relevant laws and regulations, but also by actively assisting people in the communities in which it operates to improve the quality of life. Data4 cares about the economic development of every country in which it conducts business and respects the culture, customs and traditions of each country and region.

Data4 also encourages and supports its employees to volunteer and collaborate with community groups.

5.   Reporting a Violation

Each Data4 Person is required to co-operate with the Company and this Code to ensure that the high standards which make Data4 an ethical, honest and innovative Group, are upheld.

Each person’s co-operation cannot and must not be limited to simply implementing the principles and rules in their individual actions.

Control over the correct fulfilment of the provisions of the Code of Business Conduct is an essential requirement for the Company’s effectiveness and can only be achieved through reports of violations.

Data4, therefore, asks everyone to report any violations of the Code’s rules that they become aware of – even if this is only a suspected violation of the rules.

The procedures and channels for making such reports are specified in Data4’s Whistleblowing Policy, which guarantees Whistleblowers absolute confidentiality and protection from retaliation.

We therefore invite all Data4 People to read and comply with the Whistleblowing Policy and to make considered and responsible use of the reporting channels that Data4 has made available.

[1] For purposes of the Code, “temporary workers” include non-full-time employees and consultants and contractors etc. that work on our premises. The business group retaining a temporary worker is responsible for ensuring that the temporary worker certifies their commitment to comply with the Code.

[2] “Discrimination” means the differential treatment of an individual or group based on prescribed characteristics protected by law. Prescribed characteristics generally include age, color, race, religion, sex, gender, marital status, ancestry, sexual orientation, national origin, disability. It does not matter whether the discrimination is intentional; it is the effect of the behavior that matters.

[3] “Violence” means an action (oral, written or physical) which causes, is intended to cause, could reasonably be interpreted as a threat to cause, or is capable of causing death or bodily injury to oneself or others, or property damage.

[4] “Harassment” means conduct which is known or ought reasonably to be known to be unwelcome and includes conduct (e.g., comments and actions) which would be perceived by a reasonable person as being hostile, humiliating or abusive or cause him/her torment. Harassment covers a wide range of conduct and includes sexual harassment, bullying and psychological harassment. Harassment may occur in a variety of ways and may, in some circumstances, be unintentional, but regardless of intent, all harassment negatively affects individual work performance and our workplace as a whole.

[5] Facilitation payments are small payments made to secure or speed up routine actions or otherwise induce public officials or other third parties to perform routine functions they are otherwise obligated to perform, such as issuing permits, approving immigration documents or releasing goods held in customs. This does not include legally required administrative fees or fees to fast-track services.