ANTI-HUMAN TRAFFICKING, ANTI-MODERN SLAVERY & PROHIBITION ON CHILD LABOR STATEMENT
I. 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, Anti-Modern-Day Slavery and Prohibition of Child Labor 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.
II. STATEMENT APPLICATION
This Statement is applicable to the Company’s worldwide operations. This Statement sets forth the Company’s commitment to combatting human trafficking, modern slavery and child Labor clearly and 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, Thailand, Malaysia and the Philippines. 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, CHILD LABOR AND HUMAN TRAFFICKING
The Company will use all available tools to avoid human trafficking, child labor 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, modern slavery or child labor, and we demand the same opposition from all who work for or with us.
V. PROHIBITION ON CHILD LABOR
The Company strictly prohibits the use of child labor in its operations and supply chain. The Company will not engage, directly or indirectly, any worker below the minimum legal working age as prescribed by applicable local law.
The Company expects all suppliers and third-party business partners to maintain the same zero tolerance standard for child labor. Any supplier found to be employing child labor shall be required to take immediate remedial action and may be subject to termination of the business relationship.
VI. RELEVANT DUE DILIGENCE 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.
VII. RISK ASSESSMENT AND MANAGEMENT
Understanding our human trafficking, modern slavery and child labor risks 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, modern slavery and child labor, 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.
VIII. 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 ongoing assessment process against a range of criteria, including compliance with our ethical standards and corporate values. Key suppliers are reviewed more frequently 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.
IX. TRAINING ON MODERN SLAVERY AND TRAFFICKING
The Company has published 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 protects our employees when they raise a concern thereunder.
X. VIOLATIONS AND INVESTIGATIONS
Any breach / violation of this Statement and related policy/es shall be investigated as per the procedure laid out in the Company’s Code of Conduct Policy. Personnel may appeal any determination made under this Policy in accordance with the procedure prescribed in the Code of Conduct Policy. Any decision under such appeal shall be deemed final and non-appealable.
XI. CONTACTS AND FURTHER INFORMATION
For further information or any clarification, please contact:
- Head of Legal and Compliance: joe.b@digitaledgedc.com
- Compliance Officer: vishal.jain@digitaledgedc.com