Governance
Compliance and Integrity
Operating with integrity is a core value at Equinix that requires knowledge of and commitment to ethical business practices.
Acting with accountability and transparency builds stakeholder trust, which strengthens our customer relationships and the value we can deliver to them.
At the Board of Directors level, the Nominating and Governance Committee of the Board oversees our business ethics and compliance. The Ethics and Compliance Office provides quarterly updates on these matters to the Committee. Our Executive Management team sets the tone for ethical conduct and supports efforts to ensure integrity remains at the core of everything we do. The Executive Management team also receives periodic ethics and compliance reports and conducts reviews as necessary.
Regulatory compliance
Our dedicated, cross-functional Global Regulatory, Public Policy, Privacy and Compliance (GRPC) team navigates the complexities of maintaining legal compliance and ethical standards everywhere we operate. Overseen by the Senior Vice President (SVP) of Global Regulatory, Public Policy, Privacy and Compliance, the GRPC comprises four groups:
- Data and Privacy Office
- Ethics and Compliance Office
- Global Regulatory Office
- Public Policy and Government Affairs
In 2024, we adopted a charter that defines the purpose of each office within the GRPC and how the teams work together to achieve results.
We adopt a globally consistent approach to managing common regulatory issues. Apart from our Public Policy and Government Affairs team, the offices of the GRPC have compliance responsibilities in their respective areas of expertise. The Global Regulatory Office also has primary responsibility for interpreting and advising on the applicability of and compliance with regulations that have or could have a significant impact on the company’s business operations. These include regulations relating to telecommunications licensing, critical national infrastructure, power licensing, cybersecurity and sustainability.
Regulatory assessment
Various teams across Equinix share responsibility for ensuring our compliance with regulations. In 2024, our efforts focused on adapting to new sustainability and AI regulations and responding to updated laws in countries where we operate. To support our compliance, we:
- Built a process to evaluate and monitor evolving regulations impacting Equinix across our value chain and globally.
- Implemented a robust program management framework to ensure effective execution of regulatory requirements, track progress against compliance goals and facilitate cross-functional collaboration across the business.
- Reviewed marketing and communication materials as they relate to regulatory requirements.
- Provided regulatory-based trainings and other support across the business.
Business conduct
We reinforce integrity as a core value at Equinix through our Code of Business Conduct. The Code outlines our expectations for ethical behavior in the workplace and applies to all officers, directors, employees and those acting on behalf of Equinix, including agents, representatives and consultants. To ensure alignment with global standards, we regularly review and update the Code. Reflecting our global workforce, we publish the Code in multiple languages.
We take proactive measures to minimize the risk of unethical behavior. Examples include:
- Digital announcements and messages in company spaces, such as conference rooms, to remind employees of ethical workplace behavior
- Requiring annual ethics training for all employees and offering training sessions on specific topics as needed
- Maintaining an online portal where employees can confidentially seek advice from the Compliance team or report concerns
Supplier code of conduct
To ensure adherence to our ethics standards, every supplier contract requires suppliers to follow all laws and Equinix polices and to acknowledge and abide by our Business Partner Code of Conduct. The Code provides guidance on our ethical standards as well as material supply chain sustainability topics. To ensure compliance with the Code, we evaluate and monitor suppliers through a third-party risk management program.
Our internal Global Purchasing Policy (GPP) sets sourcing standards for employees, including compliance and sustainability considerations, and provides guidelines for business process owners responsible for purchasing decisions. We regularly update the GPP to reflect evolving standards.
Reporting concerns
We foster a safe and supportive environment where employees and stakeholders are encouraged to speak up if they have concerns. Anyone can report potential compliance or ethical issues confidentially or anonymously to our ethics and compliance hotline without fear of retaliation. Hosted by an independent third party, the hotline is available online and by phone (in select countries) and offers translation services to accommodate our global workforce. Each inquiry or report is addressed on a case-by-case basis.
Employee training
To ensure understanding and compliance, we educate all employees on their ethical and legal responsibilities. Specifically, we:
- Mandate trainings for new hires within 180 days of joining Equinix, including two courses covering anti-bribery and corruption and the Code of Business Conduct (including Honesty and Integrity; Conflicts of Interests and Ways to Speak Up).
- Require employees to complete refresher training for both courses every other year.
- Publish regulatory factsheets and newsletters to relevant business functions to enhance awareness of emerging regulations.
- Host “Ethically,” a podcast providing ethics and compliance tips.
Our training is offered both virtually and in person. Most virtual courses are hosted on the Equinix Learning Center platform and are available in multiple languages. In-person training sessions are conducted by our Ethics and Compliance Office, customized to address regional priorities and relevant topics. In 2024, 100% of employees completed annual ethics and compliance trainings.
“Ethically,” a podcast for ethics and compliance tips
“Ethically” is an internal podcast series that provides employees with ethics and compliance tips beyond our Code of Business Conduct. Each episode features interviews with leaders from across the business. In 2024, we released a total of eight episodes, including two focused on how we prioritize sustainability in our operations.
During those episodes, host Alex Rosenbaum, Senior Legal Counsel, spoke with Patricia Leyva, Senior Manager, Global Sustainability Stakeholder Engagement, Sustainability Program Office (SPO) and Melissa Gray, Senior Director of Supply Chain, Sustainability and Corporate Services about ethics and compliance tips for employees as they relate to sustainability.
Patricia highlighted the growing importance of sustainability for Equinix’s investors, employees and communities. She shared tips on how customer- and vendor-facing teams can effectively communicate Equinix’s sustainability strategy.
Melissa explained how the Procurement Team collaborates with other functions within the organization to meet sustainability goals, including managing Scope 3 emissions from suppliers’ operations. She also discussed how employees can contribute to sustainability efforts, such as by choosing preferred suppliers with strong sustainability commitments, disposing of electronics responsibly and asking for guidance on procurement-related sustainability practices.
