Integrity is a core Equinix value. We know that our commitment to maintaining our values develops a strong culture of trust with our employees and customers. As Equinix grows and expands into new regions and manages the complexity of a growing employee base, our commitment to doing business ethically only becomes stronger.

We want our employees to feel safe and supported so that they are empowered to speak up when things aren’t right. We have implemented consistent processes to maintain our strong culture and rely on executive support to ensure that integrity remains at the core of everything we do.

Compliance

Equinix maintains compliance with all applicable local, state, federal and international laws and regulations in the regions in which we operate. The VP, Legal and Chief Compliance Officer leads the implementation and execution of matters related to ethics and compliance and reports directly to the Chief Legal and Human Resources Officer. Our emphasis on performing beyond compliance and our strong governance structure enables us to operate with integrity and maintain a sense of trust with our stakeholders. Equinix also maintains a Privacy Office led by the company’s SVP, Legal, Corporate and Chief Privacy Officer which oversees the company’s response to evolving privacy laws and applicable regulations.

Code of Business Conduct

Employee Training and Awareness

We require regular compliance trainings for all Equinix employees on how to uphold Equinix’s ethical standards in their day-to-day decision-making and actions on behalf of our company. New employees are required to complete two compliance trainings upon hire. These trainings must be completed within 6 months of the employees’ start date. Subsequently, all Equinix employees are required to complete an annual compliance training. In 2021, Equinix’s annual ethics and compliance training, which was focused on anti-bribery and corruption, was completed by 100% of employees globally. Equinix has achieved 100% completion of its annual compliance training for the past 8 years.

In addition to training, we use various communication tools to engage and educate employees on compliance topics. We expect to continue to expand these tools and plan to enhance our employee communication strategies in the coming year.

Our Code of Business Conduct, which contains our guiding principles on ethics and compliance, is periodically reviewed and updated and made available on our public facing equinix.com website and our internal company sites. It is also available in multiple languages for our diverse employee base.

Anti-Discrimination and Labor Laws

We are opposed to all forms of discrimination. We are also opposed to all forms of modern slavery, human trafficking, forced or compulsory labor and child labor. More information about how we conduct our business around the world and the requirements we place on our partners and suppliers can be found in the Equinix Business Partner Code of Conduct.

Anti-Bribery and Corruption

We address all inquiries and reports of misconduct and manage the review and resolution of issues on a case-by-case basis. The Nominating and Governance Committee of the Board oversees and receives regular updates on the company’s Governance Risk and Compliance (GRC) program led by the Chief Compliance Officer.

We regularly assess the effectiveness of our Ethics and Compliance Program in order to ensure we are meeting the highest standards of integrity.

Conflicts of Interest

We believe it is essential to create an environment in which individuals feel able to raise any matters of genuine concern without fear of retaliation and are confident that their concerns will be taken seriously and acted upon. Our Ethics and Compliance Helpline is available for anyone, both employees and the public, to report an incident or situation concerning our Code of Business Conduct, our policies or the law, or any other concerns they may have. In 2021, we added a ‘Conflicts of Interest’ portal within our Ethics and Compliance Helpline, streamlining our process and making it simpler for employees to submit relevant and required information for conflict of interest inquiries.