Uncompromising Integrity and Compliance

Integrity is a core Equinix value. By maintaining our values, we create a strong culture of trust between our employees and customers. Equinix’s commitment to ethical business practices grows as we expand into new regions and manage the resulting complexity, including acknowledging global situations.

We want our employees to feel safe and supported so that they are empowered to speak up when things are not 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.

Regulatory and Compliance

Equinix complies with all applicable local, state, federal and international laws and regulations in the regions in which we operate. This task becomes increasingly complex as we expand operations into new countries and as regulations in the countries in which we currently operate evolve. We have a strong cross-functional team responsible for managing this complexity. The VP, Legal and Chief Compliance Officer leads the implementation and execution of matters related to ethics and compliance, and reports directly to the SVP, Global Regulatory, Public Policy, Privacy and Compliance. Equinix also maintains a Privacy Office led by the company’s SVP, Deputy General Counsel and Chief Privacy Officer, which oversees our response to evolving privacy laws and applicable regulations. 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.

In 2022, we globalized our approach to the evolving regulatory landscape through the formation of the Global Regulatory Office (GRO). The GRO manages Equinix’s increasingly complex regulatory compliance across our business, which includes, but is not limited to, areas like ESG and power regulation. As Equinix grows, the GRO plays a critical role in aligning our global businesses and ensuring we are compliant with relevant laws, especially as we enter new markets. The GRO reports to the SVP, Global Regulatory, Public Policy, Privacy and Compliance.

Understanding legislative and regulatory differences within the regions in which we operate requires a responsive, knowledgeable and coordinated team. Our team closely monitors how various governments set requirements for data centers. We actively engage with governmental authorities and industry groups around the world on developing green policies with data centers. Equinix works closely with internal leaders, external experts and local resources to meet these requirements.

Code of Business Conduct

Our Code of Business Conduct, which contains our guiding principles on ethics and compliance, is periodically reviewed and updated and made available publicly. It is published in multiple languages to be accessible for our diverse employee base.

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 can be 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.

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 Equinix’s Governance Risk and Compliance (GRC) program led by the Chief Compliance Officer.

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

Employee Training and Awareness

For the ninth year in a row, 100% of our employees completed our annual compliance training in 2022. As we expand, we continue to prioritize ensuring every Equinix employee understands the value of adhering to our ethical standards while making their day-to-day decisions and acting on behalf of our company. New employees are required to complete two compliance training courses upon hire. These training sessions have been successful due to our global consistency and support from leaders within Equinix.

In addition to virtual training, we use various communication tools to engage and educate employees on compliance topics. Through in-person training, which was reignited in 2022, our compliance team traveled to various sites and delivered training sessions highlighting topics of specific interest to those locations.

Launch of “Ethically”, Equinix’s Ethics and Compliance Podcast

In 2022, the Ethics and Compliance Office successfully launched “Ethically”, a podcast series that takes employees beyond the Code of Business Conduct to provide ethics and compliance tips for real-life situations. Each quarter, the host, Alex Rosenbaum, Senior Legal Counsel at Equinix, welcomes two Equinix experts to talk about a specific topic. One subject matter expert speaks to the technical side and the other shares how the topic impacts Equinix. Topics are selected based on interest and relevance and are intended to be easily accessible and generally applicable, while highlighting where cultural differences exist. Each episode post received over 8,500 views and successfully directed employees to additional resources on the topic.

In the Q3 2022 podcast episodes, Alex spoke to Sujata Narayan and Kevin Montgomery about charitable giving resources available to employees at Equinix and their intersection with the Code of Business Conduct.

Alex Rosenbaum, Senior Legal Counsel at Equinix

Alex Rosenbaum

Senior Legal Counsel

Kevin Montogomery, Senior Project & Program Associate at Equinix

Kevin Montgomery

Sr. Project & Program Associate at Equinix, spoke to Alex about navigating Equinix’s charitable giving processes.

Sujata Narayan, Director of Corporate Citizenship at Equinix

Sujata Narayan

Director, Corporate Citizenship at Equinix, spoke to Alex about Equinix’s approach to charitable giving.

Business Partner Code of Conduct

Our Business Partner Code of Conduct, which sets our environmental, social, and governance standards for vendors, must be acknowledged and followed by all new suppliers.

The digital foundation for Equinix and our vendors is our supplier portal. This crucial foundation serves as a meeting point for Equinix and its vendors.

Supply Chain Sustainability