Commitment to Integrity and Compliance

Operating with integrity is a core value at Equinix and calls for knowledge of and a commitment to ethical business practices. We foster a culture of trust among our employees and customers while staying true to our core beliefs.

Consistent processes help us uphold our ethical standards. We rely on executive support to ensure that integrity remains at the core of everything we do. Our safe and supportive environment encourages employees to speak up when they have concerns.

The Global Regulatory, Public Policy, Privacy and Compliance Team (GRPC)

In 2023, we formed the Global Regulatory, Public Policy, Privacy and Compliance Office (GRPC) to enhance regulatory management at Equinix. The GRPC consists of four groups: the Regulatory Office, the Public Policy and Government Affairs team, the Data & Privacy Office and the Ethics and Compliance Office. The GRPC reports to the SVP, Global Regulatory, Public Policy, Privacy and Compliance.

The Regulatory Office reports to the GRPC and has primary responsibility for interpreting and advising on the applicability of and compliance with global regulations that have a material impact on the company’s business operations. These include regulations relating to telecommunications licensing, critical national infrastructure, power, industry-specific trade restrictions, foreign investment policies and sustainability. Where regulatory compliance measures must be adopted and are reasonably practicable, the Regulatory Office adopts a globally consistent approach to managing common regulatory issues.

The Regulatory Office conducted several regulatory assessments to evaluate our current state of compliance. We are using these findings to inform future initiatives to ensure alignment with regulatory expectations.

Navigating legislative and regulatory nuances across our operational regions requires a responsive, knowledgeable and coordinated team. Externally, we continue to work to build strong partnerships with local authorities, global industry groups and third-party experts to inform and support our compliance program.

Legislative Compliance

Equinix complies with all ethics and compliance regulations in the regions and countries where we conduct business. We have a robust cross-functional team dedicated to managing and handling the complexities of maintaining legal and ethical compliance. The VP of Legal and Chief Compliance Officer leads the implementation and execution of matters pertaining to ethics and compliance. This role reports directly to the SVP of Global Regulatory, Public Policy, Privacy and Compliance. Our Data & Privacy Office (DPO), led by the company’s global Head of Data & Privacy Office, oversees our response to evolving privacy laws and regulations. Our commitment to going above and beyond basic compliance requirements, coupled with a strong governance structure, allows us to operate with integrity and fosters ongoing trust with our stakeholders.

The Chief Compliance Officer also leads Equinix’s Governance Risk and Compliance (GRCC) program. The program provides a global, cross-functional forum for relevant governance, risk and compliance issues, opportunities and activities to be identified, prioritized and addressed. The Nominating and Governance Committee of the Board oversees the GRCC program, providing strategic management, driving accountability and contributing to the overall integrity and compliance framework of Equinix. The committee regularly receives updates on this program, fostering transparency and informed decision-making.

Due to the potential security risks and upcoming regulations associated with artificial intelligence (AI), we will continue to monitor developments in AI-related regulations, with a view to develop and implement an effective and appropriate AI governance program. In 2024, we plan to conduct a gap assessment against the requirements of the Federal Information Security Modernization Act (FISMA) and strengthen our technical controls.

Business Conduct

We regularly review, update and make publicly available our Code of Business Conduct, which establishes our guiding principles on ethics and compliance. To support our diverse employee base, we publish it in multiple languages, enabling accessibility and understanding of our compliance obligations.

We require all suppliers to acknowledge and follow our Business Partner Code of Conduct, which sets our ESG standards for suppliers and is part of our standard terms for supplier contracts. The Business Partner Code of Conduct acts as the digital foundation and meeting point for Equinix and our suppliers. To ensure compliance, we monitor suppliers via our Supplier Risk Management program.

Ethics and Compliance Helpline

We foster an environment where individuals feel empowered to raise concerns without fear of retaliation. Our third-party hosted Ethics and Compliance Helpline (the Helpline) allows both named and anonymous submissions and provides a safe site for individuals to share their questions and concerns. The Helpline encourages individuals to report issues, reinforcing a culture of accountability and integrity within and outside our organization. This service is accessible to anyone, online or via phone (in specific countries), and it provides a translation service to meet the needs of anyone wishing to report a concern. We address all inquiries and reports of misconduct on a case-by-case basis.

Assessing Effectiveness

We take a multifaceted approach to evaluating the effectiveness of our Ethics and Compliance Program, including risk assessments and industry collaboration. We actively monitor the compliance landscape to ensure we are aligned with industry best practices.

Privacy considerations are of great importance. We adhere to regional requirements, ensuring a high standard of data protection and compliance with international standards. Because of the complex compliance landscape, we strive to ensure our program remains robust and adaptable to evolving international standards.

Employee Training and Awareness

As we grow, our ongoing priority is to make certain that every employee understands the importance of adhering to our ethical standards in their day-to-day decision-making and actions on behalf of Equinix. By fostering an ethical corporate culture, we believe we build trust with stakeholders and mitigate the risk of legal and reputational issues.

Employee Training

In 2023, Equinix reached a remarkable milestone by maintaining a 10-year track record of 100% completion in our annual compliance training. Compliance education is an essential part of our work to ensure that our workforce is well versed in upholding ethical standards and regulatory requirements. We take pride in this accomplishment and commend our leadership for their crucial role in this achievement.

New hires, whether through direct recruitment or merger and acquisition, must complete two ethics and compliance courses within 180 days of joining Equinix: the Anti-Bribery and Corruption (ABC) course and the Code of Business Conduct course. The ABC course covers the Foreign Corrupt Practices Act (FCPA) and anti-bribery regulations in various jurisdictions. The Code of Business Conduct training comprises two third-party courses that are customized to Equinix.

We offer both virtual and in-person training. Most virtual courses are delivered on the Equinix Learning Center platform and offered in a variety of languages. Our compliance team delivers in-person training sessions tailored to regional needs and associated topics of interest.

Employee Communications

In 2023, we focused on enhancing internal awareness of the Regulatory Office’s program and policies. In line with this effort, we launched a newsletter to keep relevant teams informed about relevant regulatory developments. The newsletter focused on regulations expected to have global implications, such as the EU Cross Border Adjustment Mechanism (CBAM) and the Corporate Sustainability Reporting Directive (CSRD), highlighting their potential impact.

The newsletter underscores the critical importance of aligning with global regulations to secure opportunities for growth and expansion in key markets, the value of regulatory foresight and the need for proactive employee engagement.

The “Ethically” Podcast for Ethics and Compliance Tips

In 2023, we continued the publication of “Ethically,” an internal podcast series aimed at expanding the reach of our Code of Business Conduct. “Ethically” features insightful interviews of both individuals responsible for compliance and leaders overseeing specific topics. Throughout the year, “Ethically” covered topics like data privacy, insider trading, and community and belonging. In total, the podcast produced 15 episodes.

In the 12th episode of the series, host Alex Rosenbaum, Senior Legal Counsel, spoke to JP Feidner, Managing Director, Germany. The episode focused on Germany’s tightening of sustainability requirements for data centers, which could pose challenges and opportunities for Equinix. JP shed light on the role of the Public Policy and Government Affairs team in assisting Equinix Germany in navigating these changes and representing the company’s interests before the German government.

“Ethically” stands not only as a testament to our commitment to ethics and compliance but also as a catalyst for fostering a culture of responsibility and continuous learning within Equinix.