This Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 covering the financial year to 31 December 2022 and relates to Vantage Data Centers UK Limited as part of the group of companies making up Vantage Data Centers and how we support and promote the elimination of human trafficking and modern slavery throughout our businesses and supply chains. This statement sets out our commitment to preventing slavery and human trafficking in our business activities and the steps we are taking to meet this commitment.

Organizational Structure and Supply Chain
Vantage Data Centers is a global provider of wholesale data center campuses, powers, cools, protects and connects the technology of the world’s well-known hyperscalers, cloud providers and large enterprises. Vantage engages employees, suppliers and service providers to support the acquisition, construction and operations of data centers globally.

Policy Statement
Vantage strictly prohibits unlawful child labor, prison or forced labor, human trafficking, and physical punishment in accordance with the Vantage Code of Conduct, the Supplier Code of Conduct and our core values of transparency and accountability.

Vantage employees, suppliers, contractors, subcontractors and others with whom Vantage does business are prohibited from participation in any practice that constitutes human trafficking or slavery. This includes, but is not limited to:

1. Engaging or knowingly aiding and abetting in any form of trafficking in persons
2. Procuring commercial sexual acts during working hours, while traveling on business, while attending off-site working functions, or in any situation in which the acts may be directly associated with Vantage
3. Using forced labor of any kind for any reason
4. Destroying, concealing, confiscating or otherwise denying an individual access to the individual’s identification or immigration documents
5. Using fraudulent practices to recruit candidates for employment or contract positions such as failing to disclose basic information about important terms and conditions of the position, such as wages, fringe benefits, workplace location, living and working conditions, or any significant costs to be charged to or born by the candidate
6. Using recruiters that do not comply with local labor laws of the county in which the recruiting takes place
7. Charging applicants candidate recruitment fees
8. If required by law or contract, failing to provide or pay for return transportation at the end of employment
9. If required by law or contract, failing to provide or arrange for housing that meets the housing and safety standards of the host country
10. If required by law or contract, failing to provide an employment contract, recruitment agreement or other required document in writing
11. If required by law or contract, failing to provide legally required and/or mutually agreed compensation and welfare
12. Providing accommodations and/or employment for unauthorized entrants to the jurisdiction

Policy Implementation

Risk Assessment
The modern slavery and human trafficking risks of each third party engagement are routinely evaluated as part of our Third Party Risk Management program and mitigations put in place on a case by case basis. Periodically, Vantage conducts risk assessments to identify areas where our business and supply chain may be vulnerable to human trafficking and slavery.

Supplier Due Diligence
All suppliers are required to adhere to the Vantage Supplier Code of Conduct, which prohibits any practice that would constitute human trafficking or slavery. Before the engagement, due diligence is conducted to identify and address human trafficking and slavery risks of all high risk suppliers.

Employee Training
All employees are trained on the requirements of the Vantage Code of Conduct. Employees responsible for procurement of materials, services and products are given additional training to enable the completion of risk assessments, due diligence activities and the identification of red flags.

Reporting
Employees and suppliers are required to report any violation or suspected violation of law or the Code of Conduct, which prohibit human trafficking and slavery. Such reports can be made to manager, contract manager or relationship manager, Human Resources, Corporate Compliance or the Vantage Whistleblower Hotline.

Monitoring and Enforcement
Vantage will conduct audits and perform investigation to verify compliance with this policy. All employees and third parties are required to cooperate fully with any such audit or investigation. Failure to participate, cooperate, or any actions taken to hinder an audit or investigation will result in the termination of employment or the third-party relationship.

Board Approval
This statement was approved by the Board of Directors of Vantage Data Centers UK Limited on 5 July 2023.