Code of Business Conduct - English Language Version.pdf
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CONFIDENTIALITY NOTICE: This document is intended only for the use of the recipients to which Equinix sends it.
EQUINIX CODE OF
BUSINESS CONDUCT
Code of Business Conduct 1
EQUINIX CODE OF
BUSINESS CONDUCT
Code of Business Conduct 1
®
Code of Business Conduct 2
3 OUR MESSAGE
From Adaire Fox-Martin and Charles
Meyers
4 OUR PURPOSE AND VALUES
5 OUR CODE
Why We Have a Code of
Business Conduct
Who is Required to Follow Our Code?
Ethics in Action: What Our Code Means
for You
6 OUR PEOPLE
Dignity and Respect
Diversity
Safety
7 OUR BUSINESS RELATIONSHIPS
Conflicts of Interest
Gifts and Entertainment
Prohibited Payments and Gifts to
Government Personnel
Protecting Our Reputation and Property
Speaking on Behalf of Our Company
13 OUR COMMITMENT TO THE LAW
Competition and Fair Dealing
Data Privacy
Anti-bribery and Corruption
Intellectual Property
Inside Information and Securities Trading
16 OUR COMMUNITY
Human Rights
Charitable Contributions
Political Activities and Contributions
The Environment
18 OUR RESPONSIBILITY
Your Voice Matters
Ways to Speak Up
Whistleblower Protection Policy
Code of Business Conduct Waivers
20 ADDITIONAL RESOURCES
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 2
3 OUR MESSAGE
From Adaire Fox-Martin and Charles
Meyers
4 OUR PURPOSE AND VALUES
5 OUR CODE
Why We Have a Code of
Business Conduct
Who is Required to Follow Our Code?
Ethics in Action: What Our Code Means
for You
6 OUR PEOPLE
Dignity and Respect
Diversity
Safety
7 OUR BUSINESS RELATIONSHIPS
Conflicts of Interest
Gifts and Entertainment
Prohibited Payments and Gifts to
Government Personnel
Protecting Our Reputation and Property
Speaking on Behalf of Our Company
13 OUR COMMITMENT TO THE LAW
Competition and Fair Dealing
Data Privacy
Anti-bribery and Corruption
Intellectual Property
Inside Information and Securities Trading
16 OUR COMMUNITY
Human Rights
Charitable Contributions
Political Activities and Contributions
The Environment
18 OUR RESPONSIBILITY
Your Voice Matters
Ways to Speak Up
Whistleblower Protection Policy
Code of Business Conduct Waivers
20 ADDITIONAL RESOURCES
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 3
Adaire Fox-Martin
Chief Executive Officer and President
OUR MESSAGE
From Adaire Fox-Martin and Charles Meyers
Dear Colleagues,
At Equinix, we are incredibly proud of the successful organization we have built together. And as a global, industry-
leading company, we have the opportunity and responsibility to set the standard for ethical business practices, which
lets our customers and partners know they can trust our company and the products and services we deliver. As such,
our ethical reputation is one of our strongest differentiators and one we all need to support.
Our Code of Business Conduct reflects the ethical values and standards foundational to Equinix. It provides us with the
information, resources, and tools we need to create clear, consistent global standards for ethical business conduct and
compliance with laws. Please take the time to learn our Code and use it to guide our efforts on behalf of the company.
It is designed to help us make the right choices when encountering challenging ethical situations.
As Equinix employees, we all have the right and the responsibility to protect our Company culture from any conduct
that threatens our values or harms our reputation. If you ever have questions or concerns that our Code of Business
Conduct is being violated, please speak up. You are encouraged to talk with your manager, Equinix’s chief compliance
officer, the global general counsel, or the Chief HR officer. You may also report anonymously using our online ethics
form or multilingual phone service.
Our adherence to the highest ethical standards reflects the caliber of our people and the strength of our culture. Our
people and our culture have made Equinix the leader it is today - and they will be the foundation on which we build our
continued success.
Charles Meyers
Executive Chairman
Code of Business Conduct 3
Adaire Fox-Martin
Chief Executive Officer and President
OUR MESSAGE
From Adaire Fox-Martin and Charles Meyers
Dear Colleagues,
At Equinix, we are incredibly proud of the successful organization we have built together. And as a global, industry-
leading company, we have the opportunity and responsibility to set the standard for ethical business practices, which
lets our customers and partners know they can trust our company and the products and services we deliver. As such,
our ethical reputation is one of our strongest differentiators and one we all need to support.
Our Code of Business Conduct reflects the ethical values and standards foundational to Equinix. It provides us with the
information, resources, and tools we need to create clear, consistent global standards for ethical business conduct and
compliance with laws. Please take the time to learn our Code and use it to guide our efforts on behalf of the company.
It is designed to help us make the right choices when encountering challenging ethical situations.
As Equinix employees, we all have the right and the responsibility to protect our Company culture from any conduct
that threatens our values or harms our reputation. If you ever have questions or concerns that our Code of Business
Conduct is being violated, please speak up. You are encouraged to talk with your manager, Equinix’s chief compliance
officer, the global general counsel, or the Chief HR officer. You may also report anonymously using our online ethics
form or multilingual phone service.
Our adherence to the highest ethical standards reflects the caliber of our people and the strength of our culture. Our
people and our culture have made Equinix the leader it is today - and they will be the foundation on which we build our
continued success.
Charles Meyers
Executive Chairman
®
Code of Business Conduct 4
OUR PURPOSE, DREAM AND VALUES
The Equinix Promise
OUR PURPOSE
To be the platform where the world
comes together, enabling the
innovations that enrich our work, life and
planet.
OUR VALUES
• Customers count on us to deliver on
our commitments.
• Equinix is all about dedicated people
holding each other accountable for
superior execution.
• We value a culture of disciplined thought
and action.
• At Equinix, we set high standards
of excellence.
• Our passion to create an enduring great
company is priority number one.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 4
OUR PURPOSE, DREAM AND VALUES
The Equinix Promise
OUR PURPOSE
To be the platform where the world
comes together, enabling the
innovations that enrich our work, life and
planet.
OUR VALUES
• Customers count on us to deliver on
our commitments.
• Equinix is all about dedicated people
holding each other accountable for
superior execution.
• We value a culture of disciplined thought
and action.
• At Equinix, we set high standards
of excellence.
• Our passion to create an enduring great
company is priority number one.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 5
OUR CODE
Understanding and embracing ethical behavior
WHY WE HAVE A CODE OF BUSINESS
CONDUCT
Equinix is built on a foundation of strong
corporate values and business practices,
and we know that our continued success
depends on our commitment to doing business
with honesty, integrity, professionalism and
commitment to superior results. That means as
a company we value:
• Every employee
• Doing the right things for the right reasons
• Uncompromising integrity
• A commitment to ethical business practices
• Compliance with the law
In most situations, our personal values and
honesty will guide us to the right and ethical
decision. But if we have questions about the
right actions to take, our Code of Business
Conduct (our “Code”) is there to give us
additional guidance. We should also remember
that not every situation can be addressed in
our Code. In those situations, you should talk
with your manager or the Compliance Office.
WHO IS REQUIRED TO FOLLOW
OUR CODE?
Our Code applies to every Equinix officer,
director and employee, including part-time
and temporary employees. Our Code should
also be provided to and followed by those
acting on Equinix’s behalf, such as agents,
representatives and consultants.
ETHICS IN ACTION: WHAT OUR CODE
MEANS FOR YOU
We are all expected to comply with both the
letter and the spirit of our Code. This means
you must understand and comply with all of
our policies, laws and regulations that apply
to your job and seek guidance if you have
questions or concerns. Employees who violate
our Code put themselves, fellow employees
and our Company at risk and are subject
to disciplinary action up to and including
termination of employment.
Employees who supervise others have an
especially important responsibility to lead by
example and maintain the highest standards of
behavior. If you supervise others, you should
promote an environment where employees
understand their responsibilities and feel
comfortable raising issues and concerns
without fear of retaliation. If an issue is raised,
you must take prompt action.
You must also make sure that each employee
under your supervision understands our
Code and the policies, laws and regulations
that affect our workplace. Our Code may
complement other policies, procedures and
practices. If you or anyone on your team
encounters an inconsistency or conflict, bring it
to the attention of both your manager and the
Compliance Office.
We are ALL expected
to comply with both the
letter and the spirit of
our Code.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 5
OUR CODE
Understanding and embracing ethical behavior
WHY WE HAVE A CODE OF BUSINESS
CONDUCT
Equinix is built on a foundation of strong
corporate values and business practices,
and we know that our continued success
depends on our commitment to doing business
with honesty, integrity, professionalism and
commitment to superior results. That means as
a company we value:
• Every employee
• Doing the right things for the right reasons
• Uncompromising integrity
• A commitment to ethical business practices
• Compliance with the law
In most situations, our personal values and
honesty will guide us to the right and ethical
decision. But if we have questions about the
right actions to take, our Code of Business
Conduct (our “Code”) is there to give us
additional guidance. We should also remember
that not every situation can be addressed in
our Code. In those situations, you should talk
with your manager or the Compliance Office.
WHO IS REQUIRED TO FOLLOW
OUR CODE?
Our Code applies to every Equinix officer,
director and employee, including part-time
and temporary employees. Our Code should
also be provided to and followed by those
acting on Equinix’s behalf, such as agents,
representatives and consultants.
ETHICS IN ACTION: WHAT OUR CODE
MEANS FOR YOU
We are all expected to comply with both the
letter and the spirit of our Code. This means
you must understand and comply with all of
our policies, laws and regulations that apply
to your job and seek guidance if you have
questions or concerns. Employees who violate
our Code put themselves, fellow employees
and our Company at risk and are subject
to disciplinary action up to and including
termination of employment.
Employees who supervise others have an
especially important responsibility to lead by
example and maintain the highest standards of
behavior. If you supervise others, you should
promote an environment where employees
understand their responsibilities and feel
comfortable raising issues and concerns
without fear of retaliation. If an issue is raised,
you must take prompt action.
You must also make sure that each employee
under your supervision understands our
Code and the policies, laws and regulations
that affect our workplace. Our Code may
complement other policies, procedures and
practices. If you or anyone on your team
encounters an inconsistency or conflict, bring it
to the attention of both your manager and the
Compliance Office.
We are ALL expected
to comply with both the
letter and the spirit of
our Code.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 6
OUR PEOPLE
Working together as one
DIGNITY AND RESPECT
Our employees are the foundation of our
Company. We all have a responsibility to
each other to ensure a work environment built
on honesty, integrity and mutual respect. We
do not tolerate any form of discrimination,
harassment or demeaning behavior against
any individual or group on the basis of race,
religion, sex, sexual orientation, gender
identification, national origin, age, marital
status, covered veteran status, disability,
pregnancy or any other basis prohibited by
applicable law. If you see or suspect any
violation or feel you are a victim
of harassment or discrimination, promptly
report it to the Human Resources
Department. Reporting options can be found
in the Additional Resources section.
DIVERSITY
Having a diverse workforce–made up of team
members who bring a wide variety of skills,
abilities, experiences and perspectives–is
essential to our success. Always take full
advantage of what our team members
have to offer. Listen and be inclusive. We
are dedicated to the principles of equal
employment opportunity, inclusion
and respect.
SAFETY
We are committed to providing a pleasant,
productive and secure work environment
for all of our employees. We adhere to the
highest environmental, health and safety
standards in our workplace and rely on
everyone to report accidents, injuries and
unsafe equipment, practices or conditions.
To further ensure a safe workplace,
violence and threatening behavior are never
permitted.
We insist on maintaining a drug-free
workplace where all employees must work
free from the adverse effects of drugs,
alcohol or other controlled substances. At the
same time, we recognize that employees who
suffer from drug and alcohol dependence can
be treated, and we encourage employees to
seek professional care and counseling
before they violate Equinix’s drug and
alcohol policies. For further guidance on a
healthy and safe workplace, please refer
to our Global Employee Handbooks.
Working together, we create a safe,
diverse work environment built on:
• Honesty
• Integrity
• Self-respect
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 6
OUR PEOPLE
Working together as one
DIGNITY AND RESPECT
Our employees are the foundation of our
Company. We all have a responsibility to
each other to ensure a work environment built
on honesty, integrity and mutual respect. We
do not tolerate any form of discrimination,
harassment or demeaning behavior against
any individual or group on the basis of race,
religion, sex, sexual orientation, gender
identification, national origin, age, marital
status, covered veteran status, disability,
pregnancy or any other basis prohibited by
applicable law. If you see or suspect any
violation or feel you are a victim
of harassment or discrimination, promptly
report it to the Human Resources
Department. Reporting options can be found
in the Additional Resources section.
DIVERSITY
Having a diverse workforce–made up of team
members who bring a wide variety of skills,
abilities, experiences and perspectives–is
essential to our success. Always take full
advantage of what our team members
have to offer. Listen and be inclusive. We
are dedicated to the principles of equal
employment opportunity, inclusion
and respect.
SAFETY
We are committed to providing a pleasant,
productive and secure work environment
for all of our employees. We adhere to the
highest environmental, health and safety
standards in our workplace and rely on
everyone to report accidents, injuries and
unsafe equipment, practices or conditions.
To further ensure a safe workplace,
violence and threatening behavior are never
permitted.
We insist on maintaining a drug-free
workplace where all employees must work
free from the adverse effects of drugs,
alcohol or other controlled substances. At the
same time, we recognize that employees who
suffer from drug and alcohol dependence can
be treated, and we encourage employees to
seek professional care and counseling
before they violate Equinix’s drug and
alcohol policies. For further guidance on a
healthy and safe workplace, please refer
to our Global Employee Handbooks.
Working together, we create a safe,
diverse work environment built on:
• Honesty
• Integrity
• Self-respect
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 7
OUR BUSINESS RELATIONSHIPS
Fostering fair, honest business relationships and protecting our Company’s interests
CONFLICTS OF INTEREST
Each of us has an obligation to do what
is right for Equinix. This means avoiding
situations that create–or even appear to
create–a conflict between our own personal
interests and the Company’s interests. A
conflict of interest is anything that impedes
objectivity or effectiveness in our job
performance or decisions we make on behalf
of Equinix. Transparency is essential to
avoiding conflicts of interest.
Conflict of Interest:
Anything that impedes
objectivity or effectiveness
in our job performance
or decisions we make on
behalf of Equinix
It’s impossible to list all the ways that a
potential conflict of interest could arise, but
there are certain situations where conflicts are
more likely to occur. Below we describe a few
ways you may encounter a conflict of interest.
It’s important that you are able to recognize a
potential conflict and take appropriate action.
If you have any questions about possible
conflicts, please talk with your manager
or contact the Compliance Office before
engaging in the activity or as soon as it comes
to your attention that a conflict may exist.
Doing business with friends and family
can create a conflict of interest. Conflict of
interest guidelines are not meant to interfere
with our families or personal lives, but there
are a few situations where the actions of
close friends and family members could
create concerns. For example, if you have a
spouse, relative or close friend who works for
a company that provides goods or services
to Equinix, you must make sure that you
do not use your position to influence the
bidding process or other negotiations. If you
are directly involved in purchasing functions,
you should make your manager aware of the
situation and discuss any potential problems.
You should also make your manager aware
of any relatives or close friends who work
for competitors.
Be careful if you are doing work for other
companies. Working as a director, officer,
consultant or employee of any organization
that supplies goods or services to Equinix,
purchases goods or services from Equinix, or
competes with Equinix can present a conflict.
You are not allowed to work for a competitor in
any capacity.
Starting your own part-time business or taking
on additional part-time work with an outside
organization that has no association with
Equinix does not necessarily create a conflict
of interest. However, it’s important to talk with
your manager to make sure there is no conflict
and that the second job does not interfere with
your time and responsibilities at Equinix.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 7
OUR BUSINESS RELATIONSHIPS
Fostering fair, honest business relationships and protecting our Company’s interests
CONFLICTS OF INTEREST
Each of us has an obligation to do what
is right for Equinix. This means avoiding
situations that create–or even appear to
create–a conflict between our own personal
interests and the Company’s interests. A
conflict of interest is anything that impedes
objectivity or effectiveness in our job
performance or decisions we make on behalf
of Equinix. Transparency is essential to
avoiding conflicts of interest.
Conflict of Interest:
Anything that impedes
objectivity or effectiveness
in our job performance
or decisions we make on
behalf of Equinix
It’s impossible to list all the ways that a
potential conflict of interest could arise, but
there are certain situations where conflicts are
more likely to occur. Below we describe a few
ways you may encounter a conflict of interest.
It’s important that you are able to recognize a
potential conflict and take appropriate action.
If you have any questions about possible
conflicts, please talk with your manager
or contact the Compliance Office before
engaging in the activity or as soon as it comes
to your attention that a conflict may exist.
Doing business with friends and family
can create a conflict of interest. Conflict of
interest guidelines are not meant to interfere
with our families or personal lives, but there
are a few situations where the actions of
close friends and family members could
create concerns. For example, if you have a
spouse, relative or close friend who works for
a company that provides goods or services
to Equinix, you must make sure that you
do not use your position to influence the
bidding process or other negotiations. If you
are directly involved in purchasing functions,
you should make your manager aware of the
situation and discuss any potential problems.
You should also make your manager aware
of any relatives or close friends who work
for competitors.
Be careful if you are doing work for other
companies. Working as a director, officer,
consultant or employee of any organization
that supplies goods or services to Equinix,
purchases goods or services from Equinix, or
competes with Equinix can present a conflict.
You are not allowed to work for a competitor in
any capacity.
Starting your own part-time business or taking
on additional part-time work with an outside
organization that has no association with
Equinix does not necessarily create a conflict
of interest. However, it’s important to talk with
your manager to make sure there is no conflict
and that the second job does not interfere with
your time and responsibilities at Equinix.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 8
Investing in companies that compete or
work with Equinix can be a conflict of
interest. Having a material financial interest in
a customer, supplier, developer or competitor
of Equinix may create a conflict of interest. In
deciding whether to make such an investment,
you should consider the size and nature
of the investment, your ability to influence
decisions of Equinix or of the other company,
your access to confidential information about
Equinix or the other company, and the nature
of the relationship between Equinix and the
other company.
You may not use your position with
Equinix for personal gain. Any opportunities
that you become aware of while using
Company property information, or as a result
of your position, belong to Equinix. You may
not use confidential or proprietary information
or processes you learned of through your
position with Equinix for personal gain or
to Equinix’s detriment, including consulting
engagements with hedge funds and other
investment professionals.
GIFTS AND ENTERTAINMENT
In many places and cultures, giving and
receiving gifts is an important part of doing
business and can serve legitimate business
purposes. At Equinix, we believe the purpose
of business entertainment and gifts in a
commercial setting is to create goodwill and
sound working relationships, not to gain an
unfair advantage with customers or vendors.
Equinix employees are prohibited from giving,
offering or receiving any gift or entertainment–
either directly or indirectly–that may appear to
influence a business decision or compromise
independent judgment. We are all expected
to use good judgment and moderation when
giving or receiving gifts or entertainment.
You should never offer or provide any gift or
entertainment unless it:
• Is reasonable and not extravagant
• Is appropriate under the circumstances
and serves a valid business purpose
• Is customary and appropriate under U.S.
and local customs
• Is not being offered for any improper
purpose and could not be construed as a
bribe or payoff
• Does not violate any Equinix policy
• Does not violate any U.S., local or
international laws or regulations
• Is accurately described in Equinix’s books
and records
What is a “gift?” A gift is anything of value.
It includes tangible items, such as cash
and art, as well as intangible items, such as
discounts, favors, loans and advantages that
are not available to the general public. A gift
also includes meals, entertainment, trips and
tickets to cultural and sporting events, as well
as any other merchandise or services.
In some cultures, it may be customary to
give gifts of cash in nominal amounts as
a business courtesy or on local holidays.
Decisions about these situations must be
carefully weighed and prior written approval
must be obtained from your manager, after
consultation with the chief legal officer or
compliance officer, before proceeding.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 8
Investing in companies that compete or
work with Equinix can be a conflict of
interest. Having a material financial interest in
a customer, supplier, developer or competitor
of Equinix may create a conflict of interest. In
deciding whether to make such an investment,
you should consider the size and nature
of the investment, your ability to influence
decisions of Equinix or of the other company,
your access to confidential information about
Equinix or the other company, and the nature
of the relationship between Equinix and the
other company.
You may not use your position with
Equinix for personal gain. Any opportunities
that you become aware of while using
Company property information, or as a result
of your position, belong to Equinix. You may
not use confidential or proprietary information
or processes you learned of through your
position with Equinix for personal gain or
to Equinix’s detriment, including consulting
engagements with hedge funds and other
investment professionals.
GIFTS AND ENTERTAINMENT
In many places and cultures, giving and
receiving gifts is an important part of doing
business and can serve legitimate business
purposes. At Equinix, we believe the purpose
of business entertainment and gifts in a
commercial setting is to create goodwill and
sound working relationships, not to gain an
unfair advantage with customers or vendors.
Equinix employees are prohibited from giving,
offering or receiving any gift or entertainment–
either directly or indirectly–that may appear to
influence a business decision or compromise
independent judgment. We are all expected
to use good judgment and moderation when
giving or receiving gifts or entertainment.
You should never offer or provide any gift or
entertainment unless it:
• Is reasonable and not extravagant
• Is appropriate under the circumstances
and serves a valid business purpose
• Is customary and appropriate under U.S.
and local customs
• Is not being offered for any improper
purpose and could not be construed as a
bribe or payoff
• Does not violate any Equinix policy
• Does not violate any U.S., local or
international laws or regulations
• Is accurately described in Equinix’s books
and records
What is a “gift?” A gift is anything of value.
It includes tangible items, such as cash
and art, as well as intangible items, such as
discounts, favors, loans and advantages that
are not available to the general public. A gift
also includes meals, entertainment, trips and
tickets to cultural and sporting events, as well
as any other merchandise or services.
In some cultures, it may be customary to
give gifts of cash in nominal amounts as
a business courtesy or on local holidays.
Decisions about these situations must be
carefully weighed and prior written approval
must be obtained from your manager, after
consultation with the chief legal officer or
compliance officer, before proceeding.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 9
Equinix’s gift and
entertainment guidelines
apply at all times and
in all circumstances–
there are no exceptions
for holidays or
Company events.
Reporting gifts and entertainment. It
is important that you accurately report
expenditures for gifts or entertainment, so the
purpose, amount and recipient of the gift or
entertainment are obvious (i.e., transparent)
to finance and other personnel who may
review our books and records. Your expense
report should accurately state the purpose
of the expenditures and the identities of the
individuals receiving the gift or entertainment
and state whether the gift or entertainment
was given to a public sector official or to any
employee of a government entity.
PROHIBITED PAYMENTS AND GIFTS
TO GOVERNMENT PERSONNEL
Almost every country in the world has laws
that prohibit payment of bribes to government
officials in exchange for government action,
services or other advantages. We support and
comply with anti-bribery laws, because they
are designed to protect companies like ours
that seek to compete based upon the quality
of our products and services, rather than on
favors granted in exchange for bribes.
In addition to country-specific laws, because
we are a company based in the United
States, all Equinix employees, officers and
directors are obligated to comply with the U.S.
Foreign Corrupt Practices Act, which strictly
prohibits the payment of bribes to government
officials or employees of a government entity
anywhere in the world. These laws also place
significant legal restrictions on providing
gifts, entertainment, travel and promotional
expenditures related to government officials.
Please see Our Commitment to the Law
section for more information about
complying with anti-bribery and
corruption laws and our rules regarding
gifts and entertainment for government
officials.
PROTECTING OUR REPUTATION
AND PROPERTY
Equinix is committed to providing you with
the tools and information you need to do
your job effectively and successfully. In
return, the Company trusts you to use good
judgment to protect and conserve these
valuable Company resources and to use them
only for legitimate Company business. Your
responsibility for Equinix property includes
Company records and information, intellectual
property such as copyrighted materials, and
electronic and physical assets.
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Equinix’s gift and
entertainment guidelines
apply at all times and
in all circumstances–
there are no exceptions
for holidays or
Company events.
Reporting gifts and entertainment. It
is important that you accurately report
expenditures for gifts or entertainment, so the
purpose, amount and recipient of the gift or
entertainment are obvious (i.e., transparent)
to finance and other personnel who may
review our books and records. Your expense
report should accurately state the purpose
of the expenditures and the identities of the
individuals receiving the gift or entertainment
and state whether the gift or entertainment
was given to a public sector official or to any
employee of a government entity.
PROHIBITED PAYMENTS AND GIFTS
TO GOVERNMENT PERSONNEL
Almost every country in the world has laws
that prohibit payment of bribes to government
officials in exchange for government action,
services or other advantages. We support and
comply with anti-bribery laws, because they
are designed to protect companies like ours
that seek to compete based upon the quality
of our products and services, rather than on
favors granted in exchange for bribes.
In addition to country-specific laws, because
we are a company based in the United
States, all Equinix employees, officers and
directors are obligated to comply with the U.S.
Foreign Corrupt Practices Act, which strictly
prohibits the payment of bribes to government
officials or employees of a government entity
anywhere in the world. These laws also place
significant legal restrictions on providing
gifts, entertainment, travel and promotional
expenditures related to government officials.
Please see Our Commitment to the Law
section for more information about
complying with anti-bribery and
corruption laws and our rules regarding
gifts and entertainment for government
officials.
PROTECTING OUR REPUTATION
AND PROPERTY
Equinix is committed to providing you with
the tools and information you need to do
your job effectively and successfully. In
return, the Company trusts you to use good
judgment to protect and conserve these
valuable Company resources and to use them
only for legitimate Company business. Your
responsibility for Equinix property includes
Company records and information, intellectual
property such as copyrighted materials, and
electronic and physical assets.
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Confidential information. Maintaining
the confidentiality and integrity of Equinix
information is critically important to our
success. Confidential information is
information that you may become aware of as
part of your job, including everything you know
about Equinix, our customers, our vendors
and other third parties that is not available to
the public.
Confidential
information is one of our
most valuable assets. It is
essential to our success.
You are responsible for
keeping it safe, protected
and private.
To protect our confidential information, we
should never:
• Share information with any third party that
does not need to know the information to
perform their assigned work
• Share information with any person or
organization that is not bound by a non-
disclosure agreement, unless
specifically authorized by management–
this includes friends, family members
and other contacts
• Disclose information in any public
chat room, social media website or to
any member of the press–this includes
confirming or denying facts–or even
providing hints about the validity of
specific information
• Discuss confidential information in public
spaces, such as airports, restaurants
or elevators
Our technology and innovation are hallmarks
of our success. You have a responsibility
to protect our trade secrets and proprietary
information while you work at Equinix and
even after you leave the Company.
Records and record-keeping. Our records
are our corporate memory. These records
provide evidence of actions and decisions.
They contain information and data that are
critical to the success and continuity of our
business and they enable us to meet our legal
and regulatory obligations. Records consist of
all forms of information we create or receive
that contain information about our Company
or our business activities. Examples of
Company records include paper documents,
email and electronic files that are stored on
disk, tape or any other medium.
We have a responsibility to be honest and
accurate in what we report and record in all
Equinix documents, including accounting
records, time cards, expense reports, safety
records, business records, etc. If you see or
suspect misconduct in our financial records,
notify your manager and contact
the Compliance Office.
All records are the property of Equinix and
should be managed in accordance with our
Global Record Management Policy to ensure
we are all following the same approved
processes for retaining, storing and destroying
our Company records. From time to time,
the legal team may ask employees to retain
certain records for specific legal purposes. It is
important to follow these instructions carefully
to avoid legal implications.
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Confidential information. Maintaining
the confidentiality and integrity of Equinix
information is critically important to our
success. Confidential information is
information that you may become aware of as
part of your job, including everything you know
about Equinix, our customers, our vendors
and other third parties that is not available to
the public.
Confidential
information is one of our
most valuable assets. It is
essential to our success.
You are responsible for
keeping it safe, protected
and private.
To protect our confidential information, we
should never:
• Share information with any third party that
does not need to know the information to
perform their assigned work
• Share information with any person or
organization that is not bound by a non-
disclosure agreement, unless
specifically authorized by management–
this includes friends, family members
and other contacts
• Disclose information in any public
chat room, social media website or to
any member of the press–this includes
confirming or denying facts–or even
providing hints about the validity of
specific information
• Discuss confidential information in public
spaces, such as airports, restaurants
or elevators
Our technology and innovation are hallmarks
of our success. You have a responsibility
to protect our trade secrets and proprietary
information while you work at Equinix and
even after you leave the Company.
Records and record-keeping. Our records
are our corporate memory. These records
provide evidence of actions and decisions.
They contain information and data that are
critical to the success and continuity of our
business and they enable us to meet our legal
and regulatory obligations. Records consist of
all forms of information we create or receive
that contain information about our Company
or our business activities. Examples of
Company records include paper documents,
email and electronic files that are stored on
disk, tape or any other medium.
We have a responsibility to be honest and
accurate in what we report and record in all
Equinix documents, including accounting
records, time cards, expense reports, safety
records, business records, etc. If you see or
suspect misconduct in our financial records,
notify your manager and contact
the Compliance Office.
All records are the property of Equinix and
should be managed in accordance with our
Global Record Management Policy to ensure
we are all following the same approved
processes for retaining, storing and destroying
our Company records. From time to time,
the legal team may ask employees to retain
certain records for specific legal purposes. It is
important to follow these instructions carefully
to avoid legal implications.
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Physical and electronic assets. As an
Equinix employee, we have been entrusted
with a variety of physical assets–from basic
office supplies to computers–and we have
a responsibility to protect all of them. This
includes taking reasonable precautions
against theft, carelessness and unnecessary
waste. It also means only using Equinix
supplies and equipment for legitimate
business purposes.
Equinix also provides us with information
and technology resources to help us perform
our jobs effectively. These electronic assets
include email, networks, the Internet, our
internal intranet, cell phones, other wireless
communication devices, telephones and
voicemail systems. These are Company tools
and should only be used in a manner that
reflects positively on Equinix and all who work
here. Anything sent, received, downloaded
or stored on Company assets is owned by
Equinix. This means that Equinix may review
your records or Equinix equipment at any time
as permitted under applicable privacy laws.
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Physical and electronic assets. As an
Equinix employee, we have been entrusted
with a variety of physical assets–from basic
office supplies to computers–and we have
a responsibility to protect all of them. This
includes taking reasonable precautions
against theft, carelessness and unnecessary
waste. It also means only using Equinix
supplies and equipment for legitimate
business purposes.
Equinix also provides us with information
and technology resources to help us perform
our jobs effectively. These electronic assets
include email, networks, the Internet, our
internal intranet, cell phones, other wireless
communication devices, telephones and
voicemail systems. These are Company tools
and should only be used in a manner that
reflects positively on Equinix and all who work
here. Anything sent, received, downloaded
or stored on Company assets is owned by
Equinix. This means that Equinix may review
your records or Equinix equipment at any time
as permitted under applicable privacy laws.
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SPEAKING ON BEHALF OF
OUR COMPANY
Providing information to the public that is
complete, consistent and accurate is crucial
to maintaining our reputation. It is also a
requirement for complying with regulatory
and legal obligations. Unless you have been
authorized to do so, do not speak on behalf of
the Company. Instead, refer the individual to
Equinix’s Corporate Communications team.
Remember: Always
be professional and
courteous in all of your
emails, instant messages
and other electronic
communications.
Use social media responsibly. Equinix
embraces social media as a powerful
collaboration tool, and we respect your right
to use online tools on your personal time
using your personal computer. However, when
social media impacts your job performance
or Equinix’s business interests–in either a
business or personal context–it becomes
a proper focus for Company policy. We
must always use online tools in a way that
is consistent with our Company policies
and remember our obligation to protect our
confidential information and the confidential
information of the companies with which we
do business. We should also be careful to
respect and obey all copyright, trademark, fair
use, privacy, financial disclosure and all other
laws.
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SPEAKING ON BEHALF OF
OUR COMPANY
Providing information to the public that is
complete, consistent and accurate is crucial
to maintaining our reputation. It is also a
requirement for complying with regulatory
and legal obligations. Unless you have been
authorized to do so, do not speak on behalf of
the Company. Instead, refer the individual to
Equinix’s Corporate Communications team.
Remember: Always
be professional and
courteous in all of your
emails, instant messages
and other electronic
communications.
Use social media responsibly. Equinix
embraces social media as a powerful
collaboration tool, and we respect your right
to use online tools on your personal time
using your personal computer. However, when
social media impacts your job performance
or Equinix’s business interests–in either a
business or personal context–it becomes
a proper focus for Company policy. We
must always use online tools in a way that
is consistent with our Company policies
and remember our obligation to protect our
confidential information and the confidential
information of the companies with which we
do business. We should also be careful to
respect and obey all copyright, trademark, fair
use, privacy, financial disclosure and all other
laws.
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OUR COMMITMENT TO THE LAW
Understanding and adhering to lawful business practices
Being an ethical and honest company also
means obeying the law. As a global company,
we must comply with the laws in all the places
we do business. And as Equinix employees,
we are responsible for understanding and
complying with all laws and regulations that
affect our jobs.
COMPETITION AND FAIR DEALING
At Equinix, we value a free and open
marketplace and seek to outperform our
competition fairly and honestly. We do not
seek to obtain the proprietary information of
others, possess trade secret information that
was obtained without the owner’s consent,
or ask past or present employees of other
companies to share another company’s
proprietary information with us.
We are committed to dealing fairly and
honestly with all of our vendors, regardless of
where they’re located or the type of products
or services they provide. We engage in open
and fair procurement, where vendors are
selected on a competitive basis and establish
a mutually beneficial relationship based on
close cooperation and open communications.
Remember: Always
respect and protect
confidential or
proprietary information
our vendors share with
you–and let them know
we expect them to use
the same care with our
information.
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OUR COMMITMENT TO THE LAW
Understanding and adhering to lawful business practices
Being an ethical and honest company also
means obeying the law. As a global company,
we must comply with the laws in all the places
we do business. And as Equinix employees,
we are responsible for understanding and
complying with all laws and regulations that
affect our jobs.
COMPETITION AND FAIR DEALING
At Equinix, we value a free and open
marketplace and seek to outperform our
competition fairly and honestly. We do not
seek to obtain the proprietary information of
others, possess trade secret information that
was obtained without the owner’s consent,
or ask past or present employees of other
companies to share another company’s
proprietary information with us.
We are committed to dealing fairly and
honestly with all of our vendors, regardless of
where they’re located or the type of products
or services they provide. We engage in open
and fair procurement, where vendors are
selected on a competitive basis and establish
a mutually beneficial relationship based on
close cooperation and open communications.
Remember: Always
respect and protect
confidential or
proprietary information
our vendors share with
you–and let them know
we expect them to use
the same care with our
information.
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DATA PRIVACY
Data privacy laws and regulations can
be complex, and they vary from country
to country. At Equinix, we respect the
confidentiality of the personal information
of our employees and work to keep that
information private and only use that personal
information in a reasonable and appropriate
way for the purposes of your employment with
Equinix. You are expected to follow all
Company policies regarding the handling and
retention of this personal information. If you
have questions about data privacy, you
should contact your local privacy officer.
ANTI-BRIBERY AND CORRUPTION
At Equinix, our business practices are based
on honesty and integrity. We do not offer or
provide bribes, kickbacks or other improper
payments for any reason.
As a global company, we must comply with
the anti-bribery and corruption laws in the
countries in which we do business, including
the U.S. Foreign Corrupt Practices Act (FCPA)
and the U.K. Bribery Act. These laws strictly
prohibit bribery and corruption, especially
when government officials are involved.
No Equinix employee, officer, agent or
independent contractor acting on our behalf
may offer or provide anything of value to
anyone in order to obtain business or gain an
unfair advantage. Violations can subject you
and Equinix to severe penalties and damage
our reputation.
The U.S. laws prohibiting bribery are very
broad, which means many kinds of gifts
or entertainment provided to government
employees might be considered improper. For
that reason, employees must not give, offer,
promise or authorize any payment, benefit or
gift of money or anything else of value to a
government or public official, except under the
very limited circumstances below. This rule
applies whether you are giving the gift or other
benefit yourself or through a third party, such
as a distributor or independent contractor.
This rule applies whether you are trying to
secure business or seeking an advantage
over others (such as special, preferential
treatment not offered to competitors). Any gift
or entertainment offered to a government or
public official must meet these specific criteria:
• Any entertainment must be reasonable,
bona fide and directly related to the
promotion, demonstration or explanation
of products or services–or linked to the
performance of a contract between Equinix
and the government or public entity.
• All gifts and entertainment must comply
with all Equinix policies, including our
Travel and Expense Policy.
• No gift or entertainment should ever
be offered to a government employee
for the purpose of securing an improper
business advantage.
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DATA PRIVACY
Data privacy laws and regulations can
be complex, and they vary from country
to country. At Equinix, we respect the
confidentiality of the personal information
of our employees and work to keep that
information private and only use that personal
information in a reasonable and appropriate
way for the purposes of your employment with
Equinix. You are expected to follow all
Company policies regarding the handling and
retention of this personal information. If you
have questions about data privacy, you
should contact your local privacy officer.
ANTI-BRIBERY AND CORRUPTION
At Equinix, our business practices are based
on honesty and integrity. We do not offer or
provide bribes, kickbacks or other improper
payments for any reason.
As a global company, we must comply with
the anti-bribery and corruption laws in the
countries in which we do business, including
the U.S. Foreign Corrupt Practices Act (FCPA)
and the U.K. Bribery Act. These laws strictly
prohibit bribery and corruption, especially
when government officials are involved.
No Equinix employee, officer, agent or
independent contractor acting on our behalf
may offer or provide anything of value to
anyone in order to obtain business or gain an
unfair advantage. Violations can subject you
and Equinix to severe penalties and damage
our reputation.
The U.S. laws prohibiting bribery are very
broad, which means many kinds of gifts
or entertainment provided to government
employees might be considered improper. For
that reason, employees must not give, offer,
promise or authorize any payment, benefit or
gift of money or anything else of value to a
government or public official, except under the
very limited circumstances below. This rule
applies whether you are giving the gift or other
benefit yourself or through a third party, such
as a distributor or independent contractor.
This rule applies whether you are trying to
secure business or seeking an advantage
over others (such as special, preferential
treatment not offered to competitors). Any gift
or entertainment offered to a government or
public official must meet these specific criteria:
• Any entertainment must be reasonable,
bona fide and directly related to the
promotion, demonstration or explanation
of products or services–or linked to the
performance of a contract between Equinix
and the government or public entity.
• All gifts and entertainment must comply
with all Equinix policies, including our
Travel and Expense Policy.
• No gift or entertainment should ever
be offered to a government employee
for the purpose of securing an improper
business advantage.
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You must make sure that any gift you give
in connection with your job is transparent,
properly recorded in our corporate records
and permitted under our policy. When
reporting the gift, you must state the purpose
of the gift and the person to whom you gave
it. If the gift is for a government official, you
should always obtain advance approval from
the Compliance Office.
If you have any questions or need guidance
in this area, contact Equinix’s Compliance
Officer. If you are aware of a suspected or
actual violation of this policy, you have a
responsibility to report it promptly.
INTELLECTUAL PROPERTY
Intellectual property includes copyrights,
patents, trademarks, trade secrets and other
intangible property. We take active measures
to protect and enforce our own intellectual
property rights, and we must use similar
measures to protect the intellectual property
of third parties. When sharing our intellectual
property with third parties, we need to ensure
that they agree to use and protect our
property in accordance with our
Equinix policies.
Many of the materials you use every day
are protected by copyright laws, including
computer software, books, manuals, audio
and video resources, trade journals and
magazines. Other less obvious examples
of copyrightable works include presentation
slides, training materials, management
models and problem-solving methodologies.
We should never knowingly infringe upon the
intellectual property rights of others. Equinix
strictly forbids the reproduction, distribution or
alteration of any copyrighted materials without
the permission of the owner or authorized
agent. You should also make sure you never
illegally copy or use company-licensed
computer software for personal or business
use.
INSIDE INFORMATION AND
SECURITIES TRADING
You must not buy or sell Equinix stock if
you possess any “material information”
about the Company that has not been
publicly disclosed (also known as “inside
information”). Similarly, if you are aware of
inside information about other companies,
such as customers or vendors, you must not
buy or sell the securities of that company. If
you share inside information or provide insider
“tips” to a third party who then trades on that
information, you may be held responsible
for the illegal trade. You may also be liable
for trades made by someone else based on
confidential information you shared with an
Inside information is
confidential information
that if made public would
influence an investor’s
decision to buy, sell or
hold Equinix stock.
outside party–including family members and
friends. If you share inside information that
influences a family member or friend to buy or
sell Equinix stock, you may be criminally liable
as a “tipper” under federal securities laws.
Equinix considers it improper for those who
are employed by or associated with Equinix
to engage in short-term or speculative
transactions in Equinix’s securities or in other
transactions in Equinix’s securities that may
lead to inadvertent violations of the insider
trading laws. Accordingly, your trading in
Equinix securities is subject to the additional
guidelines as more fully described in the
Equinix Securities Trading Policy.
To make sure you are complying with laws
against insider trading, please refer to
Equinix’s Securities Trading Policy. If you
have any questions, you should contact the
Compliance Office.
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You must make sure that any gift you give
in connection with your job is transparent,
properly recorded in our corporate records
and permitted under our policy. When
reporting the gift, you must state the purpose
of the gift and the person to whom you gave
it. If the gift is for a government official, you
should always obtain advance approval from
the Compliance Office.
If you have any questions or need guidance
in this area, contact Equinix’s Compliance
Officer. If you are aware of a suspected or
actual violation of this policy, you have a
responsibility to report it promptly.
INTELLECTUAL PROPERTY
Intellectual property includes copyrights,
patents, trademarks, trade secrets and other
intangible property. We take active measures
to protect and enforce our own intellectual
property rights, and we must use similar
measures to protect the intellectual property
of third parties. When sharing our intellectual
property with third parties, we need to ensure
that they agree to use and protect our
property in accordance with our
Equinix policies.
Many of the materials you use every day
are protected by copyright laws, including
computer software, books, manuals, audio
and video resources, trade journals and
magazines. Other less obvious examples
of copyrightable works include presentation
slides, training materials, management
models and problem-solving methodologies.
We should never knowingly infringe upon the
intellectual property rights of others. Equinix
strictly forbids the reproduction, distribution or
alteration of any copyrighted materials without
the permission of the owner or authorized
agent. You should also make sure you never
illegally copy or use company-licensed
computer software for personal or business
use.
INSIDE INFORMATION AND
SECURITIES TRADING
You must not buy or sell Equinix stock if
you possess any “material information”
about the Company that has not been
publicly disclosed (also known as “inside
information”). Similarly, if you are aware of
inside information about other companies,
such as customers or vendors, you must not
buy or sell the securities of that company. If
you share inside information or provide insider
“tips” to a third party who then trades on that
information, you may be held responsible
for the illegal trade. You may also be liable
for trades made by someone else based on
confidential information you shared with an
Inside information is
confidential information
that if made public would
influence an investor’s
decision to buy, sell or
hold Equinix stock.
outside party–including family members and
friends. If you share inside information that
influences a family member or friend to buy or
sell Equinix stock, you may be criminally liable
as a “tipper” under federal securities laws.
Equinix considers it improper for those who
are employed by or associated with Equinix
to engage in short-term or speculative
transactions in Equinix’s securities or in other
transactions in Equinix’s securities that may
lead to inadvertent violations of the insider
trading laws. Accordingly, your trading in
Equinix securities is subject to the additional
guidelines as more fully described in the
Equinix Securities Trading Policy.
To make sure you are complying with laws
against insider trading, please refer to
Equinix’s Securities Trading Policy. If you
have any questions, you should contact the
Compliance Office.
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OUR COMMUNITY
Making a positive difference in our communities and around the world
HUMAN RIGHTS
Equinix supports and respects the protection
of all human rights around the world. We
are committed to upholding the fundamental
human rights of our employees and of the
workers of companies we engage. We expect
our vendors and partners to adhere to these
same high standards.
CHARITABLE CONTRIBUTIONS
Giving back to our communities. Equinix
encourages employees to make positive
contributions in the communities where they
live and work. Equinix is also committed
to supporting relevant social, economic
and sustainability issues that matter most
to our business, our employees and our
communities. Equinix has identified a number
of focus areas for charitable giving that are
based on their relevance to our business
and which we will support through Company
donations. Given our focus areas, we
generally do not accept unsolicited funding
requests. Instead, we prefer to invite requests
for proposals that contribute to our strategic
program areas and funding priorities. The
Corporate Social Responsibility team is
responsible for reviewing and evaluating these
requests.
Equinix encourages individual employees
to make their own contributions to charities.
However, Equinix will not, under any
circumstances, reimburse individual or
personal contributions made by employees
to a charity, school, nonprofit agency or
non-governmental organization (NGO).
Additionally, you should never personally
make a payment on behalf of Equinix to a
charity, school, nonprofit agency or NGO–
including payments for event tickets–
because Equinix will not reimburse these
expenses. Any exceptions to these
guidelines must be approved by the
regional controller and/or the Corporate
Social
Responsibility team.
For more information about our giving
strategy, please reference the Global Giving
Policy or contact the Corporate Social
Responsibility team.
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OUR COMMUNITY
Making a positive difference in our communities and around the world
HUMAN RIGHTS
Equinix supports and respects the protection
of all human rights around the world. We
are committed to upholding the fundamental
human rights of our employees and of the
workers of companies we engage. We expect
our vendors and partners to adhere to these
same high standards.
CHARITABLE CONTRIBUTIONS
Giving back to our communities. Equinix
encourages employees to make positive
contributions in the communities where they
live and work. Equinix is also committed
to supporting relevant social, economic
and sustainability issues that matter most
to our business, our employees and our
communities. Equinix has identified a number
of focus areas for charitable giving that are
based on their relevance to our business
and which we will support through Company
donations. Given our focus areas, we
generally do not accept unsolicited funding
requests. Instead, we prefer to invite requests
for proposals that contribute to our strategic
program areas and funding priorities. The
Corporate Social Responsibility team is
responsible for reviewing and evaluating these
requests.
Equinix encourages individual employees
to make their own contributions to charities.
However, Equinix will not, under any
circumstances, reimburse individual or
personal contributions made by employees
to a charity, school, nonprofit agency or
non-governmental organization (NGO).
Additionally, you should never personally
make a payment on behalf of Equinix to a
charity, school, nonprofit agency or NGO–
including payments for event tickets–
because Equinix will not reimburse these
expenses. Any exceptions to these
guidelines must be approved by the
regional controller and/or the Corporate
Social
Responsibility team.
For more information about our giving
strategy, please reference the Global Giving
Policy or contact the Corporate Social
Responsibility team.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 17
Matching gifts. Equinix has established a
matching gifts program to support employees
in their personal philanthropy, charitable giving
and volunteer efforts. If you make a monetary
contribution or volunteer your time to an
eligible organization, Equinix will “match”
that money or time contribution with a
monetary contribution.
Additional information and requirements of the
Matching Gifts Policy and Program, including
specific eligibility requirements for employees
and organizations, are outlined in the Equinix
Matching Gifts Program.
POLITICAL ACTIVITIES AND
CONTRIBUTIONS
We support good relations with the
communities where we operate. You may
participate in local activities that address
the needs of the communities in which you
live and work. As a private citizen, you may
also support your local political process with
personal contributions or by volunteering your
personal time. These activities, however, must
not be conducted on Company time or involve
the use of Company resources. You may not
make or commit political contributions on
behalf of Equinix.
Make sure that your involvement in political
activities is in compliance with applicable
U.S. and local laws and is not prohibited by
other Equinix policies.
THE ENVIRONMENT
At Equinix, we seek to be good stewards of
the environment and of the resources we
consume with a goal of minimizing our carbon
footprint. We do this by focusing on:
• Designing, building, and operating
efficiently in order to reduce our
consumption of all resources,
including electricity, water, natural
gas, diesel and refrigerants
• Playing an active role in the
“greening” of our business and being
a leader in evaluating and deploying
innovative solutions
• Measuring ourselves using industry
best practices and Equinix specific
KPIs, publicly set goals and report
progress in a transparent manner
RECOMMENDED READING: EQUINIX
MATCHING GIFTS PROGRAM
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 17
Matching gifts. Equinix has established a
matching gifts program to support employees
in their personal philanthropy, charitable giving
and volunteer efforts. If you make a monetary
contribution or volunteer your time to an
eligible organization, Equinix will “match”
that money or time contribution with a
monetary contribution.
Additional information and requirements of the
Matching Gifts Policy and Program, including
specific eligibility requirements for employees
and organizations, are outlined in the Equinix
Matching Gifts Program.
POLITICAL ACTIVITIES AND
CONTRIBUTIONS
We support good relations with the
communities where we operate. You may
participate in local activities that address
the needs of the communities in which you
live and work. As a private citizen, you may
also support your local political process with
personal contributions or by volunteering your
personal time. These activities, however, must
not be conducted on Company time or involve
the use of Company resources. You may not
make or commit political contributions on
behalf of Equinix.
Make sure that your involvement in political
activities is in compliance with applicable
U.S. and local laws and is not prohibited by
other Equinix policies.
THE ENVIRONMENT
At Equinix, we seek to be good stewards of
the environment and of the resources we
consume with a goal of minimizing our carbon
footprint. We do this by focusing on:
• Designing, building, and operating
efficiently in order to reduce our
consumption of all resources,
including electricity, water, natural
gas, diesel and refrigerants
• Playing an active role in the
“greening” of our business and being
a leader in evaluating and deploying
innovative solutions
• Measuring ourselves using industry
best practices and Equinix specific
KPIs, publicly set goals and report
progress in a transparent manner
RECOMMENDED READING: EQUINIX
MATCHING GIFTS PROGRAM
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 18
OUR RESPONSIBILITY
Live our Code and speak up when you have a question or concern
YOUR VOICE MATTERS
Our reputation as an ethical company
depends on all of us working together
to ensure our high ethical standards are
upheld. Sometimes it may seem easier to
keep quiet if you see someone violating our
Code, but doing nothing can result in serious
consequences. Speaking up when you
observe illegal or unethical behavior means
you care about ensuring we maintain an
ethical workplace.
WAYS TO SPEAK UP
You have the right and the responsibility
to protect our Company from conduct that
violates our Code. If you encounter Code
violations or concerns, we rely on you to
report these matters promptly. When you
speak up, you can be assured that your
concern will be addressed promptly and
in confidence.
At Equinix, there are a number of appropriate
ways for you to speak up about questions or
concerns you may have, including:
• Talking to your manager
• Contacting your HR representative
or [email protected]
• Contacting Equinix’s compliance officer
• Emailing the Compliance Office at
[email protected]
• Reaching out to your local legal
representative
• www.equinix.ethicspoint.com
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 18
OUR RESPONSIBILITY
Live our Code and speak up when you have a question or concern
YOUR VOICE MATTERS
Our reputation as an ethical company
depends on all of us working together
to ensure our high ethical standards are
upheld. Sometimes it may seem easier to
keep quiet if you see someone violating our
Code, but doing nothing can result in serious
consequences. Speaking up when you
observe illegal or unethical behavior means
you care about ensuring we maintain an
ethical workplace.
WAYS TO SPEAK UP
You have the right and the responsibility
to protect our Company from conduct that
violates our Code. If you encounter Code
violations or concerns, we rely on you to
report these matters promptly. When you
speak up, you can be assured that your
concern will be addressed promptly and
in confidence.
At Equinix, there are a number of appropriate
ways for you to speak up about questions or
concerns you may have, including:
• Talking to your manager
• Contacting your HR representative
or [email protected]
• Contacting Equinix’s compliance officer
• Emailing the Compliance Office at
[email protected]
• Reaching out to your local legal
representative
• www.equinix.ethicspoint.com
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 19
WHISTLEBLOWER PROTECTION
POLICY
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, confident that their
concerns will be taken seriously and acted
upon by the Company.
Equinix has a zero-tolerance policy when it
comes to retaliation against any employee
who makes a good faith report of potential
misconduct or helps with an investigation.
We want you to feel free to ask questions
and raise concerns without fear of retaliation,
knowing that you have done the right thing in
coming forward.
CODE OF BUSINESS CONDUCT
WAIVERS
It is the responsibility of all Equinix employees
to understand and to comply with our Code.
Subject to applicable law, if you violate the
policies and procedures in our Code, you may
be subject to disciplinary action, up to and
including termination of your employment.
If you believe your actions may violate our
Code, you need to raise the issue to your
manager and the Compliance Office.
Equinix may waive application of the policies
set forth in our Code only when circumstances
warrant granting a waiver based on the best
interests of Equinix and its shareholders.
A waiver of any Equinix policy or section
of our Code requested by an employee must
be approved by the employee’s manager and
the Compliance Officer. Employee waiver
requests will be reviewed and granted on a
case-by-case basis.
Waivers of the Code for directors and
executive officers must be approved by
disinterested directors and will be disclosed as
required by applicable law or regulation.
Requests for a waiver of our Code may be
made on the intranet at:
www.equinix.ethicspoint.com
Our Code is on your
Equinix Mobile One app
and all of our policies
can be found on the
Equinix Intranet.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 19
WHISTLEBLOWER PROTECTION
POLICY
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, confident that their
concerns will be taken seriously and acted
upon by the Company.
Equinix has a zero-tolerance policy when it
comes to retaliation against any employee
who makes a good faith report of potential
misconduct or helps with an investigation.
We want you to feel free to ask questions
and raise concerns without fear of retaliation,
knowing that you have done the right thing in
coming forward.
CODE OF BUSINESS CONDUCT
WAIVERS
It is the responsibility of all Equinix employees
to understand and to comply with our Code.
Subject to applicable law, if you violate the
policies and procedures in our Code, you may
be subject to disciplinary action, up to and
including termination of your employment.
If you believe your actions may violate our
Code, you need to raise the issue to your
manager and the Compliance Office.
Equinix may waive application of the policies
set forth in our Code only when circumstances
warrant granting a waiver based on the best
interests of Equinix and its shareholders.
A waiver of any Equinix policy or section
of our Code requested by an employee must
be approved by the employee’s manager and
the Compliance Officer. Employee waiver
requests will be reviewed and granted on a
case-by-case basis.
Waivers of the Code for directors and
executive officers must be approved by
disinterested directors and will be disclosed as
required by applicable law or regulation.
Requests for a waiver of our Code may be
made on the intranet at:
www.equinix.ethicspoint.com
Our Code is on your
Equinix Mobile One app
and all of our policies
can be found on the
Equinix Intranet.
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 20
ADDITIONAL RESOURCES
Helping us understand and embrace our Code, policies and guidelines
A NOTE FROM
OUR COMPLIANCE
OFFICER
Equinix is absolutely
committed to honest and
ethical business practices,
and this commitment drives
and informs all of the
guidelines and policies in the Equinix Code of
Business Conduct.
As Equinix employees, we are responsible
for acting ethically and honestly in all of
our business dealings, which includes
understanding the guidelines and policies
in our Code, following them, and reporting
issues and violations when we see them.
Working together, we make Equinix a model
of honesty and integrity–and build an ethical
workplace we can all be proud of.
Equinix has a variety of tools and resources to
help you seek guidance and report concerns.
Please use the one you are most comfortable
with.
You may also contact me directly at
[email protected]
Mary Anne Wellman
VP, Legal and Chief Compliance Officer
REPORT CONCERNS OR VIOLATIONS
Use any of the following options to report your
compliance issues and concerns:
Compliance Reporting Hotline:
www.equinix.ethicspoint.com
INQUIRIES
For human resources inquiries, please
contact:
• Your local HR representative
• [email protected]
For legal inquiries, please contact:
• The Equinix compliance officer
• Your local vice president of legal in
Americas, AsiaPacific or EMEA
• Chief legal officer and general counsel
For information security inquiries, please
contact:
• The Global Information Security team -
[email protected]
• The information security officer
For charitable contribution inquiries,
please contact:
[email protected]
CONFLICT OF INTEREST WAIVERS
www.equinix.ethicspoint.com
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 20
ADDITIONAL RESOURCES
Helping us understand and embrace our Code, policies and guidelines
A NOTE FROM
OUR COMPLIANCE
OFFICER
Equinix is absolutely
committed to honest and
ethical business practices,
and this commitment drives
and informs all of the
guidelines and policies in the Equinix Code of
Business Conduct.
As Equinix employees, we are responsible
for acting ethically and honestly in all of
our business dealings, which includes
understanding the guidelines and policies
in our Code, following them, and reporting
issues and violations when we see them.
Working together, we make Equinix a model
of honesty and integrity–and build an ethical
workplace we can all be proud of.
Equinix has a variety of tools and resources to
help you seek guidance and report concerns.
Please use the one you are most comfortable
with.
You may also contact me directly at
[email protected]
Mary Anne Wellman
VP, Legal and Chief Compliance Officer
REPORT CONCERNS OR VIOLATIONS
Use any of the following options to report your
compliance issues and concerns:
Compliance Reporting Hotline:
www.equinix.ethicspoint.com
INQUIRIES
For human resources inquiries, please
contact:
• Your local HR representative
• [email protected]
For legal inquiries, please contact:
• The Equinix compliance officer
• Your local vice president of legal in
Americas, AsiaPacific or EMEA
• Chief legal officer and general counsel
For information security inquiries, please
contact:
• The Global Information Security team -
[email protected]
• The information security officer
For charitable contribution inquiries,
please contact:
[email protected]
CONFLICT OF INTEREST WAIVERS
www.equinix.ethicspoint.com
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
®
Code of Business Conduct 21
RELATED POLICIES AND
RECOMMENDED READING
Brand Guidelines
Global Employee Handbooks
Global IT Security Policies
Global Giving and Matching Policy
Global Record Management Policy
Global Social Media Guidelines
Matching Gifts Policy
Securities Trading Policy
(i.e. “Insider Trading Policy”)
Sustainability
Travel and Expense Policy
(i.e. T and E Policy)
Whistleblower Protection Policy
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
Code of Business Conduct 21
RELATED POLICIES AND
RECOMMENDED READING
Brand Guidelines
Global Employee Handbooks
Global IT Security Policies
Global Giving and Matching Policy
Global Record Management Policy
Global Social Media Guidelines
Matching Gifts Policy
Securities Trading Policy
(i.e. “Insider Trading Policy”)
Sustainability
Travel and Expense Policy
(i.e. T and E Policy)
Whistleblower Protection Policy
Table of
Our
Our Purpose
Our
Our
Our Business
Our Commitment
Our
Our
Additional
Contents Message & Values Code People Relationships to the Law Community Responsibility Resources
EQUINIX CODE OF BUSINESS CONDUCT
©2019
Equinix Code of Business Conduct v0419 EN PS-AO 0419 Q219
©2019
Equinix Code of Business Conduct v0419 EN PS-AO 0419 Q219
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