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Code of Conduct

1. Introduction

CDC Data Centres (CDC, us, we, our) is committed to socially responsible, professional, and ethical business practices. This Code:

  1. clear and consistent expectations of CDC employees, affiliates, company officers, directors and suppliers (together being you or your);
  2. promotes a high standard of integrity, honesty and ethical conduct;
  3. reinforces CDC values towards being ‘Tenacious’, ‘Committed’ and ‘Meticulous’; and
  4. provides a framework for reporting unlawful, dishonest, and improper conduct.

You are expected to read, understand and comply with our Code and to complete all training made available to you on our Code.  Our Code applies globally to all directors, employees and contractors of CDC and to any other person notified that our Code applies to them. The Code covers a range of important aspects of how we do business, including behaving ethically and in accordance with the law.

2. CDC Values 

Tenacious: We are determined to grow beyond our limits. Our tenacity keeps us moving forward through a challenge.

Committed: We do it right. We own the task given to us and see it through to the end.

Meticulous: There are no shortcuts to quality work. Being meticulous keeps customer data stable and secure.

3. Standards of conduct 

We act with honesty and integrity. It is essential that you conduct yourself with a high degree of personal responsibility and accountability. You are required to do the right thing by acting fairly, with due care, lawfully, in the best interests of the company and shareholders.

You must:

  1. act with honesty, integrity and in CDC’s best interests at all times;
  2. carry out your duties diligently and to the best of your ability;
  3. act fairly and reasonably in all our business dealings, including with those that have lesser bargaining power;
  4. never engage in deception or dishonesty at work, including to obtain a financial or other benefit for ourselves or others;
  5. never offer or accept any bribes, pay-offs, facilitation payments, secret, unjustified or inflated commissions, kickbacks, or any like payments or improper benefits, either directly or indirectly, as required under the CDC Fraud and Corruption Control Plan;
  6. not offer or receive gifts or hospitality that are excessive, inappropriate, or have the potential to improperly influence, or be perceived to improperly influence, a decision or outcome;
  7. behave professionally in the workplace and at work related functions;
  8. not allow personal relationships, business, financial and other interests to conflict with, or have the potential to conflict with, your work duties or CDC’s best interests;
  9. use CDC property and information for its intended purpose and not engage in conduct which may cause damage to CDC’s property;
  10. not share confidential or sensitive information about CDC with anyone, including in social settings, unless you have approval to do so or there are appropriate protections in place;
  11. maintain any qualifications, certifications, licences and permits necessary to perform your duties; and
  12. comply with all laws, the Code and all accompanying policies.

4. Health and safety 

We maintain a safe and inclusive working environment where we treat each other with respect. We take responsibility for the health, safety and wellbeing of our people, partners and customers. We promote diversity, equity and inclusion and are respectful and fair in the way we work with our colleagues, customers and our communities.

Our goal is to provide a workplace that is free from health and safety risks. Where risk cannot be eliminated, we aim to reduce it to as low as reasonably practicable levels. Ultimately, health and safety is a shared responsibility, and it is your duty to assist CDC in ensuring our workplace is as safe as possible.

You must:

  1. take reasonable care of your, your colleagues’ and visitors’ physical and psychological safety;
  2. not undertake any work that appears unsafe and immediately report a concern, hazard or incident if you become aware of it;
  3. understand and follow all applicable health, safety, wellbeing and environment policies, standards, minimum requirements and procedures that apply to your work.
  4. comply with all CDC rules or procedures relating to safety (including safe work method statements and standard operating procedures);
  5. ensure appropriate PPC and PPE is worn on sites in accordance with Personal Protective Equipment (PPE) and Uniform Procedure;
  6. maintain strict compliance with the Alcohol and Drug Policy;
  7. not engage in unacceptable actions or behaviours that involve harassment, sexual harassment, discrimination, bullying or victimisation;
  8. comply with your legal obligations under WHS laws, which includes reporting any instances of sexual harassment and discrimination you encounter; and
  9. report hazards, incidents and near misses in accordance with the HSE Incident Management Procedure.

5. Customers

A positive customer experience is every person’s responsibility at CDC. Those outside of traditional customer facing roles may be required to assist with customer activities and requests, so it is essential that you represent yourself in a professional manner reflective of CDC values.

You must:

  1. ensure all communications with customers are timely, honest and respectful;
  2. act honestly and accurately represent CDC;
  3. not provide advice to a customer when you are not qualified or authorised to do so;
  4. protect customer’s confidential and personal information (including the fact the customer is procuring services from CDC);
  5. take proactive steps to ensure customers have a positive experience; and
  6. ensure all feedback and complaints are directed to CDC management.

6. Security 

CDC is committed to the delivery of high-security data centres to support government and critical infrastructure. All CDC personnel have a role to play in protecting people, information and assets within our data centres.

You must:

  1. discharge your responsibilities in accordance with the CDC Security Policy;
  2. utilise CDC assets, network and system access in accordance with the IT and Networked Systems Acceptable Use Policy when working at CDC premises and when working remotely;
  3. correctly assess the sensitivity of the information you generate and handle in the course of your work and ensure that information is stored and transmitted in a way that is consistent with its sensitivity;
  4. only access business information or provide others with access to business information where there is a genuine business need to do so;
  5. treat the personal and confidential information of others with respect at all times. Any personal information we collect, use, store and disclose must be managed in accordance with our policies, procedures, and the law;
  6. take reasonable care of any physical or digital credentials issued to you as part of your work at CDC and ensure credentials are not compromised;
  7. follow the directions set out by CDC and our customers in respect to the carriage and use of portable electronic devices and data bearing devices in our data centres;
  8. take reasonable steps to prevent unauthorised persons from accessing CDC premises;
  9. report all security incidents, threats and observations to a member of the CDC Security Team as soon as practicable;
  10. complete all activities associated with initial and ongoing security vetting requirements in a timely manner, including security clearances, criminal history checks and other kinds of activities as directed by CDC and/or our customers; and
  11. complete mandatory security awareness training in a timely manner.

7. Integrity and trust

CDC is committed to ensuring responsible business practices are implemented to align with shareholder, customer, regulator and community expectations. Any evidence or perception of corrupt conduct can significantly impact CDC’s reputation and the lives of those involved. We place significant trust on you to monitor compliance within your business areas and to report improper conduct.

You must:

  1. not use insider information to trade in securities or facilitate a third party to do so including the insider information of suppliers, customers and shareholders, as required under the CDC Financial Products Trading Policy;
  2. not bribe, gift or provide payments (either internally or to a third party) to influence someone’s behaviour to gain an unearned reward or favourable treatment;
  3. only accept gifts in accordance with the Gifts, Travel and Entertainment Policy and ensure they are declared immediately;
  4. disclose any relationship which gives rise to a perceived or actual conflict of interest in accordance with the Conflicts of Interest Policy;
  5. never entice, encourage or invite any person or entity to breach any statutory or contractual obligation they may have, including your colleagues which have ongoing duties to a previous employer;
  6. immediately report any instances of fraud, money laundering or non-compliance with sanctions/trade controls in accordance with CDC policies;
  7. incur expenses responsibly in the course of business only in accordance with the Expenses and Reimbursement Policy;
  8. ensure you do not exceed your authorisations under the Delegation of Authority Policy; and
  9. ensure that you consult the CDC Legal and Finance Teams before committing CDC to any expenses or binding legal obligations.

8. People 

CDC is an equal opportunity employer, and it is our responsibility to ensure that we have an inclusive workplace without barriers to opportunity and advancement. We maintain a safe and inclusive working environment where we treat each other with respect.

We maintain an environment free of unlawful harassment or unacceptable conduct, and don’t tolerate such behaviour by an employee, customer, supplier or any person we deal with as part of our work. We take action to address such behaviour if we are aware of it.

You must:

  1. not engage in any form of unlawful discrimination (including but not limited to age, gender, sex, race, religion, sexual orientation, disability and marital status);
  2. respect and embrace diversity;
  3. not engage in any form of intimidation, coercion, offensive behaviour or physical or psychological harm against any other person;
  4. hire and promote individuals on merit, that promote CDC values, and exhibit characteristics consistent with this Code; and
  5. proactively foster the career development of CDC employees to help them achieve their goals.

9. Environment, social and governance

CDC prides itself on developing environmentally and socially responsible business practices which minimise harm to the environment and community. We are committed to creating a better digital world, sustaining our planet and doing business responsibly.

You must:

  1. consider the environmental footprint you create and how it can be reduced;
  2. seek to minimise carbon emissions in undertaking business;
  3. consider the social impact of suppliers and promote those aligned with CDC’s ESG values;
  4. procure goods and services from ethical and sustainable sources, and challenge suppliers to promote ethical and sustainable practices in their supply chains; and
  5. ensure suppliers adhere to the CDC Supplier Code of Conduct particularly in relation to the management of modern slavery, inhumane labour conditions and human rights breaches.

10. Reputation

CDC’s reputation and brand is an important tool in representing itself to the market. Your actions impact CDC and how it is perceived in the market and community.

Do not speak on behalf of CDC unless you are authorised to make public comments. We care about the reputation of CDC, so when we speak about CDC or release any information about CDC externally, we do so responsibly. All communications must be lawful, accurate, fair, complete and clear, and must not breach any confidentiality or privacy requirements.

You must:

  1. not purport to speak on behalf of, or represent CDC, without explicit approval from the CDC External Affairs team;
  2. ensure that you use social media in accordance with the Social Media Policy, and do not represent your personal views as those of CDC;
  3. not use CDC branding, logos or intellectual property without the explicit approval from the CDC External Affairs team;
  4. refrain from making statements or acting in such a way that brings CDC into disrepute;
  5. seek consent from the CDC External Affairs team before discussing or promoting CDC at a public event or discussion panel; and
  6. seek consent from the CDC External Affairs team before making donations or participating in charitable activities on behalf of CDC.

11. Accountability 

We are all individually accountable for complying with the Code, and we call things out that don’t seem right.  It is essential that you report any illegal, unethical, unacceptable, or improper conduct that you may encounter.

What should I do? Quick conduct test

Sometimes asking yourself a few simple questions can help clarify whether you need to be careful in how you conduct yourself.

  • If you answer “no” to any of these integrity questions, then you could be facing a behaviour that may be in breach of our Code.
  • Is the behaviour in line with our values framework and our guiding principles? Is this the right thing to do for our customers?
  • Is the behaviour in line with our health, safety and environmental standards?
  • Would I be comfortable telling my family about this, or seeing it in the media?
  • Is it right that I am the most senior person who knows about this issue? (Or do I need to report it to someone else?

We trust your judgement to speak up honestly about your concern to ensure CDC can maintain the high standard of service and trust with the community.

Reports may be lodged to:

  • your manager (copying in the People and Culture team at people@cdc.com).
  • CDC’s Company Secretary at companysecretary@cdc.com;
  • for Health and Safety matters, log in Protecht.ERM: Home; or
  • through our whistleblower hotline service facilitated via a third party service provider.

The Code of Conduct requires that you comply with all relevant CDC policies, which include:

Delegation of Authority Policy

Conflicts of Interest Policy

Supplier Code of Conduct

Privacy Policy

Anti-Discrimination Bullying and Harassment Policy

Financial Products Trading Policy

Gifts, Travel and Entertainment Policy

Fraud and Corruption Control Plan

Expenses and Reimbursement Policy

Social Media Policy

Alcohol and Drug Policy

HSE Incident Management Procedure