Code of Conduct

EcoDataCenter's Code of Conduct clarifies how we should behave in everyday life - as individual employees as well as business partner, employer and social actor.
466A5746

Code of Conduct

EcoDataCenter's vision is a sustainable and secure digital society. Our mission is to
deliver the conditions for a sustainable and secure infrastructure in the digital society.
Our core values provide guidance on how to act and make decisions in everyday life.
They describe what we stand for, how we work, what we can achieve and how we want
to be perceived. Our core values are the compass in all encounters with customers,
business partners, suppliers and colleagues.
EcoDataCenter's Code of Conduct clarifies for all employees how we should behave as
a business partner, employer, employee and social actor.

The purpose of the Code of Conduct is to:
• ensure that applicable laws, rules and regulations are always followed
• ensure that information in financial reports and other public communications is
complete, fair, accurate, understandable and disclosed in a timely manner
• manage conflicts of interest appropriately
• protect and make proper use of company property
• protect non-public information

About the Code of Conduct

Why a Code of Conduct?

The Code of Conduct is designed to ensure that EcoDataCenter's business activities
and communications with the market are conducted in an open and trustworthy manner
in accordance with the law. The Code of Conduct constitutes minimum requirements. If
local, national or international legislation imposes stricter requirements than this Code,
these must be complied with.
Conducting business based on our core values and this Code of Conduct is important
to maintain the trust and credibility of our business partners, employees, owners and
other stakeholders. We choose to be transparent about how we conduct our business
while respecting our business assets and the privacy of individuals.

To Whom does the Code of Conduct apply?

The Code of Conduct applies to all employees within the EcoDataCenter Group from
the Board of Directors to individual employees. The contents of the Code must be
respected and followed. It is everyone's responsibility to set a good example.
EcoDataCenter expects the Code of Conduct to be respected and followed by our
business partners (customers, partners, suppliers).
The Code of Conduct is an overall framework and is supplemented by detailed rules
and guidelines for individual areas.

Sustainable business

EcoDataCenter shall conduct profitable business with good ethics. EcoDataCenter
shall be a role model in sustainable business, which includes environment, business
ethics, anti-corruption, gender equality, diversity, working conditions and human rights.
In order to respect human rights and promote fair employment conditions, safe working
conditions, responsible environmental practices and high ethical standards, we adhere
to the United Nations Global Compact.
EcoDataCenter shall be a good place to work for everyone, regardless of gender,
transgender identity or expression, ethnicity, religion or other belief, disability, sexual
orientation or age. Everyone should have the same rights, opportunities and
obligations.
EcoDataCenter works for sustainable development and our sustainability work is based
on the UN's Global Sustainable Development Goals - Agenda 2030.
The Code of Conduct reflects EcoDataCenter's commitment to conducting business in
a responsible and ethical manner towards both its own operations and the outside
world. In summary, it means that
• being responsible citizens
• respecting human rights
• ensuring health and safety
• working for sustainable development

Business ethics

EcoDataCenter shall comply with the laws and regulations that apply to our business.
We only engage in business activities that comply with laws and agreements and that
are in accordance with our Code of Conduct. We do not engage in activities for which
we cannot openly vouch or account, and we do not make business decisions based on
personal interests or relationships. Bribes, kickbacks, or other illegal or unethical
benefits are not permitted. EcoDataCenter employees shall not engage in any form of
collaboration or otherwise act in a manner that may be perceived as anti-competitive.
EcoDataCenter supports the international fight against money laundering and takes its
legal obligations very seriously.
EcoDataCenter wants to build trusting relationships with customers, suppliers and
contractors and therefore follows the rules for procurement and sales that exist within
the company. We will not engage suppliers or contractors if we are aware that they
have breached their obligations to business partners or employees, violated laws,
regulations or contracts, or have unclear ownership structures.
Violations of applicable laws or regulations can have serious consequences, both for
EcoDataCenter and for the individuals involved. Therefore, it is everyone's
responsibility to be aware of and collectively comply with relevant laws and regulations.

Code of Conduct EcoDataCenter

EcoDataCenter's Sustainability Policy

Company vision

EcoDC's vision is a world where AI infrastructure powers global innovation and local progress. Guided by this vision, our sustainability policy reinforces our commitment to ensure our operations benefit both the environment and the communities where we operate.

We strive for leadership in sustainable digital infrastructure by actively minimizing our environmental footprint, promoting social responsibility, and fostering local economic development. By embedding sustainability into our organization, from strategic decisions to everyday operations, EcoDC aims to create lasting positive impacts, ensuring a balance between technological advancement, environmental stewardship, and 
community enrichment.

About the sustainability policy

EcoDC's sustainability policy applies to the entire group and forms the basis for the company's sustainability work. EcoDC complies with laws and requirements and fulfils its commitments, for example linked to current environmental permits and third-party certification. 


Sustainability is deeply integrated into the company's strategy, decision-making processes and governance. EcoDC's Board of Directors has overall responsibility for the strategic direction of the sustainability work and follow-up of set sustainability goals. The CEO, together with the management team, has overall responsibility for the operational implementation and daily monitoring of the sustainability work. The success of the sustainability programme requires close cooperation between the Board and management.

Within the framework of the business plan, EcoDC strives to reduce its dependence on resources in order to limit the company's negative  environmental impact and increase our resilience as a company.

EcoDC monitors and reports on material sustainability impacts based on double materiality analysis according to ESRS. As part of this work, actual and potential impacts of the company's operations are systematically identified and assessed. The company's material impacts on the environment and people, as well as the related risks and opportunities, are publicly disclosed as part of our annual Sustainability Report.


Targets and third-party auditing

Sustainability goals are an essential part of the company's overall goals and governance. The company's sustainability goals are public and are stated on EcoDC's website. An annual sustainability report is prepared in accordance with globally accepted frameworks such as the GHG Protocol and GRI and is third-party audited by an independent auditor.

We report progress to the UN Global Compact and undergo annual third-party assessment based on CDP and EcoVadis. We are certified to ISO9001 and ISO140001.


Environmental impact of operational activities

The identification, assessment and management of environmental aspects is a central part of EcoDC's environmental work. As a complement to the identified impact based on double materiality analysis according to ESRS, the organisation determines which aspects 
have or may have one or more types of significant environmental impact based on established criteria. The basis for significant environmental aspects in our operations are listed the Environmental Aspects List. Each employee has a responsibility to raise incidents 
or suggestions for improvement in order to continuously improve our environmental work. Furthermore, it is incumbent on all employees concerned to follow the operational routine descriptions that are linked to the environment in their daily work.

Environmental impact in the value chain

We actively engage with our suppliers and partners in the value chain to collectively minimise the environmental impact of our operations. 

We systematically monitor and report our indirect environmental impacts to stakeholders. New suppliers undergo a due diligence process, and all suppliers sign our supplier-specific Code of Conduct. We are committed to respecting all internationally recognised human rights 
along our value chain and strive to work in accordance with the UN International Covenant on Human Rights and the principles of
fundamental rights. All operators active on site are subject to General Environmental, Health and Safety Regulations set up by EcoDC.

Social sustainability

We promote equality and diversity in the workplace by ensuring that all employees are treated equally, regardless of gender, ethnicity, religion, sexual orientation or disability. Science shows that diversity in the workforce increases creativity, broadens our horizons and boosts competitiveness.

We strive to create an inclusive work environment where all employees feel valued and respected. We want our company to be psychologically and physically safe, which is why we eliminate workplace hazards and systematically reduce health and safety risks. These positions are also reflected in our Code of Conduct.

We take responsibility for supporting and developing the local community around our operations. By prioritising local suppliers in purchasing and procurement and actively participating in projects and initiatives that promote sustainability and community development, we contribute to positive and sustainable development in the local area.

Communication

We welcome talking about sustainability issues, and we communicate responsibly and factually about the environment and sustainability internally and externally. We avoid greenwashing by being clear and transparent about our progress as well as our challenges.

Environmental awareness of employees

We work to constantly increase the environmental awareness of all employees, both in matters related to their professional role and in the behaviour and choices they make as employees. The basis for this is that all employees sign our Code of Conduct, which contains clear expectations regarding sustainability. In addition, there is annual training in sustainability and incentives for making sustainable choices.

Enforcement and compliance

Everyone working at EcoDC is subject to this environmental policy and is responsible for applying and respecting its content. The owner of the environmental policy is the Group's CEO, who has operational responsibility for implementation together with management and supervisors. Compliance with the environmental policy is regularly monitored as a natural part of regular operations, for example during internal and external audits. The environmental policy is approved by the CEO. The policy is reviewed annually to ensure relevance and 
continuous improvement.

EcoDataCenter Sustainability Policy