March 2025
In 2025, AtlasEdge Data Centre maintains its commitment to respecting all human rights, including the elimination of slavery and human trafficking in our supply chain and operations. We continue to empower any individual who has concerns about unethical behaviour across our business or operations to speak up, and to do so without fear of retaliation.
We are always looking to improve our approach. Below you will find our updated 2025 Modern Slavery Act Statement in compliance with our obligations under the UK’s Modern Slavery Act 2015 (the “Act”).
About AtlasEdge Data Centres
AtlasEdge Data Centres is one of the fastest growing data centre providers in Europe. Together with our clients and partners, we’re defining European digital infrastructure. Our distributed data centre portfolio allows customers to plan and shape their technology and network infrastructure to meet their growing requirements for lower latency, better performance and localised solutions. The portfolio includes data centers in key markets across Europe, including Amsterdam, Barcelona, Berlin, Brussels, Copenhagen, Dusseldorf, Hamburg, Leverkusen, Leeds, Lisbon, London, Madrid, Manchester Milan, Paris, Stuttgart, Vienna and Zurich. With demand gravitating towards the edge of networks, AtlasEdge’s distributed and highly connected footprint provides a unique solution that is aligned with the next wave of growth in digital infrastructure. AtlasEdge owns or operates data centres across eleven countries in Europe, supporting more than 700 customers and providing connectivity to more than 50 different on-net carriers.
Policies
Employees
Our Code of Conduct is designed to provide the basic principles to support our people in working to the best of their abilities, while maintaining the trust and solid reputation we have built. We conduct all business honestly and ethically. Our Anti-Bribery & Corruption Policy details our zero-tolerance approach to bribery and corruption and commitment to acting professionally, fairly, and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption. All employees are required to complete mandatory training on our Code of Conduct, which includes training on the key elements of our Anti-Bribery & Corruption Policy.
We have published a Procurement Policy, the purpose of which is to establish a standardised approach to the acquisition of goods and services across AtlasEdge. The Policy mandates a strict compliance culture across all procurement activities, ensuring adherence to legal, regulatory and internal governance requirements including modern slavery laws & legislation.
We provide a workplace that is positive, creative and rewarding, giving every employee the opportunity to achieve their full potential and contribute to AtlasEdge’s success. We will not tolerate harassment of any kind in our workplace. We promote an open and inclusive culture, where people are encouraged to ask questions if they are unsure and to raise concerns if they believe our Code of Conduct has been violated.
Employees who become aware of or suspect any behaviour violates any applicable law, rule, regulation, company policy or other provision of the Code of Conduct, are required to report such improper conduct as promptly as possible. Employees can report the matter directly to our People or Legal teams or the General Counsel. Additionally, a web-based reporting system is operated by a third-party vendor and is available 24 hours a day, seven days a week.
Supply Chain
The risk of slavery and human trafficking in our business sits predominantly in our supply chain.
Supplier Code of Conduct
Suppliers to AtlasEdge are required to meet the standards set out in our Supplier Code of Conduct which includes Labour and Employment Compliance (Local Labour Law Regulations). Suppliers must comply with all local labour laws and international labour standards, ensuring fair treatment of workers:
- Fair Compensation: Workers must be provided with fair wages, benefits, and working conditions that meet or exceed local legal requirements.
- No Child or Forced Labour: Suppliers must not use child labour, forced labour, or engage in any form of human trafficking.
- Employee Rights: Employees must be free to associate, bargain collectively, and work in a non-discriminatory environment free from harassment or abuse.
Supplier assessments and monitoring
We continuously monitor our supply chain and are not aware of any issues of modern slavery or human trafficking in our operation or supply chain. We have conducted a risk-based assessment of the key categories of suppliers for AtlasEdge. As a result of our assessment and given the nature of our operations, we maintain that the risk of modern slavery and human trafficking in our supply chain continues to be low.
As part of our improved onboarding system, we ask all of our suppliers to review our modern slavery statement and that all suppliers with a higher potential risk of modern slavery confirm (on an annual basis) that they comply with the principles in such statement. Suppliers with a higher potential risk of modern slavery are also required to provide us their modern slavery policies, which we then review for compliance purposes.
AtlasEdge expects all third parties we deal with to observe this commitment and to comply with all local laws and regulations, including in relation to modern slavery, human trafficking and anti-bribery and corruption. Our standard contractual provisions require all our suppliers to adhere to best practices as well as all applicable laws and regulations, including in relation to the Act, including undertaking due diligence to ensure that there is no modern slavery or human trafficking in their own operations and supply chains.
Supplier corrective actions and continuous improvement
AtlasEdge will continue to monitor supply chain compliance risk and if a supplier assessment shows, or it subsequently transpires, that a new or existing supplier is not adhering to its legal obligations under the Act or our Code of Conduct, AtlasEdge will seek to work with them to address such non-adherence through a mutually agreed corrective action plan.
Training
AtlasEdge’s Code of Conduct highlights to employees the expectations it has of suppliers and the fact that it works with suppliers to assess their risk and performance on environmental, social and ethical activities, including human rights and labour.
AtlasEdge aims to ensure an ongoing high level of understanding among its workforce of the risks of modern slavery and human trafficking in supply chains and the AtlasEdge business. Accordingly, all employees are required to undertake Code of Conduct e-training during the year. All relevant stakeholders are also provided with the details of an independent whistleblowing hotline to whom they can make disclosures anonymously.
Approval
This Statement constitutes AtlasEdge Group’s slavery and human trafficking statement for the financial year ending December 31, 2024. The Board of Directors of AE Group S.à r.l. approved this Statement and delegated authority to sign this Statement on its behalf to its General Counsel, Natalie West, at its board meeting on 26 March 2025.