AtlasEdge Data Centres Modern Slavery Act Statement
January 2024
In 2024, AtlasEdge Data Centres maintains its commitment to respecting all human rights, including the elimination of slavery and human trafficking in our supply chains 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 2024 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 a pan-European edge data centre provider with a data centre portfolio that allows customers to design and configure their technology and network infrastructure to meet the growing requirements for lower latency, higher performance and localised solutions. The portfolio includes data centers in key markets across Europe, including Amsterdam, Barcelona, Berlin, Brussels, Copenhagen, Dusseldorf, Hamburg, Leverkusen, London, Madrid, Milan, Paris 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 comprises the key elements of our Anti-Bribery & Corruption Policy.
We provide a workplace that is positive, creative and rewarding, giving every employee the opportunity to achieve their full potential and contribute to our Group’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 Compliance, People or Legal teams or the General Counsel. Additionally, a Compliance contact line and web-based reporting system are operated by a third-party vendor and are available 24 hours a day, seven days a week.
Supply Chain
Supplier assessments and monitoring
The risk of slavery and human trafficking in our business sits predominantly in our supply chain.
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 policy and that all suppliers with a higher potential risk of modern slavery confirm (on an annual basis) that they comply with our policy. 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.
We rely on all of our suppliers to meet the disclosure requirements under the Act and to undertake the necessary due diligence to ensure that there is no modern slavery or human trafficking in their operations and supply chains. 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.
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, 2023. 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 22 February 2024.