Last reviewed & updated: October, 2024

MODERN SLAVERY POLICY STATEMENT

EXA Infrastructure is an award-winning portfolio company of I Squared Capital and the largest dedicated digital infrastructure platform throughout Europe, connecting North America and Asia via the Middle East. With over 20 years of experience in building resilient networks, EXA Infrastructure provides the critical modern infrastructure and unrivalled engineering expertise that serves as the backbone for digital and economic growth. This includes mission-critical networks for governments and enterprises, hyperscale infrastructure for the world’s most innovative and influential businesses, and ultra-low latency, high bandwidth networks for financial, gaming and broadcast services.

At EXA Infrastructure, we strive to maintain the highest standard of ethical principles and to respect human rights, both within our organisation and by encouraging high standards in our supply chain. To this end, all our employees are trained on and review and sign up to our Code of Business Conduct and Ethics (“Ethics Policy”) on an annual basis. As part of our Ethics Policy, we operate a confidential whistle-blower hotline to encourage disclosure of unlawful or unethical behaviour in a confidential environment free from fear of retaliation. All our employees are made aware of our whistle-blower hotline, which they can call to report any form of human rights violation. We continually monitor the implementation and adequacy of our Ethics Policy.

We have a zero-tolerance approach to slavery in any form and are committed to continuing to build on our practices to combat slavery and human trafficking. Although we believe that due to the nature of what we do, the risk of slavery in our supply chain is relatively low compared with other industries, we are not complacent about this risk and are alert to the fact that we have suppliers in geographical areas carrying out work for us that could be susceptible to the exploitation of people.

For all suppliers, we include we maintain a Supplier Code of Conduct on our website which specifies requirements applicable to our suppliers and other third parties conducting business with or on behalf of EXA Infrastructure in the areas of compliance with laws, human rights, safe working conditions, and business integrity. We also include contractual obligations in our standard paperwork requiring suppliers to comply with all applicable laws, including laws on modern slavery and human trafficking. If a supplier does not meet our standards we will implement an action plan, which may include termination.

EXA Infrastructure will annually review and ensure that our risk management policies are adequate. This statement covers the 2021 financial year and is made in accordance with the Modern Slavery Act of 2015,