Our Commitment To the Law

Our Commitment To the Law

Understanding and adhering to lawful business practices

Being an ethical and honest company also means obeying the law. As a global company, we must comply with the laws in all the places we do business. And as Equinix employees, we are responsible for understanding and complying with all laws and regulations that affect our jobs.

Competition and fair dealing

At Equinix, we value a free and open marketplace and seek to outperform our competition fairly and honestly. We do not seek to obtain the proprietary information of others, possess trade secret information that was obtained without the owner’s consent, or ask past or present employees of other companies to share another company’s proprietary information with us.

We are committed to dealing fairly and honestly with all of our vendors, regardless of where they’re located or the type of products or services they provide. We engage in open and fair procurement, where vendors are selected on a competitive basis and establish a mutually beneficial relationship based on close cooperation and open communications.

Data privacy

Data privacy laws and regulations can be complex, and they vary from country to country. At Equinix, we respect the confidentiality of the personal information of our employees and work to keep that information private and only use that personal information in a reasonable and appropriate way for the purposes of your employment with Equinix. You are expected to follow all Company policies regarding the handling and retention of this personal information. If you have questions about data privacy, you should contact your local privacy officer.

Remember:

Always respect and protect confidential or proprietary information our vendors share with you–and let them know we expect them to use the same care with our information.

Anti-bribery and corruption

At Equinix, our business practices are based on honesty and integrity. We do not offer or provide bribes, kickbacks or other improper payments for any reason.

As a global company, we must comply with the anti-bribery and corruption laws in the countries in which we do business, including the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act. These laws strictly prohibit bribery and corruption, especially when government officials areinvolved. No Equinix employee, officer, agent or independent contractor acting on our behalf may offer or provide anything of value to anyone in order to obtain business or gain an unfair advantage. Violations can subject you and Equinix to severe penalties and damage our reputation.

The U.S. laws prohibiting bribery are very broad, which means many kinds of gifts or entertainment provided to government employees might be considered improper. For that reason, employees must not give, offer, promise or authorize any payment, benefit or gift of money or anything else of value to a government or public official, except under the very limited circumstances below. This rule applies whether you are giving the gift orother benefit yourself or through a third party, such as a distributor or independentcontractor.

This rule applies whether you are trying to secure business or seeking an advantage over others (such as special, preferential treatment not offered to competitors). Any gift or entertainment offered to a government or public official must meet these specific criteria:

Any entertainment must be reasonable, bona fide and directly
related to the promotion, demonstration orexplanation of products
or services–or linked to the performance of a contract between
Equinix and the government or public entity.
All gifts and entertainment must comply with all Equinix policies,
including our Travel and Expense Policy.
No gift or entertainment should ever be offered to a government
employee for the purpose of securing an improper business
advantage.

You must make sure that any gift you give in connection with your job is transparent, properly recorded in our corporate records and permitted under our policy. When reporting the gift, you must state the purpose of the gift and the person to whom you gave it. If the gift is for a government official, you should always obtain advance approval from the Compliance Office.

If you have any questions or need guidance in this area, contact Equinix’s Compliance Officer. If you are aware of a suspected or actual violation of this policy, you have a responsibility to report it promptly.

Intellectual property

Intellectual property includes copyrights, patents, trademarks, trade secrets and other intangible property. We take active measures to protect and enforce our own intellectual property rights, and we must use similar measures to protect the intellectual property of third parties. When sharing our intellectual property with third parties, we need to ensure that they agree to use and protect our property in accordance with our Equinix policies.

Many of the materials you use every day are protected by copyright laws, including computer software, books, manuals, audio and video resources, trade journals and magazines. Other less obvious examples of copyrightable works include presentation slides, training materials, management models and problem-solving methodologies. We should never knowingly infringe upon the intellectual property rights of others. Equinix strictly forbids the reproduction, distribution or alteration of any copyrighted materials without the permission of the owner or authorized agent. You should also make sure you never illegally copy or use company-licensed computer software for personal or business use.

Inside information and securities trading

You must not buy or sell Equinix stock if you possess any “material information” about the Company that has not been publicly disclosed (also known as “inside information”). Similarly, if you are aware of inside information about other companies, such as customers or vendors, you must not buy or sell the securities of that company. If you share inside information or provide insider “tips” to a third party who then trades on that information, you may be heldresponsible for the illegal trade. You may also be liable for trades made by someone else based on confidential information you shared with an outside party–including family members and friends. If you share inside information that influences a family member or friend to buy or sell Equinix stock, you may be criminally liable as a “tipper” under federal securities laws.

Equinix considers it improper for those who are employed by or associated with Equinix to engage in short-term or speculative transactions in Equinix’s securities or in other transactions in Equinix’s securities that may lead to inadvertent violations of the insider trading laws. Accordingly, your trading in Equinix securities is subject to the additional guidelines as more fully described in the Equinix Securities Trading Policy.

To make sure you are complying with laws against insider trading, please refer to Equinix’s Securities Trading Policy. If you have any questions, you should contact the Compliance Office.

Remember:

Inside information is confidential information that if made public would influence an investor’s decision to buy, sell or hold Equinixstock.