About This Policy

GDS deeply embeds the concept of sustainable development into the core of its corporate culture and operations. Adhering to high standards of corporate governance and actively fulfilling social responsibilities, GDS is committed to the harmonious coexistence of enterprises and society. This ESG policy outlines how we integrate these principles into corporate practices, strategic directions, and visions, ensuring alignment with global standards and stakeholder expectations.

1. Scope and Purpose of the Policy

Scope: This policy applies to all operations, facilities, and consolidated subsidiaries of GDS Holdings Limited and its consolidated subsidiaries, covering business activities across different geographical locations and cultural contexts.

Purpose: Integrate ESG principles into our business model, ensuring that environmental management, social responsibility, and governance integrity run through every business decision and operational practice to promote the company's sustainable development.

2. Environmental Management

2.1 Energy Efficiency

Data Center Efficiency: Invest in advanced data center infrastructure to improve operational efficiency and reduce energy consumption while ensuring high performance. Implement comprehensive energy management to optimize data center PUE and overall energy performance.

Renewable Energy Transition: Commit to gradually increasing the proportion of renewable energy, with the goal of achieving 100% renewable energy operations by 2030.

Lifecycle Green Data Centers: Achieve and maintain LEED or equivalent green building certifications across all regions, covering the design, construction, and operation phases of data centers.

2.2 Resource Management

Comprehensive Recycling Program: Develop internal recycling procedures to handle specific types of waste generated by data centers, including packaging, decommissioned hardware, and daily operational waste.

E-Waste/Hazardous Waste Management: Collaborate with certified recyclers to ensure the responsible recycling of electronic and hazardous waste.

Use of Sustainable Materials: Prioritize recycled and environmentally friendly materials in construction and daily operations to minimize environmental impact.

2.3 Climate Change Response

Carbon Footprint Assessment: Conduct a comprehensive measurement of our carbon footprint, including Scope 1, Scope 2, and Scope 3 greenhouse gas emissions.

Carbon Reduction Initiatives: Set goals for gradual carbon emission reduction, formulate Scope 1, Scope 2, and Scope 3 greenhouse gas reduction targets in accordance with SBTi (Science Based Targets initiative) or other scientific emission reduction planning tools, and strive to achieve operational carbon neutrality by 2030.

Offset Programs: Participate in carbon offset projects such as renewable energy or renewable energy certificate projects to balance residual emissions.

Climate Risk Response Strategies: Invest in technological and infrastructure improvements to enhance resilience against climate-related physical risks (e.g., floods and other extreme weather). Conduct comprehensive assessments to identify risks and opportunities posed by climate change to corporate transformation.

3. Social Responsibility

3.1 Employee Welfare

Human Rights Protection: GDS supports and respects human rights, adhering to the United Nations International Bill of Human Rights (comprising the Universal Declaration of Human Rights and related covenants) and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work and its Follow-up. It strictly prohibits child labor and forced labor, ensures equal pay for equal work, and respects and safeguards the legitimate right of all employees to freedom of association. We are committed to adhering to high standards in the handling and protection of employees' personally identifiable information (PII); opposing workplace discrimination; and promoting diversity. We also expect our suppliers and business partners to share these values to ensure their operations respect and support human rights.

Health and Safety Initiatives: To safeguard employees' physical and mental health and workplace safety, the company continuously conducts health and safety training to enhance employees' ability to respond to potential risks. Additionally, by providing external mental health resources, it helps employees understand their own and their families' health conditions and supports them in maintaining mental well-being and a healthy lifestyle.

Diversity, Equity, and Inclusion Programs: Formulate specific goals around diversity, equity, and inclusion, promote comprehensive practices in talent management-related areas such as recruitment, promotion, and retention, and support employees at all levels in career development and skill enhancement through learning, seminars, and certification programs.

Career Development: Through a comprehensive learning and development system, provide all employees with online and offline learning resources, seminars, and certification programs to enhance core competencies, enable career advancement and skill improvement, and achieve mutual growth and long-term development of the company and employees.

3.2 Community Engagement

Charitable and Public Welfare Participation: Collaborate with charitable organizations to participate in public welfare activities supporting various social causes, such as fundraising events and community service projects. To the extent feasible, the company makes regular donations to public welfare fund institutions that meet national standards to assist children with disabilities in need.

Volunteer Programs: Encourage employees to participate in community service and provide corresponding time support for employees engaged in such activities.

Local Recruitment Initiatives: Actively promote community employment and economic development through prioritizing local recruitment, while providing internships and apprenticeship opportunities for local students to cultivate regional talent and lay the foundation for the sustainable development of the enterprise and the community.

3.3 Stakeholder Engagement

Regular Stakeholder Surveys: Conduct regular surveys to collect feedback from customers, investors, and community members on our ESG initiatives and overall impact.

Enhanced Communication Strategies: Develop and regularly update multi-channel communication strategies, including through our website, annual reports, and direct communication, to ensure stakeholders are informed of our latest ESG initiatives and progress.

4. Governance and Ethics

4.1 Corporate Governance

Board Diversity and Expertise: Ensure our board represents diverse professional backgrounds and perspectives, including members with expertise in sustainability and ethics.员。

Ethics and Compliance: Provide comprehensive ethics training for all employees to strengthen awareness of ethical compliance.

4.2 Data Security and Privacy

GDS adopts a "zero-tolerance" attitude toward data breaches. The audit department regularly inspects potential data security risks and integrates data security risk management into the group's overall risk management process. We also expect suppliers and partners to comply with our data security and privacy requirements.

Comprehensive Security Framework: Implement a comprehensive security framework covering physical, administrative, and technical controls to protect the integrity, confidentiality, and availability of data. This framework complies with international standards such as ISO/IEC 27001/27701 and incorporates industry best practices. Conduct at least one information security risk assessment annually and update security controls based on the results. Continuously track emerging security threats and promptly deploy new technologies to enhance protection capabilities.

Regular Cybersecurity Audits: Conduct regular cybersecurity audits to identify vulnerabilities and ensure the integrity and confidentiality of customer data.

Data Privacy Compliance: Commit to complying with local/global data protection regulations. We ensure all personal data is processed legally and provide transparent privacy statements to our customers and users. Data is classified based on sensitivity and importance (e.g., public, internal, confidential) with differentiated protection measures. We adhere to the principle of least privilege, restrict data access through identity authentication (e.g., multi-factor authentication) and permission approval processes, and ensure data integrity during transmission and storage through log auditing, digital signatures, and other technologies.

Information Security Threat Monitoring and Response: Deploy real-time monitoring systems to detect network anomalies and malicious activities, and establish a hierarchical emergency response process to ensure timely handling of security incidents. High-risk vulnerabilities must be remediated within 48 hours, and root cause analysis must be conducted for all incidents to improve protective measures.

Enterprise-Wide Information Security Responsibility: All employees must receive annual security training and sign confidentiality agreements, with a prohibition on unauthorized data leakage. Management must ensure resource investment and incorporate security performance into assessments. Violators will face accountability measures ranging from warnings to contract termination.

Third-Party Information Security Requirements: Suppliers must pass security qualification reviews for access, and contracts must clearly specify data protection responsibilities and compensation clauses. The company will conduct regular audits of third-party operations and restrict their data access permissions to reduce risks.

4.3 Reporting and Disclosure

Enhanced Disclosure Practices: Adhere to sustainability reporting standards such as those of the Global Reporting Initiative (GRI) and the Sustainability Accounting Standards Board (SASB) to disclose detailed ESG performance and progress.

5. Implementation and Monitoring

5.1 ESG Committee

Role and Function Expansion: The ESG Committee will oversee the formulation of ESG goals, monitor the implementation of cross-departmental ESG work, and ensure ESG priorities are integrated into the company's strategy.

5.2 Performance Indicators

Key Performance Indicators (KPIs): Develop and track KPIs for each ESG domain, using data to guide decision-making and improvements. Deploy real-time monitoring systems to track energy usage, resource management, and waste reduction, providing actionable guidance for continuous improvement.

5.3 Employee Training

Customized Training Modules: Develop customized ESG training modules for different departments and positions to help employees gain a deep understanding of ESG concepts, integrate such concepts into their daily work, and enhance their participation and execution in advancing the company's ESG goals. Meanwhile, cultivate internal experts in the ESG field to support the company in achieving its long-term objectives.

6. Supply Chain and Value Chain Engagement

6.1 Responsible Sourcing

Supplier Selection: Implement strict supplier selection processes, evaluating potential suppliers based on their environmental policies, social practices, and governance structures. Use a scoring system to ensure transparency and objectivity in supplier evaluation.

Supplier Code of Conduct: Develop a comprehensive code of conduct specifying our expectations for environmental management, labor rights, and anti-corruption practices. All suppliers agree to comply with this code as a contractual condition.

Sustainable Procurement Practices: Prioritize procurement of materials and services that meet certified environmental and social standards, in line with relevant standards of the data center industry and stakeholders.

6.2 Supplier Auditing and Evaluation

Regular Audits: Evaluate key suppliers to fully understand their compliance with our ESG standards.

Reporting and Accountability: Require suppliers to regularly report their ESG performance, including specific indicators related to carbon footprint, waste management, and labor practices.

6.3 Sustainability Collaboration with Suppliers

Joint Sustainable Projects: Launch sustainable projects with suppliers, such as renewable energy projects, waste reduction, and energy efficiency improvement initiatives. Share resources and knowledge to enhance sustainability impact.

Training and Communication: Conduct various forms of sustainability topic sharing and training interactions with suppliers to promote knowledge sharing of sustainable practices.

6.4 Value Chain Optimization

End-to-End Engagement: In the future, strive to extend our ESG principles beyond direct suppliers to include secondary suppliers, customers, and end-users. Ensure our ESG efforts permeate the entire value chain.

Collaboration with Customers: Collaborate with customers to understand their sustainability goals and how we can support them through our products and services. This may include providing specially designed data center solutions that minimize environmental impact.

7. Review and Update

7.1 Annual Review

Policy Review Process: Incorporate feedback from internal and external stakeholders, adjusting and updating the policy as needed. Revise and improve the ESG policy based on annual review results, integrating the latest environmental data, social trends, and governance best practices.

7.2 Continuous Improvement

Budget Support: Allocate relevant budgets to support pilot projects for new methods aimed at improving ESG performance, such as deploying artificial intelligence to optimize energy usage.