GDS EHS (Environment, Health, Safety) Policy

As one of China's leading high-performance data center operators and service providers, the company attaches great importance to environmental governance, as well as the health and safety of employees and partners. It commits to formulating clear and transparent EHS policies, proactively conducting information disclosure, and accepting supervision from the public and stakeholders.

1. Scope of Application

This policy applies to all employees and contractors of GDS Holdings Limited, its consolidated subsidiaries, consolidated variable interest entities, and other affiliated companies. We request suppliers, business partners, and other stakeholders to comply with this policy.

2. Guiding Principles

Comply with laws and regulations, and pursue continuous improvement;

Save energy and reduce carbon emissions to protect the environment;

Prioritize safety and put people first;

Focus on prevention to eliminate hidden risks;

Implement standardized management to strictly control risks;

Achieve scientific development and give back to society.

3. Governance Structure and Responsibility Mechanism

The company has established an efficient management system to ensure effective monitoring of EHS risks and opportunities, and to maximize economic, environmental, and social values. The Board of Directors, as the highest governance body, provides overall guidance and supervision on environmental management, occupational health, and safety-related affairs. The Sustainability Committee and Risk Management & EHS Committee are responsible for promoting the formulation and supervision of environmental, occupational health, and safety policies. Various functional departments implement specific tasks in actual operations. Through multi-level management with clear responsibilities, the company ensures accountability and the effective implementation of policies.

4. Environmental Compliance and Management

4.1 Compliance and Training

Adhere to environmental laws, regulations, and requirements of the ISO 14001 environmental management system in the regions where the company operates, and establish corresponding evaluation processes to ensure legal and compliant operations. Establish an employee training mechanism to enhance employees' awareness of key issues such as energy conservation, emission reduction, water resource management, and waste disposal. Proactively communicate environmental issues with internal employees and external stakeholders to improve overall awareness of sustainable development. GDS encourages employees to actively participate in optimizing data center energy efficiency, promptly report abnormal energy consumption of equipment, and requires that waste electronic equipment must be recycled environmentally through designated company channels. Disposal of components containing heavy metals or hazardous chemicals (such as batteries) by individuals is strictly prohibited.

4.2 Performance Improvement and Goal-Driven Actions

GDS is goal-driven in actively carrying out environmental protection and sustainable development initiatives to continuously improve environmental performance. The company has joined the Science Based Targets initiative (SBTi), made commitments in areas such as energy efficiency management, renewable energy use, and building environmental impact, and regularly evaluates the achievement of environmental goals, adjusting management strategies in a timely manner to achieve dynamic optimization.

By 2030, achieve carbon neutrality in operations and increase the proportion of renewable energy to 100%.

For data centers put into use after 2020 with a utilization rate exceeding 30% and using new technologies and architectures, the annual average PUE shall reach 1.20.

100% of self-built data centers put into use since 2020 shall apply for green building certification to provide customers with green data center solutions.

4.3 Key Management Areas and Policy Requirements

Production, Operations, and Facilities

The company fully implements green concepts in data center site selection, construction, and daily operation and maintenance, and conducts refined energy efficiency management. With the continuous optimization of PUE (Power Usage Effectiveness) and WUE (Water Usage Effectiveness) as core goals, it introduces feasible solutions such as intelligent energy efficiency management systems, high-efficiency cooling systems, modular power supply architectures, and water recycling technologies to ensure data centers achieve both high performance and low carbon emissions. At the same time, it promotes the procurement of green electricity and green certificates, and implements real-time environmental monitoring, striving to achieve "energy consumption transparency, controllable indicators, and green operations."

Waste Management

For solid waste and hazardous waste generated during data center construction, operation, and upgrading, the company implements full-chain refined management, clarifies classification standards and disposal procedures for various types of waste, and requires general contractors and other service providers to cooperate in implementing green construction site and transportation specifications. During the operation period, it strengthens the compliant disposal of waste equipment and other materials, and establishes a closed-loop cooperation relationship with professional recycling enterprises to systematically promote resource recycling work with scientific methods to enhance recycling efficiency and effectiveness.

Products and Services

The company attaches great importance to environmental impacts in data center product design and operation services. It introduces energy-saving redundancy strategies in standard cabinets, modular systems, and customized deployment solutions; and integrates energy efficiency monitoring, energy-saving technologies, carbon emission calculation, cooling load optimization, and other means to form green data center solutions, helping customers achieve their own carbon emission reduction goals.

Suppliers, Service Providers, and Contractors

The company requires all partners to strictly comply with environmental protection laws and regulations in the regions where they operate, and clarifies their environmental compliance requirements through the Sustainability and EHS Commitment Letter. Environmental due diligence and EHS audit links are set up in the cooperation process, covering core dimensions such as energy structure, pollutant emissions, and resource utilization efficiency. Major service and equipment suppliers are required to submit environmental performance data or certifications (such as ISO 14001) and be promoted to gradually adopt green manufacturing and carbon reduction roadmaps. Major outsourcing service projects are also included in the environmental assessment mechanism and audit plan. The company also promotes green collaboration through the procurement team, and arranges corresponding incentive mechanisms for suppliers with outstanding performance in environmental protection and carbon reduction.

Other Key Business Partners

The company requests all business collaborators (such as joint ventures, licensees, and outsourcing teams) to refer to and adopt the company's environmental management standards in their business activities. Green operation clauses are included in cooperation agreements to promote them to share environmental data, accept environmental audits, or on-site evaluations during project implementation. In co-branded or operational projects, the company will play a leading role in setting green bottom-line evaluations and guiding partners to continuously improve.

Due Diligence, Mergers, and Acquisitions

In investment, merger and acquisition, and strategic cooperation projects, the company incorporates environmental factors into pre-investigation, value evaluation, and post-integration. The review includes the target company's historical environmental compliance records, data center energy efficiency (such as PUE/WUE), renewable energy usage, carbon emission baselines, and existing improvement plans, etc. For projects with identified environmental risks, mitigation measures or additional integration clauses are formulated to ensure that business growth and sustainable development complement each other.

5. Occupational Health and Safety Management

5.1 Compliance with International Standards and Regulations

The company strictly complies with applicable national/local laws and regulations, international standards, industry standards, and the Occupational Health and Safety Management System (ISO 45001). It has established a GDS occupational health and safety management system covering all businesses, including hazard identification, risk assessment, and emergency response. It also refers to the World Health Organization (WHO) and International Labour Organization (ILO) occupational safety guidelines to strengthen compliance in all links. Health and safety requirements are embedded into daily management and various operational processes to ensure the efficient advancement of the management system.

5.2 Goal Setting and Performance Disclosure

The company formulates clear occupational health and safety goals, regularly reviews and updates them based on implementation progress, and continuously optimizes occupational health and safety management measures through performance monitoring and regular disclosure mechanisms.

Goal: Total Recordable Incident Rate (TRIR) ≤ 1.0

5.3 Risk Identification, Prevention, Reporting, and Responset

The company has established an occupational health and safety risk prevention and control mechanism. All departments regularly conduct joint assessments of occupational health and safety risks and hidden dangers to comprehensively identify risk factors in all links. Priorities are classified based on risk probability and consequence severity, and corresponding mitigation action plans are formulated for high, medium, and low risks to ensure efficient risk management.

The company provides occupational health and safety guidance training and necessary personal protective equipment for employees, contractors, and other relevant personnel, ensuring that practitioners master emergency evacuation procedures, first-aid skills, and post-specific emergency operation specifications to reduce the incidence of safety accidents from the source.

The company is committed to building a sound emergency management system and strengthening full-chain risk prevention and control. All departments must formulate preventive management systems and hierarchical emergency response plans for emergencies such as potential safety accidents, natural disasters, and public health incidents in production and operation. They must also systematically maintain and drill the full-system emergency response procedures annually, focusing on clarifying operational specifications for key links such as on-site command and coordination, personnel safety evacuation, medical first-aid disposal, and environmental impact monitoring in emergency situations. This ensures that the response mechanism can be quickly activated in emergencies, minimizing negative impacts on on-site personnel safety, the surrounding community environment, and enterprise operational order, and building a solid safety defense line.

The company has established an occupational health and safety accident reporting mechanism, which classifies incidents into different levels. After an accident occurs, it must be reported within the specified time limit. The relevant department shall take the lead in establishing an investigation team, initiate an investigation within the specified time, conduct analysis and judgment, and issue a report. It shall also standardize the handling process, implement rectification measures and accountability, conduct regular reviews and summaries, and improve the prevention and control system to ensure timely response and loss reduction.

5.4 Consultation, Participation, and Cultural Co-construction

The company continues to listen to employees' voices, actively consults with employees in formulating and implementing occupational health and safety policies, complies with voluntary plans and/or collective agreements, encourages all employees to participate in communication regarding EHS matters, organizes health promotion activities, and encourages employee participation to promote the establishment of a safety culture with full participation.