By issuing and implementing the GDS Code of Business Conduct, GDS has established the basic principles, important policies and procedures with which should be complied when engaging in business activities. While complying with the applicable laws and regulations, GDS is also committed to complying with the highest standards of the code of business ethics. For the business relationship between the employees and between the employees and the users, clients and suppliers, shareholders and other relevant parties, GDS is also committed to complying with the highest standards of business conduct guidelines. To this end, GDS hereby issues the GDS Supplier Code of Conduct (hereinafter referred to as "Supplier Code of Conduct"), applies the same in the business relationship between the suppliers and GDS and requests the suppliers to follow.

Compliance with the Supplier Code of Conduct

The Supplier Code of Conduct applies to all projects, equipment, services and other various suppliers of GDS Holdings Limited, its consolidated subsidiaries, consolidated VIE entities and other affiliates (collectively "GDS"). The suppliers must comply with and implement and shall request their employees, subsidiaries, affiliates, agents and subcontractors and sub-suppliers (the aforementioned suppliers and their employees, subsidiaries, affiliates, agents and subcontractors) (collectively "Suppliers") to comply with and implement the Supplier Code of Conduct in their business operation and the whole supply chains. When any Supplier is aware of any situation that causes it to breach the Supplier Code of Conduct, it shall promptly notify the contact person of GDS (a management member of GDS) or the contact person specified at the end hereof. GDS reserves the right to conduct necessary verification of the Suppliers' compliance with the Supplier Code of Conduct.

Compliance with applicable laws and regulations

When conducting business with and/or on behalf of GDS, the Suppliers must fully comply with all applicable laws and regulations in their business activities and must satisfy the following requirements (including but not limited to):

• Anti-corruption and anti-bribery. The Suppliers shall comply with the anti-corruption and anti-bribery laws and regulations and international conventions of the PRC and all applicable countries and regions, including but not limited to the PRC Anti-Unfair Competition Law and the U.S. Foreign Corrupt Practices Act ("FCPA") and the Hong Kong Prevention of Bribery Ordinance. The Suppliers shall resist corruption and bribery, and shall never directly or indirectly offer, pay or promise or authorize to give any government authority, company, enterprise or other organization or association, government official or non-state functionary any remuneration, gifts and anything of value, entertainment, or other benefits in violation of the applicable laws or regulations or the rules and regulations of the entity to which they belong, for the purpose of obtaining or retaining businesses, or seeking transaction opportunities or competitive advantages or obtaining any improper benefits. The Suppliers shall develop and establish relevant anti-corruption and anti-bribery policies and systems and shall have corresponding audit items in place in order to supervise the implementation thereof.

• Anti-money laundering. The Suppliers shall comply with the anti-money laundering laws and regulations and international conventions of the PRC and all applicable countries and regions, including but not limited to the Anti-Money Laundering Law of the PRC and the Law of the PRC on the People's Bank of China. The Suppliers shall conduct the identification of clients, keep the clients' data and the transaction records, and promptly report any high-value transaction or suspicious transaction. The Suppliers shall strictly comply with regulations in relation to the supervision of anti-money laundering and counter-terrorism financing and shall carry out internal controls over anti-money laundering.

• Antitrust and fair competition. The Suppliers shall comply with the antitrust and fair competition laws and regulations of the PRC and all applicable countries and regions, including but not limited to the Anti-Monopoly Law and the Anti-Unfair Competition Law of the PRC. None of the Suppliers shall participate in the price-fixing, classification of markets or clients, division of markets or bid rigging with competitors, and other related actions.

• Import and export controls and sanctions. The Suppliers shall comply with the import and export controls, trade restrictions, sanctions laws and regulations and international conventions of the PRC and all applicable countries and regions. The Suppliers shall, at the request of GDS, provide GDS with the information and supporting documents in respect of the commodities, software and technologies provided by them and cooperate with GDS in compliance in this field.

Business ethics

The Suppliers must carry out business interactions and activities with integrity and must satisfy the following requirements (including but not limited to):

• Conflicts of interest. The Suppliers shall avoid all conflicts of interest and the situations that may lead to potential conflicts of interest, including the conflicts of interest between any individual (including such individual's spouses, family members and friends) and GDS, as well as the situations that may lead to potential conflicts of interest. An example of a conflict of interest or which may lead to a potential conflict of interest is that any employees, officers or directors of GDS (or their spouses, family members or friends) obtain personal benefits from or have business with any Suppliers. When any conflict of interest or any situation that may lead to a potential conflict of interest occurs, the Suppliers shall immediately notify GDS.

• Business records. The Suppliers shall record and report all business information honestly and accurately and comply with all applicable laws and regulations in respect of the completeness and accuracy thereof. The Suppliers shall create, retain and process the business records in full compliance with all applicable laws and regulations.

• Gifts and entertainment. The Suppliers shall not provide gifts or entertainment for the purpose of obtaining improper benefits or attempting to influence business decisions. When providing gifts or entertainment, the Suppliers shall ensure that such gifts or entertainment are reasonable and not extravagant, reasonable frequency, and occur during the normal course of business. When providing gifts or entertainment, none of the Suppliers shall violate the applicable laws and regulations and the rules and regulations of the organizations to which the receipts of such gifts or entertainment. The Suppliers shall also comply with the aforementioned regulations when providing gifts or entertainment to any employees of GDS.

• Insider trading. The Suppliers shall comply with the applicable securities laws and regulations. The Suppliers and their personnel are prohibited from using non-public information obtained in business with GDS for stock and other securities transactions.

Intellectual property protection, information security and privacy protection

The Suppliers shall respect and protect the intellectual property, comply with the applicable laws and regulations that protect intellectual property, and shall not infringe on intellectual property. The Suppliers shall strictly keep the confidential information obtained during the cooperation with GDS in confidence and shall not use such confidential information for any purpose other than the cooperation with GDS. The Suppliers shall comply with the applicable laws and regulations on personal privacy protection and take appropriate measures to prevent personal information from being disclosed or used without permission.

Employment and fair employment practices

The Suppliers shall comply with the applicable laws and regulations on labor and employment and must satisfy the following requirements (including but not limited):

• Prohibition of child labor. Under no circumstances shall the Suppliers employ any child labors. The Suppliers shall not employ any persons under the age of 16 or under the legal minimum working age (whichever is more stringent).

• Prohibition of forced labor and human trafficking. Forced labor and human trafficking by Suppliers are prohibited. It is prohibited to support or participate in any form of human trafficking or forced labor through threats, force, fraud or other coercion.

• Non-discrimination and harassment. The Suppliers are prohibited from any discrimination in hiring and employment of persons based on race, cultural background, religion, age, sex, nationality, sexual orientation, marital and family status, disability, or other circumstances protected by applicable laws and regulations. The Suppliers shall provide a work environment free from harassment and are prohibited from abusing or coercing any employees in a harsh or inhumane manner and from sexual harassment.

• Working hours and wages. The Suppliers shall comply with the applicable laws and regulations on working hours, overtime work and wage standards. The Suppliers shall respect the employees' right to rest, pay wages that meet or exceed the local statutory minimum wage standard for all working hours, and shall pay overtime wages in accordance with applicable laws and regulations if overtime work is required.

• Health and safety. The Suppliers shall provide a safe working environment and establish a health and safety management system to protect the health, safety and well-being of employees, contractors, visitors and other persons that may be affected by the Suppliers' activities. The Suppliers shall comply with all applicable laws and regulations on environment protection, health and workplace safety.

Environment protection and sustainable development

• Environmental protection. GDS is committed to environmental protection. The Suppliers shall comply with all applicable laws and regulations on environment protection, including but not limited to laws and regulations governing hazardous substances, emissions of air pollutants, sewage discharge, and waste disposal, as well as laws and regulations that prohibit or restrict the use of specific substances in manufacturing or product design and clients' requirements. The Suppliers shall obtain and maintain the environmental protection permits, approvals and/or filings necessary for their business as required in the applicable laws and regulations. The Suppliers shall establish and implement the rules and regulations in relation to environmental management to prevent environmental pollution incidents. GDS encourages the Suppliers to obtain environmental management system certification, such as ISO14001.

• Sustainable development. GDS is committed to sustainable development, which is one of the core goals of GDS's business. GDS encourages the Suppliers to establish and implement corporate sustainable development and social responsibility management systems, develop corresponding management goals, and encourages the Suppliers to disclose annual corporate sustainability reports and corporate social responsibility reports.

Community interaction

The Suppliers shall not bring material adverse impact on the surrounding communities during the course of business. GDS encourages the Suppliers to participate in interactions with surrounding communities, such as charity activities.

Correction, improvement and accountability

The Suppliers shall supervise themselves and prove their compliance with the Supplier Code of Conduct. GDS may audit the Suppliers or inspect their facilities to confirm their compliance. If there is any breach of the Supplier Code of Conduct, GDS shall have the right to request the Suppliers to make corrections within a reasonable period. If the Suppliers repeatedly or materially breach the Supplier Code of Conduct, GDS shall have the right to take appropriate actions, including but not limited to terminating the contract or cooperation, making up for losses suffered by GDS and reserving the right to further hold the Suppliers legally liable therefor.

Raise concerns and report suspicious acts or violations

If you want to report any suspicious acts or acts that may violate the Supplier Code of Conduct, you are welcome to cooperate with your main GDS contact person to resolve your concerns. If it is not possible or the situation is not suitable, please contact GDS by any of the following methods:

Reporting line: +86 021 5831 5858

Reporting email: ethics@gds-services.com

Reporting letter: GDS legal and compliance department, 5/F, Block C, Sunland International Center, 999 Zhouhai Road, Pudong District, Shanghai, 200127

Compliance web page: http://www.gds-services.com

GDS will keep the reported information and the reporter confidential and will not tolerate any punishment and retaliation against any individual who seeks advice in good faith or reports the suspicious acts or the acts that may violate the Supplier Code of Conduct.

For more details and information, please visit: www.gds-services.com/en/supplier-code-of-conduct