Applying the Code of Conduct

Everyone working for Xstorage, regardless of location or role, must comply with the Code and the company policies. The Code seeks to ensure that the aspirations embodied in our Values are reflected in our daily actions and decisions and in our corporate culture.


This Code applies to all permanent and temporary employees, directors and officers as well as contractors (where they are under a relevant contractual obligation)


The Code does not include prescriptive rules covering every eventuality. It defines the minimum requirements and provides direction and guidance in applying our Values. In the absence of guidance from applicable law or external requirements, in the Code, or in the relevant supporting documents, you are expected to exercise sensible judgement.


All permanent and temporary employees, contractors, directors and officers must familiarise themselves with the Code, standards and policies, and the applicable laws relevant to their work. Behaviour that is in breach of the law, this Code or our policies, must be reported to a supervisor or manager.


Lack of compliance with the requirements of the Code, relevant Xstorage policies or the law, may result in disciplinary action, including termination of employment.

Joint ventures

When we enter into joint ventures where we are not the operator, we seek to influence our partners to adopt similar policies and procedures to those of Xstorage wherever possible.

Responsibilities of leaders

All our leaders, supervisors and managers must lead by example and be seen to work with integrity while creating an environment where team members:

• are encouraged and trained to do the right thing;

• are able to ask for and receive appropriate guidance if they are uncertain what to do; and

• feel comfortable raising questions or concerns without embarrassment or fear of retaliation.

We expect managers, supervisors and leaders to communicate our Values and the Code to their teams and proactively identify, assess and discuss relevant issues with them, as well as to implement appropriate risk mitigation controls. They must seek to prevent breaches of the Code through strong leadership and ensure that relevant policies and procedures are properly implemented and followed.


We seek to ensure that our suppliers, including contractors, maintain:

• lawful business practices;

• agreed standards of quality and timeliness of delivery;

• safe, healthy and fair workplaces;

• zero tolerance for human rights violations, in relation to both their people and the communities in which they work; and

• business practices that minimise environmental impact.

Where appropriate, these requirements should be supported through communication, training and/or contractual arrangements. We may terminate (or decline to renew) the contract of any provider or contractor who breaches the law, the Code or Xstorage’s relevant policies.

Raising concerns

You must raise promptly any situations in which the Code, its underlying policies or the law appear to be breached with a supervisor or manager. Alternatively, concerns can be raised with the appropriate manager in human resources, legal, corporate affairs, sustainability or senior management, or with your local compliance contact, whose details are available in the Compliance section of the Group intranet or on notice boards.

Health and safety

The safety of our people is our number one priority. We believe that all fatalities, occupational diseases and injuries are preventable and that we must all take responsibility for maintaining a safe and healthy workplace.

Our people

Our people are fundamental to our success. We believe that a diverse workforce is essential for a successful business. We treat our people fairly and with respect, and ensure they have the opportunity to develop their careers to match their potential. We are committed to upholding the International Labour Organisation Declaration on Fundamental Principles and Rights at Work.

Human rights

We support and respect human rights in a manner consistent with the Universal Declaration of Human Rights. We uphold the dignity, fundamental freedoms and human rights of our employees, contractors and the communities in which we live and work, and others affected by our activities. We ensure that human rights awareness is embedded in our internal risk assessment processes.


We believe that our operations have a predominantly positive impact on the communities in which we operate. We aim to build lasting relationships with our neighbours by identifying and addressing their concerns, and by contributing to activities and programmes designed to improve their quality of life.


We are aware that our operations can have direct and indirect impacts on the environment. In everything we do, we seek to minimise any negative impact on the environment in accordance with the precautionary principle.


We are committed to full compliance with relevant laws and external and company reporting requirements, including those concerning disclosure to tax authorities and reporting on the tax payments that we make.


We believe in the importance of maintaining active engagement and dialogue with stakeholders. We are committed to communicating regularly, openly and accurately with our employees, contractors, customers, suppliers, local communities, and investors, as well as appropriate associations, governments and other stakeholders.