We are committed to operating in accordance with strong ethical principles. We expect everybody working for Xstorage to take personal responsibility for ensuring that their conduct conforms to these principles.

We will not knowingly assist any third party in breaching the law, or participate in any criminal, fraudulent or corrupt practice. We seek to prevent such misconduct through training programmes and strong leadership underpinned by internal policies, procedures and controls.

Conflict of interest

A conflict of interest is a situation in which an individual has a private interest sufficient to potentially influence the objective exercise of his or her professional duties. Everybody working for Xstorage must avoid actual conflicts of interest and, wherever possible, avoid apparent or potential conflicts as well. We must safeguard Xstorage’s legitimate interests through properly performing our professional duties. Any concerns around an actual or potential conflict of interest or an unclear situation should be immediately referred to an appropriate supervisor, manager or compliance contact. Contractors, suppliers and partners are engaged through a fair, formal process that includes, where appropriate, written requirements reflecting our Values and policies.


A bribe is any financial or other advantage which is offered, provided, authorised, requested or received as an inducement or reward for the improper performance of a person’s relevant function.

The receipt of a bribe constitute an improper conduct. You must not solicit, accept, offer, provide or authorise any bribe either directly or indirectly or through any third party.

Any concerns about potential bribery must be reported to a manager, supervisor or an appropriate compliance contact or, where appropriate, through the ‘Raising Concerns’ programme.

A public official may offer to enable or speed up a process that is his or her duty to perform, in return for a small payment. Such payments are often called facilitation payments and should not be made. All dealings with public officials must be transparent and we must guard against circumstances where even the appearance is made of inducing a public official to perform his or her work improperly. Further guidance on this matter can be obtained from the global anti-corruption policy or an appropriate compliance contact.

Anyone working for Xstorage who fails to comply with applicable anti-corruption laws and the Xstorage Anti-Corruption Policy may face disciplinary action that could include dismissal.

Political contributions and activities

We do not permit any of our funds and resources to be used as a contribution towards a political campaign, political party, political candidate or any affiliated organisations.

We will not use charitable donations as a substitute for political payments.


We are committed to the principles enshrined by competition laws.

We expect everybody working for Xstorage to be aware of competition laws, to avoid infringement and ensure that suppliers or trade customers are not engaging in anti-competitive activities that could damage our business or reputation.

We provide our at-risk employees with specific training and guidance on what actions may breach the law and the practical steps that can be taken to ensure compliance.


Sanctions are laws, regulations and compulsory measures enacted by governmental authorities in relation to particular states, regimes, entities and individuals.

Such laws, regulations and measures may directly or indirectly restrict transactions involving goods, services, payments and capital transfers, or the movement of persons. They may also include other prohibitions, licensing and reporting obligations. You must respect and uphold any applicable sanctions.

Money laundering

Money laundering is a process whereby the origin of funds generated by illegal actions is concealed and those funds are inserted into economic circulation, making them seem as though they are derived from a legitimate source.

We will not participate or assist any third party in money laundering or any other illegal practice. We encourage and support everybody working for Xstorage to report to a supervisor, manager or compliance contact any concerns relating to a current or prospective counterparty being engaged in money laundering.

Inside information

We have systems and processes in place that help to ensure that inside or confidential information about Xstorage is secure and protected.

Inside information:

  • is precise and material in that it would be likely to affect an investor’s decision about whether to make a transaction relating to the Group’s securities
  • has not been made public
  • relates directly or indirectly to Xstorage or another company that we are doing business with or are seeking to acquire securities in
  • could have a significant effect on the price of securities if made public.

Inside information should not be used when making decisions on when to deal in securities. Employees or contractors who are in possession of inside information relating to Xstorage must not disclose this information to anybody else, including family members.

Confidential information about publicly traded companies may also constitute inside information. Anybody working for Xstorage who obtains such information about another company during their work will be subject to similar restrictions concerning the securities of that company.