Effective: 01 July 2026
- Purpose and Scope
DayOne Data Centers Limited (and all its subsidiaries, affiliates, and associated entities) (“DayOne”) is committed to conducting business with honesty, integrity and professionalism, and to maintaining the highest ethical and sustainability standards across our supply chain. This Code sets out DayOne’s minimum standards and expectations for all suppliers providing goods and/or services, including consultants, contractors, subcontractors and key sub-suppliers (“Supplier” or "Suppliers").
For clarity, DayOne is committed to applying in its own business operations the same core principles reflected in this Code. DayOne maintains internal policies, controls, training, reporting channels and oversight processes designed to promote integrity, compliance with applicable laws, respect for human rights and labor standards, workplace health and safety, environmental responsibility, privacy and information security, fair dealing, responsible procurement and good governance by its directors, officers and related personnel. DayOne expects its personnel to engage with Suppliers fairly, professionally and consistently with these principles, and prohibits retaliation against anyone who raises a concern in good faith.
Suppliers are responsible for compliance with this Code across their operations and supply chains, for promptly notifying breaches, and for taking reasonable steps to remedy and prevent recurrence.
We reserve the right to conduct audits, assessments and request supporting evidence. Suppliers are expected to cooperate fully.
Suppliers are expected to maintain internal controls and practices proportionate to their size and the nature of their business, to support compliance with this Code.
- Legal Compliance and Ethical Conduct
Suppliers must comply with all applicable laws and regulations and conduct business ethically and with integrity.
Anti‑Bribery/Corruption, Anti-Money Laundering and Fair Dealing
Suppliers shall conduct business ethically, fairly, and with integrity, and shall not engage in bribery, corruption, anti-competitive conduct, money laundering, terrorist financing, or violations of applicable sanctions or export control laws. Suppliers must comply with all applicable anti-bribery, anti-corruption, fair competition, anti-money laundering, counter-terrorist financing, sanctions, and other financial crime laws in any jurisdiction where they operate or interact with DayOne. Suppliers are expected to deal only with legitimate and reputable business partners, for lawful business purposes, and through legitimate means. Suppliers are also strongly encouraged to maintain policies, controls, training, and monitoring measures proportionate to the nature, size, and risk profile of their business.
Conflicts of Interest
Actual or perceived conflicts of interest shall be avoided and promptly disclosed. Examples of conflicts include a material financial interest in DayOne, or a close personal relationship with a company employee who can influence a procurement or contracting decision. Where any such situation arises or is reasonably anticipated, the Supplier must disclose it to the designated ethics or compliance contact without delay.
Gifts, Meals and Entertainment
Business courtesies are expected to be modest, lawful, culturally appropriate, and serve a genuine business purpose. They must never be intended to influence a business decision or be capable of being construed as a bribe/kickback or improper payment. Suppliers must never offer gifts or entertainment to a DayOne employee or their immediate family members that fall outside these parameters or that violate any applicable laws or regulations.
Business Records and Insider Trading
Business records are expected to be accurate, complete, and retained in accordance with applicable laws. Where a Supplier receives confidential or non-public information in connection with its engagement with DayOne, such information must not be misused for personal or commercial gain.
- Intellectual Property, Privacy and Confidentiality
Suppliers must respect intellectual property rights and use them only as permitted, and notify DayOne of any unauthorized use, infringement or suspected infringement of DayOne’s intellectual property by any third party.
To the extent that a Supplier receives or processes DayOne’s confidential information or personal data in connection with its engagement, Suppliers are expected to protect such information using appropriate technical and organizational safeguards, comply with applicable[1] privacy and data protection laws, report data breaches promptly, and retain information only as long as lawfully necessary. This obligation survives the expiry or termination of any contract or engagement with DayOne.
- Labor, Human Rights and Workplace Standards
DayOne is committed to ethical labor practices and expects Suppliers to uphold the same standards throughout their own operations. Suppliers must respect internationally recognized human rights and comply with all employment and labor laws.
This includes:
- No forced, bonded, trafficked, compulsory/modern slave labor
- No child labor[2]
- Freedom of association and collective bargaining
- Lawful working hours, wages and benefits
- Fair, voluntary employment practices
- No harassment, bullying, corporal punishment or abusive conduct
- Accessible grievance mechanisms without fear of retaliation
Suppliers are also prohibited from withholding, destroying, concealing, confiscating, or otherwise restricting workers’ access to their identity or immigration documents, including passports, national identity cards, drivers’ licenses, or work permits. Workers must be free to resign from their employment in accordance with applicable law without unlawful penalty.
- Diversity, Equity and Inclusion
Suppliers are expected to comply with applicable anti-discrimination laws and treat all workers with dignity and respect, irrespective of race, gender, religion, nationality, age, disability, or any other characteristic protected by applicable law. DayOne encourages Suppliers to foster inclusive workplaces and to ensure hiring and employment decisions are based on merit.
- Health, Safety and Wellbeing
Suppliers are expected to provide a safe and healthy working environment, comply with occupational health and safety laws, and maintain appropriate safety management systems.
Workers should have reasonable access to clean sanitary facilities, potable water, and safe food preparation areas. Where housing or transport is provided, it must meet local safety and living standards.
- Environmental Sustainability
Suppliers must comply with all applicable environmental laws and permits. Suppliers are encouraged to minimize their environmental footprint/impact, including where practicable reducing emissions, waste, hazardous substances, energy and water consumption.
Suppliers are expected to manage hazardous emissions and waste responsibly and comply with any applicable prohibited or restricted substance requirements.
DayOne may, from time to time, request information about a Supplier’s environmental practices to support its own reporting obligations. Suppliers are encouraged to respond to such requests to the best of their ability.
- Communications and External Publications
Suppliers shall not publish, issue, or permit any marketing materials, press releases, social media content, case studies, or media interviews that reference DayOne, its customers, or the work performed together, without DayOne’s prior written approval. Any request to publish such content must be submitted to DayOne’s designated communications or marketing contact and will be considered on a case-by-case basis.
- Personnel Background Screening
Where personnel will access DayOne’s premises, systems, or confidential information, Suppliers are expected to conduct appropriate background screening (where appropriate and proportionate to the role and risk involved and as may be legally permissible) on such personnel and in accordance with applicable law and data protection requirements before such access is granted.
- Procurement Controls
Suppliers must not commence any work for DayOne without an authorized purchase order or written contract, where required by DayOne’s procurement procedures. Suppliers must not subcontract any work performed for DayOne to third parties without DayOne’s prior written consent. Where subcontracting is permitted, Suppliers must apply equivalent standards to subcontractors and conduct appropriate due diligence before engaging them.
- Responsible Supply Chains
Suppliers are expected to exercise reasonable oversight of their own subcontractors, take a risk-based approach to identifying and addressing human rights/environmental risks in their supply chains. Where a Supplier’s goods or supply chain involve the sourcing of minerals (including tin, tantalum, tungsten and gold), the Supplier must conduct appropriate due diligence to ensure that such minerals do not originate from conflict-affected areas or fund human rights abuses.
- Monitoring, Audits and Corrective Action
Suppliers must self‑monitor compliance, provide information upon request, support audits, and implement timely corrective actions for any non‑compliance. The nature and frequency of any monitoring or audit activity should be proportionate to the assessed risk and materiality of the Supplier relationship. Suppliers that act in a manner that is unlawful or inconsistent with this Code risk consequences up to and including termination of the business relationship. Non-compliance will generally be addressed through a tiered approach: (i) issuance of a corrective action plan with defined remediation timescales; (ii) probationary status pending verification of remediation; (iii) suspension of new business; and (iv) termination of the relationship where material or repeated breaches are not remediated.
- Questions, Reporting and Whistleblowing
The Supplier may report, in good faith, any suspicious acts or acts that may violate the Code by contacting its main DayOne contact person to resolve any concerns. If it is not feasible/possible, the Supplier prefers another avenue, or applicable law requires otherwise, the Supplier may contact DayOne by any of the following methods and DayOne will handle reports as confidentially as reasonably possible, consistent with applicable whistleblowing protection laws and the need to review and address the matter appropriately.
Reporting line: +65 6015 0522
Reporting email: compliance_reporting@dayonedc.com
Reporting letter: c/o DayOne Data Centers Singapore Pte Ltd,
Legal and Compliance Department,
5 Temasek Boulevard,
#10-01/02/06 Suntec Tower 5,
Singapore 038985
DayOne will treat reported information and the reporter’s identity confidentially to the extent reasonable and possible and in accordance with applicable law; and will not tolerate punishment or retaliation against any individual who seeks advice in good faith or reports suspicious acts or acts that may violate the Code.
Acceptance of, or continued engagement under, this Code constitutes agreement to comply with the requirements herein. This Code may be amended or updated from time to time and published on: https://dayonedc.com
[1] Including, where applicable, the EU General Data Protection Regulation (GDPR).
[2] Suppliers must not employ any person below the minimum legal working age under applicable law or below the minimum age established under internationally recognized labor standards, including internationally recognized frameworks such as the International Labour Organization (ILO) conventions.
