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Hero Green Bond

Committed to Ethics and Integrity

Good Governance

We are dedicated to conducting business consistent with the highest standards of business ethics. Our Code of Business Conduct and Ethics sets forth our policies and standards on conflicts of interest, corporate opportunities, confidential information, competition and fair dealing, gifts and entertainment, protection and use of company assets, company records, accuracy of financial reports and other public communication, compliance with laws, regulations and insider trading laws, public communication, environment, health and safety, and employment practices.

In 2019, we revised our Code to include policies on labor and human rights, and supporting the principles contained within the Universal Declaration of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. The Code applies to all directors, officers, employees and agents, wherever they are located and whether they work for Digital Realty on a full or part-time basis and is available to all employees globally. We require written acknowledgment from employees that they understand and comply with the Code every year during our annual attestation program. For full information on our Corporate Governance, including management structure, Board of Directors, committee charters and policies, see Investors page.

Ethics and Integrity

Digital Realty has a zero-tolerance policy on corruption and bribery. We comply with the US Foreign Corrupt Practices Act, the UK Bribery Act, the UK Modern Slavery Act 2015, the German Criminal Code and other applicable laws. Our Foreign Corrupt Practices Act (FCPA) and Anti-Corruption Compliance Policy is administered by the General Counsel. All employees are required to both read the policy and undergo training for the policy during Digital Realty’s annual attestation period. Our annual attestation covers training on our Insider Trading Policy, our FCPA and Anti-Corruption Compliance Policy, and anti-money laundering compliance. In 2019, 100% of Digital Realty employees received this training. All members of our Board of Directors also receive these policies and procedures.

All employees are provided information on how to report questionable ethical behavior or violations of the Code. Information can be reported to their supervisor or senior management. They can also send communications anonymously via a confidential hotline. In 2019, we did not have any confirmed incidents of corruption.

We require that our suppliers and their employees, agents and subcontractors share the same high standards of ethics and integrity. Our Supplier Code of Conduct outlines core company principles and describes the requirements for our suppliers to establish and maintain a business relationship with Digital Realty, supporting a professional environment where all are treated with respect and dignity, and in an environment where their health and safety are protected.

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