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Ethics and Compliance Helpline

Frequently Asked Questions

About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX Global to help us at Equinix work together in preventing and addressing fraud, abuse, and other misconduct in the workplace, all while cultivating a positive work environment.

Why do we need a system like EthicsPoint?

  • EthicsPoint provides everyone at Equinix with an independent, secure channel of communication to air concerns, ask a question, seek guidance and share suggestions for improvement.
  • Publicly traded companies like Equinix are required by US law to have an anonymous reporting vehicle to address accounting and auditing fraud directly to the audit committee.
  • An effective reporting system augments our other efforts to promote a safe, diverse environment at Equinix built on honesty, self-respect, and accountability to one another.

Reporting – General

May I report using either the internet or the telephone?

Yes. With EthicsPoint, you can file a confidential report either by telephone or the internet.

What type of situations should I report?

The EthicsPoint system is designed for employees to report an incident or situation concerning our Code of Business Conduct, our policies or the law, or to share another concern you may have. You may also ask questions or seek guidance about the Code or any Equinix policy.

Do I have to provide my name?

That depends.

  • To report a concern through the EthicsPoint online form or the call center, you can choose to make an anonymous report if this is permitted by local law, or you can choose to provide your name. Giving your name and contact details could shorten the review process, so you will be invited to tell us who you are when first making contact.
  • To ask a question about the Code of Business Conduct or to manage a potential conflict of interest, you will need to provide your name before you can complete and submit the form.
  • Whether Equinix receives your name or not, we will make every reasonable effort to keep your information confidential. We will share it only with the people who review your reported concern, guidance question or approval request.

If I see an incident or situation that raises concerns, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

When you learn of a situation or observe behavior that you believe is inconsistent with the Equinix Code of Business Conduct, our policies or the law, we rely on you to report it promptly. Ideally, you should raise any concerns with your direct manager, or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable contacting management directly. In those situations, EthicsPoint provides you with an alternative channel to share your concerns.

Why should I report what I know? What's in it for me?

We all have the right to work in a positive environment, and with that right comes the responsibility to act in an ethical manner and let your manager or other appropriate people know if someone is not acting in the spirit or letter of the Equinix Code of Business Conduct, policies and procedures. We would rather you report through EthicsPoint, anonymously if you prefer and as allowed under local law, than keep the information to yourself. Corporate misconduct can threaten the livelihood of an entire company. Working together to address situations of concern, we can maintain a healthy and productive environment.

Does management really want me to report?

We certainly do. In fact, we rely on you to report. You know what is going on at Equinix, and you may know about a situation that could be cause for concern. Your prompt reporting can minimize the potential negative impact on Equinix and your coworkers. In addition, using the separate form provided to ask questions may help identify issues needing attention and improve our work environment, our performance and our commitments to our customers. In other words, your voice matters at Equinix!

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server to prevent a breach in security. EthicsPoint makes these reports available only to specific individuals at Equinix who are charged with reviewing your report or answering your question, based on the nature of the concern or question.

Isn't this system just an example of someone watching over me?

We believe EthicsPoint is a positive communication tool for Equinix. We want you and everyone else at Equinix to feel engaged and empowered to make ethical decisions, and to take pride in being part of a company where your voice truly matters. We encourage you to use EthicsPoint to report a concern, ask a question about the Code of Business Conduct, other Equinix policy, or for ethical guidance on a situation you are facing. Effective communication is critical in today's workplace and using the EthicsPoint tool can increase understanding of our code, policies and each other. It also enables prompt action where needed, and ultimately, helps us all to realize our values of accountability and high standards of excellence.

What happens if I face retaliation for sharing a concern?

Equinix does not tolerate any threat or act of retaliation against an employee who raises a concern in good faith, or provides information about a concern shared by a coworker. Officers, managers and other employees who retaliate against those speaking up will face disciplinary action that could include losing their job. If you experience retaliation, you should report it immediately.

Reporting Security & Confidentiality

Understanding that any report I send from an Equinix computer generates a server log that shows every web-site connection from my PC, won’t this log identify me as a report originator?

Equinix does not condone any attempt by any individual to identify an anonymous reporter. In addition, EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is provided. In fact, EthicsPoint is committed by contract not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside your work environment (such as one located at home, a friend’s house or another secured channel) through the EthicsPoint website. EthicsPoint studies indicate that most people choose an external option.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor's computer, or any internet portal will remain anonymous. An internet portal does not identify a visitor by screen name and the EthicsPoint system strips away internet addresses to maintain anonymity. Plus, EthicsPoint is contractually committed not to pursue a reporter's identity. Security of your transmission depends on using a secured internet connection and other factors.

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system is designed to protect your anonymity when you share a concern. As a reporting party, however, if you wish to remain anonymous, you need to ensure that the details you provide in your report do not reveal your identity. For example, "From my cube next to Kim Smith…" or "In my 17 years as an engineer at the company…".

Is the telephone toll-free helpline confidential and anonymous too?

Yes. EthicsPoint will ask you to provide the same information that you would in an internet-based report and an interviewer will type your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish. You may also disclose your identity after your initial report, by making a follow-up report through EthicsPoint.

Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

At Equinix, we all have a responsibility to each other to cultivate a work environment built on honesty, integrity and mutual respect. Speaking up when you observe illegal or unethical behavior shows you care about maintaining an ethical workplace. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. So, if you know of any incidents of potential misconduct or ethical breaches by employees, vendors or other business partners, consider it your duty to yourself and your coworkers to report it.

I am not sure if what I have seen or heard violates company policy or involves unethical conduct, but it just does not look right to me. What should I do?

If you don't feel comfortable discussing your concern with your manager, file a report. EthicsPoint can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

What if my boss or other managers are involved in the situation of concern? Won't they get the report and start a cover-up?

The EthicsPoint system and report distribution are designed so that persons involved in the situation are not given access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if Equinix has further questions for me about my report?

When you file a report at the EthicsPoint website or through the EthicsPoint Call Center, you receive a unique user name and are asked to create a password. You can return to the EthicsPoint system again either by internet or telephone and access the original report to add more detail or answer questions that an Equinix representative may post to you, and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions.

Are these follow-ups on reports as secure as the first one?

Yes. All follow-up correspondence for reports you make in EthicsPoint are held under the same security controls and confidence as the initial report, continuing under the umbrella of anonymity if you choose to remain anonymous.

Can I still file a report if I don't have access to the internet?

You can file an EthicsPoint report from any computer that can access the internet. You can file from home. Many public locations, including the public library, have internet computers. If you don't have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free helpline, which is available 24 hours a day, 365 days a year.

What should I do if I forget or lose my password?

Because of the high level of confidentiality involved, neither EthicsPoint nor Equinix can look up your password. If you forget or lose your password, you will have to submit your concern again. If you make a new report, it will save time if you mention that it relates to a report you previously made through EthicsPoint.