Modern SlaveryStatementFINANCIAL YEAR 2022-23

Modern Slavery Statement | FY2022-232CONTENTS
01. ABOUT THIS STATEMENT302. MESSAGE FROM THE CEO403. FY23 HIGHLIGHTS

504. OUR BUSINESS

605. ASSESSMENT OF MODERN SLAVERY RISKS

906. ADDRESSING MODERN SLAVERY RISKS

1007. MEASURING EFFECTIVENESS

1308. CONSULTATION AND APPROVAL

14

Modern Slavery Statement | FY2022-2301.
ABOUT THISSTATEMENT3This Modern Slavery Statement is jointly made bythe following entities within the AirTrunk Group:Air Trunk Pty Ltd,as trustee for AirTrunk Sydney Land TrustABN 89 561 908 089
AirTrunk Holding T1 Pty Ltd,as trustee for AirTrunk Australia Holdings TrustABN 89 469 259 695
Andante Holding Company Pty Limited,as trustee for Andante Holding TrustABN 57 334 256 317

References to AirTrunk (we, us or our)throughout this Modern Slavery Statement
refer to these entities and are also intended
to include the broader AirTrunk Group, which
includes entities not subject to the reporting
requirements under the Modern Slavery Act
2018 (Cth), but which nonetheless intend toimplement the key principles set out in thisModern Slavery Statement.
This statement is made in relation to thefinancial year commencing 1 July 2022 andending 30 June 2023.

Modern Slavery Statement | FY2022-2302.
MESSAGEFROM THE CEO

4

The acceleration of artificial intelligence andmachine learning is driving up demand for
hyperscale critical digital infrastructure that can
support these technologies. AirTrunk is responding
to this demand by expanding our Asia-Pacific &Japan hyperscale data centre platform, with newdata centre developments announced in the last
12 months in Hong Kong and Malaysia.
As we expand our platform, it is important that
we do so sustainably and responsibly. We remaincommitted to acting ethically and with integrity
and transparency in everything we do.
We uphold a zero-tolerance approach to modern
slavery and continue to identify the best ways tomitigate the risks of modern slavery in the region.
We expect the same standard from our employees,
business partners, contractors and those acrossour supply chain.
Our efforts to ensure consistent and responsible
management across our operations wererecognised in FY23 when we were awarded aPlatinum EcoVadis Sustainability medal.
EcoVadis benchmarks companies based on theirsustainability management systems in the areasof Environment, Labor & Human Rights, Ethics andSustainable Procurement.
This statement, which addresses the financial
year 2022-23, sets out the steps we have taken
to address our responsibilities under the Modern
Slavery Act 2018 (Cth), and how we continue toenhance our practices to protect the human rightsof our communities.
We can report that to date, AirTrunk has not
identified any incidents of modern slavery in ouroperations or supply chain.

Robin Khuda
Founder and CEOModern Slavery Statement | FY2022-23

503. FY23
HIGHLIGHTS
During FY23, and since the end of the reporting period, AirTrunk is proud to have achieved certain milestones tominimise the risk of modern slavery in its business including:

01.

02.

03.

Implementation of a supply
chain assurance program,which includes enhanced
due diligence processes inrespect of new and existing
partners and suppliers.

Maintenance of a crossfunctional Modern Slavery
Working Group, whichmonitors the risk of modernslavery across the businessand reviews modern slavery
risk as AirTrunk expands intonew markets.

Roll out of our annual
multi-tiered due diligencequestionnaire to understandmodern slavery approach,supply chain management
and workplace conditions ofour key suppliers.

These milestones build on AirTrunk’s existing initiatives designed to minimise and mitigate modern slavery risk, as
outlined in Section 6: Addressing Modern Slavery Risks.

Modern Slavery Statement | FY2022-23

604. OUR
BUSINESSAirTrunk is a best-in-class hyperscale data centre
specialist creating a platform for cloud, content andlarge enterprise customers across the APJ region.
AirTrunk designs, develops and operates data
centre campuses with industry leading reliability,
technology innovation and energy and water
efficiency. Our suppliers and business partners
support us in developing this infrastructure andproviding services to our customers.

Our business is organised into business units
reflective of its primary functions including
technology team (responsible for design),
development team (responsible for construction)and operations team (responsible for data centre
and core business operations). AirTrunk has
approximately 225 employees across APJ1, and asthese employees predominantly consist of highly
skilled professionals engaged in accordance withlocal employment requirements, we consider thisresults in low modern slavery risk in our directbusiness operations.

Founded in Australia and privately owned, AirTrunkcurrently has business operations in Australia,
Singapore, Hong Kong and Japan, and has adata centre under development in Malaysia. As
the largest independent hyperscale data centre
operator in APJ (with 1.38GW capacity across theplatform), AirTrunk takes its responsibility to protect
its communities seriously.

TOK1, TOK2*2SYD1:SYDNEY
AUSTRALIASYD2SYDNEYAUSTRALIASYD3SYDNEYAUSTRALIA

HKG1, HKG2*MEL12MELBOURNE
AUSTRALIATOK1JHB1*EAST TOKYO
JAPANSGP1SGP1LOYANG
SINGAPORE

TOK2WEST TOKYOJAPANHKG1TSING YIHONG KONG

JHB1JOHOR BAHRU
MALAYSIA

SYD1, SYD2, SYD3*MEL1

To find out more about our business,please go to airtrunk.com.

1 As at 30 June 2023.

* Under development

Modern Slavery Statement | FY2022-23

04. OUR
BUSINESSOur Purpose and Values
AirTrunk’s purpose is to scale and sustain therelentless growth of APJ’s digital future. Our
purpose is underpinned by our company values.

These values are the cornerstones of who we are
and are what drive us when engaging with eachother, our suppliers and our customers.

7Modern Slavery Statement | FY2022-23

804. OUR
BUSINESSOur Supply Chains
The AirTrunk Group engages with multiple suppliers
and third-party business partners. These suppliers
and business partners are typically located in
the countries in which we operate across the APJregion.
Most of our procurement activities involve sourcing
goods and services required to develop andconstruct new data centres or the operation andmaintenance of existing facilities. This includes: Design and construction services; Critical data centre plant and equipment; Energy and utility services; Data centre operational facility management
services and security;
 Information and communication services; and Other professional services.

The businesses we engage provide a wide range ofservices including: Design and construction of data centres; Provision of data centre software and hardware; Facilities management; and Security.
In FY23, 18 organisations accounted for 80% of ourtotal spend on goods and services. The majorityof those key suppliers and business partners arelarge multi-national companies with establishedgovernance structures and their own corporatesocial responsibility programs, including in relation
to human rights and modern slavery2. AirTrunk iscommitted to ensuring that its suppliers are taking
action to address modern slavery risk (as discussedin Section 6: Addressing Modern Slavery Risks).
Our commitment to sustainable growth, respect forour communities, the use of ethical labour and themitigation of modern slavery risk is fundamental
to our procurement decisions at every point in oursupply chain.

2 These key suppliers are headquartered in either Australia, Singapore, Japan, Europe or in the United States.

Modern Slavery Statement | FY2022-23

05. ASSESSMENT OF
MODERN SLAVERY RISKS
AirTrunk acknowledges that there are risks in every business model, including in its own operations andsupply chains. AirTrunk considers it fundamental to its sustainable growth and long-term success that theserisks are identified, mitigated and managed appropriately.
Similar to our risk assessment in prior years, we consider that AirTrunk has the following modern slavery risks
in our business:

RISK

01

AirTrunk has not yet conducted adverse media screening on 100% of its suppliers andalso does not always have visibility or approval rights over our Tier 1 suppliers’ subcontracting arrangements.

02

AirTrunk has limited visibility regarding ICT procurement in relation to Tier 2 equipment
suppliers and other suppliers deeper in the supply chain, for example, where our generalcontractor procures ICT equipment from third party suppliers.

03AirTrunk’s construction and manufacturing contracts for the construction of our data
centres and procurement of related equipment exhibit comparatively higher modernslavery risks due to the vulnerabilities in those industries and, in some cases, thelocation of the activities.

AirTrunk acknowledges that the APJ region hosts the largest number of people in modern slavery, with anestimated 15 million people in forced labour3. Of the countries in which AirTrunk operates, Malaysia has thehighest prevalence of modern slavery.
AirTrunk will continue to assess modern slavery risk on an ongoing basis, particularly where there are changes
to its business, supply chains and geographic footprint, and is committed to ensuring it takes appropriate
actions to address any risks identified – please see Section 6: Addressing Modern Slavery Risks for details.

3 Walk Free Regional Findings.

9Modern Slavery Statement | FY2022-23

06. ADDRESSING
MODERN SLAVERY RISKS
To minimise and manage the modern slavery risks identified in AirTrunk’s business, AirTrunk:

FOCUS

ACTIONCORPORATEPOLICIES

Maintains a suite of corporate policies communicating AirTrunk’s stance on modernslavery and human rights, including a Modern Slavery Policy, a Human Rights Policy
and a Supplier Code of Conduct. These policies are reflective of modern slavery andother risks in AirTrunk’s operations and supply chains and are in line with AirTrunk’s
risk management strategy and activities. These policies are reviewed periodically toensure they remain appropriate and align with local requirements as AirTrunk enters
new markets. These policies are made publicly available on AirTrunk’s website andcommunicated to suppliers as part of the onboarding process.

“SPEAK UP”
CULTURE

Makes available an anonymous whistleblowing platform to ensure employees,
contractors, suppliers and other business partners can anonymously raise
modern slavery and other serious concerns appropriately. Reports can be made in
English as well as in the local languages of the countries in which AirTrunk operates.
This is supported by the AirTrunk Group Whistleblowing Policy publicly available on
AirTrunk’s website.

SUPPLIER DUEDILIGENCE

Conducts robust supplier due diligence (as discussed further in the FY23 initiatives
section below).

CONTRACTUALREQUIREMENTSAdopts contractual requirements, wherever possible, to ensure that suppliers haveappropriate policies and procedures in place to address modern slavery risks and arelegally obliged to inform AirTrunk of instances of modern slavery.

AWARENESSTRAINING

Delivers modern slavery awareness training to employees to ensure staff are equipped
to identify modern slavery risks, via a compulsory training module made available toall staff and included as part of employee induction.

REMEDIATION
PLAN

Maintains a modern slavery remediation plan to ensure any risks identified areaddressed appropriately, with a ‘people focused’ approach to ensure that thewellbeing and fair treatment of any affected persons is always prioritised.

10Modern Slavery Statement | FY2022-23

1106. ADDRESSING
MODERN SLAVERY RISKS
To further build upon the progress made in recent
years and the practices outlined above, in FY23
AirTrunk has focused on: Implementation of a supply chain assurance
program, which includes enhanced due diligenceprocesses in respect of new and existing partners
and suppliers; Maintenance of a cross-functional ModernSlavery Working Group to monitor the risk ofmodern slavery across the business and review
modern slavery risk as AirTrunk expands into newmarkets; and Roll out of our annual multi-tiered due diligencequestionnaire to understand modern slavery
approach, supply chain management andworkplace conditions of our key suppliers.

Implementation of Supply Chain
Assurance Program
In FY22, AirTrunk identified the need for a supply
chain assurance program to formalise andstrengthen our supplier due diligence process
to ensure we are engaging with suppliers of thehighest quality, including from a risk perspective.
In FY23, the focus has been on implementing
this program to ensure AirTrunk has a formalised
procurement strategy and resilient supply chain.
This has been supported by the expansion of acentral procurement function to focus on supply
chain responsibilities across the whole business.
Significant progress has been made in
implementation of the supply chain assurance
program during FY23. Initial implementation has
focused on suppliers involved in the construction of
our data centres (Development Suppliers).
We are pleased to report that 100% of all new
Development Suppliers have been successfully
vetted through our supply chain assurance
program, and we are currently working to transition
existing Development Suppliers onto the program.
Implementation of the supply chain assurance
program will continue to be a priority in FY24.

The supply chain assurance program will allow
AirTrunk to: Onboard all suppliers, and manage existing
suppliers, via a dedicated platform; Systematically identify and manage risk andcompliance throughout the supplier lifecycle;
 Create and manage automated workflows toconfirm compliance with AirTrunk’s policies andstandards and legal/regulatory obligations; and Screen suppliers against a multitude of data
sources to identify legal, financial, ESG, cyberand regulatory risks.
Modern slavery risk will be addressed through thesupply chain assurance program, via identificationof higher risk suppliers based on Global Slavery
Indices and ESG predictors. AirTrunk will alsocollect information from suppliers directly as
part of the onboarding process which includes
confirmation from suppliers that they comply
with modern slavery laws, maintain appropriate
supporting policies and are not aware of modern
slavery incidents in their supply chain.
The supply chain assurance program will also
encompass ongoing screening of suppliers formodern slavery risks through adverse media
searches, ensuring that AirTrunk is made awareof any reported modern slavery incidents withrespect to screened entities. AirTrunk has
screened over 300 Tier 1 and Tier 2 suppliers
to date, with no instances of modern slavery
identified with respect to those entities.

Modern Slavery Statement | FY2022-23

1206. ADDRESSING
MODERN SLAVERY RISKS
Maintenance of Modern Slavery
Working GroupRoll Out of Annual Multi-tiered Due
Diligence Questionnaire

In FY22, we established a cross-functional Modern
Slavery Working Group, comprising members of thelegal, procurement and risk teams.

Consistent with previous years, AirTrunk rolled out
an annual modern slavery questionnaire for our Tier
1 suppliers which represent in aggregate 80% of our
total spend on suppliers (Key Tier 1 Suppliers). This
provides AirTrunk with increased visibility over our
Key Tier 1 Suppliers’ approach to modern slavery,
supply chain management and working conditions,and that of their key suppliers (our Tier 2 suppliers).

In FY23, this group continued to meet monthly todevelop and implement initiatives to monitor andreduce the risk of modern slavery in our businessand review the modern slavery risk in the AirTrunkbusiness as we grow into new markets. Key risks,
and any emerging risks identified in this Modern
Slavery Working Group, are escalated and discussedwith AirTrunk’s executive team as required.
During FY23, the working group has supported
the procurement function in implementing
the supply chain assurance program, and withprioritisation of screening new suppliers basedin Malaysia given the heightened modern slavery
risk identified in that market. The working groupalso reviews responses to the annual due diligencequestionnaire, including third-party screening
results (as discussed below), and determines
whether further engagement is required with therelevant suppliers.

With respect to Tier 2 suppliers identified as partof the FY22 annual multi-tiered due diligencequestionnaire, we screened those entities for any
adverse media and confirm that no instances ofmodern slavery were identified.

Modern Slavery Statement | FY2022-23

1307. MEASURING
EFFECTIVENESSAirTrunk is committed to the continued improvement of its human rights framework to combat modern slavery.
The processes we employ to assess our effectiveness at dealing with modern slavery risks in our business andsupply chains will continue to mature in line with our growth, changes in our operations and supply chains,
the UNGP Principles, UN Global Compact and regulatory requirements.

VETTINGPROCType and frequency
of ongoingassurance orreviews conducted.

Percentage of suppliers
and subcontractors thathave been vetted for
ethical labour practices
with no material red flags.

SSNE
REWA
EMPLOYEE A

Percentage ofstaff trained onmodern slavery.

Percentage ofreported issues
satisfactorily
remediated withina reasonable
timeframe from timeof identification.

SUPP
LIERDUE DILIGENCE

EW
EVIRCENAURESUREDASSTo assess the effectiveness of its actions, AirTrunk evaluates the following performance indicators on anongoing basis:

Quality of informationand data received when
conducting due diligence on
suppliers and contractors,
including quality ofinformation on howissues identified are being
addressed by suppliers.

REPO
RTED ISSUESModern Slavery Statement | FY2022-2308. CONSULTATION
AND APPROVALIn developing our Modern Slavery Statement, weengaged with key business areas responsible forprocurement, risk and legal. All reporting entities
are under common management and directorship.
The Statement was approved on 24 October 2023
by the Board of Directors of each of the AirTrunkentities named in Section 1: About this Statement.
The AirTrunk Group is dedicated to continuous
improvement to address the challenging andcomplex issue of modern slavery.

14Modern Slavery Statement | FY2022-2315APPENDIX:MANDATORY REQUIREMENT INDEXThe table below outlines the sections of thisStatement which address AirTrunk’s response
to meet the mandatory reporting requirementsof the Modern Slavery Act 2018 (Cth).

NO.

REPORTING REQUIREMENTSECTION

01

Section 16(1)(a): Identify the reporting entities

01

02

Section 16(1)(b): Describe the reporting entities structure,operations and supply chains.

04

03

Section 16(1)(c): Describe the risks of modern slavery practices in
the operations and supply chains of the reporting entity and any
entities it owns or controls.

05

04

Section 16(1)(d): Describe the actions taken by the reporting entityand any entities it owns or controls to assess and address theserisks, including due diligence and remediation processes.

06

05

Section 16(1)(e): Describe how the reporting entity assesses theeffectiveness of these actions.

07

06

Section 16(1)(f): Describe the process of consultation with anyentities the reporting entity owns or controls.

08

07

Section 16(1)(g): Include any other information which the reporting
entities consider relevant.

N/A