A FRAMEWORK FOR THE FUTUREREPORT FY22

AIRTRUNK.COM

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CONTENTS

Introduction

PlanetAppendices

05.
06.
07.
09.
  
13.

33.
37.
43.
46.

89. Sustainability Data
94. GRI Content Index
103. KPMG Assurance Report

Message from our Founder and CEO
Message from our Board Chairperson
About the Report
The Home of Hyperscale in
Asia Pacific and Japan
Sustainability at AirTrunk FY22

Sustainability
Approach
16.
18.
23.
24.
25.
26.
28.
  

Shaping a Sustainable Future For All
Our Sustainability Commitments
Our TCFD Commitment
Sustainable Financing
Sustainability Governance
Stakeholder Engagement
Contribution to Global Sustainable
Development Goals

Energy Management
Carbon Management
Waste Management
Water Management

People53. Environmental Health and Safety
58. Talent Attraction and Retention
63. Community Engagement
67. Customer Data Privacy   and Protection

Progress
71. Innovation
75. Customer Experience   and Satisfaction
79. Sustainable Supply Chain
84. Risk Management   and Corporate GovernanceAcknowledgement of Country
AirTrunk acknowledges the Traditional Owners ofCountry, and recognises their continuing connection
to land, water and community. We pay our respects
to their Elders past, present and emerging.
Acknowledgement of Stakeholder Support
AirTrunk would like to thank the broad and diverse
range of stakeholders who contributed ideas andcomments in the development of this Report.
We welcome any feedback and insights about oursustainability strategy and reporting. Please directthese to info@airtrunk.com.

3

INTRODUCTION
4

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

MESSAGE FROMOUR FOUNDER AND CEO
Over the last year, consumer andbusiness digital transformation
has continued to drive demand forcloud-based services that need
to be supported by critical digital
infrastructure.
As the largest data centre provider
in Asia Pacific & Japan, we
consider it our responsibility toscale this relentless digital growth,sustainably.
Against the backdrop of macroeconomic challenges, our FY22
Sustainability Report reflects on ourachievements against our Planet,
People and Progress pillars, andconfirms our commitments for amore sustainable, inclusive andresilient future.
Economies around the world arestill recovering from the global
COVID-19 pandemic with thegradual reopening of international
borders; while the war in Ukraine,
supply chain disruptions andincreasing inflation continue topresent industry-wide challenges.
Although AirTrunk has remained
resilient to many of these global
challenges, we acknowledge that weare at a critical moment in time, andwe must address one of the mostimportant global challenges of ourgeneration: The Climate Crisis.

Our Net Zero Commitment

FY22 Sustainability
Achievements

In this report, we declare
our commitment to Net Zeroemissions by 2030.

In this Report, we outline theprogress we have made in FY22, inparticular innovations relating towater management, sustainablefinancing and embodied carbon.

Our 2030 Net Zero target exceeds
the objective set out in the Paris
Agreement to limit global warming
to 1.5°C by 2050, and covers Scope 1
and Scope 2 emissions.

Sustainability is about continuous
improvement and this year, forthe first time, we are reporting our
Scope 3 emissions and our strategy
for a sustainable supply chain.

By taking immediate action to
reduce our emissions, we aremaking an important commitment
to our employees, investors,
customers, partners andcommunities, for generations tocome.

We also share our leading safety
performance, alongside theprograms in place to support ourpeople and communities as we
focus on developing STEM pathways
and increase the representation of
women above our strategic targets.

As the pioneer of hyperscaledata centres in the region, weare also pioneering a global
standard for managing Net Zeroemissions in hyperscale data
centre environments. It is basedon transparency, accountability
and customer collaboration, andbalances ambition with ownership.

To ensure our strategy remainsaligned to global reporting
standards, this year, we voluntarily
joined the United Nations Global
Compact and Task Force on ClimateRelated Financial Disclosures(TCFD) and continue to publicly
share our GRESB and EcoVadis
results in which we earned five stars
and a gold rating respectively.

You can read more about our plansin the Carbon Management sectionof this Report.

The Journey Ahead
Together with our stakeholders,
we are well-positioned to lead thetransformation of our industry
to enable a Net Zero emissions
future.
Each year, we will be responsive
to any new challenges andopportunities presented,
continuing to assess our goals
and reshape our commitments toensure a long-term climate view.
On behalf of the Managementof AirTrunk, thank you for yourcontinued trust and support.

Robin Khuda

Founder and CEO

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Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

MESSAGE FROMOUR BOARD CHAIRPERSON
On behalf of the AirTrunk Board, I
commend the AirTrunk teams’ bold
commitment to Net Zero emissions
by 2030.
Our generation has a realopportunity to transform ourclimate future, at a time whendriving climate action has neverbeen more critical. AirTrunk istaking a leadership position thatboth addresses the complexitiesof this industry and enhancestransparency and accountability
through stakeholder collaboration.
AirTrunk pioneered hyperscaledata centres in the Asia Pacificand Japan, and has continued toinnovate, setting the benchmark
on several initiatives including
sustainable financing and energy
efficiency.

The achievements highlighted
in AirTrunk’s FY22 Sustainability
Report show progress throughinnovation, investment andinclusion. AirTrunk’s ambitions arebalanced, with clear action andcommitments, and overseen bya robust governance framework
to ensure risks are managed andopportunities realised.
Moreover, AirTrunk is supportingand empowering its people andcommunities with an increased
focus on wellbeing and safety.
The strategies AirTrunk is actively
pursuing aim to deliver sustainablelong-term value and growth acrossthe region as it continues to expand
its footprint in new and existing
markets.
On behalf of the Board, I
congratulate Robin and the AirTrunkteam on their FY22 sustainability
achievements.
AirTrunk’s Board and management
look forward to continuing our work
together, and with our clients, tobuild a safer, more sustainable
future for all.

Ani Satchcroft

Senior Managing Director
Real Assets | Macquarie AssetManagement

6Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

ABOUT
THE REPORT‘A Framework for the Future’is AirTrunk’s second annual
Sustainability Report covering
activity in the financial year
1 July 2021 to 30 June 2022 (FY22).
The Report was published on
27 October 2022 and outlines
the environmental, social andgovernance (ESG) strategy,
initiatives and performance material
to AirTrunk and its stakeholders.
The report covers operations wholly
owned and directly managed by
AirTrunk (headquarters, offices
and data centres) in Australia,
Singapore, Japan and Hong Kong,
unless otherwise stated. In FY22,
we expanded our Planet reporting
scope to include data centres
including SGP1 in Singapore, HKG1
in Hong Kong, and SYD2 in Australia.

Reporting Scope
CATEGORYNAME

OPENING

INCLUDED IN FY22

PLANET*
SYD1

Sep 2017

MEL1

Nov 2017

SGP1

Dec 2020

NEW

HKG1

Dec 2020

NEW

SYD2

Mar 2021

NEW

TOK1

Nov 2021

Scope 3 only

SYD3

-

-

TOK2

-

-

SYD-HQ

Apr 2018

SGP-HQAug 2019

TOK-HQAug 2021

PEOPLEPROGRESS

Data Centres

Head Offices

We expanded our FY21 stakeholder
engagement and materiality
analysis process by conducting asurvey with the Management team,comprised of key sustainability
stakeholders, which identified theimpact level of certain material
topics.
A new material topic,‘Sustainable Supply Chain’,
was identified and two FY21
material topics were merged
to become ‘Risk Management
and Corporate Governance’.
To understand the full scope of
AirTrunk’s sustainability activities,
this report is to be read in
conjunction with:
 AirTrunk’s sustainability-related
disclosures which can be foundon airtrunk.com/sustainability.
 Additional annexes including
the Sustainability Data, whichsummarises our sustainability
indicators, the GRI Content
Index, and the KPMG assurance
statement.

Scope 3 only

* Reporting scope consists of AirTrunk data centres and offices operational for at least 12 months except for Scope 3 emissions which also include
TOK1 and TOKHQ.

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Sustainability Report FY22

Introduction

Alignment with Global
Reporting Frameworks
This report is prepared inaccordance with the GRI Standards
and its latest Universal Standards
2021. The GRI Content Index can befound here.
AirTrunk’s goals are aligned to thelong-term global goals of society,articulated as the Sustainable
Development Goals (SDGs). The aimof the SDGs is to create long-termsustainable value, while driving
positive outcomes for business,
society, and the planet. In thissustainability report, AirTrunkprovides an account of thecompany’s ambitions, performance,and challenges against the SDGs.
In our effort to voluntarily alignour sustainability reporting with
non-financial frameworks andbest practices, we have used
the Sustainability AccountingStandards Board (SASB) Standards
as a reference and considered CDP,GRESB and EcoVadis to guide our
ESG performance disclosures.

Sustainability Approach

PlanetPeopleProgress

Appendices

Our GHG emissions are calculated
following the GHG Protocol
Guidance, the world’s most widelyused greenhouse gas accounting
standards, as well as the National
Greenhouse and Energy Reporting(NGER) guidelines for operations inAustralia.

External Assurance
KPMG has been engaged toindependently assure selectedsustainability information including
Scope 1, 2 and select Scope 3
emissions as well as carbon offsets.
The Independent Limited Assurance
Report can be read here.

Feedback
We welcome any feedback andinsights about our approach tosustainability and reporting.
Please direct these to
info@airtrunk.com.

In FY22, we endorsed the TCFD
framework, and present ourapproach to climate-related
governance, strategy, risk
management, metrics and targets in‘Our TCFD Commitment’ section ofthis report.

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Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

THE HOME OF HYPERSCALE
IN ASIA PACIFIC AND JAPAN
About AirTrunkFounded in 2015, AirTrunk is a
hyperscale data centre specialist
creating a platform for cloud,content and large enterprisecustomers across the Asia-Pacificand Japan (APJ) region. We develop
and operate data centre campuseswith industry leading reliability,
technology innovation, and energy
and water efficiency.
AirTrunk’s unique capabilities,
designs and construction
methodologies allow us to provide
customers with a scalable andsustainable data centre solution
at a significantly lower build andoperating cost than the market.
Our purpose is to scale and sustain
the relentless growth of APJ’s digital
future, putting sustainability at theheart of our company. We continue
to enable sustainable growth forthe cloud, while safeguarding
communities and the planet.

Our vision is to continually redefine
and deliver the hyperscale data
centres of tomorrow. We areconstantly evolving and driving
improvement across our designs,
developments, and operations, andsetting new standards for the futureof data centres.
Our difference is that we are theteam our customers trust to deliver
where, when and how they need
it. Our solutions are tailor-madeto meet the needs of technology
companies.
Our values are our company DNA,
guiding us as we work with ourcustomers, partners, communityand one another. We stay true tothem as we scale across the region.

Our strategic objectives guide us to achieve our vision:

01.

Meet or Exceed
Financial Targets

02.

The Preferred Partner
for Cloud Service
Providers across APJ

Place Talent
03. TheWants to Be

Leader in Safety
04. Global
and Sustainability

9Sustainability Report FY22

Introduction

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PlanetPeopleProgress

Appendices

The AirTrunk operating model is centred on strong customer engagement across seven key phases:

01.

07.

OPERATIONS

01.

EARLY ENGAGEMENT
AND SITE SELECTION

06.

02.

02.

HANDOVER
AND SERVICE
DELIVERY03.

DESIGN ANDINNOVATION

04.
CUSTOMER ENGAGEMENTACROSS ALL STAGES

05.

03.

CONSTRUCTION05.

RFP AND
CONTRACTING

04.

06.

OSE PROCUREMENTAND GC SELECTION

07.

EARLY ENGAGEMENT AND SITE
SELECTION
Identify needs early includingarchitecture and capacity growthrequirements
DESIGN AND INNOVATION
Develop customised, sustainable
solutions, considering long-term
growth plans

Our operating model is delivered byour team of AirTrunkers.
Every AirTrunker brings their uniquebackground and diverse perspective tofind solutions that help our customers
succeed, and our communities thrive.

RFP AND CONTRACTING
Actively engage across all levels andfunctions, building long-lasting trust
and partnership
OSE PROCUREMENTAND GC SELECTION
Select vendors that meet AirTrunk's
quality, timeline and design
requirements
CONSTRUCTION
Refine building and data hall details
for quality and timely delivery
HANDOVER AND SERVICE
DELIVERY
Ensure consistency and excellence
through the delivery phase
OPERATIONS
Deliver SLA commitments and ongoingcustomer service and support10

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeople:SYDNEY WESTOPERATIONAL AND EXPANDING

Progress

Appendices

Data Centred in APJ
AirTrunk is headquartered in Sydney,
Australia with regional headquarters
in Singapore and Tokyo, Japan.

TOK1, TOK2*

AirTrunk’s data centre platform spanseight facilities across five cities andfour countries/regions – Australia,
Singapore, Hong Kong and Japan.
AirTrunk provides the only dedicatedhyperscale data centre platform in all
Tier 1 markets throughout the region.
In FY22, AirTrunk opened TOK1,
Japan’s largest and most efficient
data centre in Tokyo East. We alsoannounced new data centres SYD3,
in Sydney West which will be APJ’slargest data centre by MW (ex-China),
and TOK2 in Tokyo West, continuing
our momentum in Japan.

2

SYD1 | 130MW+

HKG1

SYD3 | 320MW+

MELBOURNE WESTOPERATIONAL AND EXPANDING

SGP1 | 78MW+

HKG1 | 20MW+

SINGAPORE
OPERATIONAL AND EXPANDING

AirTrunk

Founded2015

Founder and CEO

Robin Khuda

Company address

AirTrunk Head Office
Level 11, 1 Pacific Highway,
North Sydney, NSW, Australia, 2060
Singapore Head Office
18 Robinson Road, Level 23-01,
Singapore 048547

MEL1 | 130MW+SYDNEY WEST
*UNDER DEVELOPMENT

SGP1

COMPANY PROFILE
Company name

SYD2 | 110MW+SYDNEY NORTHOPERATIONAL AND EXPANDING

TOK1 | 300MW+

EAST TOKYOOPERATIONAL AND EXPANDING

MEL1

HONG KONG
OPERATIONAL AND EXPANDING

TOK2 | 110MW+

WEST TOKYO*UNDER DEVELOPMENTSYD1, SYD2, SYD3*Japan Head Office
E-Space Tower, 3-6 Maruyamacho,
Shibuya-ku, Tokyo150-0044
APJ DATA
Total platform capacity

1.2 GW(at 30 June 2022)
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Sustainability Report FY22

Introduction

Sustainability Approach

Our Investors

Accelerating Growth

In 2020, Macquarie Asia Infrastructure
Fund 2 (MAIF2) and including Public
Sector Pension Investment Board (PSP
Investments), acquired a major stake in
AirTrunk, investing alongside Founder and
CEO Robin Khuda. MAIF2 is managed byMacquarie Asset Management (MAM),
one of the world’s leading alternative
asset managers and part of the ASX-listed
Macquarie Group Limited (ASX: MQG).

Since the investment, AirTrunk has experienced rapid growth across the following areas:

MAM’s strong track record in APJ
infrastructure investments, combinedwith PSP’s insight into its global
infrastructure and real asset investments
portfolio, provides valuable experience as
AirTrunk expands across the region.

3.5X

CAMPUS CAPACITY

2.0X
SITES

PlanetPeople2.8X

MWs CONTRACTED

Progress

Appendices

3.3X

AIRTRUNKERS

Underpinned by:

100%
DATA CENTRERELIABILITY

ISO 27001,
45001
AND 9001

CERTIFIED SITES100%
ON TIMEPROJECT DELIVERY90%

CUSTOMERSATISFACTION

100%
AUDIT
COMPLIANCE

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Sustainability Report FY22

Introduction

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PlanetPeopleProgress

Appendices

SUSTAINABILITY AT
AIRTRUNK FY22
Key Achievements
PLANETPEOPLEPROGRESS Committed to Net Zero by 2030 for Scope 1 and Scope 2
emissions Achieved 786,521 hours with zero LTIs in our first Japan data
centre development, TOK1

 Announced two new data centres - SYD3 (320+ MW) and TOK2
(110+ MW)

 Achieved carbon neutrality for 100% of AirTrunk direct Scope 1
and corporate Scope 2 emissions for FY22

 AirTrunk TRIR 0.38 well below Australian benchmark of 2.61

 Converted existing corporate loan facility (A$2.1b+) to thelargest Sustainability Linked Loan (SLL) in global data centre
history, the first in APJ and the first to utilise Operating PUE asa KPI Disclosed for the first time our Scope 3 emissions including
embodied carbon, business travel, employee commutes andemployees working from home
 Provided renewable energy sourcing options to our customers
including direct contracting options (Data Centre Energy
Network Agreement) Achieved ISO 45001 and 9001 certifications across all
locations Zero major cyber security incidents
 Established community programs in 100% of markets where
our data centres have been operating for more than 12 months

 Opened TOK1 in Tokyo East, the largest and most efficient data
centre in Japan Achieved high employee engagement scores with 96%
of employees stating they are proud to work for AirTrunk(Engagement Survey 2022) and 99% participation rate

 Set an ambitious operational (rather than design) PUE target in
our Sustainability Linked Loan

 94% of employees feel they are genuinely supported to choose
flexible working arrangements Achieved Operating PUE of 1.35 in FY22 and set ambitious
target range of 1.23-1.28. Our designs enable annual averages
as low as 1.14

 Increased year-on-year representation of women by 5.6% to32.6%

 Implemented water efficiency pilot in SYD1 and MEL1
 Received 5-STAR NABERS certification in Australia for SYD1
(Phase 2)
 Progressed Zero Waste to Landfill pilot program in HKG1, MEL1
and SGP1

 Launched Employee Resource Groups (‘ERG’) as part of our DEI
strategy Launched the second annual Women in Leadership Program Appointed a Chief People Officer to our Leadership Team Achieved average customer satisfaction rating of 9/10 or‘extremely satisfied’ across our customer satisfaction surveys
 Designed Battery Energy Storage Systems as substitute todiesel generator sets
 Published first TCFD report with strategic response measures
for the identified climate-related risks
 Achieved Digital Transformation Agency (DTA) certified
strategic facility status recognising AirTrunk Australian data
centres as compliant with privacy, sovereignty and security
requirements for storing Australia Government data.
 Achieved high scores in public sustainability disclosures,
including 5-STAR GRESB score, B- CDP score and Gold
EcoVadis medal2
 Appointed new roles including Chief Information Officer, Headof Innovation and Intelligence, Head of PMO and Head ofProcurement to our Leadership Team

1 Industry Benchmark Rate: Total Recordable Injury Rates, 2018, Australian Government Building and Construction Non-Scheme Commercial Providers.
2 AirTrunk reached EcoVadis Gold rating in the 93rd percentile, meaning score is higher than or equal to the score of 93% of all companies rated by EcoVadis at the time of score publication.

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Introduction

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PlanetPeopleProgress

Appendices

AWARDS AND RECOGNITION
Existing Certifications

01. and Standards

Achieved thehighest security andquality certificationin 100% of our data
centres: PCI DSS,
ISO 27001:2013 and
SOC 2 Type 2 andBCA Green Mark
Platinum for SGP1
Built to SCEC Zone 3 orhigher in SYD1, MEL1
and SYD2 data centres inAustralia

Certifications

02. Achieved in 2022
Achieved ISO 45001:2018,
standards for management
systems of occupational
health and safety (OHS)

03. Memberships
Obtained Defence Industry
Security Program (DISP)
membership

SLL awarded ANZBest Sustainable
Finance Corporate
Deal at the Finance
Asia Achievement
Awards 2021

Joined the Task Force on
Climate-Related Financial
Disclosures (TCFD) as asupporter

SLL awarded IJGlobal’s
APAC Sustainability
Linked Loan Transactionof the Year 2021

Achieved ISO 9001:2015 forQuality Management System chieved the highest levelAof assurance under theAustralian Government’s
Digital Transformation Agency(DTA) Hosting Certification
Framework (HCF) – Certified
Service Provider and Certified
Strategic FacilityAwards and

04. Recognition

Joined the United
Nations Global
Compact (UNGC)
as a participant

SLL recognised as
one of The Banker’s(FT) APAC Loan Dealof the Year 2022
AirTrunk recognisedin Top 10 Most
Sustainable Data
Centre Operators by
Data Centre Magazine(Nov 2021)
Founder and CEO,Robin Khuda,
recognised in Capacity
Media’s Power 100 list
Founder and CEO,Robin Khuda,
recognised in Top 10
Sustainable CEOs by
Sustainability Magazine

ESG

05. Scores
Named as data
infrastructure
sector leader inthe global GRESB
benchmark 2022
 #1 data centre
on the global
benchmark 5-STAR rating
CDP Score: BGold EcoVadis
Medal and in
the top 5% ofcompanies
Gold EcoVadis Medal
Feedback
Customer 1:“Many thanks for the update
and congratulations on thismilestone! These criticalaccomplishments are key
to our decision-making
process.”
Customer 2:“Thanks for sharing with us,
this is indeed an impressive
achievement… sustainability
is one area that we focus
heavily on.”

COO, Dana Adams,
recognised in InterGlobix
Magazine’s Women in
Leadership issue
14

SUSTAINABILITY
APPROACH
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Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

SHAPING ASUSTAINABLE
FUTURE FOR ALL
AirTrunk designs, builds, and operates
the critical digital infrastructurethat enables our customers to drive
transformational change.
Our strategy is underpinned by threepillars: Planet, People and Progress,
with 12 commitments and targets
spanning our social, environmental
and economic performance across thevalue chain.
We continue to work with our key
stakeholders to focus on those areas
where we can have the greatest
impact and support the UN SDGs.

01.
PLANET

02.
PEOPLE03.
PROGRESS We're always looking to find betterways to reduce our impact on theplanet and manage resources
responsibly.

 We believe in enhancing the lives of
our team, customers and the wider
community.

 Through innovation, growth andtransparency, we're helping shape aprogressive and sustainable future.

 We strive to uplift all people, by
making a positive social impact
in the communities in which we
operate.

 Based on a foundation of clear
principles and sound governance,
we're challenging the status quo tocome up with new and better ways.

 We're continuously improving ourdesign and operations to maximise
efficiency and targeting carbon
neutrality at all AirTrunk offices anddata centres.

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Sustainability Report FY22

Focusing on material issues

Introduction

PeopleProgress

Appendices

CRITICAL
Energy Management
Carbon Management
Water Management
Environmental Health and Safety
Customer Experience and Satisfaction
Risk Management and Corporate Governance
Customer Data Protection and Cyber Security
Importance to stakeholders

In FY22, we identified ‘Sustainable Supply
Chain’ as a new material topic. We also
conducted a materiality survey with
AirTrunk Sustainability Committee members
and senior executives to prioritise topics
based on their impact on the economy,
environment and people, as well as theirsubstantive influence on stakeholders.

Planet

AirTrunk’s Materiality Matrix

In FY20, we conducted a program to identify
the key material topics affecting ourbusiness in alignment with GRI standards,
SDGs, SASB, and industry sustainability
trends and benchmarks.
We review and discuss all potential material
topics during monthly sustainability
meetings to ensure our stakeholders’concerns, emerging risks and opportunities
are addressed immediately.

Sustainability Approach

VERY IMPORTANT
Sustainable Supply Chain
Innovation

IMPORTANT
Waste Management
Community Engagement
Talent Attraction and Retention

Impact on the economy, environment and people

PlanetPeopleProgress

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PlanetPeopleProgress

Appendices

OUR SUSTAINABILITYCOMMITMENTS
PLANET

ENERGY MANAGEMENT
Set the benchmark for best-in-class
PUE across APJ, and continuously
improve transparency and performance

PEOPLEENVIRONMENTAL HEALTH AND
SAFETY
Achieve industry-leading safety
performance that demonstrates EHS
leadership in the sector

PROGRESSINNOVATION
Deliver innovative initiatives that drive
growth across APJ and support ourcustomers, people and communities

TALENT ATTRACTION AND
RETENTIONCUSTOMER EXPERIENCE AND
SATISFACTION

Build an inclusive culture while attracting
and growing a team who continuously
raises the bar

Build strong partnerships anddeliver consistently high satisfaction
throughout the customer experience

WASTE MANAGEMENTCOMMUNITY ENGAGEMENTSUSTAINABLE SUPPLY CHAIN

Enhance waste measurement andreporting and improve diversion rate
across all sites

Amplify social impact in the local
communities in which we operate

Maximise sustainable impacts throughresilient and responsible supply chain
practices and partnerships

WATER MANAGEMENTCUSTOMER DATA PROTECTION ANDCYBER SECURITY

RISK MANAGEMENT AND
CORPORATE GOVERNANCE

Ensure a best-in-class control environmentthat secures and protects our customer data

Identify, assess and manage risks andopportunities to preserve AirTrunk’s value

CARBON MANAGEMENT
Achieve Net Zero emissions by 2030 for
all Scope 1 and 2 emissions, and work
toward further measuring and addressing
Scope 3 emissions

Optimise water productivity throughwater strategies across all sites

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Introduction

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PlanetPeopleProgress

AppendicesIn the spirit of transparency, we are sharing our progress, regardless of achievement. We revise our targets every year to ensure they remain ambitious
and effective to achieve our long-term sustainability goals.

MATERIAL TOPICTARGETS ANNOUNCED IN SR FY21

FY22 PERFORMANCEFUTURE TARGETS

EnergyManagement

 Achieve an annual average operating PUE range
between 1.23-1.28 across our stabilised portfolio.

ACHIEVED Annual average operating PUE for FY22 is 1.35, whichis in line with long-term projections.
 Introduced an operating PUE KPI in our FY22
Sustainability Linked Loan.

 Maintain annual average operating PUE within the
AirTrunk PUE band (p.35) with the long-term goal ofachieving 1.23-1.28 annual average operating PUE as
AirTrunk portfolio stabilises.

CarbonManagement

 Maintain carbon neutrality for all direct Scope 1
emissions.
 Set emission reduction targets aligned with the Paris
Agreement.
 Develop Net Zero roadmap in 2022.
 Provide customers with renewable energy supply
options at all facilities with the goal of fully matchingcustomer Scope 2 emissions.

ON TRACK Achieved carbon neutrality for 100% of direct Scope 1
and corporate Scope 2 emissions.
 Measured and reported Scope 3 emissions.
 Finalised our Net Zero strategy to achieve a Net Zerotarget for Scope 1 and Scope 2 emissions by 2030.
 Provided renewable energy sourcing options.
 Registered to the Carbon Call and the Climate Pledge.

 Maintain carbon neutrality for all direct Scope 1 andcorporate Scope 2 emissions.
 Continue to measure, manage and report on Scope 3
emissions.
 Demonstrate progress on our Net Zero by 2030
strategy.
 Provide customers with renewable energy supply
options at all data centres.

Waste
Management

 Achieve a waste-free office in 2022 by reducing thewaste we generate and divert it from landfills.
 Achieve zero waste to landfill certification in at least
one market (Singapore, Australia or Hong Kong) by
December 2022.

WORKING TOWARD
 Implemented new waste initiatives to support ourwaste targets.
 Completed Zero Waste to Landfill pilot program in
HKG1, MEL1 and SGP1.
 Continued efforts to achieve UL Zero Waste
Certification as soon as possible.

 Continue efforts to achieve UL Zero Waste
Certification in all our data centres.
 Enhance waste measurement, reporting and diversion
rate across all offices and data centres.

Water
Management

 Undertake initiatives and trials in SYD1 and MEL1 tounderstand the relationship between water and power
consumption, enabling optimisation and improved
efficiencies moving forward.

ACHIEVED Undertook initiatives in SYD1 and MEL1 for improved
water efficiency.
 Established the relationship between water andelectricity consumption and developed waterproductivity thresholds (p.47).
 Achieved an annual average WUE of 0.84 across theportfolio.

 Reduce WUE in SYD1 and MEL1 sites throughoptimisation initiatives.
 Use water productively when it exceeds our waterproductivity thresholds.
 Align deployment of new heat rejection systems withlocal water stress limits.
 Include a water metric in our Green Financing
Framework.

PLANET

19

Sustainability Report FY22

MATERIAL TOPIC

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

TARGETS ANNOUNCED IN SR FY21

FY22 PERFORMANCEFUTURE TARGETS

Environmental
Health and Safety

 Maintain our commitment to safe delivery everyday bycontinuing to strive for elimination of injuries across
our projects and operations.
 0 regulatory notices issued.

ACHIEVED Total Recordable Incident Rate (TRIR) – Employees: 0
 Total Recordable Incident Rate (TRIR) – Contractors:
0.41
 Lost Time Incident Rate (LTIR) – Employees: 0
 Lost Time Incident Rate (LTIR) – Contractors: 0.05
 Total number of health and safety regulatory notices
issued: 0 Achieved ISO 45001 certification in 100% of ourfacilities.

 Maintain ISO 45001 certification in 100% of ourfacilities.
 Maintain a Safety Culture Survey result above
benchmark score.
 0 regulatory notices issued.
 Conduct safety induction and hazard specific training
for all relevant employees.

Talent Attraction
and Retention

 Accelerate representation of women to 30% of all
employees across the business by 2025.
 Establish NextGen talent partnerships in key markets.
 Launch Learning@AirTrunk program to provide
ongoing learning opportunities for our staff.

ON TRACK Our FY22 women representation is:- Board: 38%- Total employees: 32.6%- 43.5% of new hires were women.
 Introduced a women representation KPI in our FY22
Sustainability Linked Loan.
 Built programs with the University of Sydney, Nanyang
Technological University (NTU), and National Universityof Singapore (NUS) to support the development of
NextGen talent.
 Launched Learning@AirTrunk program and Grow@
Hyperscale employee value proposition.

 Increase company wide representation of women to
35% by 2025 and 40% by 2030.
 Maintain our employee engagement survey scoreabove benchmarks and high participation rate.

Community
Engagement

 Continue supporting causes in 100% of our markets
that have been operational for at least 12 months
across our CSR pillars.

ACHIEVED Deployed community initiatives in 100% of ourmarkets operational for at least 12 months.
 Established regional partnership with SolarBuddy.

 Continue supporting causes in 100% of our markets
that have been operational for at least 12 months.
 Identify opportunities to enhance our impact in thecommunities in which we operate.

Customer Data
Protection
and Cyber Security

 Report 100% of identified incidents to the customer
within 72 hours and for incident response actions to
be underway within the same timeframe.
 100% of staff (both internal and contractor) coveredby comprehensive onboarding and annual refresher
training that communicates the importance ofconfidentiality and data protection.

ACHIEVED Customer data security breaches: 03
 Regulatory notices or fines received around data
privacy and confidentiality: 0

 Report 100% of customer data security breaches tothe customer within 72 hours and undertake incident
response actions within the same timeframe.
 100% of staff (both internal and contractor)
complete comprehensive onboarding and annual
refresher training on confidentiality and dataprotection.
 Maintain compliance with international standards
including ISO 27001, SOC2, PCI-DSS, and financial
auditing standards.

PEOPLE

3 Customer data security breaches refer to any identified leaks, thefts or loss of customer data.

WORKING TOWARD
 98% of AirTrunk employees and contractors received
and acknowledged data privacy, protection, andsecurity awareness training within the required
deadlines.

20

Sustainability Report FY22

MATERIAL TOPIC

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

TARGETS ANNOUNCED IN SR FY21

FY22 PERFORMANCEFUTURE TARGETS

Innovation

 Continue exploring opportunities to deliver PUE
benefits through ongoing innovation.
 Provide innovative carbon reduction solutions to ourcustomers.
 Continue to test our customer solutions for more
efficient, cost-effective and scalable options.

ACHIEVED Hired a Head of Innovation and Intelligence andestablished an innovation framework to identify
innovation opportunities across the business.
 Implemented innovative carbon and water reduction
initiatives.
 Integrated an ‘Innovation Award’ into AirTrunk’s
Awards program.

 Conduct innovation pilots across initiatives prioritised
through the innovation framework.
 Create specific sustainable solutions that bringpositive and tangible impact to our customers, people
and communities as part of our product offering.

CustomerExperience andSatisfaction

 Continue to meet or exceed our customer
commitments for projects and services.
 Ensure high customer satisfaction levels and longterm relationships throughout Asia-Pacific withpositive annual growth rates in MW sold.
 Integrate customer experience into the reward andrecognition program.

ACHIEVED Achieved 9/10 ‘extremely satisfied’ customer
satisfaction score.
 Since inception, our average annual growth rate for
MW sold for our Top 5 customers is 53.8%.
 Integrated a ‘Customer Hero Award’ into AirTrunk’s
Awards program.

 Continue to meet or exceed our customer
commitments for projects and services.
 Ensure high customer satisfaction levels throughout
APJ with positive annual growth rates in MW sold.

Risk
Management

 Continue strengthening the adequacy andeffectiveness of AirTrunk’s risk management system.
 Identify our climate-related risks and opportunities,
test our resilience and further develop our climate
response.

ACHIEVED Conducted quarterly assessments with risk owners,
and quarterly discussions with Management and theBoard.
 Joined TCFD as a supporter and published our first
TCFD report.
 Identified climate-related risks/opportunities anddeveloped a climate response.

 Continue strengthening the adequacy andeffectiveness of AirTrunk’s risk management
framework.
 Test our resilience to climate-related risks andopportunities and further develop our climate
response.

Corporate
Governance Continue to reinforce strong, organised, transparent
and intentional corporate governance.
 Embed AirTrunk sustainability commitment into ourfinancing platform through a Sustainability Linked
Loan.
 Maintain ESG transparency through annual
Sustainability Report, CDP and GRESB submission.

ACHIEVED Robust governance, transparency and accountability
through:- Release of inaugural Sustainability Report;- Multiple award-winning Sustainability Linked Loan;- CDP Score of B- and 5-STAR GRESB score andSector Leader for Data Infrastructure, Data Storage;and- Gold EcoVadis rating.

 Continue to reinforce sound corporate governancethrough disclosure, transparency, and risk
management.
 Maintain ESG transparency through our annual
Sustainability Report, CDP, GRESB and EcoVadis
submissions.
 Ensure annual achievement of our SLL targets withincreased transparency and accountability.

PROGRESS21

Sustainability Report FY22

MATERIAL TOPIC

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

TARGETS ANNOUNCED IN SR FY21

FY22 PERFORMANCEFUTURE TARGETS

 N/A – Not a material topic in FY21.

ACHIEVED Appointed key roles including Head of Procurement
and Senior Supply Chain Manager.
 Designed new Supplier Governance Framework.
 Evolved the Procurement function to centralise supply
chain responsibilities.
 Joined the UNGC as a participant actively supporting
its human rights, labour standards, environmental
protection and anti-corruption principles.

 Fully implement Supplier Governance Framework.
 Assess all new and existing development contractors
and equipment vendors through our Supply Chain
Assurance Program.
 Fully integrate UNGC principles on human rights,
labour, environment and anti-corruption in our supply
chain.

PROGRESS
Sustainable Supply
Chain
NEW TOPIC

22

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

OUR TCFDCOMMITMENTTCFD Framework
The Task Force on Climate-Related
Financial Disclosures (TCFD) isa framework designed to enabletransparency and standardisation
across companies in their public
disclosure of climate-related risks
and opportunities.
TCFD recommendations are
structured around four thematic
areas that represent core elementsof how organisations operate. The
areas are governance, strategy,
risk management, and metrics andtargets.

TCFD Progress
In FY22, AirTrunk made significant
progress in aligning with the TCFD
recommendations including: Establishing a governance andrisk management approach toclimate change; Conducting knowledge sessions
on the TCFD with senior
management and other key
stakeholders; Performing a detailed
assessment of climate risks andopportunities; and Performing scenario analysis forpriority climate risks.

These actions highlighted theclimate-related risks that AirTrunk
could be exposed to under two
climate scenarios:
1. A speedy Net Zero scenarioaligned to a well-below 2-degree
world (IPCC Scenario Reference:
SSP1-2.6); and2. A hot house world aligned to theworst case for climate outcomes(IPCC Scenario Reference: SSP58.5).
The scope of risks identified ranged
from transition risks, including
evolving investor and customer
expectations, through to significant
physical climate risks on operations(e.g. drought, flooding, and higher
average temperatures).
From this assessment, AirTrunkdesigned strategic response
measures for the identified
priority risks to reduce climate
risk exposure to acceptable levels
and realise strategic opportunities
related to the climate transition.

Looking to the Future
AirTrunk will continue toleverage the insights from theassessment to further embed therecommendations of the TCFD by:
 Conducting quarterly reviewsof climate-related risks andopportunities as part of the ERM
process; Performing quantitative scenario
analysis of priority risks and theassociated financial impact; Assessing and refining climate
strategies and response
measures; and Enhancing its disclosure on
Scope 3 emissions including its
plan to manage these emissions.
By adopting the TCFD
recommendations, AirTrunk isenacting its important role inaddressing the risks of climatechange and acting now to mitigatetransition and physical risks.

TCFD Commitment
AirTrunk is publicly committing
itself as a TCFD supporter.
For further information on the TCFD
disclosures, refer to AirTrunk’s
company website.

23

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

SUSTAINABLE
FINANCING
In September 2021, AirTrunk converted its
existing corporate loan facility (A$2.1b+) toa Sustainability Linked Loan (SLL). AirTrunk’s
SLL is the largest in global data centre history,4
the first by a data centre operator in APJ,
and the first to utilise Operating PUE as a
Sustainability KPI globally.5
An SLL links a company’s financing to
Sustainability KPIs, encouraging borrowers
to make bold and ambitious sustainability
commitments, focus on improving theirenvironmental and social performance andincrease transparency for their stakeholders.
AirTrunk’s existing loan as well as future
increment loans and investments are now
sustainability linked, ensuring long-lasting
positive impact on the environment andcommunity as we further expand ourhyperscale data centre platform across APJ.
This showcases our leadership position
in designing, building, operating and now
financing digital infrastructure across the APJ
region in a sustainable way.
A comprehensive review of our business
was undertaken to identify meaningful andambitious KPIs which would drive positiveenvironmental and social change. With thehelp of Sustainability Advisors, we selected
three KPIs around Energy Efficiency, Gender
Diversity and Carbon Neutrality.

Energy Efficiency KPI:

Weighted operational portfolio PUE, providing
transparency on the actual energy efficiency
performance of our data centres.

“AirTrunk’s financing platform, including the new Green Financing
Framework and SLL, takes AirTrunk to a clear leadership position insustainable data centre financing. Linking our debt facilities to sustainability
performance, holds our business to account on our commitments.”

Diversity, Equity and Inclusion KPI:

Gender ratio, to increase transparency andinfluence higher women representation in the
STEM industry which has historically been
under-represented by women.

Prashant Murthy

Chief Financial Officer

Carbon Neutrality KPI:

100% offset of Scope 1 emissions using highquality carbon credits.
In FY22, 100% of our annual SLL targets havebeen met.
We are committed to influencing positivechange across our industry and will regularly
evaluate our KPIs, as well as the broader KPI
universe.

First Green Loan in JapanIn September 2022, we announced thesuccessful close of a landmark green loan
in Japan as part of our new Green Financing
Framework. Financing AirTrunk TOK2, thegreen loan is the first for a data centre in
Japan and first to use operating PUE and waterproductivity eligibility criteria.

4 At the time of conversion.
5 https://airtrunk.com/airtrunk-announces-first-data-centre-sustainability-linked-loan-in-asia-pacific-region/24

Sustainability Report FY22

Introduction

SUSTAINABILITY
GOVERNANCE

Sustainability is embedded and prioritised inevery aspect of our business.

Sustainability
Steering
Committee

PlanetEvery month, our Head of Risk andSustainability chairs the Sustainability
Steering Committee comprised ofrepresentatives across the company who leadthe delivery of our Planet, People and Progressgoals. The Committee meets every month to:

We have established a clear governancestructure and are leveraging specialised skills
and expertise across our team to manage our
ESG performance and deliver long-term value
for our stakeholders.

1

Sustainability Approach

PeopleProgress

Appendices

We regularly invite other employees to share
their knowledge on specific ESG topics to raiseawareness and bring new ideas. The progressand outcome agreed at the Committee are
directly reported to AirTrunk’s Chief Executive
Officer, Chief Operating Officer and theBoard who is accountable for the overall ESG
performance.

 Discuss sustainability priorities;
 Review the progress against our targets andcommitments; and Propose new initiatives and solutions.

BOARD

2

CHIEF EXECUTIVE OFFICER / CHIEF OPERATING OFFICER

3HEAD OF RISK AND SUSTAINABILITY

1

2
4
3

01.
PLANET

02.
PEOPLE Chief Technology Officer
 Chief Operating Officer
 Head of Energy and Climate
 Energy Team Chief Safety Officer
 Chief Marketing Officer
 Chief People Officer
 Chief Information Officer

03.
PROGRESS Chief Operating Officer
 Chief Technology Officer
 Chief Financial Officer
 Chief Legal Officer
 Chief Marketing Officer
 Head of Risk and Sustainability
 Head of Innovation and Intelligence

4

The Board sets expectations
and is accountable for AirTrunk’s
sustainability performance
The CEO and COO embedsustainability into strategies andday-to-day decisions at AirTrunk
The Head of Risk andSustainability oversees thedelivery of our sustainability
targets, policies and initiatives
Senior representatives from eachbusiness function drive and executethe sustainability strategy

25

Sustainability Report FY22

STAKEHOLDERENGAGEMENT
Stakeholder collaboration is critical toachieving our sustainability goals, ensuring: Early identification of emerging risks andopportunities;
 Collaborative input into strategicplanning and actions; Continuous improvement on existing
initiatives; and Support and alignment to achievesustainability goals.
Our employees, customers, investors,
partners, governments, regulators,
suppliers, and the communities in which welive and work are engaged in a trustworthy,
open, transparent and responsible manner.
We listen to their concerns and, whereappropriate and relevant to our business,
incorporate their feedback into ourplanning and actions.
We have summarised our stakeholders’ key
concerns and developed the corresponding
engagement methods and strategies toaddress them.

Introduction

STAKEHOLDER GROUP
AND SIGNIFICANCE TO AIRTRUNK

Sustainability Approach

PlanetPeopleProgress

Appendices

KEY CONCERNSKEY ENGAGEMENT METHODS AND STRATEGYCUSTOMERS
Delivering high-quality service and building
strong, long-lasting relationships with ourcustomers is a top priority. We continuously
engage with our customers through diverse
communication channels to ensure a dynamic,
responsive and customised customer
experience.

 Climate priorities
 Service delivery
 Data privacy protection

 Customer surveys and meetings
 Customer-led 360 degree performance reviews
 Service delivery program tailored to each customer
 Regular, transparent customer communications and reporting Monthly and Quarterly Business Reviews
 Managing customer confidentiality and data privacy
 Assisting customers in achieving their sustainability goals
 AirTrunk Sustainability Report AirTrunk website
 AirTrunk policies

EMPLOYEES
AirTrunk is powered by our people. We foster asafe, collaborative and productive environment
through prioritising employee health, safety
and wellbeing. AirTrunkers are continuously
informed of strategic business updates andprovided opportunities for empowerment andgrowth.

 Work-life balance Annual AirTrunk Employee Engagement Survey
 Monthly all-staff town halls
 AirFit wellness program Social activities across all markets
 Perks and benefits e.g. team lunches, staff off-sites and recharge days

 Diversity, Equity

 DEI Strategy, dashboard and reporting Talent attrition mandates Recruitment and interviewer training Employee Resource Groups
 Regular Inclusion workshops
 Cultural Day in all regions
 Women in Leadership Program Career development

 Employee onboarding training series Skills training programs
 Goal setting and performance reviews
 Growth and development planning Recognition programs
 Leadership programs Health and safety

 EHS committee with safety representatives across all AirTrunk locations
 Health and Safety Survey
 Consultation, communication, and coordination
 Contractor and stakeholder partnering Reporting and escalation channels
 Sharing lessons learnt

 Corporate direction

 Management team meetings
 Organisational KPIs
 Strategic focus groups AirTrunk company policies
 Intranet

and wellbeing

and Inclusion (‘DEI’)and training

26

Sustainability Report FY22

Introduction

STAKEHOLDER GROUP
AND SIGNIFICANCE TO AIRTRUNK

Sustainability Approach

PlanetPeopleProgress

Appendices

KEY CONCERNSKEY ENGAGEMENT METHODS AND STRATEGYINVESTORS
We build confidence and trust by ensuringtransparent and timely communicationof AirTrunk’s business and sustainability
performance with our investors.

 Climate priorities
 Growth and performance Investor briefings and updates with environmental and social focus
 Sustainability linked loan disclosures Financial reporting and disclosures AirTrunk website
 AirTrunk Sustainability Report

BUSINESS PARTNERS
We regularly engage with our partners to build
trusted relationships and collaborate to provide
industry-leading services.

 Environmental and social

 Regular engagement on key matters important to our partners
 AirTrunk website
 AirTrunk Sustainability Report

GOVERNMENT AND REGULATORSWe engage with government agencies andregulators to contribute to national objectives
and economic progress.

 Transparency and Conduct business with integrity and comply with all applicable laws and Elevate industry

 Elevate sustainability leadership position (CDP, GRESB, EcoVadis)
 Active participation in industry groups
 Strong CSR activities in local communities Contribution to national

 Regular dialogue, consultative meetings, and briefings with government

SUPPLIERS
We work in close partnership with our
suppliers to enable shared success and faircompetition. We select our suppliers based on
our procurement policy and pre-qualification
procedures. We require our suppliers to comply
with our Supplier Code of Conduct and other
AirTrunk policies including those focused onhuman rights and workers health and safety.

 Fair competition
 Collaboration for shared Procurement policy and tendering procedures
 Supplier Governance Framework
 Supply Chain Assurance Program Supplier Code of Conduct
 EHS policies
 Human Rights Policy Statement
 Voice of supplier program

COMMUNITIESWe believe in creating sustainable and positivesocial impact in each market where we operate
through job creation, digital development,
community investment and engagement.

 Contribution to local

responsibilities
 Transparency andengagement
compliancesustainability standards

objectives

success

 Social responsibility Compliance with laws
and AirTrunk policies

 Health and safety Human rights
 Sustainable supply chaincommunities
 Local employment andprocurement

regulations

 Close consultation with government, local councils, charities andcommunity groups Community engagement programs
 Nurture local new talent in the industry
 Purchase from local companies in the places we do business Ensure long-lasting positive impact by contributing to various charities andorganisations

27

Sustainability Report FY22

Introduction

CONTRIBUTIONTO GLOBAL SDGS
SDG

PlanetPeopleProgress

Appendices

As a United Nations Global Compact (UNGC) participant, AirTrunk fully supports the Sustainable Development Goals (SDGs) set out by the United
Nations in 2015. The 17 SDGs represent a global call for action to be achieved by 2030, in an effort to reduce inequality, make the world a better
place for future generations, develop solutions to tackle climate change and ensure all people can live in good health, peace and prosperity.
While AirTrunk’s business considers all 17 interrelated SDGs, we have identified 10 priority goals that will drive the greatest long-term impact.

RELATED MATERIAL ESG TOPICAIRTRUNK’S POSITION

AIRTRUNK'S EFFORTS AND PROGRAMS

 Environmental Health and Safety
 Talent Attraction and Retention
 Sustainable Supply Chain

We work to achieve safedelivery every day byempowering our people.
We build systems thatenable successful work,
develop, and engage
leaders who go beyond
compliance to build
resilient approaches towork.

Workplace health and safety:
It is a priority of ours to create safe and healthy work environments. We remain committed
to the continuous improvement of our safety performance and providing safe and healthy
working conditions that minimise work-related injury and ill-health. In 2022, all our data
centres and head offices were certified ISO 45001:2018 - Occupational Health and Safety
Management System. An annual safety culture survey was conducted to understandexisting engagement and identify areas for continued improvement (p.53).

AirTrunk adopts a focus on
enhancing diverse gender
representation in theworkplace and sustaining
a culture of inclusivity.

Gender representation in the workplace:
Women are represented across all organisational levels at AirTrunk. In FY22, ourrepresentation of women increased by 5.6% to 32.6%.

We are committed tousing water consciously
and deliberately, andoptimising water
efficiency through water
conservation strategies forall operating data centres
across APJ.

Ensuring efficient water-use:
In FY22, we implemented a water strategy that establishes clear guidelines for the use ofwater in the design and operation of our data centres. Sustainable water-based coolingtechnologies were developed to optimise energy savings and carbon emissions reduction.

Goal 3: Good Health andWellbeing
Ensure healthy lives andpromote wellbeing for all
at all ages.

 Talent Attraction and Retention
 Corporate Governance
Goal 5: Gender Equality
Achieve gender equality
and empower all womenand girls.
 Water Management
 Innovation
Goal 6: Clean Water andSanitation
Ensure access to waterand sanitation for all.

Sustainability Approach

Employee wellbeing:
Providing opportunities that promote positive physical and mental wellbeing of all
employees is important to ensure productivity, engagement and empowerment. As part of
our AirFit program, we encourage regular participation in wellness activities to maintaina healthy lifestyle. For example, all employees have access to four ‘Recharge Days’ acrossthe year where they can take leave to focus on their wellbeing. We also provide an annual
allowance to support AirTrunkers engage with wellbeing activities, and weekly teamlunches in all offices to encourage team bonding and healthy eating (p.61).

As a long-term goal, we aim to increase company-wide representation of women to 35% by2025 and 40% by 2030 (p. 58).

Contributing to sustainable water resource management:
AirTrunk’s water management strategy is aligned with local water conditions. For example,
AirTrunk applies a local water stress limit at data centres to manage water use.
To tackle water scarcity, AirTrunk ensures sustainable water supply through onsite andmunicipal water recycling, rainwater catchments and greywater (p.46).

28

Sustainability Report FY22

SDG

Introduction

Goal 9: Industry,Innovation
and Infrastructure
Build resilient
infrastructure, promote
inclusive and sustainableindustrialisation and foster
innovation.

PlanetPeopleProgress

Appendices

RELATED MATERIAL ESG TOPICAIRTRUNK’S POSITION

AIRTRUNK'S EFFORTS AND PROGRAMS

 Energy Management
 Innovation

We are committed toadopting and offering ourcustomers better accessto cleaner energy.

Energy efficiency of operations:
We have set ambitious energy efficiency targets as we continue towards our goal ofachieving industry-leading energy efficiency standards across our operating facilities (p.33).

At AirTrunk, we create
new jobs, attract the besttalent, and maintain highretention and engagement
across a global and diverse
workforce.

Protecting labour and human rights:
Maintaining a high standard of labour and human rights across our value chain is crucial
to AirTrunk. Our sustainable supply chain program ensures our business activities are
conducted ethically and sustainably. AirTrunk policies, including the Supplier Code of
Conduct, Modern Slavery, Human Rights, Anti-bribery and Corruption policies, are alignedwith international and local human rights laws (p.82).

Goal 7: Affordable andClean Energy
Increase substantially theshare of renewable energy
in the global energy mix.

Goal 8: Decent Work andEconomic Growth
Promote sustained,
inclusive, and sustainableeconomic growth, full andproductive employment,
and decent work for all.

Sustainability Approach Talent Attraction and Retention
 Innovation
 Community Engagement
 Sustainable Supply Chain

Sourcing renewable energy:
AirTrunk works with utility providers, energy retailers and renewable project developers tooffer our customers renewable energy supply choices. Many of our customers are global
leaders in renewables and are driving significant investments into clean energy throughgroup-wide procurement efforts (p.38).

Promoting economic growth:
AirTrunk’s development of innovative hyperscale data centres contribute to domestic
economic growth across our operating markets. We provide employment opportunities,
invest in local communities and enable the growth and innovation in the cloud throughsustainable digital infrastructure across the APJ region (p.71).
 Carbon Management
 Energy Management
 Waste Management
 Water Management
 Risk Management and Corporate Governance Sustainable Supply Chain

We are constantly
exploring new ways
to adopt responsible
consumption andproduction practices.
We actively monitor ourenergy, carbon, water,
and waste management
practices as part ofour environmental
conservation efforts.

Infrastructure investment and innovation:
The APJ region is experiencing rapid growth in demand for ICT services and at AirTrunk,
we work closely with our customers to provide flexible, innovative hyperscale data centre
solutions to meet this demand. Innovation is embedded across our data centre lifecycle andremains key to achieving our vision of continually redefining and delivering hyperscale data
centres of tomorrow. Our investment in local communities also helps progress universal
and affordable digital access (p.63).
Infrastructure:
As critical digital infrastructure, we make significant investments in projects that consider
customers, the communities and our partners. AirTrunk also engages extensively with thegovernment and the broader security industry to leverage collective cyber security andinformation sharing networks (p.68).

29

Sustainability Report FY22

SDG

Introduction

Goal 12: Responsible
Consumption and
Production
Ensure sustainableconsumption andproduction patterns.

Goal 13: Climate Action
Take urgent action tocombat climate change
and its impacts.

PlanetPeopleProgress

Appendices

RELATED MATERIAL ESG TOPICAIRTRUNK’S POSITION

AIRTRUNK'S EFFORTS AND PROGRAMS

 Energy Management
 Innovation
 Sustainable Supply Chain

We attract, empowerand grow a diverse team.
We make a positive
contribution in local
communities in which
we operate data centres
through job creation,
digital development,
community investment
and engagement.

Diverse and inclusive workplace:
We value diversity and strive to create an inclusive work environment with equal
opportunities where all employees feel welcome and can be their authentic selves. As partof our DEI program, we provide non-discriminatory and unconscious bias training. We also
run DEI educational sessions throughout the year (p.59).

 Carbon Management
 Innovation
 Talent Attraction and Retention
 Risk Management and Corporate Governance Customer Data Protection and Cyber Security

We build innovative,
reliable, and energyefficient data centres andcontribute to the creationof sustainable low-carbon
cities with our customers
and stakeholders.

Sustainable low-carbon cities:
AirTrunk’s data centre platform includes eight hyperscale facilities across four Tier 1
countries/regions in APJ. We provide reliable, energy-efficient and sustainable data
centres which contribute toward the development of smart, low-carbon cities. In Australia,
we support projects to enhance disaster resilience and safeguard communities andbiodiversity, including indigenous fire management and bush regeneration (p.40).

 Carbon Management
 Energy Management
 Waste Management
 Water Management
 Risk Management and Corporate Governance Sustainable Supply Chain

We are constantly
exploring new ways
to adopt responsible
consumption andproduction practices.
We actively monitor ourenergy, carbon, water,
and waste management
practices as part ofour environmental
conservation efforts.

Responsible waste management:
We align with circular economy principles by adopting a preventive approach to reduce theenvironmental impact of waste produced by our operations. We aim to achieve zero waste
to landfill certifications for several of our data centres and continually monitor our waste
and recycling disposal patterns for continuous improvement. We have recently installed
compost bins to encourage the recycling of food waste and use water consciously in ourdata centres to deliver energy savings and carbon reduction (p.43).

 Energy Management
 Carbon Management
 Waste Management Community Engagement
 Risk Management and Corporate Governance Sustainable Supply Chain

We are committed toraising awareness andpromoting actions tocombat climate change
and minimising ourenvironmental footprint
across our value chain.

Minimising carbon footprint:
AirTrunk is continuing to achieve carbon neutrality for its Scope 1 emissions, as well as the
Scope 2 emissions from its corporate head offices. This year, we pushed the bar further, andannounced our Net Zero emissions targets for Scope 1 and 2 emissions aligned with theParis Agreement. We are committed to further improving our emissions reduction initiatives
and exploring alternative energy sources in each of our markets (p.37).

Goal 10: Reduce Inequality
Reduce inequality within
and among countries.

Goal 11: Sustainable Cities
and Communities
Make cities and humansettlements inclusive, safe,
resilient, and sustainable.

Sustainability Approach

Community engagement:
The COVID-19 pandemic disproportionately burdened underprivileged and vulnerable
communities, deepening inequalities. In FY22, we provided COVID-19 support to local
charities, social enterprises, and local communities in need through donations, staff
volunteering and profile raising. This included a regional partnership with SolarBuddy. We
focus on causes relating to Youth and Education, Environment and Community Care (p.63).

30

PLANET
31

Sustainability Report FY22

Introduction

PLANET

Sustainability Approach

PlanetPeopleProgress

Appendices

ENERGY MANAGEMENT PUE of 1.35 achieved (improved year-on-year) Portfolio PUE Band updated with new deployments
 5-STAR NABERS rating

Global challenges are interconnected
When considering how we manage Energy,
Carbon, Waste and Water, we acknowledge
that these cannot be done independent ofeach other.
For example, the way we manage watermust consider how we manage energy,
and similarly, the way we manage carbon
must consider the way we manage waste.
The interconnectedness of these issues isat the heart of the SDGs, which have been
purposefully crafted to be inclusive andintegrated across environmental, social, andcorporate governance.

CARBON MANAGEMENT Net Zero by 2030 target set
 Scope 3 emissions reported

Our strategy is shaped looking at each topic,
as they relate to one another, with a view toachieving the greatest combined impact.
Refer to Innovation section for more details on
how we bring each of these elements together.

WASTE MANAGEMENT UL Zero Waste Certification in progress Waste diversion trials at MEL1

WATER MANAGEMENT Sustainable water management framework introduced Water efficiency initiatives launched32

Sustainability Report FY22

Introduction

Why it matters?

ENERGYMANAGEMENT

Sustainability Approach

PlanetPeopleProgress

Appendices

It has been estimated that data centres account for approximately 1% of global electricity consumption and this is
projected to increase with the digitisation of our economies.6
As APJ’s largest data centre provider, we have a responsibility to operate to the highest energy efficiency measures.

How does AirTrunkmanage this?

The single most important metric for managing energy across the industry is Power Usage Effectiveness (PUE).
AirTrunk optimises, measures, and continuously improves on its annual average operating PUE as its key metric.7
PUE and energy-efficiency is managed across the lifecycle of our data centres. Starting with the design process,
AirTrunk advises its customers on the most energy-efficient configuration; our engineers recommend the best coolingsolution for the local climate; and we select the most efficient technology solutions. AirTrunk’s standard processincludes PUE and WUE evaluation reports for all deployments which ensures that designs consider energy and water
resources (see Water Management section).
We test the energy efficiency of our facilities during the commissioning process and continuously monitor
performance throughout the operation period. We run innovation and continuous improvement programs to further
raise energy efficiency of all our operating facilities.

What is our commitment?

 To set the benchmark for best-in-class PUE across APJ, and continuously improve our transparency andperformance.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE Annual average operating PUE for FY22 was 1.35 forour data centres that have been in operation for atleast 12 months - a year-on-year improvement.8
 Achieved FY22 average annual operating PUE of 1.32
for SYD1 and MEL1 as a like for like comparison to the1.37 average annual operating PUE reported in FY21.
 We are on track to achieve our target range as theportfolio stabilises.

Who manages this at
AirTrunk?

Under the leadership of AirTrunk’s Head of Energy and Climate, our dedicated Energy Management Team manages
energy efficiency across our portfolio.

FUTURE TARGET(S) Maintain annual average operating PUE within the
AirTrunk PUE band (p.35) with the long-term goal ofachieving 1.23-1.28 annual average operating PUE as
AirTrunk portfolio stabilises.

Our PUE commitments are sponsored and reviewed by AirTrunk’s Chief Technology Officer and Chief Operating Officer.
Which SDGs does it
contribute to?

6 According to estimates of the International Energy Agency published in September 2022, data centres consumed about 200TWh globally which was 0.8% of global electricity in 2019.
7 PUE measures the ratio between total facility energy consumed and the IT equipment energy consumed. A lower PUE value indicates less energy is required to operate the IT servers and the data centre is operating more
efficiently.
8 In FY22, this includes SYD1, MEL1, SGP1, SYD2 and HKG1.

33

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

SETTING APJ BENCHMARKSFOR HYPERSCALE EFFICIENCY
The scale of the deployments of
AirTrunk’s data centres allow us toachieve superior energy efficiency– compared to the average Asia
Pacific PUE of 1.69 (Uptime
Institute).
In FY22, AirTrunk achieved anaverage annual operating PUE of
1.35.
This represents an improvementfrom our FY21 performance of 1.37
as shown in the graph below. The
performance improvement is driven
by increasing IT load utilisation andthe commissioning of new, highly
efficient data hall capacities andcooling technologies as well as
energy savings initiatives rolled out
across already operational sites.

On an underlying basis excluding
new sites, our FY22 performance
improved even more from 1.37 to
1.32 year-on-year.
We are setting ambitious targets
to continuously improve our
performance. We are targeting an
average annual PUE range between
1.23-1.28 across our stabilised
portfolio.
AirTrunk is also working with ourcustomers to decarbonise thesourcing of energy and providing
renewable supply options – pleasesee our Carbon Management
section.

AirTrunk’s Average Operating PUE
1.37
1.35

FY21

FY22

34

Sustainability Report FY22

Driving towards our PUE
targets
We work closely with our customers
to design electrical and mechanicalsystems that will achieve the lowest
PUE in the local climatic conditions.
AirTrunk facilities can achieve
annual average PUEs as low as
1.14 as discussed in the Innovation
section of this report.
In FY21, we introduced the AirTrunk
PUE band, which tracks the averageannual operating PUE values
our facilities achieve. We do notreport the best instantaneous
performance as this has limited
influence on actual energy
consumption over time. In FY22,
the PUE band has been updated toinclude the collective performanceof our portfolio.
The actual average PUE number
depends on several factors:
Utilisation of the facility
The higher the utilisation of the
IT servers in a facility, the betterthe overall energy efficiency. Thismeans we will achieve our optimal
PUE performance as the server
utilisation in our new data centres
stabilise. We are showing our PUE
performance as a curve at different
utilisation points to reflect this.

Introduction

Climatic conditions
Cooling requirements and energy
consumption closely trackambient temperatures. In FY22,
we included SGP1 and HKG1 in
the reporting scope which arelocated in tropical and sub-tropicalclimates, and where the averageannual PUE will naturally be higher
than in temperate climates suchas Melbourne, Australia. When
comparing PUE performance, we
therefore show a PUE band for ourfacilities across different climates.
Customer deployment
In each data centre, we host several
customers with bespoke server
requirements. This enables us
to incorporate customer-driven
efficiency choices into the facility
design from day one.
Energy efficiency, through ouroperating PUE, is a key performanceindicator (KPI) as part of AirTrunk’s
Sustainability Linked Loan. In FY22,
we exceeded this SLL KPI target andtracked well toward the 2025 target.

Sustainability Approach

PlanetPeopleProgress

Appendices

Average PUE in APJ for 2020 (Uptime Institute)
1.69

1.50

1.41

PUE band of AirTrunk facility portfolio(annual average)

1.33

1.33

1.20
1.16

25%

1.14

50%

75%

1.16

100%

IT Load Utilisation
Figure 1: PUE band of AirTrunk facility portfolio (annual average)

35

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Clear PUE boundaries
The operating PUE and thestabilised operating PUE values arequoted as average annual actuals
in accordance with the Green Grid
PUE definition.9 As AirTrunk receives
power at extra high voltages throughonsite substations (usually at 66kV
or higher), this PUE calculation
includes transformation losses aswell as technical and offices spaces.
Green Grid also offers a narrower
definition known as partial PUE(pPUE), where only the plant andequipment serving the IT data halls
are considered. If AirTrunk had
adopted this narrower definition ofPUE, the resulting PUE band would
reduce by a further 3% i.e. achieving
a PUE as low as 1.11.

Achieving a 5-STAR NABERS
for Data Centres rating
As part of AirTrunk’s commitment
to operating green buildings, weundertook a NABERS for data
centres assessment pilot at one of
the buildings in our SYD1 facility.
NABERS for data centres provides
a star rating for buildings focusedsolely on operational PUE, notdesign PUE.

PUE boundary commonlyused in the data centre
industry
By narrowing boundaries
to IT load, cooling load,
UPS (i.e. all load from TX
output to data hall IT).
PUE could be lowered by
up to a further 3%.
pPUE Range: 1.11-1.31

PUE Boundary
consistent with the Green
Grid definition of PUE

ACC's on roof

132kV site substation
Generators andTransformers with UPS's
on gantry

Tech and Office Building

Quoted average annual
PUE target to include
substation losses, techand office space load.
PUE Range: 1.14-1.33
Figure 2: AirTrunk SYD1 illustration

The result of this assessment was
a 5-STAR rating, demonstrating
excellent energy efficiency of thisfacility.

9 The Green Grid, PUE: A Comprehensive Examination of the Metric, White Paper #49. This reflects the ratio of total facility energy consumption at high-voltage utility meters to IT energy consumption at low-voltage data
hall meters.

36

Sustainability Report FY22

Introduction

Why it matters?

CARBONMANAGEMENT

Sustainability Approach

PlanetPeopleProgress

AppendicesTemperatures are at their highest in 10,000 years. The Intergovernmental Panel on Climate Change has said that unless
we take action by 2030, we will not be able to limit the temperature rise to 1.5°C by 2050 resulting in catastrophic
consequences.
We have a responsibility to protect the communities in which we operate for generations to come.

How does AirTrunkmanage this?

AirTrunk measures Scope 1, Scope 2 and Scope 3 emissions. We measure both CO2 and other greenhouse gas (GHG)
emissions which are converted to CO2 equivalents (CO2e), otherwise known as our carbon footprint.
Since 2020 AirTrunk has participated in the Carbon Disclosure Project (CDP) in which we publicly and voluntarily
disclose our carbon management activities and performance.

What is our commitment?

AirTrunk is committing to achieving Net Zero emissions by 2030 for all Scope 1 and Scope 2 emissions. This includes
implementing safeguards to ensure 100% of electricity consumption is covered in our Net Zero targets, or equivalentcarbon-free targets by either AirTrunk or our customers.  
AirTrunk is also committed to reducing our Scope 3 emissions, with a particular focus on Embodied Carbon from GHG
Protocol’s Scope 3 subcategory - Capital goods.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE
Scope 1 emissions

1,442 tCO2e

Scope 2 emissions (market-based):

257,893 tCO2e

Scope 2 emissions (location-based):

294,930 tCO2e

Scope 3 emissions

201,022 tCO2e

FUTURE TARGET(S) Maintain carbon neutrality for all direct Scope 1 andcorporate Scope 2 emissions.
 Continue to measure, manage and report on Scope 3
emissions.
 Demonstrate progress on our Net Zero 2030 strategy.
 Provide customers with renewable energy supply
options at all data centres.
Refer to Appendix 1 of the Report for details.

Who manages this at
AirTrunk?

Our dedicated engineering function manages carbon under the leadership of AirTrunk’s Head of Energy and Climate.
Our carbon commitments are sponsored and reviewed by the Chief Technology Officer and Chief Operating Officer.

Which SDGs does it
contribute to?

37

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

AIRTRUNK’S NET ZERO COMMITMENT
Working closely with our customers,
suppliers, investors and the executive team,
we have spent the past year developing ourdecarbonisation target and roadmap.

Setting a Standard for Net Zero in Hyperscale Data Centre Environments
AirTrunk has developed an industry-leading approach to Net Zero and emissions reporting standards based on six principles.

This is our commitment:

Net Zero emissions by 2030
Our 2030 Net Zero target exceeds theobjective set out in the Paris Agreement tolimit global warming to 1.5°C by 2050.
Initially, our Net Zero target will cover our
Scope 1 and Scope 2 emissions while wecontinue to monitor, measure, and report our
Scope 3 emissions. Our plan is to develop
a roadmap to further manage our Scope 3
emissions.
Customer electricity consumption accounts
for the vast majority of carbon emissions
associated with a data centre.
Our customers are global leaders in
renewable energy procurement and offsetting
Scope 2 emissions from data centre facilities
against their own public climate targets.
Our Net Zero targets and roadmap must
therefore align with, and leverage, thestrategies of our cloud customers.

01.

Pursue leading climate targets
Achieve Net Zero by 2030, or equivalent carbon-freetarget, to align with 1.5°C (for 100% of electricity to site).

04.

02.

Leverage competencies
Given scale and leadership of customers in the area,
enable their energy and renewable procurement.

05.

03.

Ensure zero double-counting
Clear, accurate and precise emissions accounting forinteroperable carbon ledgers including for electricity
consumption.

06.

Be accountable and transparent
Acknowledge responsibility over emissions including
electricity, be transparent and implement safeguards.

Align with standards
Consider quality renewable solutions that align with thetechnical requirements of internationally recognised
standards.
Mutual collaboration
Work closely with customers to achieve shared climate
objectives.

Through these principles, we are introducing an industry-leading approach for managing Net Zeroemissions in hyperscale data centre environments.

Industry-Leading Approach forManaging Net Zero in Hyperscale Data
Centre Environments
We recognise that we have a stewardship role
for the electricity consumption at our data
centres.
At the same time, we will enable customers
to take ownership and responsibility forelectricity consumption at AirTrunk data
centres and manage this under the customers’
own carbon reduction targets.

In this case, we will report these under
AirTrunk value chain emissions (Scope 3).
We will take a stewardship role for the
integrity of Net Zero targets and commit
to safeguarding that 100% of electricity
consumption at our data centres is covered
under a decarbonisation target (AirTrunk or
customer).

This approach aligns with the six principles
we have set out for Net Zero approach and is
crucial to enable interoperable carbon ledgers
and avoid double-counting.

38

Sustainability Report FY22

Scope 1 Emissions
Our reported Scope 1 emissions include directemissions from our operations. The main
components of our Scope 1 emissions are:
 The combustion of diesel fuel for backup
generators;
 Any fugitive emissions from refrigerants
used in cooling equipment; and Specialty gases present in our transformers
and substations.
We convert the measured consumption ofthese items into carbon emissions using
recognised emission factors.
In FY22, the Scope 1 emissions are 1,442
tCO2e. This has increased due to the additionof SYD2, SGP1 and HKG1 as new sites whencompared to FY21.

Introduction

As part of our Net Zero roadmap AirTrunk will
reduce Scope 1 emissions by: Moving to low or zero global warming
potential (GWP) refrigerants such as
R1234ze or R513a to replace fugitive
emissions from cooling equipment,
which account for the majority of Scope 1
emissions; Considering alternative back-up generation
technology such as Battery Energy Storage
Systems to replace reliance on diesel
generation in full; Minimising our use of SF6 – one of themost potent climate gases – and using
alternatives. For example, AirTrunk isincorporating air insulated or low GWP
insulating gases in future builds to avoid theuse of SF6;
 Reducing non-productive diesel generation
operation through resilience in HV
substation design; and Considering drop-in renewable diesel fuels
in selected locations (subject to sustainable
feedstock).

Sustainability Approach

PlanetPeopleProgress

Appendices

For residual emissions that cannot be reduced
further, AirTrunk will offset 1,442 tCO2e
using 1,446 high-quality, meaningful andmeasurable carbon credit offsets.
In FY22 AirTrunk sourced:
 1,220 Australian Carbon Credit Units(ACCU) carbon offsets from two of thehighest quality projects in Australia. Eachcredit is verified and assessed to certify
the impact of carbon reduction or removalof GHG emissions. Regulated by Clean
Energy Regulator (‘CER’) at the Emissions
Reductions Fund offset standard, thesecarbon emission offsets are eligible under
the Climate Active Carbon Neutral Standard.
 226 Verified Carbon Standard (VCU) offsetsfrom a high-quality rainforest protection
project in Indonesia. The project offers local
communities a diversified and sustainablesource of income while tackling global
climate change.

COMMODITYCOMMODITY STANDARD

COMMODITY TYPECOMMODITY PROJECT TYPECOMMODITY LOCATIONQUANTITY

Project 1

Emissions Reduction Fund

ACCU

Bush Regeneration

Australia

610

Project 2

Emissions Reduction Fund

ACCU

Indigenous Fire Management

Australia

610

Project 3

Verified Carbon Standard

VCU

Rainforest Protection

Indonesia

226
1,446

39

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Project 1:
Bush Regeneration

Project 2:
Indigenous Fire Management

Project 3:
Rainforest Protection

Location:
Western New South Wales, Australia

Location:
Northern Territory, Australia

Location:Central Kalimantan, Indonesia

The Project:
Widespread land clearing has significantly impacted
local ecosystems. This degradation and loss of plant
species threatens the food and habitat on which othernative species rely. This Native Forest Regeneration
project works with landholders to regenerate and protect
native vegetation. The area harbours various indigenous
plant species which provide important habitat andnutrients for native wildlife. The project avoids emissions
caused by land clearing and achieves key environmental
and biodiversity benefits.

The Project:
Arnhem Land in the Northern Territory is prone toextreme, devastating wildfires that affect the landscape,people, plants, and animals. Aboriginal Traditional
Owners and rangers utilise customary fire knowledge toaccomplish highly sophisticated landscape-scale fire
management. Controlled burns are conducted early inthe dry season to reduce fuel on the ground and establish
a mosaic of natural firebreaks, preventing bigger, hotter,and uncontrolled wildfires later in the season.

The Project:
The Katingan Project in Indonesia is one of the largest,
protecting and restoring 149,800 hectares of a uniquepeat swamp forest habitat. The project offers local
communities a diversified and sustainable source ofincome while tackling global climate change. By reducing
deforestation and degradation, the project secures vital
habitat - millions of endemic and endangered rainforest
species - for animals like the Bornean Orangutan.

Percentage of Units:
42% of 1,446 units
Key Benefits and Impacts:
 Local employment; Emissions reduction;
 Biodiversity protection.
The project meets the following SDGs:

Percentage of Units:
42% of 1,446 units
Key Benefits and Impacts:
 Local employment; Community development; Biodiversity protection;
 Ancient culture site protection.
The project meets the following SDGs:

Percentage of Units:
16% of 1,446 units
Key Benefits and Impacts:
 Biodiversity protection;
 Emissions prevention;
 Wildlife protection;
 Habitat conservation;
 Community empowerment; Sustainable agriculture.
The project meets the following SDGs:

40

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Scope 2 Emissions
Our reported Scope 2 emissions include
the total indirect emissions from electricity
consumed at our facilities. We convert theelectricity consumption into carbon emissions
using the prevailing grid emissions factors
from the local electricity grid (location-based
method).
In FY22 our location-based Scope 2 emissions
were 294,930 tCO2e. This includes bothelectricity consumption for AirTrunk corporate
use at head offices and data centres andcustomer Scope 2 emissions for pass-throughelectricity. The increase over FY21 is driven
by new sites with 57,198 tCO2e of Scope 2
emissions and 200,695 tCO2e coming from ourexisting sites and offices.
We achieve carbon neutrality on our corporate
Scope 2 emissions at our corporate head
office and regional offices through sourcing
renewable energy and high-quality RECs.
As part of our Net Zero roadmap AirTrunk will
reduce Scope 2 emissions by: Continuing to improve on our energy
efficiency as described under Energy
Management and reduce our Operational
PUE;
 Supporting our customers in sourcing
renewable energy where they are taking
ownership of indirect emissions fromelectricity consumption; and Sourcing renewable energy to match
electricity consumption provided by AirTrunkto customers.
A Net Zero by 2030 progress update will be
released in the upcoming year.

41

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Scope 3 Emissions
In FY22, we have expanded our reporting scope
to include value chain (or Scope 3) emissions
for the first time.
The below emission categories were
determined to be materially relevant forreporting: Capital goods - carbon emissions associatedwith the construction of our data centres(‘Embodied Carbon’); Business Travel; Employee Commuting; and Indirect Business-related Factors(emissions associated with employees
working from home).
AirTrunk will continue to review and expand
Scope 3 reporting to include additional value
chain categories as appropriate.
Total Scope 3 emissions in FY22 were 201,022
tCO2e with Embodied Carbon from capital
goods accounting for 99.7%. Embodied Carbon
includes emissions from construction ofbuildings as well as the plant and equipment
deployed by AirTrunk in our data centres.
AirTrunk progressed its management of
Embodied Carbon in FY22 by: Systematically quantifying project-specificemissions; Reducing materials; and Switching to greener materials in the design
and build process.

Case Study
Embodied Carbon at SGP1In FY22, we completed a pilot projectthat measured the carbon emissions
from our SGP1 construction process,including Mechanical, Electrical andPlumbing (MEP) equipment.
The study independently quantified thelifecycle carbon emissions from raw
material supply, manufacturing andconstruction stages (A1-A5) in line with
the RICS Standards.

Plant and Equipment
Building Elements
2,126
1,779
6,639
2,734

The calculations considered thedetailed bill of quantities for the coreand shell building (e.g. the concreteand steel used to construct buildings
and perimeter), as well as the plantand equipment fitted into the building(e.g. the electrical and mechanicalinfrastructure supporting the data halls).
The findings: Emissions from building
materials are the major contributors forembodied carbon – accounting for 83%
of the total. Plant and equipment related
embodied carbon accounted for 17%.  

9,974

33,281

9,878

Other
Steel
Concrete

In the building materials category, steel
and concrete are the largest drivers.
Concrete accounted for 34% of total
embodied carbon and steel for 25%.
These findings highlight the importanceof sourcing low-carbon materials suchas recycled concrete or green steel,as well as the efficient use of building
materials to maximise IT deployment perunit of steel and concrete used.

Other
PTU
Generator

13,429SGP1 embodied carbon

Detailed breakdown42

Sustainability Report FY22

Introduction

Why it matters?

WASTE
MANAGEMENT

Sustainability Approach

PlanetPeopleProgress

AppendicesApproximately 2 billion tons of waste is generated every year.10 Improper waste disposal can result in air, water, andsoil contamination, which in turn can cause harm to the environment, biodiversity as well as communities.
Effective waste management is essential for communities to thrive sustainably.

How does AirTrunkmanage this?

Office waste and e-waste are generated as part of AirTrunk’s day-to-day operations. To ensure waste is properly
managed with minimal environmental impact, we constantly look for opportunities to better identify, measure,manage, reduce, and dispose our waste in more responsible and sustainable ways.
This includes implementing strategies to minimise contamination in our office waste streams and creating diversion
pathways that minimise the waste to landfills.

What is our commitment?

 Enhance waste measurement and reporting and improve diversion rate across all sites.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE Implemented new waste initiatives to support ourwaste targets.
 Commenced accurate tracking and validation of ourwaste streams at MEL1, our pilot site. Over the pilot
period, 16 tons of waste were generated.
 Completed Zero Waste to Landfill pilot program in
HKG1, MEL1 and SGP1.
 Continued efforts to achieve UL Zero Waste
Certification as soon as possible.

Who manages this at
AirTrunk?

All AirTrunkers are responsible for waste management.

FUTURE TARGET(S) Continue efforts to achieve UL Zero Waste Certificationin all our data centres.
 Enhance waste measurement, reporting and diversion
rate across all offices and data centres.

Our Head of Risk and Sustainability champions the initiatives which are relayed to site managers to implement.

Which SDGs does it
contribute to?

10 WorldBank.

43

Sustainability Report FY22

Introduction

ADDRESSINGWASTE
At AirTrunk, we believe the most effective way to reduce waste is to not create it in the first place.
Our waste strategy follows a Waste Management Hierarchy that prioritises reducing waste in
the first instance. The Hierarchy then prioritises the reuse, repair, recycling and re-earthing withdisposal in landfill as our least preferred option.

Sustainability Approach

PlanetPeopleProgress

Appendices

Waste management strategies

Managing the diversion of waste

To further improve our waste performance, we
conducted waste audits in SGPHQ, SGP1 andHKG1. We have prioritised recommendations
for each site which will help us adopt more
responsible waste management.

We work directly with our waste vendors toachieve the maximum diversion rate. This
includes ensuring waste is sent to the rightfacility to receive, store, process and treat thewaste, minimising the amount of waste sent
to landfill and responsibly disposing of any
hazardous waste that may be generated at
our sites.

Additional waste management training
and procedures have been developed to becommunicated to all employees in FY23 as we
progress on the UL2799 certifications of oursites.

Waste Management Hierarchy

ReduceReuse

Repair

AirTrunk’s
most preferredsolution

RecycleRe-earth(compost)

Our least preferred solution
Incineration (orwaste to energy)

Landfill

44

Sustainability Report FY22

Addressing organic waste:
Trialling compost bins

Introduction

Bin Type

These bins allow staff to separate organic andfood waste, which is then disposed of by ourvendor through organic composting. We intend
on learning from this pilot and installing morecompost bins across all our sites.

PlanetPeopleProgress

Appendices

AirTrunk waste bins and treatment methods

Food waste and packaging represent a large
amount of the total waste at AirTrunk.
In FY22, we explored ways to reduce foodand packaging waste. This included engaging
with food vendors and resulted in installingcompost waste bins in MEL1 as a pilot.

Sustainability Approach

Acceptable materials

Treatment after collection

Dedicatedrecycling bin

Paper waste such as brochures, magazine, newspaper, etc.
Glass waste such as cleaned jars and bottles.
Plastic waste such as empty bottles and rigid plastic containers.
Metal waste such as empty beverage cans.

Mixed orcommingled
recycling bin

A combination of the above

Confidential
paper

Confidential and sensitive documents

E-wasterecycling bin

Electronic waste for recycling such as batteries,
old mobile phones, light bulbs, etc.

Food or organic
waste bin

Food waste (putrescible waste).
No plastics in this bin.

General wasteor landfill bin

Non recyclable waste items

End-of-life (EOL)
products

Sorting facility

Recycling facilities

Sorting facility

Recycling facilities

OR  Shredder

The resulting compost or fertiliser
could be used for the production of foodRecycling facilities

Landfill or incineration

Sorting facility

Recycling facilities

OR
ComposterComposting facilities

Landfill or incineration
Responsible
Asset Disposal(reusing, repurposing,
repairing)OR

Recycling
program45

Sustainability Report FY22

Introduction

Why it matters?

WATER
MANAGEMENT

Sustainability Approach

PlanetPeopleProgress

Appendices

Water is a critical resource and the source of life in communities and the natural environment. It is also key in theoperation of data centres where using water for cooling delivers significant energy savings and reductions in carbon
emissions.
Water availability is limited in many APJ regions, and any use of water must be sustainable.

How does AirTrunkmanage this?

Water is applied consciously in the design and operation of our data centres to deliver significant energy savings andcarbon reduction. AirTrunk has implemented strategies and key design guidelines around heat rejection systems that
require water.
This follows the below key principles: Principle 1: Using water to minimise carbon.
 Principle 2: Using water sustainably in the local context and aligning with Water Stress Limits (WSL).11
 Principle 3: Using water productively to save energy using minimum Water Productivity Thresholds (WPT).12
We note that similar efforts are ongoing in the industry notably from the Climate Neutral Data Centre Pact (CNDCP) in
Europe. We are encouraged to see that our guidelines significantly align with the emerging framework under CNDCP.

What is our commitment?

 To optimise water productivity through water conservation strategies for all operating data centre sites across APJ.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE Undertook initiatives in SYD1 and MEL1 for improved
water efficiency.
 Established the relationship between water andelectricity consumption and developed waterproductivity thresholds.
 Annual average WUE of 0.84.13
 Achieved FY22 WUE of 0.59 for SYD1 and MEL1
compared to 0.73 WUE reported in FY21.
 WPT estimated at 20-40 kWh/m3 range across theportfolio.

Who manages this at
AirTrunk?

Water is managed across the lifecycle of our data centres.

FUTURE TARGET(S) Reduce WUE in SYD1 and MEL1 sites throughoptimisation initiatives.
 Use water productively when it exceeds our waterproductivity thresholds.
 Align deployment of new heat rejection systems withlocal water stress limits.
 Include a water metric in our Green Financing
Framework.

Our dedicated engineering team manages water under the leadership of AirTrunk’s Chief Technology Officer, withongoing support from engineering and operations teams.

Which SDGs does it
contribute to?

11 Water Stress Limits (WSL) define maximum WUE for a given region based on WRI’s water stress classification.
12 Water Productivity Thresholds (WPT) have been developed at AirTrunk as threshold to define a minimum amount of energy savings (kWh) per m3 of water consumed.
13 In FY22, this includes SYD1, MEL1, SGP1, SYD2 and HKG1.

46

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

AIRTRUNK’S WATERDESIGN STRATEGY
AirTrunk has implemented
strategies and key design guidelines
around heat rejection systems that
require water. This follows the below
key principles:
Principle 1:
Using water to minimise carbon.
Principle 2:
Using water sustainably in the local
context and aligning with local
water stress limits (WSL).
Principle 3:
Using water productively to saveenergy by applying minimum waterproductivity thresholds (WPT).

Principle 1: Using water tominimise carbon
Using water-based coolingtechnologies has clear benefits
for energy savings and carbon
reductions.
There are two types of carbon andenergy savings achieved by using
water:
 Increasing the cooling capacity ofefficient heat rejection plants:
Water-cooled solutions require alower machinery and equipment
footprint meaning large numbersof air-cooled heat rejection
systems are not needed. This
results in reduced emissions
across the supply chain becauseof the decreased carbon andenergy cost required to produce
equipment.
 Improving operational energy
efficiency: During peak loads
and ambient conditions whereenergy efficiency is typicallycompromised in water-lesssolutions, water-cooled solutions
are used to reduce the energy
consumption of operations. This
reduction in energy consumption
directly reduces carbon.

AirTrunk has developed a design
optimisation model for water usethat systematically assesses a
series of parameters during the data
centre design process to determine
the most applicable and sustainable
heat rejection solution, considering
the carbon emissions associatedwith each solution.
This includes modelling therelationship between energy andwater consumption for various
technology options such as aircooled, water-cooled and hybrid
cooling systems.
We apply a double hurdle when
considering water use in the
optimisation: Water use intensity is alignedwith the local WSL and does not
unduly burden the sustainabilityof local water supplies at the data
centre location (Principle 2).
 Water use is sufficiently
productive in terms of energy
savings to warrant use according
to the WPT (Principle 3).

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Sustainability Report FY22

Principle 2: Using water
sustainably in the local
context and align with WSL
Water stress occurs when the
demand for water exceeds theavailable amount, for example ina period of drought, or when poor
water quality restricts its use in thecommunity.
In an environment of low water
stress, excluding water (subject tothe productivity of the water used)
is a missed opportunity for energy
savings.
Prior to considering the WPT,
AirTrunk applies a WSL to manage
water use.

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices Where water stress is a limiting
factor, AirTrunk will deploy
either waterless heat rejection(extreme water stress) or minimal
water use only in peak hours
and with very high energy saving
performance.
 Where water stress is not a
constraint, AirTrunk will maximise
energy savings whereby it willsave more energy than it costs to
produce water.
The Climate Neutral Data Centre
Pact (CNDCP) in Europe outlined
targets around water use andefficiency in data centres. This
includes target WUE numbers
determined by water stress, source
and climate. Our strategy aroundwater and WSL guidelines aligns
with the CNDCP approach.
Similarly, where water comesfrom recycled resources, different
considerations for limits would
apply.

Figure 3: Aqueduct Water Risk Atlas, developed by the World Resources Institute48

Sustainability Report FY22

AirTrunk will continue to monitor
and take reference from theindustry standards as they evolve,
and review and develop WPT and
WSL numbers as data becomes
available.
AirTrunk works to actively contributeto water sustainability in regard to
non-potable water sources. This canfor example include: Rainwater catchments at oursites;
 Onsite water recycling for reuse inother functions; and Supporting municipal water
recycling and use of recovered
water (greywater) e.g. NEWater at
SGP1.

Introduction

In the event of increased pressure
on water resources or a tightening
or water stress in any given region,
we have developed guidelines
relating to if and how water will be
used in this situation. For example,
if a drought were to occur inmedium-high or high water stressareas, water would be used only
as a tool to maintain heat rejection
capacity in peak conditions, withenergy savings no longer the priority.
Dynamic water setpoints in all
operational AirTrunk facilities
ensure we can optimise againstenergy savings and limited
water usage to safeguard all ouroperational capacity.

Sustainability Approach

PlanetPeopleProgress

Appendices

WATER
STRESSAIRTRUNKDATA CENTRESELIGIBLE HEAT REJECTION(example)

WATER STRESS LIMIT(MAX WUE)

Extreme (>80%)-

Dry rated air-cooled chillers

0.0High (40-80%)

MEL1

Adiabatic air-cooled chillers

0.2-0.6

Medium-High (20-40%)

SYD1, SYD2, TOK1

Hybrid dry coolers

0.7-1.2

Low-Medium (10-20%)-

Indirect Evaporative Cooling

1.2-1.9

Low (<10%)

SGP1, HKG1Open circuit cooling towers

1.9-2.5

Figure 4: Water Stress Limits by selected APJ locations

Flexibility is key and if waterconditions were to change, so would
our consumption of this resource.

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Sustainability Report FY22

Principle 3: Using waterproductively to save energy byapplying minimum thresholds(WPT)
AirTrunk follows a rigorous design
process to evaluate and optimise
energy and water consumption. Under
this process, we have adopted a waterproductivity threshold metric, which isa measure of how much energy is being
saved per unit of water consumed. This
metric is applied to ensure even wherewater is available, it is used productively.
By using the metric, we arebenchmarking heat rejection solutions
that require water (either adiabatic
assist or fully water-cooled systems
with open circuit cooling towers) against
an equivalent dry solution for that given
climate and capacity, and assessing
whether the use of water has asufficiently productive energy efficiency
benefit.
The WPT metric is relevant to allmechanical solutions deployed across
AirTrunk’s portfolio.
Based on our assessment of key
available heat rejection technology
solutions, AirTrunk applies a minimum
WPT of 15 kWh/m3 to all designs. So, if
consuming a m3 of water does not saveat least 15 kWh of energy, we do notconsider it sufficiently productive andwill not use it.

Introduction

Facility Design
Parameters and Setpoints

Sustainability Approach

Detailed Vendor
Equipment Selection Data

PlanetPeopleProgress

Appendices

Historical Weather Data
from Local Weather Station

AirTrunk Energy and Water Modelling

PUE and Energy
Consumption

WUE and Water
Consumption

E1 = Energy
consumption of
selected system (kWh)W1 = Water
consumption of selected
system (kL)

E2 = Energy
consumption ofequivalent
dry air-cooled chiller
system (kWh)W2 = 0L – Water
consumption ofequivalent dry air-cooled
chiller system (kL)

Water Productivity Threshold
(WPT)
WPT =

E2 - E1> 15 kWh/kL
W1

Figure 5: AirTrunk Energy and Water Modelling50

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

AirTrunk’s Water Productivity Threshold
While we continue to investigate the mostefficient way to measure water efficiency, we
consider 15 kWh/m3 a meaningful thresholdcompared to the energy intensity of water
treatment and production.
Water sources vary widely by location, forexample primarily surface water is used in
Sydney while primarily recycled water is usedin Singapore, and different supply sources varyin the energy intensity required to produce
water.
Given it requires approximately 3.5kWh to
produce a m3 of water through desalination,with a WPT of 15, we save almost five times
the amount of energy it takes to produce waterusing the most energy-intensive method.
WPT can also be applied to indicative carbon
impact. With the carbon intensity factor of
anywhere from 0.4-0.8kgCO2e/kWh across
APJ regions in which AirTrunk operates, thiscorresponds to an emissions saving of atleast 8-16kgCO2e per cubic metre of water
consumed for the lower-end of our target WPTrange at 20. As power grids in APJ move toward
full decarbonisation, we will further revisit WPT.

Case Study
Energy Saving Trial: Optimisationof Adiabatic Setpoints
In a bid to improve water productivity,
AirTrunk recently commenced a trial
to optimise adiabatic setpoints.
This trial involved installation of an
upgraded chiller controller on a single
system of air-cooled chillers, aimed at
optimising and improving energy andwater consumption of air-cooled chiller
systems.
AirTrunk has carried out internal designmodelling around water use in adiabatic
systems on air-cooled chillers and has
used this pilot as an opportunity tovalidate energy and water modelling thatadvises operational water activation
setpoints to maximise WPT.

In this pilot, a mature data hall was
selected as it best demonstrates thebenefits to be achieved at design loads.
In the cooling system serving this data
hall, the chiller controller has been
upgraded in all chillers serving this datahall.
In assessing the results of this pilot,
two months of data has been recorded
and analysed for the chillers operatingwith the upgraded controller. This isthen benchmarked against recorded
operational data onsite from chillers
operating at similar loads and ambientconditions (analysed in 50kWr and 5C
condenser on temperature buckets)since 2017.
Throughout this pilot program, weobserved an average 70% water usage

reduction in ambient temperatures
below 25°C with no energy penalty. We
are aware however that these same
benefits will not be achieved throughout
the warmer months of the year.
Taking the savings seen through thistrial and extrapolating this across theyear for SYD1, when ambients are below
25°C, the expected annual savings areapproximately an 18% reduction in sitewater consumption.
Although only cooler ambient conditions
are being captured during this pilot
program period due to the trial beingrolled out in the Australian winter, theresults observed are positive and willcontinue to be monitored during warmer
months before the trialled chiller
controller is potentially rolled out acrossmore air-cooled chiller systems onsite.

Site level water consumption (and WUE) ismonitored with the ability to measure water
usage of individual heat rejection systems withmulti-layered metering strategies. This allows
AirTrunk to conduct water efficiency pilots
across our sites, understand the energy andwater usage implications and potentially rollthese out across additional deployments whilst
also feeding back into future designs.

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PEOPLE52

Sustainability Report FY22

ENVIRONMENTALHEALTH AND
SAFETY (EHS)

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Why it matters?

We value and consider safety in everything we do. A safe and healthy workplace prevents incidents, increasing
performance and productivity.

How does AirTrunkmanage this?

AirTrunk aims to implement the highest safety standards across our APJ footprint. Every day, we strive to positively
impact the health, safety and wellbeing of everyone associated with our business.
AirTrunk actively engages with workers and delivery partners to maintain safe working environments. We recognisethat our people are best placed to identify and mitigate risks and hazards and empower them with this important
responsibility.
We undertake an annual Safety Culture Engagement Survey to understand the perceptions and views of our people tobetter inform our safety strategy and initiatives.
We focus on training, coaching, mentoring and oversight to ensure safe execution of our projects and operations.
Our EHS management system is certified to ISO45001:2018 Occupational Health and Safety international standard.

What is our commitment?

 Achieve industry-leading safety performance that demonstrates EHS leadership in the sector.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE
Total Recordable Incident Rate (TRIR) –Employees0

Total Recordable Incident Rate (TRIR) –Contractors

0.41

Lost Time Incident Rate (LTIR) – Employees0

Lost Time Incident Rate (LTIR) – Contractors

0.05

Total number of fatalities

0

Total number of health and safety regulatory
notices issued

0

Facilities achieved ISO 45001 certification
Who manages this at
AirTrunk?

FUTURE TARGET(S) Maintain ISO 45001 certification in 100% of ourfacilities.
 Maintain a Safety Culture Survey result above
benchmark score.
 0 regulatory notices issued.
 Conduct safety induction and hazard specific training
for all relevant employees.

100%

Safety is a shared responsibility across AirTrunk, integrated and embedded within all functions, activities, andprocesses. Functional executives are accountable for safety leadership. Our Chief Safety Officer, in consultation with
our Chief Executive Officer and the support of the EHS Board Committee, leads our safety commitments.

Which SDGs does it
contribute to?

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Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

HEALTH AND SAFETY
LEADERSHIP
With thousands of people working
across the construction andoperational lifecycle of AirTrunk’s
data centres, it is essential to havewell managed and governed EHS
strategies that protect our people.
In FY22, we undertook significant
bodies of work in setting thestandard for EHS across APJ. We
continued to drive high levelsof engagement, training andcollaboration with AirTrunk and ourdelivery partners, and customers,
empowering everyone associatedwith AirTrunk to contribute to asustainable culture of safe delivery.
Some of the highlights over the last
12 months include: Achieving certification in ISO
45001:2018 Occupational Healthand Safety;
 Implementing Global MinimumStandards (GMS);
 Achieving 87% Annual Safety
Culture Score; Developing a Critical Risk
Management (CRM) program; Undertaking a 10-week Safety
Leadership for Supervisors andManagers program attended by
new members of the EHS Team,
Development Project Managers
and Data Centre Managers; and Commenced First Aid and Fire
Warden training program.

ISO Certification

Highlights included:

As part of AirTrunk’s commitment
to achieving safe delivery every
day, we established an Integrated
Management System (IMS) in late
2021. The IMS provides a strong
framework for managing ourquality and safety systems andensuring continual improvement.
The IMS aligns to the clauses of
ISO 45001:2018 Occupational
Health and Safety Management(ISO 45001) and ISO 9001:2015
Quality Management (ISO 9001)
and interprets each clause within
the context of AirTrunk’s business
operations.

 Inaugural Integrated Management
System Management Review andInternal Audit.
 Over 30 audit sessions completed
across AirTrunk’s Head Office inAustralia, regional headquarters
in Singapore, SGP1 and MEL1.
 Zero non-conformances raised
through the ISO certification
audit.

Since implementing the IMS,
AirTrunk has successfully
achieved certification across all
its locations to internationallyrecognised standards ISO 45001
and ISO 9001.

Upcoming priorities:
 Inclusion of ISO 14001:2015 Environmental management
systems requirements to the IMS
and certification to that standard
in 2023.
 Further integration
enhancements of the existing ISO
27001:2013 Information Security
Management System to the IMS.

Having undertaken a rigorous
auditing process, we are proud tohave attained certification withzero non-conformances. This
demonstrates the maturity of thesystems AirTrunk has built and theteam’s dedication to continually
manage safety and quality acrossthe business.

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Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

SAFETY CULTURE
ENGAGEMENT SURVEY
To enable AirTrunk’s goal to bea global leader in safety, it was
important that we gained a clear
understanding of how safety isvalued across our work activities.
To do this AirTrunk launched
its inaugural Safety Culture
Engagement Survey in November
2021.
Our objectives were to understandsafety engagement across thebusiness, provide leaders withprioritised safety focus areas,
gain clarity on safety culture
perceptions, and benchmark ourpractices against companies inother high hazard industries.
To deploy the survey, we engaged
Safer Together, a high-risk industry
group who works across theAustralian resources sector tobenchmark and improve safety
culture performance.

We asked AirTrunk employees andvendor personnel associated with
our activities to take part in thesurvey.
Responses allowed AirTrunk tobenchmark ourselves against
other high-risk industries andform a clear understanding of
our areas for improvement. The
information from the survey also
provided an additional assurance
layer to verify, monitor and improve
the performance of our safety
management systems.

We are proud that ourscore of 87% exceeded theAustralian benchmark scoreof 83%, which demonstrates
our commitment to ensuringa safe workplace for ourpeople.

What Our People Said

Data centre projects are
extremely fast paced. Goodplanning is required to
execute tasks safely.

Recognition of good safety
behaviour is a good incentive
to push for even better
performance.

Labourers always need theproactive involvement of
top management on site for
fostering safety culture to
improve working practices.

Open communication of whatis expected of the team on
a constant basis is key toensuring all team members
are on the same page.

Participation gives
individuals buy-in and asense of responsibility for theoutcomes.

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Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

REWARDINGGOOD BEHAVIOURIn FY22, we implemented a number of programs to incentivise good EHS behaviour reflected in performance, escalation and reporting.

01.

GC PARTNER
REWARDPROGRAMThe Partner Rewards Programaims to facilitate developmentof a culture of safety excellence
among AirTrunk and General
Contractor (GC) leaders, and theworkforce on AirTrunk projects.

02.

WALK ANDREWARD
A reward system to improvethe cultural alignment
between the Site Management
and the workforce promoting
good EHS practices.

03.

A GOOD SAVE
To improve safety culture we are
rewarding the workforce to raise
improvements and identify goodpractices.
Workers can give feedback via a QR
code or Suggestion Box knowing
they have an opportunity to receivea voucher for “A GOOD SAVE”.

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Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Case Study

TOK1 – A MODELOF EHS SUCCESSA safety excellence campaign that
resulted in zero lost time injuries

Initiatives implemented to drive EHS
success

Prior to construction commencing on TOK1
in Japan, the safety team designed andimplemented an improvement program to
uplift hazard and incident reporting, facilitate
better engagement in safety management andimprove workforce hazard awareness.

Hazard Hunt Campaign
A hazard hunt was undertaken throughout
the project, aimed at encouraging workers
to identify hazardous site conditions andwork activities. Workers were invited tosubmit their observations via onsite ballot
boxes. Submitted hazards were reviewed fornecessary corrective actions before being
shared and discussed at site meetings.
Participants were rewarded with recognitionand prizes for their contributions following
each campaign.

The initial phases of TOK1 provide more than
60MW of capacity for AirTrunk’s hyperscaleanchor customers and opened in November
2021. These phases: Were delivered in 45 weeks despite COVID-19
impacts;
 Had over 500 people working approximately
550,000 work hours; and Recorded no lost time injuries during
construction.
The program resulted in: Improved collaboration and safety
awareness between AirTrunk and its
construction partners;
 An increase in timely reporting of Near-Miss
incidents and hazard observations; and Timely rectification of all unsafe areas.

Work at Heights Improvements
Managing safe work at height is crucial to
the safety of our people at our construction
projects. Some variations identified inminimum regulatory standards between
Japan and AirTrunk’s other regions highlighted
the need for further action. The project
team coordinated with delivery partners to
upgrade equipment, deliver training and hostawareness sessions that included the visual
aid of a mannequin falling from height.

COVID-19 Hygiene Campaign
To reinforce the necessary hygiene standards
in a COVID-19 environment, the entire
workforce was engaged in developing
messaging for preventing the spread at the
project. Over 350 slogan submissions werereceived throughout the campaign along withseveral examples of positive feedback fromworkers and foremen about the high standardsof control onsite.

Safety Champions
Safety Champions were nominated torecognise and reward people going above andbeyond to ensure safe work outcomes. The
purpose was to openly celebrate the actions
and focus of people who demonstrate a highstandard of safety culture at the project. A
celebration ceremony was held to recognise
nominated Safety Champions where prizes
were issued together with recognition
certificates.

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Sustainability Report FY22

Introduction

Why it matters?

TALENTATTRACTION
AND RETENTION

Sustainability Approach

PlanetPeopleProgress

Appendices

Key macro drivers such as foreign labour challenges, industry growth at an accelerated pace and evolving employee
expectations, has resulted in talent shortages across the region. Demands for flexibility, purpose-driven work andopportunities for growth and development work has also increased substantially.
AirTrunk recognises the importance of investing in talent and the changing needs of the employee experience as
critical to ensure we remain the place talent wants to be.

How does AirTrunkmanage this?

We offer a range of people programs and a workplace environment that keep our people positively charged andconnected to each other and the community.
We have set a sustainable foundation for our people consisting of strong leadership, rigorous recruitment processes
and attractive benefits.
To maintain a high performing culture, we offer best practice learning and support programs, regular peer feedback
and a transparent performance management system.

What is our commitment?

 Build an inclusive culture while attracting and growing a team who continuously raises the bar.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE Our representation of women in FY22 is:Board
Total Employees

38%
32.6%

Leadership

25%

Individual Contributor

35%

FUTURE TARGET(S) Increase company-wide representation of women to
35% by 2025 and 40% by 2030.
 Maintain our employee engagement survey scoreabove benchmarks and high participation rate.

 Introduced a women representation KPI in our FY22
Sustainability Linked Loan.
 Built programs with the University of Sydney, Nanyang
Technological University (NTU), and National Universityof Singapore (NUS) to support the development of
NextGen talent.
 Launched Learning@AirTrunk program and Grow@
Hyperscale employee value proposition.
Who manages this at
AirTrunk?

Under the leadership of the Chief People Officer, the People and Culture team leads AirTrunk’s talent attraction andretention programs.
All AirTrunkers play a role in creating and fostering a culture that is inclusive, engaging, and sustainable as we continue
to grow.

Which SDGs does it
contribute to?

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Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

A DIVERSE AND INCLUSIVEWORKPLACE
AirTrunk values diversity andcreates an inclusive environment
where everyone can bring theirauthentic selves and realise theirfull potential.
With over 20 different ethnicities
across four different regions, thediverse richness of AirTrunkers
is embraced, celebrated andrespected. We recognise the valuethat cultural diversity brings tocreativity, innovation and progress.

AirTrunkers are breaking
new ground every day.
Breaking new ground would not be
possible without diverse thinking
and perspectives; and without
a place to come together where
everyone can contribute, belong,and thrive.

How do we prioritise DEI?
Our DEI strategy prioritises four main pillars focused on gender, raceand ethnicity, and generational representation, while sustaining aculture of inclusivity.

GenderAchieve more gender balanced
representation in AirTrunk’s
workforce and amongst seniorleadership.

Race and Ethnicity
Maintain and leverage racialand ethnicity diversity forenhanced business outcomesin our multi-geo environment.

Generational
Embrace all talent regardlessof age and build a sustainable
and diverse pipeline of talentand leaders for the future.

Inclusive Culture
Foster an environment where
everyone is able to contributeand succeed, and where
everyone feels they belong.

Each pillar has key objectives and measurable outcomes to ensure
we deliver what we promise.

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Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

What we achieved in FY22
In FY22, AirTrunk delivered a number of key initiatives to support ourcommitment to DEI with investment in a range of initiatives across
Recruitment, L&D, AirTrunker Experience and NextGen Talent.
We will continue to deepen our impact in these areas in FY23.

DEI Fundamental
Training Offered DEI fundamental training to all AirTrunkers through LinkedIn
Learning. This included topics such as unconscious bias, creating
inclusive cultures, ally groups and psych safety.

Race and Ethnicity Data Commenced the collection of employee cultural data, with 76% takeup in FY22, to maintain and leverage racial and ethnicity across thecompany.

DEI Dashboard

 Implemented a DEI Dashboard as the comprehensive source of truth
which provides a quarterly assessment on our gender progress.

Inclusion Workshops

 Facilitated several inclusion workshops to ideate and develop DEI
initiatives that staff are interested and passionate about.

Increased Gender
representation

 Increased Gender representation by 5.6% with women representing
43.5% of all hires in FY22.

Culture Day across APJ

 Celebrated the diverse richness of all AirTrunkers across all locations
on World Day for Cultural Diversity.

Sustainability
Linked Loan

 Largest for a data centre globally, and first in APJ.
 Increasing the representation of women is a KPI of our SLL.

Recruitment Mandates

 Enhanced AirTrunk’s centralised recruitment practices and new
mandates e.g. ensuring gender neutral pipelines and interviewer
panels. YTD hiring trend is 50:50 gender neutral for past six months.

Women in Leadership
Programs Launched our second Women in Leadership program, a bespoke series
for our top women leaders focused on building impact and influence
through personal brand and values alignment.

Neutralised Job
Descriptions

 Neutralised 100% of our job descriptions across gender, race
and age using Textio, a platform used to facilitate gender-neutral
language.

Employee Resource
Groups Launched four Employee Resource Groups (‘ERGS’).
 ERGs build awareness and promote a sense of belonging for groups
with shared identities.

NextGenTalent Program Established programs with universities to support next generation
talent, providing opportunities for learning and growth.

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Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

GROW@HYPERSCALEIn FY22, we launched our Employee Value Proposition, or people promise, which is to help all
AirTrunkers to Grow@Hyperscale.
Being an AirTrunker means you have the rare opportunity to drive the next horizon of Asia
Pacific and Japan’s digital growth and the record-breaking growth of AirTrunk, while also fasttracking your career.

This is what it means to Grow@Hyperscale. This is what it means to work at AirTrunk.
Since launching this promise, we have remained committed to providing an outstanding
employee experience for all.

GROW TONEW HEIGHTS

ELECTRICATMOSPHERE

SEE THEIRIMPACTPOSITIVELYCHARGEDAs you go above and beyond toscale APJ’s digital future; AirTrunkhelps you to grow to new heights.

As you are dynamic in the face ofchange; AirTrunk provides you with
an electric atmosphere to keep you
energised, inspired and motivated.

As you act with transparency, being
open, and respectfully direct; wecome together as a team and help
you to create and see your impact.

 We provide a flexible working
environment where AirTrunkers canwork from anywhere.
 We continued to provide weekly teamlunches to build AirTrunker connection
and community.
 We hold bi-monthly PowerUp sessions
for all AirTrunkers to come together,celebrate success and provide strategic
updates.

 We launched Reflect and Grow,
designed to help AirTrunkers succeedin their role, and accelerate their career.
Reflect and Grow is a framework to:- Ensure each AirTrunker has a 12month personalised growth plancatering to individual needs;- Give feedback to ensure feedback is
constructive;- Celebrate and reward AirTrunkers
who champion our values; and- Provide bi-annual check in’s on
progress.

As you are responsive to theneeds of our customers and fellow
AirTrunkers; AirTrunk helps you
stay positively charged in both yourwork and life.

 We launched AirTrunk Learning, acomprehensive program designed tosupport AirTrunkers in learning new
skills and developing capabilities.
 We bring together AirTrunkers fromacross all our regions to communicate,collaborate and grow at our annual
all-staff event, AirTrunk Connect. The
key agenda items were innovation andpersonal development.
 We implemented a NextGen talent
program and have worked with the
University of Sydney, Australia andNanyang Technological University
and National University in Singapore
on a number of initiatives includinginternship and graduate programs.

14 Excluding US.

 We have implemented an AirFIt
Wellness Program that includes
quarterly ‘Recharge Days’, paid days off
to focus on their mental wellbeing andwellness allowances.
 We offer 24/7 access to Uprise, ourcomplimentary employee assistanceprogram.
 We provide parental leave benefits
to ensure carers build importantconnections with their newborns.
 We offer comprehensive international
medical coverage14 for Singapore andHong Kong AirTunkers in line with bestpractice in their respective regions.

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Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

THE PLACETALENT
WANTS TO BE
High staff engagement
AirTrunk continues to deliver industry-leading engagement results as
we expanded across the region, grew our team at pace and navigated achallenging global pandemic.
We have maintained a retention rate above 95% and have grown ourheadcount by 28%.

AirTrunk’s Engagement Pulse Survey (May 2021)
received 99% participation:

82%

96%

96%

94%

engagement overall

believe we are responsive
to our customers needs

are proud to work for AirTrunkwould recommend AirTrunkas a great place to work

High staff retention
 11.4% turnover 62 new hires onboarded in FY22 (28% increase year-on-year)

62

Sustainability Report FY22

Introduction

Why it matters?

COMMUNITYENGAGEMENT

Sustainability Approach

PlanetPeopleProgress

Appendices

AirTrunk’s growth has been possible, in part, because of the communities who have welcomed our operations. We havean important role to play in these communities to help them thrive.
A commitment to community impact ensures a positive economic, social and environmental future for all.

How does AirTrunkmanage this?

AirTrunk’s data centre projects provide critical digital infrastructure to communities across APJ.
We contribute to the social and economic development in the markets in which we operate through local employment,
innovation and the provision of cloud services.
In addition, AirTrunk designates community programs in all our markets around its pillars of Youth and Education,
Environment and Community Care.

What is our commitment?

 Amplify social impact in the local communities in which we operate.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE In FY22, AirTrunk supported community causes in
100% of our markets, operational for at least 12
months.

Who manages this at
AirTrunk?

FUTURE TARGET(S) Continue supporting causes in 100% of our markets
that have been operational for at least 12 months.
 Identify opportunities to enhance our impact in thecommunities in which we operate.

Under the leadership of the Chief Marketing Officer, the Marketing team leads community engagement at AirTrunk.

Which SDGs does it
contribute to?

63Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

INVESTING IN OUR
COMMUNITIESAirTrunk’s development ofhyperscale data centres allows
large global technology companies
to make their products and services
available to nearby communities.
AirTrunk supports domestic
economic growth, generates
employment opportunities, anddevelops workforce capabilities
for the future, in markets where we
operate.

AirTrunk’s Community
Program

As we design, build and operate
our data centres across theregion, our investment into local
communities equates to billions ofdollars and will continue to help ourcommunities in their post COVID-19
recovery.

We have focused our community
efforts on the local communities
where our data centres havebeen operational for more than
12 months. This includes Western
Sydney (SYD1), Melbourne (MEL1),
Sydney’s northern suburbs (SYD2),
Singapore (SGP1), and Hong Kong
(HKG1). We have also commenced
activities in the Tokyo region (TOK1).

Our Community Framework
AirTrunk’s community framework is
a collaborative approach, working in
partnership with local communities
to achieve long-term social,environmental, and economic
outcomes. The framework consistsof the following:

Our community program focuses onYouth and Education, Environment
and Community Care.
AirTrunk follows the UN SDGs asa guidance to develop a diverse
range of community initiatives andpositively impact our society.

COMMUNITY PILLARSLINK TO SDGs

OBJECTIVES

01.

 Undertake education and outreach to generate
greater STEM awareness and progress in ourcommunity.
 Create pathways for the next generation ofworkers and women in STEM.

02.

 Actively support climate action andenvironmental sustainability.
 Preserve resources and protect biodiversity
within our local environments.

03.

 Actively contribute to social improvement andcommunity development and equality.
 Build a culture of social responsibility andcommunity involvement at AirTrunk.

Youth and Education

Environment

Community CareOur community activity in
FY22 included donations, staff
volunteering and profile raising for avariety of community organisations.

 Understand our communities
 Research and plan Implement and manage
 Monitor our impact

64Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

SINGAPORE

HONG KONG

JAPAN

SGP1, Singapore
 1,000 for 100 meals
program providing
hot meals and job
opportunities tosome of Singapore’s
underprivileged anddisadvantaged.

HKG1, Hong Kong
 Funded beach clean
ups and school
education programs
to help reduce plastic
pollution in Hong
Kong.

Tokyo
 Donated muchneeded food, clothing
and other necessities
to the homeless inTokyo.

AIRTRUNK SHOWING UP
IN TIMES OF NEED
AUSTRALIASYD1, Sydney West Donated specialist
cardiac equipment toBlacktown Hospital inWestern Sydney.

SYD2, Sydney North Funded the Lane Cove
National Park riverconservation projectto help conserve ourunique natural habitat
and wildlife.

MEL1 Melbourne West Funded scholarships
to support STEM
students in
Melbourne’s West.

NSW, Australia
 Following two severe
floods across NSW,
AirTrunk donatedto GIVIT to support
their efforts assisting
communities in need.

APJ PARTNERSHIP

NSW, Australia
 Prepared anddistributed meals to
support those in needacross Sydney.

Australia
 Supported 8
AirTrunkers toparticipate in the2022 Noosa Triathlon,
for Make-A-Wish
Australia.

NSW, Australia
 Raised funds andawareness formental health with
45 AirTrunkers
participating in a
30km Coastrek walkin Sydney.

Australia
 Built prosthetic hands
for landmine victims
across APJ.

Singapore Funds to help
empower women from
low-income families
in Singapore

AirTrunk’s partnership with SolarBuddy extends
across our three community pillars, to help create
pathways for women in STEM, renewable energy
alternatives, and critical support needed for thoseliving in energy poverty.

65Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Case StudySOLARBUDDYPARTNERSHIP
AirTrunk is a key corporate
partner to Australian foundedcharity, SolarBuddy, a global
impact organisation uniting a
global community to illuminate
the futures of all children living inenergy poverty. SolarBuddy aims
to deliver six million solar lights tochildren living in energy poverty
by 2030, helping to improve healthand wellbeing, economic stability,
educational outcomes and theenvironment.
Through our partnership, AirTrunkis helping provide solar lights andvaluable funding to those living inenergy poverty. The bespoke partner
program also enables AirTrunkto support STEM education andpathways for women, renewableenergy alternatives and employee
engagement through light builds
and the Light Moments challenge
for employee health and mental
wellbeing.

East Hills Girls Technology
High School
As part of AirTrunk’s International
Women’s Day program, we brought
the SolarBuddy Light programto East Hills Girls Technology
High School, the only designatedtechnology high school for girls in
New South Wales, Australia.
Over 1000 students participatedin a ‘hyperscale’ light build where
AirTrunk representatives helped
students build their lights andanswered questions about workingat AirTrunk, sustainability andcareer pathways. The solar lights
and letters from the students weresent to children living in energy
poverty.

OUR FY22 IMPACT 1,300 lights donated | 6,850 lives impacted
 Education: 10M extra study hours created Economic: 1,300 family wages saved the equivalent of 16 weeks wages
 Health: Help improve women and children’s health by 60%
 Environment: Offset over 1,700 tonnes of CO2 emissions the equivalentof planting over 29,000 trees

66Sustainability Report FY22

CUSTOMER DATAPRIVACY AND
PROTECTION

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Why it matters?

Protection of customer data is crucial to building successful and sustainable customer relationships and promoting
AirTrunk’s position as a responsible stakeholder in the broader digital economy.

How does AirTrunkmanage this?

AirTrunk implements and operates a number of controls to enforce end-to-end protection of customer data, including
operational procedures, technical mechanisms, and internal cyber awareness campaigns.
AirTrunk maintains zero tolerance for customer data security breaches. To minimise risk, vulnerabilities are proactively
sought, identified and swiftly remediated.

What is our commitment?

 Ensure a best-in-class control environment that secures and protects our customer data.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE
Customer data security breaches

0Regulatory notices or fines received
around data privacy and confidentiality

015% of personnel (internal and contractors)
that have received and acknowledged
annual security awareness training
including the importance of confidentialityand data protection
Who manages this at
AirTrunk?

98%

FUTURE TARGET(S) Report 100% of customer data security breaches tothe customer within 72 hours and undertake incident
response actions within the same timeframe.
 100% of staff (both internal and contractor) complete
comprehensive onboarding and annual refresher
training on confidentiality and data protection.
 Maintain compliance with international standards
including ISO 27001, SOC2, PCI-DSS, and financial
auditing standards.

Customer data privacy and protection is managed by AirTrunk’s Chief Information Officer and is supported by the Chief
Operating Officer and Chief Executive Officer.

Which SDGs does it
contribute to?

15 Customer data security breaches refer to any identified leaks, thefts or loss of customer data.

67

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

AppendicesCYBER SECURITY
STRATEGY
FY22 has been a turbulent year for digital
security with threats increasing due to:Australian Government Certifications
and Obligations

 Sophistication of email and SMS scams;
 Proliferation of services that deploy
ransomware; and Cyber attacks targeting governments andorganisations due to international conflict.

AirTrunk successfully achieved Defence
Industry Security Program (DISP) certificationand has been Certified Strategic with theDigital Transformation Agency’s (DTA) Hosting
Certification Framework.

To protect against these threats and following
Australian government advice, AirTrunk’s
cyber strategy and roadmap is aligned with
the NIST Cyber Security Framework (CSF).
Cyber security continues to be a priority at
AirTrunk, and we are continuously improving
our cyber posture against emerging threats.

These certifications confirm our Australiandata centres have received the highest levelof assurance to meet the government’s
enhanced privacy, sovereignty and security
standards for hosting classified data.

New security incident process
AirTrunk developed a new security incident
process to conform to the NIST standard (SP800-61). All security incidents are logged,
triaged and investigated according to the newprocess.
After detection, incidents are analysed todetermine the risk and impact of the security
event, and any damage is sought to becontained as a priority.
Additional analysis and containment,
eradication, recovery, and post incident
activities such as reviews and training arethen completed. A communication plan may
also be developed to assist with containment,
advise regulatory bodies and employees andmanage customer requirements.

IDENTIFY Asset Management
 Security Governance Security Architecture
RECOVER Disaster Recovery
Management

IDENTIFYPROTECTRECOVERContinuing to maintain strong government
relations, AirTrunk has also been engaged
with Department of Home Affairs (DHA)
throughout the drafting of two amendments
to the Security of Critical Infrastructure Act
2018 (SOCI):PROTECT Security Legislation Amendment(Critical Infrastructure) Act 2021; and Security Legislation Amendment(Critical Infrastructure Protection) Bill 2022.
In addition, AirTrunk’s Australian data centres
meet the Government’s critical infrastructure
requirements.

RESPOND

DETECT Third Party Risk
Management
 Security Awarenessand Training Identity and Access
Management
 Data Protection

RESPOND
 Business Continuity
Management
 Incident Management

DETECT Threat Management

Figure 6: NIST Cyber Security Framework

68Sustainability Report FY22

Introduction

Essential Eight Maturity Model

Sustainability Approach

PlanetPeopleProgress

AppendicesInformation Security
Management System

The Essential Eight Maturity Model is based oneight cyber security controls which have been
designed by the Australian Cyber Security
Centre (ACSC), a department of the Australian
Signals Directorate.

AirTrunk maintains an Information Security
Management System (ISMS) as a requirementof ISO 27001 certification. This provides
benefits in delivering a secure environment to
AirTrunk stakeholders as well as meeting otherassessment requirements, such as PCI DSS
and SOC 2.

Essential Eight is intended to helporganisations protect themselves against
various cyber threats.

In FY22, our policies were updated toensure ongoing compliance and alignment
with DISP certification requirements andAustralian Government information security
classifications. Periodic audits were also
conducted to further strengthen and secure
our technology environment.

In FY22, AirTrunk systems were assessedagainst the Essential Eight Model and wecontinue to implement additional layers of
security.

PREVENTSATTACKS
Application
controlPatchapplications

Configure
Microsoft Office
macrosUser application
hardening

LIMITS EXTENTOF ATTACKS
Restrict admin
privileges

RECOVERSDATA ANDSYSTEMAVAILABILITY

Patch operating
systemMulti-factor
authentication

Dailybackups

Figure 7: Essential Eight Cyber Security Controls – Source: Huntsman Security

69

PROGRESS
70

Sustainability Report FY22

INNOVATION

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Why it matters?

Innovation is critical to drive the industry forward and overcome the challenges of change.

How does AirTrunkmanage this?

At AirTrunk, we foster a culture of innovation where everyone is invited to propose ideas through our online innovation
survey and innovation steering committee where initiatives get prioritised.
By putting our people and customers at the heart of everything we do, we are willing to flex and are open to new ideas
if it means a better outcome for our customers.
Our leadership team has fostered this from day one and models this in everything that we do. We innovate alongside
our customers through regular technical sessions and workshops and constantly engage with our suppliers on
innovation proofs of concept and trials.

What is our commitment?

 Deliver innovative initiatives that drive growth across APJ and support our customers, people and communities.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE Hired a Head of Innovation and Intelligence andestablished an innovation framework to identify
innovation opportunities across the business.
 Implemented innovative carbon and water reduction
initiatives.
 Integrated an ‘Innovation Award’ into AirTrunk’s Awards
program.

Who manages this at
AirTrunk?

Our culture of innovation at AirTrunk enables all staff to contribute to and be responsible for innovative initiatives.

FUTURE TARGET(S) Conduct innovation pilots across initiatives prioritised
through the innovation framework.
 Create specific sustainable solutions that bringpositive and tangible impact to our customers, people
and communities as part of our product offering.

Our Head of Innovation and Intelligence leads the innovation strategy with oversight from our Chief Technology Officer
and the Executive team.

Which SDGs does it
contribute to?

71Sustainability Report FY22

Introduction

Sustainability Approach

PlanetEXPANDING THE AIRTRUNKINNOVATION STRATEGYIn FY22, we expanded our strategy
to ensure continuous application
across all functions, and value for all
stakeholders including customers,
investors, communities, employees
and vendors.
Our strategy is focused on
efficiency, sustainability andcollaboration and aims to: Facilitate a formalised idea
generation process, ensuring
everyone at AirTrunk has a chance
to contribute and co-create in theinitiative; Provide prioritisation
mechanisms to allocate the rightresources to the right initiatives;
 Develop the tools and systems
that allow implementation of
those initiatives; Award and recognise innovators,
promoting an innovation learning
culture; Position AirTrunk as a leading
innovator through the sharing ofachievements and ideas; and Create a culture of continuous
improvement.

A STRONG INNOVATION PROCESS HELPS TO OPTIMISE THE IDENTIFICATION,CAPTURE AND CURATION OF THE BEST IDEAS AND BRING THEM TO LIFE

1. Build a repository of innovation
initiatives combining innovations
in development, leader
aspirations and employee ideas.

Appendices

Using advanced
estimating tools to
reduce embodied carbon

INNOVATION PROCESSIDEA GATHERING

Progress

Case Study

Powering Innovation
Innovation has been core to
AirTrunk’s business model since
inception, as we continuously
innovate for our customers.

PeoplePRIORITISATION

IMPLEMENTATION

2. Apply a scorecard to evaluate
the ideas based on operational
criteria.

5. Develop project group andassign responsibilities for
implementation.

3. Prioritise ideas based onscorecard.

6. Regularly collaborate withexecutive stakeholders to ensure
timelines and objectives are met.

4. Present ideas to executive
stakeholders for strategic
implementation approval.

7. Once implemented,
communicate the innovationinternally and externally.

Following our SGP1 embodied
carbon pilot project, we
can estimate the amount of
embodied carbon emissions
generated for future builds
and adapt designs to reduce
emissions that are embodiedin construction materials andequipment.
During the building designphase, we use Building
Information Modelling which
is a digital representation ofassets across their lifecycle,
from planning and design, toconstruction and operations,and capture data relevant
to assess, amongst otherfeatures, the embodied
carbon of all the componentsof the assets. By using data
emanating from this process,we are implementing a radical
shift in how the carbon
emissions of built assets
are managed across theirlifecycle.
We are also working with
our supply chain partners toensure they are well-equipped
to measure the carbon
emissions that originate
from their activities, helping
them achieve meaningful
reductions in emissions.

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Sustainability Report FY22

Introduction

Elevating our ongoing energy
saving initiatives

Some of the key success stories out
of FY22 include:

Continuous Improvement Across
Our Portfolio Improved efficiency throughoperational setpoint optimisation;
 Increased efficiency of heatrejection plant throughoptimisation against load
utilisation;
 Customer-specific energy
efficiency pilot programs; and Pilot program for proactive
maintenance through monitoringof efficiency performance.

Whilst designing and building
highly efficient data centres,
AirTrunk prides itself on continuous
improvement in the designand operation of our facilities.
Throughout FY22, AirTrunk has
continued to introduce numerous
PUE and WUE optimisation
initiatives across its portfolio,
adding value for our customers inall our operational data centres,
while rolling out our FY21 PUE
optimisation pilots across the entire
SYD1 campus.
These energy and water saving
initiatives implemented as partof an ongoing working group aretargeted to maximise efficiency andlowering energy costs knowing that
operating at hyperscale means theeffect of even the most incremental
energy efficiency improvements are
magnified.

The result of these initiatives beingrolled out is a 0.06 reduction in
annual operating PUE against ourbaseline design at SYD1, MEL1
and SGP1. This represents anenergy saving of over 4% acrossthe respective sites at current
utilisation, a significant reduction
in energy consumption and theassociated carbon emissions.
Refrigerant-Free High Temperature
Solution at MEL1
As introduced in FY21 report, ourinnovative refrigerant-free elevatedtemperature solution continues
to deliver industry leading energy
efficiency outcomes for AirTrunk.
This deployment was the first of its
kind and the first of more to follow,
significantly reducing operating
PUE and providing a far superior
operating cost to our customers.

Sustainability Approach

PlanetPeopleProgress

Appendices

BEFOREAFTER

Roof rejection equipment

Roof rejection equipment

Trim waterHigh power

Trim water

Fans only

Complex machine

Large amount ofrefrigerant (GWP)

SimpleNo refrigerant(0 GWP)

Weatheranalysis

Traditional Cooling
System Design

Customerengagement
Designdata

Elevated Temperature
Cooling System Design

Systemmodelling

DATA CENTRE COOLINGDATA CENTRE COOLING

In our FY22 Sustainability Report, we can support these claims with operational data, with this system going live in June
2021. The year’s performance of this solution is as follows: Average Annual Operational PUE: 1.17 (whilst still in ramp up phase and not yet at design load).
 FY22 Q4 Average Operational PUE Achieved: 1.14.
Not only do these numbers place AirTrunk as a leader in energy and water efficiency, but this operational performance
also validates the accuracy of extensive modelling we perform on every deployment, whilst being fully transparent withour customers on where we sit in terms of energy and water efficiency.

73

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Determining Water
Productivity Threshold (WPT)
With an increased focus on water
consumption in our data centres,
we have implemented an innovative
metric to understand and control
the relationship between energy
savings through water consumption
and the quantity of water being
consumed. That is, a Water
Productivity Threshold (WPT).
Whilst WUE is a known metric in
the data centre industry, defining
water consumption as a ratio of the
IT energy consumption does not
fully capture all facets of our water
strategy, where water source andwater stress can drastically varyacross regions. This is why we havedeveloped a WPT which can thenbe applied alongside a WUE limit
defined by local water stress.
This innovative metric is leading theindustry in setting targets aroundthe optimisation of energy andwater consumption as it allows
the productivity of water to bemeasured, independent of climate
and water stress and ensuresthat we continue to use water
responsibly in our data centres.
For details, refer to the Water
Management section in the report.

74

Sustainability Report FY22

Introduction

Why it matters?

Sustainability Approach

PlanetPeopleProgress

Appendices

Everything we do is with one thing in mind, to help our customers grow. As a result, we grow too.
The success of our business depends on building strong, long-lasting relationships with our customers.

CUSTOMER
EXPERIENCEAND
SATISFACTION

We are always listening and learning to understand their needs, solve their problems, and make sure they are satisfied
with their customer experience.
How does AirTrunkmanage this?

We support our customers through every stage of the AirTrunk experience – from idea conception, design, todevelopment and through to operations and beyond. This includes:
 Early engagement to understand customer requirements and inform site selection and market strategies; Deep collaboration and subject matter expertise on strategic initiatives such as innovation, efficiency, renewableenergy, safety; and Ongoing support to ensure high customer satisfaction levels and long-term relationships.

What is our commitment?

 Build strong partnerships and deliver consistently high satisfaction throughout the customer experience.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE Achieve 9/10 ‘extremely satisfied’ customer
satisfaction score.
 Since inception, our average annual growth rate for
MW sold for our Top 5 customers is 53.8%.
 Integrated a ‘Customer Hero Award’ into AirTrunk’s
Awards program.

Who manages this at
AirTrunk?

The customer experience and satisfaction strategy is led by the Chief Marketing Officer and AirTrunk executives, andmanaged by the Marketing, Customer Success, Customer Solutions and Service Delivery teams. All AirTrunkers are
empowered to champion the customer throughout their journey with AirTrunk.

FUTURE TARGET(S) Continue to meet or exceed our customer
commitments for projects and services.
 Ensure high customer satisfaction levels throughout
APJ with positive annual growth rates in MW sold.

Which SDGs does it
contribute to?

75

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

CUSTOMER
EXPERIENCE
Customer Centricity“Counting the world’s largest
tech companies as customers,
we are inspired every day togo above and beyond in every
customer interaction, ensuring weremain dynamic, transparent andresponsive to their needs.
Hand in hand, we work together
toward their goals as we strive tobe their preferred partner acrossthe region.
Our commitment to service
excellence and customer
satisfaction means that customers
trust us to deliver where, whenand how they need it; and wecontinue to prove our capabilities,
flex to deliver what they need, andexecute on our promises.
As a result, we uphold deep andlong-lasting partnerships with ourcustomers, growing with them andsharing in success.”

AirTrunk is focused on delivering for its customers, with a unique and consistent customer value
proposition. AirTrunk delivers data centre solutions for our customers that are:

Customer focus is central to AirTrunk’s brandstrategy including our purpose, vision andpoint of difference.
From the CEO to our onsite data centre
operations team, our team delivers a seamlesscustomer experience by applying our company
values of above and beyond, dynamic,transparent, and responsive.
Customer experience training is provided tohelp all employees understand the role theyplay in delivering customer satisfaction.

As a result, in the 2022 AirTrunk
Employee Engagement Survey, 95%
of respondents stated that customer
satisfaction is a key priority for
AirTrunk and 89% understood therole they play in delivering customer
satisfaction.

FAST +SCALABLE

FLEXIBLE +COST-EFFICIENT

Trusted Partnerships
AirTrunk maintains strong and deep
relationships with our customers using a
multi-layered and multi-region engagement
approach across the entire customer journey.
Engagement is between aligned subject
matter experts at AirTrunk and its customers,
rather than through a sales team. For example
between:

TRUSTED +SECURE

SAFE +SUSTAINABLE

 AirTrunk’s executives and leaders engage
regularly with customer’s strategic sourcing
teams;
 Technical, Energy and Safety subject matter
experts; and Operations teams on the ground at our data
centres.
Our dedicated Service Delivery Directors act
as a single point of contact for our customers
across the AirTrunk data centre platform,
deeply understanding the needs of eachcustomer and engaging throughout the projectdelivery stage and ongoing.

Robin Khuda

Founder and CEO
76

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

CUSTOMERSATISFACTION
AirTrunk measures customer
satisfaction at various points
throughout the customer journey tooptimise the customer experience.

Customer Satisfaction Metric
AirTrunk’s marketing team, with
global research provider IPSOS,
measure customer satisfaction
and feedback when customers
are onboarded to an AirTrunk data
centre.

FY22 RESULTS
Overall customer

9/10 satisfaction (avg)
Overall ease of

9/10 working (avg)

Customer Feedback
Extensive partner assessments,
undertaken by a number ofcustomers, provide deep insight into
our performance across contracting,operations, engineering, scalability,
security, safety, availability, delivery,
and relationship. AirTrunk continues
to receive above average scores inthese assessments.

Closing the Feedback Loop

Hearing from our customers

Listening to and actioning feedback
is an important stage of thecustomer satisfaction program.
Once feedback is received,
AirTrunk’s Customer Focus Group
undertake a review of the results
and prepare action plans to close
the feedback loop for continuous
improvement.

Our values were created as a resultof feedback from our customers
on the experience of working with
AirTrunk.

The service delivery teamchampions this task bycommunicating the feedback to
relevant internal stakeholders,
tracks progress and uploads
feedback into the lessons learnt tool
to include in future project plans.

“The whole project
management, coordinationand follow-ups were done
professionally, lessons
learnt were captured andimproved accordingly,
looking forward to work with
AirTrunk in future projects.”
Confidential cloud customer

Here are some quotes from some of
our large cloud and tech customers.

Above and Beyond“Great team, and full supportof our objectives.”

Dynamic“AirTrunk also worked
very actively to meet <our>requirements, especiallywhen <our> project needschanged midway.”

Transparent“Appreciate the transparency
in communication of all
project status.”

Responsive“The project team is very
responsive to queries andaccommodative to lastminute requests.”77

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

FROM EXPERIENCE TO
SATISFACTION TO GROWTH
New Market Growth Story
Note: Due to confidentiality, the customer will not be named and will be referred to as ‘the Customer’ in the following case study.

The Customer Experience
TRUSTEDPARTNERSHIP

01.

02.

03.

04.

Foundation ofproven delivery
and experience
across APJ
platformcustomerrequirementwith regular
engagement

customised
solutions tomeet customer
requirement
and local
capability

with customers
across teams
for alignment on
designmarket entry
and Service
Delivery
becomes
extension of thecustomer team

UNDERSTAND

DEVELOPCOLLABORATEDELIVER

Background:

The Results:

With existing capacity in three AirTrunk data
centres across APJ, AirTrunk has built a deep
relationship with the Customer based on trustand satisfaction.

Through a thorough relationship-based
process, we were able to find a unique solutionthat enabled the Customer to deliver capacity
in a much faster timeline with much less risk
compared to a self-build.

When the Customer sought to enter Tokyo, a
new market, they approached AirTrunk whoalready had well-developed capabilities in
the country, in anticipation of future customer
demand.

The Process:Partnering with the Customer, the AirTrunkteam, led by Customer Success, sought tobuild on its existing relationship to support
their expansion into Japan.

05.

MAINTAIN
100% SLA
compliance,
consistentexperience andsatisfaction

06.

ACTIONlearning andfeedback,
closing theloop for future
projects

AirTrunk was able to facilitate a successful
new market entry for the Customer fasterthan they had experienced with other markets
which then tripled the Customer’s capacitywith AirTrunk.
The Customer and AirTrunk continue to explore
further market expansion opportunities basedon demand.

78

Sustainability Report FY22

Introduction

Why it matters?

SUSTAINABLE
SUPPLY CHAIN

Sustainability Approach

PlanetPeopleProgress

AppendicesGreater environmental stewardship and social responsibility can’t happen in isolation. It requires deep stakeholder
engagement and collaboration, including with suppliers.
Supply chain sustainability places focus on maintaining environmental and societal values including but not limited toclimate change, modern slavery, human rights and anti-corruption.

How does AirTrunkmanage this?

We work with our suppliers to minimise our impact across every step of the supply chain through our Supplier
Governance Framework which includes our:
 Supply Chain Assurance Program, and Supplier Engagement Program with sustainability expectations set out in our Supplier Code of Conduct andmonitored within this framework.
We expect our suppliers to conduct business in accordance with the Supplier Code of Conduct and set similar
expectations with their own supply chain.

What is our commitment?

 To maximise our positive impact through resilient, responsible and sustainable supply chain partners andpractices.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE Appointed key roles including Head of Procurement
and Senior Supply Chain Manager.
 Designed new Supplier Governance Framework.
 Evolved the Procurement function to centralise supply
chain responsibilities.
 Joined the United Nations Global Compact as aparticipant actively supporting its human rights,
labour standards, environmental protection and anticorruption principles.

Who manages this at
AirTrunk?

It is the responsibility of all employees at AirTrunk for ensuring suppliers share our commitment to working in a reliable
and responsible manner by ensuring they follow established policy and processes.

FUTURE TARGET(S) Fully implement Supplier Governance Framework.
 Assess all new and existing development contractors
and equipment vendors through our Supply Chain
Assurance Program.
 Fully integrate UN Global Compact principles onhuman rights, labour, environment and anti-corruption
in our supply chain.

Which SDGs does it
contribute to?

79Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

AIRTRUNK SUPPLY CHAIN
ASSURANCE
AirTrunk considers the following as
suppliers who deliver goods andservices: Development contractors
 Equipment vendors
 Consultants
 Facility management service
providers Corporate suppliers
Our Supply Chain Assurance
includes initiating, developing andmaintaining relationships withthese suppliers.

In FY22, we developed an enhanced
4-stage process to onboard andqualify new suppliers, and re-qualify
existing suppliers, to ensure: Compliance to AirTrunk’s Code of
Conduct, standards and policies; Alignment with our values andrequirements; and Identification, mitigation andmonitoring of any supply chain
risks.

Once onboarded, we work closelywith our suppliers to ensure they
have appropriate controls andmitigations in place to meet therequirements set out in AirTrunkpolicies, and applicable laws andregulations. This process provides
us with assurances that we aresourcing from a responsible andresilient supply chain.

STAGE 1
PRE-QUALIFICATIONSTAGE 2
DUE DILIGENCE

STAGE 3
ONBOARDING

STAGE 4SURVEILLANCE

 Registration of
suppliers.
 Vetting of suppliers
against AirTrunk’s
requirements.
 Initial risk screening
across PEPs,
sanctions, otherwatchlists, andextensive adverse
news and curated risk
profiles including ESG,
Finance, Cyber andmore.
 Pre-qualification
status assigned.

 Due diligenceassessment of prequalified suppliers
across risk categories.
 Formation of
appropriate controls
and mitigation.
 Qualification status
assigned.

 Onboard suppliers
meeting thequalification status,
commence managing
controls andmitigations where
necessary.

 Dashboard monitoring,
notifications actioned
and screening resultsvetted.
 Ongoing
communications with
suppliers to update
information.

80

Sustainability Report FY22

Supplier Engagement Program
AirTrunk refreshed its Supplier
Engagement Program to manage
supplier improvements, applying
appropriate treatment based on
an assessment of the suppliers’
criticality to our business.

Introduction

All suppliers are monitored in termsof performance. However, extensive
collaboration is maintained with
our Alliance suppliers, who areassessed as being highly critical to
the success of our business.
Sustainability features prominently
in the performance assessment
agenda with all of our Alliancesuppliers.

PlanetPeopleProgress

Appendices

AIRTRUNK VENDOR GOVERNANCE
SUPPLIER ENGAGEMENT PROGRAM (SEP)
AirTrunk’s suppliers will be engaged through a tiered performance framework

Suppliers are identified as either: Alliance; or Standard.

Sustainability Approach

DEVELOPMENTCONTRACTORSEQUIPMENTVENDORSCONSULTANTSFACILITY
MANAGEMENTPROVIDERS

STAGE 1

SUPPLIER
SEGMENTATIONSTAGE 2

SUPPLIER ENGAGEMENT PROGRAM (SEP) Suppliers segmented into
tiers considering strategic
importance and businesscriticality/risk:- Alliance Vendors- Standard Vendors
 Output used for:- Determining supplier
treatment level- Quality assurance
priorities

ALLIANCE
Leverage value beyond
contract and drive strategicalignment

STANDARD
Sustain commercial and performancecompliance while minimising risk.

CORPORATESUPPLIERSTECHNOLOGYDEVELOPMENTOPERATIONSCORPORATE

81

Sustainability Report FY22

Aligning our Supply Chain withthe 10 principles of UNGCIn FY22, AirTrunk became a UNGC
participant, actively supporting its
human rights, labour standards,
environmental protection and anticorruption principles. The principles
are reflected in our Supplier Codeof Conduct (amongst other policies)
and managed through our Supplier
Governance Framework.

Introduction

HUMAN RIGHTS Principle 1: Businesses should support and respect
the protection of internationally proclaimed humanrights.
 Principle 2: Make sure that they are not complicit inhuman rights abuses.

Sustainability Approach

PlanetPeopleProgress

Appendices

AirTrunk started conducting periodic online assessments and questionnaires to monitor for any
human rights related or modern slavery issues across our supply chain.
These questionnaires help us analyse our suppliers’ sustainability performance, regulatorycompliance and alignment with AirTrunk’s strategic goals and corporate policies, including our zerotolerance towards human rights abuses and modern slavery.
We may exercise our rights to take contractual action against and/or terminate our relationship with
suppliers if they breach rules outlined in the policies or any relevant laws.
Human Rights Policy | Modern Slavery Policy | Supplier Code of Conduct

LABOUR Principle 3: Businesses should uphold the freedom of
association and the effective recognition of the right tocollective bargaining.
 Principle 4: The elimination of all forms of forced andcompulsory labour.
 Principle 5: The effective abolition of child labour.
 Principle 6: The elimination of discrimination in
respect of employment and occupation.

AirTrunk suppliers are expected to comply with all applicable employment and labour laws,
regulations and fair practices, and should have policies and procedures in places to support theserequirements.
All work must be voluntary. Suppliers must not unreasonably restrict workers’ freedom to move into,out of, or around working facilities.
Our suppliers’ workers will be permitted to associate freely, bargain collectively and seek
representation in accordance with local laws.
Suppliers must maintain grievance procedures to allow workers to raise workplace concerns to theattention of management for appropriate resolution without fear of reprisal or harassment.
Supplier Code of Conduct

ENVIRONMENT Principle 7: Businesses should support aprecautionary approach to environmental challenges.

During quarterly business reviews, our Alliance suppliers report their environmental performance.
This includes their compliance with existing environmental policies and procedures as well as any
violation of environmental laws and regulations.

 Principle 8: Undertake initiatives to promote greater
environmental responsibility.

AirTrunk also conducts independent reviews during project delivery, where suppliers are required tosubmit deliverables against local environmental regulations.

 Principle 9: Encourage the development and diffusionof environmentally friendly technologies.

Supplier Code of Conduct

82

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Introduction

ANTI-CORRUPTION
 Principle 10: Businesses should work against
corruption in all its forms, including extortion andbribery.

Sustainability Approach

PlanetPeopleProgress

Appendices

AirTrunk has zero tolerance for bribery or corruption in any form.
Our suppliers must comply with, and must not knowingly permit anyone to violate, applicable laws
relating to anti-bribery, anti-money laundering, anti-corruption, extortion, embezzlement, fraud, tax
evasion, antitrust and competition, or similar or related activities.
Suppliers must maintain policies and procedures to monitor compliance with laws, to prohibit andprevent the engagement in such activities and to implement enforcement procedures to ensurecompliance.
Suppliers must seek to identify and report any conflicts of interest, be it competing personal or
professional interests. Our suppliers must avoid even the appearance of conflicts of interest in theirwork with us.
AirTrunk will take action against suppliers and other partners for attempted, suspected or actual
corrupt practices, and unethical behaviour. We may exercise our rights to take contractual action
against and/or terminate our relationship with suppliers if they breach our anti-corruption andbribery policy or any relevant laws.
Supplier Code of Conduct | Anti-bribery and Corruption Policy

83Sustainability Report FY22RISK
MANAGEMENT
AND CORPORATE
GOVERNANCE

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

Why it matters?

There is an increased need to anticipate and manage risks due to the fast-changing and uncertain environment thathas come as a result of the COVID-19 pandemic. Protecting our organisation against risks requires a robust corporate
governance ecosystem and the vigilance of multiple stakeholders. Each stakeholder plays a specific role in directing
and managing activities for long-term resilience and value.

How does AirTrunkmanage this?

AirTrunk’s approach does not seek to eliminate all risks, but to identify, understand and effectively manage the risks
arising across our business. AirTrunk has developed a robust risk framework to identify, assess, manage, and reportrisks.

What is our commitment?

 Identify, assess and manage risks and opportunities to preserve AirTrunk’s value.

What are our Performanceand Future Target(s)?

FY22 PERFORMANCE Conducted quarterly assessments with risk owners,
and quarterly discussions with Management and theBoard.
 Joined TCFD as a supporter and published our first
TCFD report.
 Identified climate-related risks and opportunities anddeveloped a climate response.
 Robust governance, transparency and accountability
through:- Release of inaugural Sustainability Report;- Multiple award-winning Sustainability Linked Loan;- CDP Score of B- and 5-STAR GRESB score andSector Leader for Data Infrastructure, Data Storage;and- Gold EcoVadis rating.

Who manages this at
AirTrunk?

The roles and responsibilities of the various stakeholders under the AirTrunk governance structure are clearly definedand communicated.

FUTURE TARGET(S) Continue strengthening the adequacy andeffectiveness of AirTrunk’s risk management
framework.
 Test our resilience to climate-related risks andopportunities and further develop our climate
response.
 Continue to reinforce sound corporate governancethrough disclosure, transparency, and risk
management.
 Maintain ESG transparency through our annual
Sustainability Report, CDP, GRESB and EcoVadis
submissions.
 Ensure annual achievement of our SLL targets withincreased transparency and accountability.

Risk is the responsibility of all AirTrunk employees and is embedded in all activities, processes, and systems. Specificaccountabilities exist for the: Board Board Committees
 Senior Risk Management Committee
 Head of Risk and Sustainability
 Risk Owners
Which SDGs does it
contribute to?

84

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

AIRTRUNK
GOVERNANCE
AirTrunk aspires to the highest standards ofcorporate governance as we believe that good
corporate governance supports long-termvalue creation.

To assist the Board with oversight activities,
various Board committees have been
constituted with clear terms of reference
covering various aspects of the business.

We have a set of well-defined policies andprocesses to enhance corporate performanceand accountability, as well as protect theinterests of stakeholders.

These are the: Audit Committee
 People and Culture Committee
 EHS, Construction and Risk Committee

BOARD
Audit Committee
To support the Board
in discharging its
responsibilities in a rangeof matters such as financial
reporting, budgets, audits,and compliance.

People and Culture
Committee
To support the Board
in discharging its
responsibilities in relation
to policies, remuneration,
performance and benefits.

EHS, Construction and Risk
Committee
To support the Board
in discharging its
responsibilities in various
areas including healthand safety, construction,
procurement and risk
management.

Our Board is comprised of:
2 Executive Directors

4 Investor Nominee Directors

The nomination and selection process
considers the following: Views of stakeholders
 Diversity
 Independence Competencies relevant to the impacts of theorganisation.

2 Independent Directors

Managing conflict of interest
Conflicts of interest are handled in accordancewith AirTrunk governance procedures andrelevant companies law.
At Board level, each director is required todisclose the nature and extent of any personal
conflict of interest to other directors. If
appropriate, they may be excluded from being
able to vote and/or be present at the relevant
meeting.
The AirTrunk company secretarial team also
maintains a conflicts of interest register,which captures cross-board membershipsof AirTrunk directors. The register is updated
regularly.

85

Sustainability Report FY22

Introduction

Managing Risks at AirTrunk
AirTrunk’s risk management approach
does not seek to eliminate all risks, but toidentify, understand and effectively manage
arising risks. This is integrated into AirTrunkIMS aligned with ISO 31000:2018 Risk
Management.

AirTrunk has developed a robust risk
framework which defines the risk appetite,practices and tools to identify, assess andmanage risks, while also managing the ongoing
monitoring and reporting of risks. Our risk
appetite, universe and framework are reviewed
and refreshed at least annually to ensurethat we constantly evolve and meet global
standards and principles.

01.

02.

03.

04.

Define risk
appetite

Identify risks

Assess andprioritise tasks

Treat, monitor
and report risks

Sustainability Approach

PlanetRisks and Opportunities relating to
Climate Change
The urgency of climate change requiresorganisations to be proactive about businessresilience. Climate risk management has been
fully embedded within AirTrunk’s Enterprise
Risk Management Framework and prioritised
as one of our top key enterprise risks.

PeopleProgress

Appendices

In FY22, we completed a climate-relatedrisks and opportunities analysis across
our operations, adopting the Task Force on
Climate-Related Financial Disclosures (TCFD)
recommendations.
More information on our progress can be foundin our TCFD report.

Supported by a robust governance structure, AirTrunk’s Risk Management Framework has been developed to ensure a culture of accountability across the business when it comes to managing risks.

RISK ACCOUNTABILITIES ACROSS THE BUSINESSBOARD

The Board reviews the risk appetite annually and ensures risk profile stays within the agreed appetite and tolerance levels (including emerging risks).
The Board reviews any significant items escalated by the ECRC.

EHS CONSTRUCTION
AND RISK COMMITTEEThe ECRC oversees the overall approach to risk-related matters and ensures ERM framework is established and effectively implemented.

SENIOR RISK MANAGEMENTCOMMITTEEThe SRMC is responsible for ensuring any key existing and emerging risks are appropriately managed and remain within AirTrunk risk appetite in a timely
and efficient manner.

HEAD OF RISK AND SUSTAINABILITY

Drive AirTrunk risk management strategy and activities, in alignment with the accepted standards. Report risks and control environment performance to
SRMC, the ECRC and the Board.

RISK OWNERS

Risk owners are responsible for conducting risk identification and assessments within their relevant risk area.

86Sustainability Report FY22

Introduction

Sustainability Approach

Safety Risk Management

Critical Risk Management (CRM)

Emerging Risks

AirTrunk identified an opportunity to improvestandards and consistency in the way wemanage EHS risk across our regional projects
and data centres. In addressing this need,
we developed a suite of Global MinimumStandards (GMS) and assessed our Critical
Risk Management.

As part of a new CRM program, AirTrunkassessed how critical risks were being
managed across our projects and data
centres (i.e. those risks with the potential forcatastrophic outcomes).

A key component of our risk management
process is the identification and managementof emerging risks. Due to a number ofsignificant global events, supply chain riskincreased for the organisation during theperiod, impacting both development andoperational activities. This was discussed by
key stakeholders at SRMC, and a Supply Chain
Risk Management Program was developed toensure a consistent approach to supply chain
risk management across AirTrunk.

Global Minimum Standards (GMS)
The GMS is a suite of 32 EHS documents
designed to align necessary controls andmitigation strategies for high-risk activities
across all projects and data centres regardlessof region.
The GMS were developed considering local
regulatory requirements and in consultation
with regional contractors and vendors toensure the standards considered the local
market context.
Work is underway to develop additional GMS
including those relating to Occupational
Hygiene and Environmental Management.

To ensure consistency across regions, theprogram provides AirTrunk and our delivery
partners with a framework to systematicallyfocus on the following: Identification of critical hazards;
 Verification of critical controls (crucial tocontrolling critical hazards);
 Identification of control defeating
factors (elements that can stop controls
functioning); Assurance for the conduct of criticalactivities (tasks that keep controls
functioning); and Undertaking critical checks (pre-task checksof critical controls).

PlanetPeopleProgress

Appendices

Two key components of the program,assurance and performance, have been
included in the previous section of this report.

To date, 11 critical risks, 35 critical hazards,
56 threats, and 125 critical controls have been
identified as part of a pilot site in Melbourne.
Based on these findings, we are currently
working toward improving the assurance of ourcurrent high-risk activities.
The completed program is anticipated to be
implemented across AirTrunk construction
projects in early FY23, with implementation
across data centres expected by the end of
FY23.

87

APPENDICES
88

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

APPENDIX 1:
SUSTAINABILITY DATAPLANET INDICATORSNOTES:

PLANET INDICATORS

Reporting scope for data centres, unless otherwise stated:

ENERGY MANAGEMENT
Operating Power Usage Effectiveness (PUE)1

Unit

FY21

FY22

-

1.37

1.35

CARBON MANAGEMENT

Unit

FY21

FY22

Total Scope 1 emissions

tCO2e

562

1,442

tCO2e

562

1,442

Total Scope 2 emissions (location-based)

tCO2e

156,616

294,930

Corporate Scope 2 emissions4,5

tCO2e

239

44.9

Total Scope 2 emissions (market-based)

tCO2e

155,027

257,893

Corporate Scope 2 emissions6,7

tCO2e

0

0

Total Scope 3 emissions

tCO2e

-

201,022

Embodied Carbon-Building Elements8

tCO2e

-

186,624

Embodied Carbon-MEP Systems Specific to Data
Center8tCO2e-13,870Business travel9

tCO2e

-

412

Employee commuting10

tCO2e

-

59

Working from home

tCO2e

-

57

2

Total Scope 1 carbon offsets acquired3
4

6

11

WATER MANAGEMENT

Unit

FY21

FY22

Water Usage Efficiency (WUE)12

l/kWh

0.73

0.84

 FY21: SYD1 and MEL1
 FY22: SYD1, SYD2, MEL1, SGP1, HKG1

Reporting scope for head offices, unless otherwise stated:

 FY21: Singapore and Sydney
 FY22: Singapore and Sydney

1. Operating PUE (or average annual PUE) for our data centres in the reporting scope, following
the Green Grid PUE definition. This reflects the ratio of total facility energy consumption
at high-voltage utility meters to IT energy consumption at low-voltage data hall meters.
Transformation losses and other loads that contribute to the facility energy consumption
such as technical and office spaces, are included in the PUE calculation. The average PUE
for FY22 using the reporting scope for data centres in FY21 is 1.32.
2. Scope 1 emissions for our data centres in the reporting scope, including GHG emissions
from combustion of diesel fuel for backup generators, transformer gas leakages (SF6) andrefrigerants leakages (HFCs) from chillers. The GHG emissions from diesel and SF6 are
calculated based on the Method 1 from the National Greenhouse and Energy Reporting(NGER) guidelines. The GHG emissions from refrigerants gases are calculated based on
the Simplified Material Balance Method, from the U.S. EPA Center for Corporate Climate
Leadership’s (The Center) GHG guidance. Source of the GWP rates used: IPCC Assessment
Report (AR4 for FY21 and AR5 for FY22).
3. Each carbon offset represents an avoidance or removal unit of GHG emissions, measured
in Australian Carbon Credit Units (ACCU) or through Verified Carbon Units (VCUs). We ensurethat those offsets are high-quality and deliver “additionality” where the carbon reduction
would not have happened in the absence of the carbon offsets.
4. Location-based Scope 2 emissions from electricity consumption, following the GHG Protocol
Guidance. This reflects the average GHG emissions intensity from grids on which energy
consumption occurs, using national grid-average emission factor data. Source of emission
factors: NGER 2020-21 for Australia and Energy Market Authority (EMA) 2019 for Singapore
and CLP Power Hong Kong 2020 for Hong Kong.
5. Location-based Scope 2 emissions from electricity consumption at our head offices in
Singapore and Sydney.
6. Market-based Scope 2 emissions from electricity consumption and sourcing of renewableenergy through our utility supply agreements, following the GHG Protocol Guidance. This
represents emissions from electricity consumption at our head offices and data centresin the reporting scope. In FY21, it includes 1% green power sourced for data centres SYD1and MEL1 and 100% green power sourced for our Sydney head office. In FY22, we apply theresidual mix emissions factor for our sites when factoring in the renewable power sourcing.

89

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices7. Market-based Scope 2 emissions from electricity consumption at our head offices
data centres in the reporting scope. In FY21 for consumption that is not passed
through to our customers and includes 1% green power sourced for data centres SYD1and MEL1 and 100% green power sourced for our Sydney head office. There is excess
green power sourced from the 1% allocated to our data centres SYD1 and MEL1 which
we used to cover the Singapore head office emissions. An estimation approach has
been used to counter the difference between emissions factors. The purchased green
power is in abundance to cover the portion of the Singapore head office emissions.
In FY22, the method remains the same as FY21 however in Australia we are more
effectively reporting market based as we are using the residual mix factor.
8. Embodied Carbon includes both emissions from construction of buildings as wellas the plant and equipment deployed by AirTrunk in all our data centres and offices(reporting scope FY22, as well as SYD3, TOK1, TOK2 and Tokyo head office). We have two
embodied carbon factors, one is for building elements which covers the core and shellof our facilities. Another factor applies to the total MW of equipment we have deployed.
As such we have split the Embodied Carbon into these two categories.
9. Our business travel calculation includes all corporate flights and hotel nights stayed.
10. Our employee commuting calculation contains taxi bookings, rideshare bookings, fuelconsumption for travel and public transport for business purposes.
11. Our employee working from home calculation is a standard factor per employee perday. This factor takes into account IT consumption including a computer plus monitors,
general consumption such as heating and lighting, using appliances such as kettles
and also water, wastewater and waste generation.
12. WUE (Green Grid & ISO/IEC CD 30134) is an industry recognised metric that assesses
water consumption in relation to the energy consumed within a facility. The WUE for
FY22 using the reporting scope for data centres in FY21 is 0.84.

90Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

PEOPLE INDICATORSTALENT ATTRACTION AND RETENTIONEMPLOYEE INFORMATION

FY21

FY22

Headcount

DIVERSITY AND INCLUSION

FY21

FY22

Gender mix by management level (% women)

Total headcount at 30 June

146

187

Board

38%

38%

of which permanent employees

144

185

Total employees

27%

32.6%

of which fixed-term employees

22

Leadership

22%

25%

Individual contributor

28%

35%

Total employees by gender
Men

107

126

Total employees by age group

Women

39

61

<30 years old

172230-49 years old

115

120

14

23

Total employees by region
Australia

86110>50 years old

Singapore38

46

Return rate for employees who took parental leave (%)

Japan

16

24

Men

100%

100%

Hong Kong

6

7

Women

100%

100%

Total employees

100%

100%

Total employees by employment type and by gender
Full-time (Men)

107

126

Part-time (Men)00

Full-time (Women)

37

60

Part-time (Women)

22

Leadership

36

39

Individual contributor

110

148

Total employees by management level91

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

FY21

FY22

11

21

PEOPLE INDICATORSNEW EMPLOYEE HIRES

FY21

FY22

New employee hires

EMPLOYEE TURNOVER
Employee turnover

Total new employees hires

57

62

New employee hires by age group

Total employee turnover
Employee turnover by age<30 years old

610<30 years old

0330-49 years old

44

43

30-49 years old

914>50 years old

79>50 years old

24

New employee hires by gender

Employee turnover by gender

Men

44

35

Men

8

14

Women

13

27

Women

3

7

New employee hires by region

Employee turnover by region

Australia

21

33

Australia

212Singapore

16

15

Singapore

3

5

Japan

16

12

Japan

3

2

Hong Kong

4

2

Hong Kong

3

2

CONTRACTORSFY22Contractors working hours1
FTE (full-time equivalent)

2

3,938,225
2,159

NOTES:
1.

Working hours for contractors, including construction contractors at our data centres in development, and operations contractors at our data centres in operation, such as security and facility management teams.

2. 2,159 FTE based on 38hr work week over 48 weeks.

92

Sustainability Report FY22

Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

PEOPLE INDICATORSENVIRONMENTAL HEALTH AND SAFETY

FY21

FY22

Total Recordable Incident Rate (TRIR)1 – Employees

00

Total Recordable Incident Rate (TRIR)1 – Contractors

0.50

0.41

Lost Time Incident Rate (LTIR)2 – Employees

00Lost Time Incident Rate (LTIR) – Contractors

0.14

0.05

Total number of fatalities3

00

Total number of health and safety regulatory notices issued4

0

0

2

NOTES:
1. TRIR provides the number of recordable injuries per 200,000 work hours. Recordable
injuries refer to medical treatments, restricted work injuries and lost time injuries.
2. LTIR provides the number of injuries resulting in more than 1 day lost per 200,000
work hours.
3. Fatality events refer to any death associated with the conduct of work for AirTrunkwork scopes.
4. Regulatory notices refer to any notice issued to AirTrunk by a Regulator or Statutory
Authority for any breach of legislation, licences or permits associated with AirTrunkwork scopes in the local jurisdiction.
5. Community engagement and CSR programs in markets where our data centres havebeen operating for more than 12 months.

COMMUNITY INVESTMENT

FY21

FY22

% of our markets with minimum of one CSR activivty5

100%

100%

CUSTOMER DATA PROTECTION AND CYBER SECURITY

FY21

FY22

Completion of security awareness training6

100%

98%

0

0

0

0

CUSTOMER EXPERIENCE

FY21

FY22

Average annual growth rate of the Top 5 customers from inception in MW sold1

58%

53.8%

Customer data security breaches7
Regulatory notices/fines around data privacy and confidentiality

8

6. Employees and contractors as of 30 June of the reporting year who have received
and acknowledged annual security awareness training within the required deadlines.
7. Customer data security breaches refer to any identified leaks, thefts or loss ofcustomer data.
8. Written statements received from regulatory or similar official body that identify
breaches of customer privacy.

PROGRESS INDICATORSNOTES:
1. Average annual growth rate from first contract signing in 2016.

93

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Introduction

Sustainability Approach

PlanetPeopleProgress

Appendices

APPENDIX 2:
GRI CONTENT INDEXThis report has been prepared in accordance with the GRI Standards and its latest Universal Standards.
Our GRI Content Index specifies each of the GRI Standards disclosures included in this FY22 Sustainability Report.

STATEMENT OF USE

AirTrunk has reported in accordance with the GRI Standards for the period 1 July 2021 to 30 June 2022 (FY22).

GRI 1 USEDGRI 1: Foundation 2021

APPLICABLE GRI SECTOR STANDARD(S)

None

GRI
STANDARDPAGE

DISCLOSUREOMISSIONREQUIREMENT(S) OMITTEDREASONEXPLANATIONGENERAL DISCLOSURE
GRI 2:
GeneralDisclosures2021

2-1 Organizational details

9-12

2-2 Entities included in theorganization’s sustainability
reporting7

2-3 Reporting period,
frequency and contact point

7-8

2-4 Restatements of
information

N/A

2-5 External assurance

8, 103-104

2-6 Activities, value chain andother business relationships

9-12, 79-81

2-7 Employees

91

2-8 Workers who are not
employees

92

2-9 Governance structure andcomposition

25, 8594

Sustainability Report FY22GRI
STANDARDDISCLOSURE

Introduction

PAGE

Sustainability Approach

REASON

2-18 Evaluation of theperformance of the highest
governance bodya, b, cConfidentiality constraints

2-19 Remuneration policiesa, bConfidentiality constraints

2-20 Process to determine
remunerationa, bConfidentiality constraints

2-21 Annual totalcompensation ratio

a, b, cConfidentiality constraints

25, 85

2-11 Chair of the highest
governance body25, 85

2-12 Role of the highest
governance body inoverseeing the managementof impacts

25, 852-13 Delegation of
responsibility for managing
impacts

25, 85-86

2-14 Role of the highest
governance body insustainability reporting25

2-15 Conflicts of interest

85

2-16 Communication ofcritical concerns

25, 85-86

2-17 Collective knowledge ofthe highest governance body25, 852-22 Statement onsustainable development
strategy

PeopleProgress

Appendices

OMISSIONREQUIREMENT(S) OMITTED

2-10 Nomination andselection of the highest
governance body

Planet

EXPLANATIONAs a privately owned company, AirTrunk does not
publish any information regarding the remunerationor performance of its Board.

5-6

95

Sustainability Report FY22GRI
STANDARDDISCLOSURE

Introduction

PAGE

Disclosed throughout the
FY22 Sustainability Reportacross our three pillars:
Planet, People, Progress.
Website: Policies and Reports

2-24 Embedding policy
commitments

Disclosed throughout the
FY22 Sustainability Reportacross our three pillars:
Planet, People, Progress.

2-25 Processes to remediate
negative impacts

Disclosed throughout the
FY22 Sustainability Reportacross our three pillars:
Planet, People, Progress.

2-26 Mechanisms for seeking
advice and raising concerns

Website: Global
Whistleblowing Policy

2-27 Compliance with laws
and regulations

In FY22, there were no
instances of non-compliancewith laws in any material
respect.

2-28 Membershipassociations14

2-29 Approach to stakeholder
engagement

26-27

2-30 Collective bargaining
agreements

As of 30 June, 2022, no
AirTrunk employees arecovered by collective
bargaining agreements.

PlanetPeopleProgress

Appendices

OMISSIONREQUIREMENT(S) OMITTED

2-23 Policy commitments

Sustainability Approach

REASONEXPLANATION

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Appendices

OMISSIONREQUIREMENT(S) OMITTEDREASONEXPLANATIONa, b, c, d, eConfidentiality constraintsaConfidentiality constraints

As a hyperscale data centre, our metric for leasing
is in megawatts (MW). As such we keep our leased
capacity, and inversely our vacant capacity,
confidential while making our total designed
capacity known. This is comparable to how an officelandlord keeps their leased capacity confidential,
while the design of the building and number offloors is made public so it can be observed.

MATERIAL TOPICSGRI 3:
Material
Topics 2021

3-1 Process to determinematerial topics

17

3-2 List of material topics

17

ENERGY MANAGEMENTGRI 3:
Material
Topics 2021

3-3 Management of material
topicsGRI 302:
Energy 2016

302-1 Energy consumption
within the organization
302-5 Reductions in energy
requirements of products andservices

33-36, 89

33-36, 89

By making our total electricity consumption known
alongside our portfolio level PUE, we inadvertently
give away confidential information as IT equipment
power at a portfolio level can be discerned when
two elements from the formula are known.
302-3 Energy intensity

33-36, 8997

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OMISSIONREQUIREMENT(S) OMITTEDREASONEXPLANATIONCARBON MANAGEMENTGRI 3:
Material
Topics 2021

3-3 Management of material
topics37-42, 89

GRI 305:
Emissions2016

305-1 Direct (Scope 1)
GHG emissions

39, 89305-2 Energy indirect(Scope 2) GHG emissions

41, 89305-3 Other indirect (Scope 3)
GHG emissions

42, 89305-5 Reduction of GHG
emissions37-42, 89

WASTE MANAGEMENTGRI 3:
Material
Topics 2021

3-3 Management of material
topics43-45

GRI 306:
Waste 2020306-1 Waste generation andsignificant waste-related
impacts

43-45

306-2 Management ofsignificant waste-related
impacts

43-45

306-3 Waste generated

43-45

a

Information unavailable/
incomplete

306-4 Waste diverted from
disposal

43-45

a, b, c, dInformation unavailable/
incomplete

We commenced accurate tracking and validationof our waste streams at MEL1, our pilot waste site.
We will expand the reporting scope as we progress
to a more sophisticated way of measuring andmonitoring our waste data.

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Appendices

OMISSIONREQUIREMENT(S) OMITTEDREASONEXPLANATIONa, b, cConfidentiality constraints

As a hyperscale data centre, our metric for leasing
is in megawatts (MW). As such we keep our leased
capacity, and inversely our vacant capacity,
confidential while making our total designed
capacity known. This is comparable to how an officelandlord keeps their leased capacity confidential,
while the design of the building and number offloors is made public so it can be observed.

WATER MANAGEMENTGRI 3:
Material
Topics 2021

3-3 Management of material
topics46-51, 89

GRI 303:
Water andEffluents 2018

303-1 Interactions with water
as a shared resource

46-51

303-2 Management of water
discharge-related impacts

Water used in our data
centres is discharged into
the public sewerage system.
The ratio of wastewater towater that comes into site
is estimated or metered by
the local water authority.
AirTrunk works closely withour contractors during
the construction phase to
track the quality of water
discharged and prevent
pollution.

303-3 Water withdrawal

By making our total water withdrawal known,
alongside our portfolio level WUE, we inadvertently
give away confidential information as IT equipment
power at a portfolio level can be discerned when
two elements from the formula are known.

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OMISSIONREQUIREMENT(S) OMITTEDREASONEXPLANATIONENVIRONMENTAL HEALTH AND SAFETY
GRI 3:
Material
Topics 2021

3-3 Management of material
topics53-57

GRI 403:
Occupational
Health and
Safety 2018403-1 Occupational healthand safety management
system53-57

403-2 Hazard identification,risk assessment, and incident
investigation

53-57

403-3 Occupational healthservices

53-57

403-4 Worker participation,
consultation, andcommunication on
occupational health andsafety53-57

403-5 Worker training on
occupational health andsafety53-57

403-6 Promotion of worker
health53-57

403-7 Prevention andmitigation of occupational
health and safety impacts
directly linked by business
relationships

53-57

403-8 Workers covered byan occupational health andsafety management system

53-57

403-9 Work-related injuries

53-57, 93100

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OMISSIONREQUIREMENT(S) OMITTEDREASONEXPLANATIONTALENT ATTRACTION AND RETENTIONGRI 3:
Material
Topics 2021

3-3 Management of material
topics58-62

GRI 401:
Employment2016

401-1 New employee hires
and employee turnover92

401-3 Parental leave

91

GRI 405:
Diversityand Equal
Opportunity
2016

405-1 Diversity of governancebodies and employees

58, 91COMMUNITY ENGAGEMENTGRI 3:
Material
Topics 2021

3-3 Management of material
topics63-66

GRI 413:
Local
Communities
2016413-1 Operations with local
community engagement,
impact assessments, anddevelopment programs

63-66, 93

CUSTOMER DATA PROTECTION AND CYBER SECURITY
GRI 3:
Material
Topics 2021

3-3 Management of material
topics67-69

GRI 418:
CustomerPrivacy 2016418-1 Substantiatedcomplaints concerning
breaches of customer privacy
and losses of customer data

67, 933-3 Management of material
topics71-74

INNOVATIONGRI 3:
Material
Topics 2021

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OMISSIONREQUIREMENT(S) OMITTEDREASONa

Information unavailable/
incomplete

EXPLANATIONCUSTOMER EXPERIENCE AND SATISFACTION
GRI 3:
Material
Topics 2021

3-3 Management of material
topics

75-78

Not applicable

Average annual growth rateof the Top 5 customers frominception in MW sold75, 93SUSTAINABLE SUPPLY CHAIN
GRI 3:
Material
Topics 2021

3-3 Management of material
topics

79-83

GRI 308 :Supplier
Environmental
Assessment
2016308-1 New suppliers thatwere screened using
environmental criteria

79-83

GRI 414:
Supplier
SocialAssessment
2016414-1 New suppliers thatwere screened using social
criteria

79-83

aInformation unavailable/
incomplete

In FY22, we further strengthened our supplieronboarding and qualification process, and set atarget to assess all new and existing development
contractors and equipment vendors through thisprocess. We will report the progress annually.

RISK MANAGEMENT AND CORPORATE GOVERNANCE
GRI 3:
Material
Topics 2021

3-3 Management of material
topics84-87

GRI 205:
Anticorruption
2016

205-2 Communication andtraining about anti-corruption
policies and procedures

In FY22, 100% of employees
received Anti-Bribery andCorruption policy training.

205-3 Confirmed incidents ofcorruption and actions taken

Zero confirmed incidents ofcorruption in FY22.

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Appendices

Appendix 3:
KPMG Assurance Report

Independent Limited Assurance Reportto the Directors of AirTrunk Operating Pty Limited
Conclusion
Based on the evidence we obtained
from the procedures performed,
we are not aware of any material
misstatements in the SelectedSustainability Information, as
described below, which has been
prepared by AirTrunk Operating
Pty Limited in accordance withmanagement measurement
methodologies as presented inAppendix 1: Sustainability Data to
AirTrunk’s Sustainability Report for
the year ended 30 June 2022.

Information Subject to Assurance

Criteria Used as the Basis of Reporting

The Selected Sustainability Information, as presented in AirTrunk Operating Pty Limited’s (AirTrunk)
Sustainability Report (Sustainability Report) and available on AirTrunk’s website, comprised thefollowing:

The criteria used in relation to the SelectedSustainability Information are AirTrunk’s
management measurement methodologies aspresented in the Carbon Management sectionof Appendix 1: Sustainability Data to the
AirTrunk Sustainability Report.

SELECTED SUSTAINABILITY INFORMATIONVALUE ASSURED FY22

CARBON MANAGEMENT
Total Scope 1 emissions (tCO2e)

1,442

Total Scope 1 carbon offsets acquired (tCO2e)

1,442

Total Scope 2 emissions (location-based) (tCO2e)294,930

Total Scope 2 emissions (market-based) (tCO2e)257,893

Embodied Carbon-Building Elements (tCO2e)

186,624

Embodied Carbon-MEP Systems Specific to Data Centre (tCO2e)

13,870Business travel (tCO2e)

412

Employee commuting (tCO2e)59

Working from Home (tCO2e)57

Basis for Conclusion
We conducted our work in accordancewith Australian Standard on Assurance
Engagements ASAE 3000 (Standard). In
accordance with the Standard we have: Used our professional judgement to planand perform the engagement to obtain
limited assurance that we are not aware ofany material misstatements in the SelectedSustainability Information, whether due tofraud or error; Considered relevant internal controls
when designing our assurance procedures,
however we do not express a conclusion on
their effectiveness; and Ensured that the engagement team possess
the appropriate knowledge, skills andprofessional competencies.

103Sustainability Report FY22

Summary of Procedures Performed
Our limited assurance conclusion is based on
the evidence obtained from performing thefollowing procedures: Enquiries with relevant AirTrunk personnel
to understand the internal controls,
governance structure and reporting processof the Selected Sustainability Information;
 Reviews of relevant documentation
including AirTrunk’s management
measurement methodologies and relevant
NGER legislation;
 Analytical procedures over the SelectedSustainability Information;
 Walkthroughs of the Selected Sustainability
Information to source documentation;
 Evaluating the appropriateness of thecriteria with respect to the SelectedSustainability Information; and Review of the Sustainability Report in its
entirety to consider whether it is consistent
with our assurance work.

Inherent Limitations
There are inherent limitations in performing
assurance – for example, assurance
engagements are based on selective testing of
the information being examined – and becauseof this, it is possible that fraud, error, or noncompliance may occur and not be detected.
An assurance engagement is not designed todetect all misstatements, as an assurance
engagement is not performed continuously
throughout the period that is the subject of theengagement and the procedures performed ona test basis. The conclusion expressed in thisreport has been formed on the above basis.

Introduction

Additionally, non-financial data may besubject to more inherent limitations thanfinancial data, given both its nature and themethods used for determining, calculating,and sampling or estimating such data. We
specifically note that AirTrunk Operating Pty
Limited has used estimates or extrapolated
underlying information to calculate certain
amounts included within the SelectedSustainability Information.

How the Standard Defines Limited
Assurance and Material Misstatement
The procedures performed in a limited
assurance engagement vary in nature andtiming from, and are less in extent thanfor a reasonable assurance engagement.
Consequently the level of assurance obtainedin a limited assurance engagement issubstantially lower than the assurance thatwould have been obtained had a reasonableassurance engagement been performed.
Misstatements, including omissions, areconsidered material if, individually or in theaggregate, they could reasonably be expected
to influence relevant decisions of the Directorsof AirTrunk.

Use of this Assurance Report
This report has been prepared for the Directorsof AirTrunk for the purpose of providing
an assurance conclusion on the SelectedSustainability Information and may not besuitable for another purpose. We disclaim any
assumption of responsibility for any relianceon this report, to any person other than the
Directors of AirTrunk, or for any other purpose
than that for which it was prepared.

Sustainability Approach

PlanetPeopleProgress

AppendicesManagement’s Responsibility
Management are responsible for:
 Determining that the criteria is appropriate
to meet their needs;
 Preparing and presenting the SelectedSustainability Information in accordancewith the criteria; and Establishing internal controls that enable
the preparation and presentation of theSelected Sustainability Information that is
free from material misstatement, whether
due to fraud or error.

Our Responsibility
Our responsibility is to perform a limited
assurance engagement in relation to theSelected Sustainability Information for theyear ended 30 June 2022, and to issue anassurance report that includes our conclusion.

Our Independence and Quality Control
We have complied with our independence andother relevant ethical requirements of theCode of Ethics for Professional Accountants(including Independence Standards) issued
by the Australian Professional and EthicalStandards Board, and complied with theapplicable requirements of AustralianStandard on Quality Control 1 to maintain acomprehensive system of quality control.

KPMG
Sydney25 October 2022

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CORPORATEINFORMATION
AirTrunk Operating Pty Ltd
Level 11, 1 Pacific Highway
North Sydney New South Wales 2060
Phone: +61 2 9953 4780
Email: info@airtrunk.com
Email: media@airtrunk.com
Company Registration ACN 612 044 283
Download this Sustainability Report online at airtrunk.com/sustainability.

105