LAST UPDATED: 2026-06-17

1 Introduction

Scandinavian Data Centers (SDC) builds and operates a scalable data center platform designed to maximize value per megawatt for customers,communities, and the energy system.

This Sustainability Policy provides a framework guiding SDC in taking environmental,social, and economic responsibility throughout its operations and value chain.

2 Scandinavian Data Centers’ sustainability vision

Scandinavian Data Centers sees a future where data centers power more than data — they power a better society.

Data centers hold untapped potential to strengthen energy systems, support communities,create resilience and accelerate the green transition. SDC aims to unlock that potential by rethinking how digital infrastructure interacts with the energy system and the world around it.

3 Environmental management system

SDC maintains an Environmental Management System (EMS) aligned with the requirements of ISO 14001 to ensure a structured and continuous approach to environmental performance, compliance obligations,and sustainability improvements throughout the organization.

The Environmental Management System encompasses all company sites and functions, ensuring a consistent approach to environmental sustainability across our business. Data center operation is excluded until the data center is fully established.4 Environment and climate impact

SDC builds and operates its facilities with the goal of minimizing environmental impact and maximizing resource efficiency.

SDC is committed to protecting the environment by preventing pollution, using resources efficiently, and minimizing environmental impact throughout its operations.

4.1 Energy

SDC commits to:

• From 2026 onwards, ensuring that 100% of electricity used is renewable and sourced from certified     suppliers.
• Striving for high energy efficiency (low PUE values). In cases where heat recovery is implemented, PUE may be slightly higher; however, this is acceptable when the overall climate benefit increases.

4.2 Cooling systems and water use

SDC commits to:

• Using free cooling and other energy-efficient cooling technologies.
• Reducing water consumption and prioritizing the use of recycled water.
• Reporting annual water usage.

4.3 Carbon footprint

SDC commits to:

• Measuring and reporting Scope 1, Scope 2, and relevant Scope 3 emissions.
• Continuously improving carbon performance, with at least one short-term and one long-term emissions     reduction target established.
• Designing data centers in dialogue with heat off-takers to ensure that excess heat is utilized. The company aims to secure heat off-takers capable of receiving heat year-round.
• Using only HVO or other renewable fuels for backup power generators.

4.4 Waste and recycling

SDC commits to:

• Following principles of responsible e-waste management.
• Providing recycling facilities at all sites and offices.

4.5 Laws and regulations

SDC complies with all applicableenvironmental legislation, regulatory requirements, permits, and other bindingobligations related to its operations.5 Social commitments

SDC aims to be a safe, inclusive, and progressive employer while building strong relationships with suppliers and local communities.

SDC commits to:

• Providing a safe working environment with zero tolerance for accidents.
• Training all employees in sustainability-related matters.
• Promoting diversity, gender equality, and equal opportunities throughout the organization.

6 Economic responsibility

SDC pursues long-term growth with sustainability as a central foundation. This means the company consciously manages potential conflicts of interest between customer needs, societal benefits, and climate goals. is always to seek solutions that create balance and long-term value for all stakeholders.

SDC commits to:

• Operating a business model that combines financial returns with societal benefit.
• Investing in technology and partnerships that support the climate transition.
• Maintaining zero tolerance for corruption and misconduct.
• Integrating sustainability into  financial decisions and investments.

7 Governance and transparency

As a keeper of critical infrastructure, SDC carries a particular responsibility. The company’s governance ensures that sustainability is consistently integrated into decisions and processes, from investments and operations to partnerships and long-term strategies.

7.1 Responsibility

The Board holds overall responsibility for ensuring that sustainability is an integrated part of the company’s long-term strategy.

The Management team is responsible for implementing this strategy in practice and ensuring that daily operations contribute to achieving sustainability objectives. SDC commits to appointing a dedicated person responsible for sustainability with in the Management Team.

Each employee is responsible for contributing to sustainable practices by complying with SDC’s policies and actively working to reduce environmental impact and strengthen social responsibility.

7.2 Reporting

SDC commits to:

• Annual reporting of sustainability data and KPIs.
• Including sustainability as a recurring item on the Board’s agenda.

7.3 Policy accessibility

This policy and associated procedures are readily accessible to all employees.

7.4 Code of Conduct

SDC maintains a Code of Conduct applicable to suppliers and customers, stating our demands and expectations concerning sustainability.

7.5 Risk

SDC has a process to annually identify, analyze, and manage climate-related risks and opportunities.

7.6 KPIs and targets

SDC continuously improves its environmental performance and environmental management system by setting clear KPIs, targets,and monitoring progress.

KPIs are defined within, but not to, the following areas:

• Energy efficiency and performance
• Carbon emissions
• Workplace safety
• Diversity and inclusion

Targets are set annually by the Managementteam and approved by the Board. Results are monitored quarterly and reported annually.