LAST UPDATED: 2026-06-17

1 Introduction

Scandinavian Data Centers (SDC) builds and operates a scalable data centerplatform 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

ScandinavianData Centers see a future where data centers power more than data — they powera better society.

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

3 Environmental management system

SDC maintains an Environmental ManagementSystem (EMS) aligned with the requirements of ISO 14001 to ensure a structuredand 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

SDCbuilds and operates its facilities with the goal of minimizing environmentalimpact and maximizing resource efficiency.

SDCis committed to protecting the environment by preventing pollution, usingresources efficiently, and minimizing environmental impact throughout itsoperations.

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 whilebuilding 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 centralfoundation. This means the company consciously manages potential conflicts ofinterest between customer needs, societal benefits, and climate goals. SDC’sprinciple is always to seek solutions that create balance and long-term valuefor 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 Boardholds overall responsibility for ensuring that sustainability is an integratedpart of the company’s long-term strategy.

The Managementteam is responsible for implementing this strategy in practice and ensuringthat daily operations contribute to achieving sustainability objectives. SDCcommits to appointing a dedicated person responsible for sustainability withinthe Management Team.

Each employeeis responsible for contributing to sustainable practices by complying withSDC’s policies and actively working to reduce environmental impact andstrengthen 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 accessability

This policy and associated procedures arereadily accessible to all employees.

7.4 Code of Conduct

SDC maintains a Code of Conduct applicable tosuppliers 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.

7.5 KPIs and targets

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

KPIs are defined within, but not limitedto, 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.