Public Policy Activities
EQUINIX POLICY REGARDING PUBLIC POLICY ACTIVITIES
As a global corporation and employer, Equinix operates in many political and regulatory environments. Equinix believes that it is the company’s responsibility to understand the environments in which the company operates, and that participation in the public policy process is in the long-term interest of our company and all of our stakeholders, including our stockholders. Equinix’s public policy priorities and advocacy efforts are based on the company’s operations and business opportunities that it believes will increase stockholder value and contribute to the overall success of the company. Equinix also believes its responsibility as a good corporate citizen extends to an active engagement with policy makers in helping advance development of and access to clean, renewable energy and a more connected and digitally secure world.
Equinix’s involvement in public policy is subject to extensive regulation at federal and state levels, and is primarily through its membership in trade associations, participation in global forums, and representation before governments that are considering regulations or legislation that may affect our business. Equinix may consider other means of participation such as government advisory committees or political contributions within the parameters of our policy.
In all regions and metros throughout the world, Equinix conducts its public policy activities with strict attention to all legal and ethical requirements and does so in a transparent manner.
Trade Associations Policy
Like most multinational companies, Equinix belongs to trade and industry associations in the United States and abroad to which Equinix pays annual dues.
Memberships include but are not limited to the following:
- California Taxpayers Association (CalTax)
- Data Center Coalition
- Dutch Data Centre Association
- European Data Center Association (EUDCA)
- Illinois Chamber of Commerce
- Information Technology Industry Council (ITI)
- Northern Virginia Technology Council (NVTC)
- Renewable Energy Buyers Alliance (REBA)
- TechUK (United Kingdom)
Membership in trade associations is important to Equinix and provides a number of benefits, including helping Equinix stay informed of emerging issues and industry standards, identifying trends, collecting and analyzing policy and political information and providing educational opportunities for Equinix employees. Trade associations also serve as a unified voice for our industry. In most cases, we are aligned with the views the associations take on matters of public policy; however, our membership in any trade association does not indicate our agreement with all views and positions taken by the association. In those situations where our views differ from those of the association, we will engage with the association to ensure our views are communicated. Our Public Policy Director periodically reviews Equinix’s trade association memberships to determine that they remain consistent with Equinix’s public policy objectives.
Equinix does not contribute to these groups beyond its membership dues and regularly reviews the costs and benefits of each membership. Equinix makes a reasonable effort to confirm that our dues are not used for political contributions.
Issue Advocacy Policy
Equinix conducts public policy advocacy efforts in compliance with applicable laws and regulations governing such activities. Before engaging in any advocacy activities for Equinix, employees are asked to contact Equinix’s Chief Compliance Officer and/or the Public Policy Director or their respective designee for approval, which ensures that such activities are consistent with the company’s public policy positions and in compliance with laws and regulations. Prior approval is also required before Equinix may retain an outside entity to engage in such activities. In the United States, certain communications with federal, state and/or local government officials or government employees may be reportable as lobbying communications and required to be disclosed. Certain countries outside the United States may also require public disclosure of such activities.
Political Contributions Policy
While certain states and jurisdictions allow such contributions, Equinix, has never made any direct political contributions to candidates. Equinix prohibits independent expenditures on behalf of candidates at any level of government. This includes political contributions made in support of, or against, a candidate that are not made through a Political Action Committee (PAC) or to a candidate’s campaign and are made without a candidate’s request or coordination. Equinix does not have a PAC.
From time to time, Equinix may participate in local and state ballot initiatives when it reasonably believes that the outcome of such measures will have a long-term impact on the interests of our company and stockholders. Likewise, Equinix may also consider contributions to certain 501(c)(4) groups (such as local community groups) and 527 organizations (such as governors’ associations) as merited based on similar considerations.
Under Equinix’s Code of Business Conduct, individual company employees are prohibited from making or committing to political contributions on behalf of Equinix.
Equinix will disclose the details of any contribution—including identification of the organization or candidate, and amount contributed—in a political contributions report published on this webpage here on a semi-annual basis. This report will also disclose details of our trade associations where membership dues exceed $50,000.
As required by the U.S. Lobby Disclosure Act (LDA), Equinix files quarterly reports—so-called LDA Reports—on its federal lobbying activities and expenditures. At the US Federal level, also as required by the Lobby Disclosure Act, Equinix files semi-annual reports (so-called LDA-203 Reports), which disclose all political contributions and spending. Both the quarterly LDA and the semi-annual LDA-203 reports can be found at the Lobbying Disclosures Search page. The most recent Equinix LDA report on lobbying activities can be found here, and the most recent LDA-203 report filed by Equinix can be found here.
In the event any political contributions are made in other jurisdictions, Equinix will adhere to all relevant legal reporting and disclosure requirements.
Board and Senior Management Oversight
Equinix’s public policy function was formally established in January 2017 and reports into Equinix’s Chief Compliance Officer. Equinix has established a cross-functional Public Policy Council comprised of executives with global responsibility to provide oversight and advice on relevant public policy concerns.
All activity in this area is reviewed and governed by our Chief Compliance Officer in consultation with the Chief Legal Officer and the Board’s Governance Committee. Any political spending aims to promote the interests of Equinix and not those of an individual director, officer or employee.
The Governance Committee semiannually reviews the policies and practices of Equinix’s Public Policy function, Equinix’s membership in trade associations, Equinix’s lobbying expenses and activities, and any other political contributions.