Legal

Energy Management PolicyDocument Ref: 5003-A-EnMS PolicyVersion 2.4 - Issue date: 28 September 2022

1. Purpose, Context & Scope

Ark Data Centres Ltd (“Ark”) is a UK data centre provider, with locations at Spring Park (Corsham), Cody Park (Farnborough) and Meridian Park (Enfield).

Information Technology (IT) has grown enormously over the past 30 years and data gathering, processing, storage and retrieval are now crucial elements for all businesses. It is recognised that a modern, well-run data centre has a superior energy-performance compared with numerous small, variable server rooms. However, that is not to say that data centres should not try to improve their performance. We recognise that climate change is happening and the need for action. By saving energy we will simultaneously make cost savings, benefitting our clients, ourselves and ultimately our environment.

This policy shall apply to all data centre campuses, employees and contractors working for or on behalf of Ark at all sites.

2. Top Management Commitment

Senior Leadership Team (SLT) commitment is fundamental to the continual improvement of energy performance and the EnMS. The SLT demonstrates its commitment through the ongoing allocation of resources, availability of resources and active involvement in the EnMS to achieve objectives and targets.

The SLT endorse all EnMS objectives to ensure they are SMART and reflect the current needs and goals of the business. Those objectives and our performance against them will be measured and evaluated as often as is necessary and in any event no less frequently than annually.

3. Undertakings

Ark is committed to environmental stewardship and we will demonstrate this by:

Maintaining our existing ISO 14001 (Environmental Management) certification;
Maintaining our existing ISO 50001 (Energy Management) certification;
Working with Tech UK and the Major Energy Users Council to obtain a CCA (or equivalent) for all of our applicable data centres;
Working as a member of the Climate Neutral Data Centre Pact (CNDCP) to develop and the implement the Self Regulatory Initiatives (SRI) for measuring, monitoring and reporting operational improvements to recognised standards;
Complying with all legal and other requirements appropriate to Ark’s energy use, consumption and efficiency, including meeting all ESOS, CCA, UK ETS and EPR targets and reporting requirements;
Quantify our energy consumption (as kWh) and associated CO2 emissions, including indirect emissions, based on recognized international protocols. This will include indirect emissions from Grid electricity;
Relate energy to measure(s) of activity. The chosen metric for this is “power usage effectiveness” (PUE): the inverse ratio of total primary energy used by the IT equipment within the data centre versus the primary energy consumed by the whole data centre facility”. PUE has been adopted for Climate-Change Agreements (CCAs) targets with UK Government;
Meet our CCA (or equivalent) targets; specifically, year-on-year PUE reduction targets (in comparison to our baseline);
Identify and progress energy-saving projects that can be implemented across our estate to help meet targets, and actively seek new opportunities, by:

maintaining awareness of any energy-efficient, renewable or low-carbon technologies relevant to the sector;
regularly conducting internal and external reviews and audits, then acting on the findings;
ensuring the availability of information and the necessary resources to achieve objectives and targets.

Within commercial reason, procure energy-efficient products and services that impact energy performance;
To procure green or renewable energy for our data centre campuses, unless the cost is prohibitive;
Continue to develop our design and service offerings to ensure that energy-efficient products are used to maximum effect;
Document in relevant Employer’s Brief’s, or other relevant documentation, Ark’s commitment to energy efficiency and compliance with ISO 50001;
Maintain regular reviews, inputs and steerage from SLT relating to energy objectives and targets;
Ensure that sufficient information and resources are available so that our Energy Management objectives and targets are met;
We are committed to continually look for ways to improve the efficiency, availability, sustainability and energy performance of our business. We will ensure continual improvement through research, lessons learned and listening to our customers and suppliers.

4. Supporting/Linkage Documentation

5160-A-Management System Objectives contains the objectives and targets set to transform the energy policy into action.

5018-E-Certification Responsibilities details the roles & responsibilities associated with the EnMS.

5126-R-Combined Legal Register contains the applicable mandatory requirements related to Ark’s energy use, consumption and efficiency.

5041-A-Environmental Policy contains Ark’s commitments on leading the industry in reducing the impact of our activities on the environment.

Additional supporting documentation that individuals following this policy may need to be aware of is located within Ark’s document management system.

Huw Owen
Chief Executive Officer
Ark Data Centres Limited
28 September 2022