The Wingu Group’s ambitions for its environmental, social and governance (“ESG”) programme are to:

  • Incorporate ESG matters into its decision-making processes.
  • Comply with both the letter and spirit of the law/regulation, wherever it applies.
  • Recognise the potential impact of businesses on the environment, workers, communities and society.
  • Ensure that human rights are respected and ensure no exploitation of children or child labour.
  • Act responsibly with respect to the environment, aiming for a sustainable approach to the use of resources and avoiding irresponsible disposal of hazardous products and unnecessary waste.
  • Ensure that management structures and policies reflect the need for transparency, accountability, equality, and probity.
  • Comply with best practice and actively manage ESG considerations and risks.
  • Identify any potential ESG risks and their related impact, with the aim of monitoring and mitigating the potential risk.
  • Identify and provide appropriate training to Wingu’s employees on all these matters.


Wingu recognises that environmental factors, such as the depletion of natural resources and the rising threat of climate change, can have a series of sustained impacts on society, and on businesses, especially financially. As such, environmentally friendly options are considered wherever possible, taking into consideration challenging jurisdictions within which Wingu operates, and the tension, in some cases, between development cost and the availability of affordable and sustainable options. Wingu also recognises the profound positive environmental impact of aggregating racks in one data center, whereby optimising energy and natural resource requirements, as opposed to each company building and operating its own smaller, inefficient data center.

Wingu considers these factors with particular reference to:

  • The way in which Wingu conducts its business in an environmentally responsible manner consistent with its corporate values.
  • Wingu’s responsibility as a driver of environmental stewardship initiatives across the enterprise, including spearheading corporate carbon and energy reduction efforts and engaging Business Partners on environmental initiatives. This includes identifying opportunities to reduce the firm’s own environmental footprint, to have a positive impact on the communities in which the firm operates.

Wingu’s environmental commitments include:

  • Complying with all relevant environmental laws and regulations.
  • Reducing the direct impact of its operations on the environment by pursuing improvement in greenhouse gas (“GHG”) emissions, energy consumption, water consumption, waste production, natural resource use and pollution prevention.
  • Reducing the use of toxic chemicals, including for pest control, where possible.
  • Promoting responsible disposal of hazardous waste.

Wingu’s climate change-related considerations include:

  • Acting, where possible and practicable, to reduce its operational emissions to keep the global average temperature increase below two degrees Celsius, in line with the Intragovernmental Panel on Climate Change recommendations, reducing the likelihood of severe and irreversible effects of climate change.
  • Identifying and executing on opportunities that reduce the environmental impact of Wingu’s value chain through implementing the following activities, where practicable:
    • Selecting greener alternative products and incorporating sustainable solutions within Wingu’s procured services, where feasible;
    • Choosing Business Partners that are committed to environmental stewardship and demonstrating progress towards reducing their carbon footprint;
    • Providing educational opportunities on relevant environmental topics and business solutions;
    • Recognising suppliers that demonstrate exceptional leadership in environmental sustainability efforts; and
    • Collaborating with suppliers, contractors, and other business partners to reduce environmental impact and driving progress towards shared sustainability goals.


Wingu’s business indirectly facilitates the education, employment, financial inclusion, entertainment and connectivity of millions of people. Directly, Wingu’s operational model is not labour intensive and employees are relatively highly skilled. Wingu recognises that inclusion, diversity and equality are important considerations in relation to how businesses operate and can generate a competitive advantage. Wingu is also aware that these areas are, deservedly, attracting increasing scrutiny from a range of stakeholders, and that there are increasing commercial benefits, including regarding the cost of capital, for businesses that have inclusive and diverse work ethics and practices.

Wingu’s main social considerations include the preservation of human rights, avoidance of any complicity in human rights abuses, including any exploitation of child labour or indentured servitude, and health and safety.

Wingu’s social commitments include:

  • Complying with all applicable social, local and national regulations including those relating to employment, health and safety and stakeholder engagement.
  • Incorporating practices detailed within the International Labour Organisation’s Core Labour Standards into Wingu’s human resources policies and management system.
  • Complying with the UN’s Guiding Principles on Business and Human Rights.
  • Complying with applicable health and safety regulations within each of the localities and countries of operations.
  • Providing a fair living wage and fair working hours for all employees that are above nationally defined requirements.
  • Ensuring employees have access to freedom of association and collective bargaining.
  • Requiring Wingu’s Business Partners to meet all their applicable local and national employment and health and safety regulations.
  • Enforcing an inclusive culture with zero tolerance towards bullying and harassment.

Stakeholder Engagement

Wingu is committed to being a good citizen of society. Wingu does this by honouring the rights of its internal and external stakeholders, treating them fairly, listening to their opinions and working to address their concerns, where reasonable.

Ongoing stakeholder engagement is a fundamental component of how Wingu carries out its business to ensure the concerns and needs of Wingu’s key stakeholders are acknowledged, registered, and managed.

Wingu commits to:

  • Treating all its stakeholders with respect and integrity to foster mutual trust and build a collaborative working relationship.
  • Treating all its stakeholders fairly, regardless of gender, gender expression, age, race, religion, colour, ethnicity, disability, family or marital status, national origin, physical or mental ability, political affiliation, sexual orientation, socio-economic status and all other characteristics that make Wingu’s stakeholders unique.
  • Ensuring the diverse perspectives of its stakeholders are given due consideration when Wingu is developing its business and strategic goals.
  • Communicating through open, honest dialogue and consultations with its stakeholders, aiming to be proactive rather than reactive in these engagements.


Wingu is committed to achieving high standards of corporate governance. This includes complying with relevant legal requirements and regulations, as well as conducting business in a socially and ethically responsible manner. Corporate governance is a key element in improving economic efficiency and growth, as well as enhancing investor confidence. In line with Wingu’s principles, it will:

  • Comply with the applicable regulations that govern companies in all countries of operation.
  • Promote best practice within Wingu’s markets including those intended to prevent extortion, bribery and financial crime.
  • Promote transparency and accountability, grounded in sound business ethics.
  • Clearly define responsibilities, procedures and controls with appropriate checks and balances within Wingu’s management structure.
  • Prevent the use of any information derived from its activities for personal financial gain by any Business Partner or any other related party.
  • Identify and manage any potential conflicts of interest that may arise during business activities.