Living Values,BuildingSuccess€¦ · Living Values, Building Success, Iron Mountain’s Code of ethics and Business Conduct, provides guidance and resources to help make legal and

Living Values, Building Success

Our Code of Ethics and Business Conduct

We pledge to live by our Core Values and put them into action every day and everywhere we operate.

www.IMEthicsLine.com | 1

Message froM BILL Meaney, CeO

My fellow Mountaineers,

for over six decades our company has earned the trust of our customers, partners, and shareholders because of our commitment to a set of Core Values. These values drive our behavior and represent the ideals we hold most important.

for this reason, we are expanding our values to reflect our organization’s long-standing commitment to safety. We’ll do this through the creation of a new combined Core Value of safety and security. We’ve intentionally paired these principles together, as both remind us of the importance of protection, whether that’s protecting our team or protecting our customers’ information. While safety has always been an implied part of our culture — and a core tenet for our operational teams — safety deserves the same level of prominence in our culture as security does.

Iron Mountain’s Code of ethics and Business Conduct, Living Values, Building Success, is an extension of these values, providing guidance and resources to help us navigate legal and ethical decisions, even under challenging circumstances. our ethical obligations go well beyond complying with the laws, rules, and regulations that apply to our business. When we face difficult decisions, we seek resolutions that are fair and honest and that embody our Core Values — Integrity, safety and security, Total Customer satisfaction, Candor, accountability, action orientation, and Teamwork. This is how we operate. our Code and our Core Values are fundamental to the promise we make to our customers, to our investors, and to each other.

You should never hesitate to tell your manager or the global Privacy and Compliance group if you believe our Code is not being followed or if you’re unsure how to handle a particular situation. We will not tolerate retaliation against anyone who raises these concerns.

our success, and each of our individual reputations, rests on all of us taking responsibility for putting our Code into practice. on behalf of the Board of Directors and our executive management team, I thank you for your dedication to our Core Values and your pledge to abide by our Code.

Kind regards,

2 | Living Values, Building Success

CONTENTSMessage from Bill Meaney, CEO 1

Contents 2

Our Core Values 5

Living Values and Building Success with Our Code 6 � Who Must follow the Code?

� special responsibilities for Management and Leadership

Raise Your Concerns: Everyone Has a Voice at Iron Mountain 8 � Zero Tolerance for retaliation

� Investigations and Disciplinary action

� The Iron Mountain ethics Line

Living Values, Building Success with Our People 11 � Promoting a safe and secure Workplace

� Valuing Inclusion and Diversity

� Preventing Harassment and Discrimination

� safeguarding our Confidential and Proprietary Information

� Managing our records appropriately

� Keeping and Disclosing accurate financial records

� responding to Inquiries from Investors, analysts, and the Media


Living Values, Building Success with Our Promise 27 � Using Technology and Information systems responsibly

� avoiding Conflicts of Interest

� Preventing Bribery and Corruption

� appropriately exchanging gifts and Hospitality

� adhering to International sanctions and Trade regulations

� Contracting with government Customers

� Competing the right Way

� selling and Marketing with Integrity

� gathering Competitive Intelligence

Living Values, Building Success in Our Communities 47 � Protecting the environment and Building sustainability

� Contributing to our Communities

� respecting Human rights

� safeguarding our Vehicles and facilities

� respecting Privacy

� effective and responsible Use of social Media

� avoiding Insider Trading

� Participating in Politics and government affairs

Live Our Values, Build Our Success 64

The Iron Mountain Ethics Line 65

our Core Values define the character of our company

and guide the way we think and act as Mountaineers.

While living our values means complying with the

law and protecting our company from harm, it is also

the way we achieve success.

our strong ethical culture and reputation for integrity

help us attract and retain the best people, build trust in

the marketplace, and open doors to new markets.


Integrity We are always honest and never compromise our Core Values.

safety and security We protect each other from harm, and we secure our customers’ information and assets as if they were our own.

Total Customer satisfaction We deliver what our customers expect, when they expect it.

Candor We communicate in an open and truthful way that is constructive and respectful.

accountability We each hold ourselves personally responsible for our actions, commitments, and results.

action orientation We are alert to opportunities and problems and act with a sense of urgency.

Teamwork We work in teams to accomplish far more together than we could as individuals.

OuR CORE VaLUes

Living Values and Building Success with Our Code

as Mountaineers, we contribute to Iron Mountain’s success by living our Core Values and abiding by the Code.

Living Values, Building Success, Iron Mountain’s Code of ethics and Business Conduct, provides guidance

and resources to help make legal and ethical decisions — even under challenging circumstances. While no

document can cover all of the situations we might face as Mountaineers, the Code addresses many of

them, and also points us in the right direction when we need more information or further advice.

WhO Must FOLLOW the COde?

every person conducting business for Iron Mountain must follow the Code. This includes employees,

officers, agents, and members of the Board of Directors. There are no exceptions.

The Code of ethics and Business Conduct applies to all Iron Mountain business units, legal entities,

controlled joint ventures, affiliates, and partnerships worldwide. our supplier Code of Conduct and

stringent procurement processes help ensure that suppliers, vendors, contractors, consultants,

temporary staff, contingent workers, and others who provide service to Iron Mountain maintain our

standards of conduct.

SPECiaL RESPOnSiBiLitiES fOR Management and Leadership

In addition to knowing the Code and exemplifying our Core Values, it is important that we encourage our teams to do the same. This means that we:

� Discuss the Code and the Core Values during team meetings and individual performance reviews

� recognize and reward acts of ethical leadership and acknowledge how these acts tie to our financial success

� set the right example for our teams by promptly completing compliance trainings

� Make sure our teams know the different ways they can report concerns and that retaliation will not be tolerated

� ensure that nonemployee staff (such as consultants, temporary staff, and contingent

workers) act in a manner consistent with the Code and our Core Values

“ our Code reinforces every Mountaineer’s commitment to an ethical workplace. By putting our policies and values into practice, we empower employees to make good decisions. This is the foundation of our success.”

Iron Mountain’s President, International



Raise Your Concerns: Everyone Has a Voice at Iron MountainIf you are unsure about a situation or you believe that our values are not being upheld, it is your duty

as a Mountaineer to speak up.

reporting inappropriate behavior or raising a concern about a situation you’re not comfortable with

can be difficult. But by speaking up, the company can investigate and address the problem so it

doesn’t happen again.

There are several ways to raise an ethics or compliance concern. You can report issues to:

� Your manager or supervisor

� Human resources

� The global Privacy and Compliance group

� global safety, risk and security

� Iron Mountain’s general Counsel

� The Iron Mountain ethics Line


ZerO tOLeranCe FOr retaLIatIOn

Iron Mountain strictly prohibits retaliation. anyone who raises a concern in good faith will not face

retaliation of any kind — including threats, harassment, reduction of hours, release from employment,

or any other negative consequence. retaliation goes against our Core Values and undermines the

trust that enables us to succeed. Iron Mountain considers acts of retaliation to be serious acts of

misconduct that will result in disciplinary action, up to and including termination of employment.

InvestIgatIOns and dIsCIpLInary aCtIOn

all reports of misconduct are investigated promptly, thoroughly, and objectively. Confidentiality will be

maintained to the fullest extent possible.

No violation will be tolerated. Where a violation may be criminal, Iron Mountain will involve all

appropriate law enforcement authorities and fully support the legal process.

When an investigation concludes, Iron Mountain will administer appropriate discipline to those

involved and make the changes necessary to prevent similar problems from reoccurring.

the IrOn MOuntaIn ethICs LIne

The ethics Line lets you raise your concerns confidentially and (where legal to do so) anonymously.

Mountaineers may contact the ethics Line to make a report or ask a question 24 hours a day, 365 days

a year. reports are taken by an independent company and then sent to Iron Mountain for review,

investigation, and appropriate action.

tO repOrt By phOne: Call the toll-free number for your country listed on the inside back cover.

tO repOrt OnLIne: file a report by visiting: www.IMethicsLine.com.

IrOn MOuntaIn

ethICs LIne

24 hours a day/365 days a year

www.IMethicsLine.com

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00 | Code of Ethics and Business Conduct

We support all Mountaineers in

reaching their full potential — both

as individuals and as members of

our team. When our people thrive,

our customers benefit and our

business succeeds.

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Living values, Building success with Our people

KnOW THE CODE

Promoting a Safe and Secure WorkplaceLiving our Values

Nothing at Iron Mountain is more important than our health, safety, and security.

Building successWe work hard to ensure a safe, secure, and healthy work environment for Mountaineers, service providers, and visitors. Mountaineers who are healthy and safe are more engaged, more productive, and more likely to maintain the high standards we’ve set for our operations.

While forklifts, shredders, and unauthorized personnel in our facilities pose obvious risks to our Core Value of Safety and Security, we consider every possibility when working to prevent, detect, and reduce the risk of harm to Mountaineers. each of us is responsible for following procedures and speaking up if something presents a danger. No operational target or metric is more important than the safety and security of a Mountaineer.

saFety starts WIth YOU!

stOp. give full attention to your work and minimize distractions.

thInK. Consider how your actions can affect your safety and the safety of others.

aCt. express action Orientation to reduce or eliminate risks. raise your concerns when something is not right.

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What It Means, every Dayat Iron Mountain, safety is nonnegotiable. By never cutting corners and immediately raising

concerns, we help to ensure the health, safety, and security of everyone around us.

MaIntaInIng physICaL seCurIty � always follow our policies and procedures, both on and off Iron Mountain premises.

� obey all traffic laws while on the road.

� always lock vehicles, activate alarms, and secure Iron Mountain equipment (like laptops).

� Do not leave doors propped open or allow people to follow you into our facilities.

� Question anybody on Iron Mountain property without a proper badge.

� Participate in all health, safety, and security trainings.

� report unsafe conditions, injuries, or traffic incidents to a supervisor.

� ensure service providers and visitors are aware of (and follow) our safety protocols.

preventIng WOrKpLaCe vIOLenCe � Conduct thorough background checks on job candidates and service providers (where legal to do so).

� report threats of violence to your manager; global safety, risk and security; or the Iron Mountain ethics Line (including threats made outside of work or on social media).

� report the presence of weapons to your manager or to global safety, risk and security.

� Call local law enforcement if there is imminent danger, and then report it to your manager or global safety, risk and security.

prOvIdIng a suBstanCe-Free WOrKpLaCe � reach out to your manager or Human resources if you are struggling with a drug or alcohol problem; the company has resources to help.

� arrive at work free from the influence of any substance that could impair your judgment or threaten safety.

� speak up if you see a coworker under the influence of alcohol or drugs at work.

I need tO KnOW. One of my coworkers is a driver, and he told me he’s been suffering from insomnia and taking prescription sleep medication. I’ve noticed that he seems a little sluggish and groggy at work. Maybe it’s because he’s not getting enough sleep or the medication is still in his system when he arrives at work. I’m worried that he might cause an accident. What should I do?

What tO dO. your coworker could be jeopardizing his health and safety, as well as that of others. Live our Core value of Candor by talking to him about your concerns and suggesting that he reach out to his manager or human resources for help. If he doesn’t (and the condition persists), it is your duty to report the situation.

vaLues IN ACTION


Valuing Inclusion and DiversityLiving our Values

We make the best decisions when we leverage the diversity of our talents, backgrounds, and perspectives.

Building successattracting, developing, and empowering individuals with a wide range of experiences, capabilities, and

points of view is a key component of our success. By embracing each other’s unique characteristics

and backgrounds, we enrich our workplace, solve problems more creatively, and better understand our

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“ Building an inclusive and diverse workforce is vitally important to the success of our business. We all benefit by having employees with different backgrounds and perspectives. By creating a supportive and trusting environment, people feel valued, respected, and able to express their ideas freely.”

Iron Mountain’s Senior Vice President of Corporate Responsibility and Chief Diversity Officer

customers’ needs. Including and respecting diversity in our discussions helps maximize

each employee’s contribution and enables us to reach the right decisions the first time.

What It Means, every Dayat Iron Mountain, we create an inclusive workplace where we value and learn from our

differences. This means that we:

� actively seek out alternative approaches and points of view

� respectfully listen to everyone’s opinion

� Consider the importance of diversity when recruiting and building teams

� openly share knowledge with those who can benefit from it

I need tO KnOW. sometimes I feel that I can’t make the most of my contribution because my manager doesn’t share enough information. I’m concerned that she doesn’t trust me. should I discuss it with her?

What tO dO. Yes. exercise our Core value of Candor, and talk about it with your manager. she may be unaware that she is treating you differently from your coworkers and not sharing the information you need to make the best decisions. Managers are responsible for keeping their employees informed about the business and for fostering an open, trusting environment within their teams.

vaLues IN ACTION


Preventing Harassment and DiscriminationLiving our Values

Iron Mountain maintains a respectful workplace that is free from harassment and discrimination. This is a fundamental part of how we live our Core Value of teamwork.

Building successHarassment and discrimination aren’t just illegal; they lower morale and create an atmosphere of mistrust

and disrespect that keeps us from reaching our full potential. By preventing harassment and discrimination,

we help to achieve a work environment where Mountaineers feel safe and empowered to succeed.

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KnOW THE CODEWhat It Means, every DayWe are committed to a workplace that is free from harassment and discrimination. This

means that we:

� always treat each other with dignity and respect

� Never exhibit abusive or offensive behavior

� Make employment decisions based on merit — not on gender, race, religion, ethnicity,

age, disability, or sexual orientation

� Immediately report harassment or discrimination to management, Human resources,

or the Iron Mountain ethics Line

What dOes harassMent LOOK LIKe?

Whether it’s in person or online, harassment isn’t just what we intend by our words or actions, but how others perceive them.

� It can be something we express — like telling offensive jokes or making racial slurs

� It can be something we do — like making unwelcome sexual advances or blocking some-body’s path

� It can be something we display — like posting lewd photos on a wall or putting offensive bumper stickers on

a vehicle

vaLues IN ACTION

I need tO KnOW. My manager asked to friend me on social media, and I agreed because I felt it would offend him if I said no. since then, it seems like he’s been finding a lot more reason to criticize my performance. I’m pretty sure he saw something on my social media account that he doesn’t like and is trying to make my life difficult because of it. What should I do?

What tO dO. While social media connections are a great way to help build our Core value of Teamwork, please be careful. When you grant “friend” status to somebody, they may be able to see things about you that you might want to keep private (such as your political beliefs or how you spend your

personal time). nevertheless, it is against Iron Mountain policy for anybody to treat you differently because of your religious beliefs, sexual orientation, or any other protected factor — whether they find out about it in person or online. you should report the issue to management, human resources, or the Iron Mountain ethics Line.

Managers should think carefully before asking employees to be friends on social media because it could lead to unintended consequences. employees may not be retaliated against for declining a request to connect on social media, and repeated requests can be considered harassment.


Safeguarding Our Confidential and Proprietary InformationLiving our Values

our confidential business information and intellectual property are vital assets that distinguish us in the marketplace. We share an important duty to protect them from misuse or unauthorized disclosure.

Building successTo maintain our competitive advantage, we must continually innovate by enhancing our existing

services and developing new ones to broaden our business and better serve our customers. This would

not be possible without carefully safeguarding the intellectual property and confidential business

know-how that has taken decades to develop. We all play a role in keeping these assets safe and

protecting them from misuse.

What It Means, every DayWe appreciate the value of Iron Mountain’s confidential and proprietary information and diligently

protect it. This means that we:

� only share information with authorized individuals who have a legitimate business need

� ensure nondisclosure agreements are in place before releasing confidential or proprietary

information outside of the company

� secure documents, data, and devices in accordance with our security policies

� only dispose of paper documents using our secure shred bins

FOr MOre InFOrMatIOn

for more information, please

refer to Iron Mountain’s

acceptable use policy or

contact the global Privacy

and Compliance group.

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KnOW THE CODE

What Is COnFIdentIaL and

prOprIetary InFOrMatIOn?

a wide range of Iron Mountain

information, or intellectual

property, is considered confidential

and proprietary, including:

� strategy documents

� Contracts

� Customer lists

� price sheets

� Chain-of-custody protocols

� technical system diagrams

� Marketing plans

� nonpublic financial

information or projections

� Information about proposed

merger and acquisition

activity

� Investigation or audit

materials

� employment-related

information

vaLues IN ACTION

I need tO KnOW. We’ve developed some cutting-edge inventory-control technology within the last year and just completed a successful global implementation. I’d love to share some of the training materials and lessons learned with my industry colleagues at a trade association event next month. Is that OK?

What tO dO. While it’s fine to share general information about Iron Mountain with colleagues at a trade association event, you should be careful to never disclose trade secrets or other confidential information. In this situation, because the materials describe our proprietary technology, their disclosure could harm our competitive advantage and our ability to provide Total Customer Satisfaction.

If you’re unsure about whether it’s OK to share certain content in a public forum like a trade association event, check with your manager or the Legal department.

I need tO KnOW. We’re working with a consulting agency to help make our processes more efficient. to better under-stand how we currently do things, they’ve asked us to send them copies of all of our policies and procedures. Is that OK?

What tO dO. It depends. First, living our Core value of Safety and Security means that it’s important to perform a thorough investigation of the third party. then, a nondisclosure agreement, which covers all of the information that will be shared, must be executed. even then, share only the minimum amount of information necessary to achieve the goal, and make sure the contract requires that when the project ends, all copies of the information are returned to Iron Mountain or are securely destroyed.

� avoid discussing confidential information in public or allowing people to view it on our

mobile devices

� escort visitors within our facilities and do not allow them into restricted areas

� report misuse of intellectual property or unauthorized disclosures to management; the

global Privacy and Compliance group; or global safety, risk and security


Managing Our Records appropriatelyLiving our Values

Iron Mountain sets the global standard for records management — and we also apply that expertise to managing our own records.

Building successThousands of companies trust Iron Mountain to manage their vital records and information. We

understand better than any other company how an effective records management program can

increase efficiency, reduce risk, and drive value across an organization.

successful records management requires action Orientation: paying attention to what we must retain

and then destroying records when their retention periods end. as an industry leader, our reputation in

the marketplace is directly tied to how well we execute our own records management program.

vaLues IN ACTION

I need tO KnOW. as I was going through my files, I came across some old letters between Iron Mountain and a former customer. When reviewing the documents to see if they could be shredded, I saw a note attached, stating “LegaL hOLd.” I haven’t heard anything about this case in years, and the documents are past their normal retention period. Can I shred them?

What tO dO. no. Living our Core value of Accountability means that we are responsible for retaining these documents until the legal hold has been officially lifted. If and when that time comes, you will receive notification from the Legal department. If you are unsure about the status of a legal hold order, please check with the Legal department.

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What It Means, every Dayas Mountaineers, we consistently demonstrate the highest standards in records and

information management. This means that we:

� Identify, classify, and retain all official records, regardless of format

� Maintain records in a secure and organized environment, so they can be easily and

reliably retrieved

� Never destroy records before their retention periods expire

� Destroy paper records securely, using our secure shred bins

� fully comply with all “legal hold” orders


for more information, please refer to Iron Mountain’s records Management policy or

contact the global Privacy and Compliance group.


Keeping and Disclosing accurate Financial RecordsLiving our Values

We keep complete and accurate financial records and make timely disclosures — not just because it’s required by law, but because our reputation for Candor and Integrity depends on it.

Building successas a publicly traded company, we are required by government regulations to maintain and disclose

accurate financial records. While it is our legal obligation, it is also critical to the operation, management,

and growth of our business. our public disclosures keep us accountable and help us maintain the trust

and confidence we’ve built with our investors, customers, and other stakeholders.

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Fraud’s WOrst eneMy: aN eTHICaL MoUNTaINeerfraud, waste, and abuse can come in many different forms. But a Mountaineer’s commitment to living our Core Values is the surest way to prevent it, detect it, and correct it if it happens.

We can help protect the company from fraud, waste, and abuse by:

� fully and accurately describing travel, entertainment, and other expenses in our books and records

� Properly classifying and accounting for financial transactions

� Billing only for services rendered, within the required timeframes

� Delivering the discounts we’ve committed to providing

� following all procurement policies and ordering only the goods and services we need

� Never using corporate funds for nonbusiness purposes

� asking for clarification if we are unsure about accounting procedures or legal obligations

� Immediately reporting concerns about inappropriate or suspicious activity

What It Means, every Dayall Mountaineers have a responsibility to ensure the accuracy and integrity of our financial

recordkeeping and reporting. This means that we:

� Comply with generally accepted accounting principles, internal financial controls, and

all related legal obligations

� Maintain books and records that honestly and accurately reflect financial transactions

� submit expense reports, time sheets, and sales invoices promptly and within the

required timeframes

� ensure that disclosures to internal and external auditors or regulators are accurate,

timely, and complete

� raise any concerns about false, misleading, or inaccurate records to the Internal audit

Department or the Iron Mountain ethics Line

vaLues IN ACTION

I need tO KnOW. Our team has worked really hard these past few months to meet our quarterly revenue goals, but, unfortunately, it looks like we’re going to fall just short. I know a big order is coming in right after the end of the quarter, so is there any harm in adding it to this quarter’s results instead?

What tO dO. yes. Our accounting policies and the law require that revenue is recognized when services are rendered — and not before. Accountability means that each of us takes responsibility to ensure that our financial records are not distorted or misstated in any way. adding the revenue to this quarter’s results would mean that we’ve created a false accounting record, which could place the company at significant legal risk.


Responding to inquiries from Investors, Analysts, and the MediaLiving our Values

Being honest and transparent in our official communications is one of the most important ways we build trust with our communities.

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Building successLiving our Core Value of Integrity means providing honest, clear information about Iron

Mountain to all of our stakeholders. It also means representing our company with a

consistent, positive voice. This enhances trust with our stakeholders and helps protect

our hard-earned reputation.

This is why only a few Mountaineers are officially designated to speak on behalf of Iron

Mountain. By directing inquiries from investors, analysts, and the media to these specially

trained individuals, we help ensure that only the best, most accurate information is being

released and relied upon.

What It Means, every DayWhile you should avoid situations where your personal opinions or beliefs could be mistaken

for the official views of the company, if you are approached either online or in person by an

investor, analyst, or the media, it is important to:

� Never disclose confidential information

� always maintain a courteous and respectful tone

� refer requests to the Corporate Communications Team for an official response

vaLues IN ACTION

I need tO KnOW. I am about to leave work for the day and see that there’s a tv crew setting up in the parking lot. I don’t know why they are there, but I think it could be related to a story about Iron Mountain I heard on the news this morning. What should I do if they ask me about it?

What tO dO. While Candor is a Core value, offering information that you are not authorized to would compromise another Core value: Safety and Security. In this situation, first inform your manager about the presence of the tv crew. If you are asked a question, politely tell them that you are not authorized to speak on behalf of the company and that they should contact the Corporate Communications team.


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00 | Code of Ethics and Business Conduct00 | Code of Ethics and Business Conduct

Iron Mountain’s success depends on

our promise to live by our Core Values.

We are committed to always making

the right choices for our people and

our communities.

OuR PROMISELiving values, Building success with Our promise

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using Technology and Information Systems Responsibly Living our Values

our technology and information systems play a crucial role in enabling us to reach our goals and fulfill our potential — though we have a responsibility to always use these assets safely and appropriately.

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I need tO KnOW. I’m working remotely today, but the connection to the office network isn’t working properly. I really need my coworker to email me a file so I can complete an urgent customer request. Can she send it to my personal email account instead?

What tO dO. no. Living our Core value of safety and security means that we may not send confidential information outside of the Iron Mountain network. doing so is against our Acceptable Use Policy and could put our customers’, employees’, or vendors’ information at risk. It might also violate contractual requirements or break privacy law. In this situation, please contact your manager and system support so that they can help you solve the problem while keeping our data safe and secure.

vaLues IN ACTIONBuilding successachieving total Customer Satisfaction would not be possible without the systems and technology

we rely upon every day. Laptops, telephones, mobile devices, and the infrastructure that supports

them, help us work more productively, communicate more effectively, and better serve our

customers. They let us access and share the information we need to innovate and grow.

Inappropriate use, however, can drain our resources, compromise our security, and lead to

lasting damage to our brand and reputation.

What It Means, every DayBecause our systems store and transmit sensitive, confidential data and are connected to

company networks and the Internet, inappropriate use or failure to follow our policies and

procedures can cause serious harm, including data breaches or violation of privacy law. To keep

this from happening:

� grant system access only to authorized individuals, and remove access as soon as it is no

longer needed.

� Do not download unapproved software or open suspicious attachments.

� Keep confidential information off of unapproved Internet or social media sites.

� Consider privacy implications when selecting and implementing new systems.

� Connect only authorized personal devices to Iron Mountain networks.

� Take steps to protect hardware from loss, damage, or theft.

� follow procedures to make sure data is securely erased before disposing of equipment.

� Never send messages that contain harassing or offensive content.

� avoid visiting inappropriate websites, and keep personal use to a minimum.


for more information, please refer to Iron Mountain’s acceptable use policy and

social Media guidelines.


I need tO KnOW. I have a nephew who I think would make a great transportation coordinator. If we hired him he would not report to me, so can I recommend him for the position?

What tO dO. some of our best hires come from employee referrals, but in this situation it’s important that your nephew is considered only for his job qualifications and not because he is related to you. to avoid the appearance of a conflict of interest, disclose your relationship to the hiring manager and human resources, and do not participate in the hiring process.

vaLues IN ACTION

avoiding Conflicts of InterestLiving our Values

as Mountaineers, it’s our obligation to put the company first. This is how we know we’re making the best choices for our customers, coworkers, and shareholders.

Building successTo achieve our Core Value of teamwork, every Mountaineer must be trusted to keep personal interests

and relationships out of our business decisions. even the appearance of a conflict of interest could

cause others to doubt our integrity, which could lower morale and hurt our ability to deliver on our

promises. When our coworkers, customers, and other stakeholders see us acting fairly and objectively,

it reinforces the values that form the foundation of our success.

What It Means, every Dayany situation that creates, or appears to create, a conflict between personal and company interests

must be avoided or, if impossible to avoid, disclosed to management for resolution. If you are aware of

an existing conflict of interest, it is your duty to report it. If you do not feel comfortable speaking about

it with your manager, contact Human resources, the global Privacy and Compliance group, or the Iron

Mountain ethics Line.

Conflicts of interest can present themselves in a number of ways. Here are some situations to watch

out for:

OutsIde eMpLOyMent Or FInanCIaL Interests

as Mountaineers, our loyalty is first and foremost to the company: supporting our coworkers and

providing total Customer Satisfaction. employment or financial interests outside of Iron Mountain

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should not impact this primary responsibility. Therefore, we should avoid:

� outside employment or consulting work that interferes with the time we need to fulfill our

Iron Mountain responsibilities

� Working for Iron Mountain’s competitors, customers, or suppliers

� Taking a significant financial stake in a company that has a connection with Iron Mountain

� acting as a supplier that sells goods or services to Iron Mountain

persOnaL reLatIOnshIps

Decisions about hiring, promoting, or contracting can be difficult if they involve close friends or

relatives. This is why we:

� Keep close friends and relatives outside of our reporting lines

� Let others handle employment-related matters involving close friends or relatives (such as

hiring, performance reviews, and promotions)

� Take steps to ensure transparency and independence when considering close friends or

relatives to be Iron Mountain service providers

� Carefully weigh decisions to use former Iron Mountain employees as consultants, suppliers,

or contractors

servIng On a BOard OF dIreCtOrs

occasionally, we may be invited to serve as a member of the Board of Directors of another

company. Because this has the potential to cause a conflict of interest, we must:

� Determine if there’s a relationship between Iron Mountain and the company

� ensure that the service will not impact our ability to fulfill our responsibilities to

Iron Mountain

� obtain prior written approval from the company’s general Counsel

I need tO KnOW. My team needs to hire a vendor to help pick up and deliver customers’ backup tapes. My neighbor owns a delivery company that has a large fleet of trucks, and they have a very good reputation. Can I hire them?

What tO dO. an objective and bias-free procurement process helps ensure that only the best vendors are hired to be our business partners. While you may refer the company to your manager or the procurement department for consideration, you may not independently hire them. decisions about forming business relation-ships with Iron Mountain should be based only on what is best for the company, not on a personal relationship you may have. to act in accordance with our Core values of Action Orientation and Candor, you must disclose your relationship, and then play no role in the decision-making process.

vaLues IN ACTION

What TO AVOID


What Is BrIBery?

Bribery involves offering any-

thing of value to influence how

someone, either in government

or in the private sector, carries

out their duties or to gain an

improper business advantage.

even if a bribe is not accepted, it

is still illegal and against Iron

Mountain policy.

Preventing Bribery and Corruption Living our Values

Iron Mountain wins business because of the quality and value of our services — not because of bribery or other corrupt practices.

Building successCorruption and bribery directly undermine our Core Values, and we do not tolerate them in any form.

These acts harm communities, put our reputation at risk, and can result in substantial fines and jail

time. regardless of local custom or the practices of other companies, we are committed to avoiding

even the appearance of impropriety — particularly when dealing with government officials.

as a global company, we must comply with the anti-bribery and anti-corruption laws in every country in which we operate. This includes the U.s. foreign Corrupt Practices act, the U.K. Bribery act, and the Brazilian Clean Companies act.

acting with integrity at all times is what makes us strong and resilient and what ultimately enables our long-term success. This is why Iron Mountain will always choose to lose business before paying

a bribe to win it.

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KnOW THE CODEWhat It Means, every DayIron Mountain stands against corruption and is committed to winning business in a legal,

compliant, and ethical manner. This means that we:

� Never offer, promise, or provide anything of value in exchange for business or to gain an

improper advantage over our competitors

� Keep books and records that fully and accurately describe all payments and expenses

We also require that our partners, suppliers, representatives, and agents share our commitment

to compliance with anti-bribery and anti-corruption laws. This means that we:

� Conduct appropriate due diligence on all of our service providers

� ensure service providers have the right skills and capabilities for the job

� Pay only fair market rates

� Never ask third parties to engage in activities we would not be comfortable engaging in ourselves


for more information, please refer to Iron Mountain’s global anti-Corruption and

anti-Bribery policy and global gifts, hospitality and Charitable Contributions policy.

I need tO KnOW. My team is bidding on a big records management opportunity with a government agency. even though we don’t need a partner to provide the service, the government procurement official is strongly recommending that we meet with a local transportation company to discuss using them as our subcontractor. everybody knows that the CeO of that company is close friends with the government official. Is it OK to proceed?

What tO dO. probably not. there are several red flags that could signal corruption here. One is the suggestion that we’ll win business in exchange for using a subcontractor with close ties to the government official, and another is the fact that we don’t need a subcontractor to provide service to this customer.

Bribery and corruption can take many forms and do not always involve a direct payment to a government official. If a situation like this comes up, please contact the global privacy and Compliance group for further advice.

vaLues IN ACTION

COrruptIOn red FLags:

things to Watch Out for When

Working With third parties

� refusing to agree to our

supplier Code of Conduct

� resisting the adoption of

anti-bribery and anti-corruption

contract requirements

� Maintaining close ties to

government officials

� requesting unusually high

commissions, payments in cash,

or payments to accounts in

someone else’s name

� offering questionable

qualifications to perform the

required services

� Having a reputation for

requesting bribes or engaging

in unethical business practices


I need tO KnOW. Our team is bidding on a major contract, and we’re expecting to learn the outcome very soon. I’m attending a conference, and a key decision maker from the other company happens to be there, too. Can I invite her to dinner to make a final pitch for Iron Mountain?

What tO dO. Maybe. acting with Integrity means that customers should choose us because of the quality of our solutions and how they stand above the competition, not because we’ve given them a valuable gift or provided

generous hospitality. In this situation, a reasonable, modest business meal to serve as a way to clarify any questions the prospective customer might have about Iron Mountain may be appropriate — as long as the value is within the limits of our Global Gifts, Hospitality and Charitable Contributions Policy. however, because the dinner is so close to the customer’s procurement decision, a lavish meal could easily be interpreted as an attempt to inappropriately influence the business decision — which is strictly prohibited.

vaLues IN ACTION

Appropriately Exchanging Gifts and Hospitality Living our Values

We believe in building strong business relationships — but we will never offer or accept gifts or hospitality as ways of influencing decisions.

Building successIron Mountain’s success is built on the quality of our services, the strength of our reputation, and every Mountaineer’s commitment to our Core Values. Building strong relationships with customers and business partners is also vitally important. But because gifts and hospitality have the potential to improperly influence business decisions, they must always be reasonable, modest, and in compliance with company policy.

What are “gIFts and hOspItaLIty”?

These can be anything of value, including:

� Meals and beverages

� Theater and sports tickets

� Cash, gift certificates, and lottery tickets

� gift baskets, flowers, and chocolates

� Travel and lodging

� Charitable contributions

KnOW THE CODE

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What It Means, every DayWhen giving gifts or providing hospitality, everything we offer must be:

� for a legitimate purpose (such as helping to demonstrate a service) and not intended to

secure an improper business advantage

� Permitted by our own policies and the recipient’s policies

� In compliance with local law (contact the global Privacy and Compliance group if you are unsure)

� reasonable in value and appropriate under the circumstances

� accurately accounted for in our books and records

When accepting gifts or hospitality, it is important to avoid even the appearance of impropriety.

This means that we:

� Never request gifts from vendors

� refuse gifts from vendors that are offered around the time of a procurement decision

� reject gifts in cash or cash equivalents (like gift certificates)

� only accept gifts that do not exceed $100 or hospitality that does not exceed $250

aBOut puBLIC OFFICIaLs

rules relating to gifts and

hospitality with public officials are

stricter and more complex than

those involving commercial

companies or individuals. The most

important thing to remember is to

always obtain approval from the

global Privacy and Compliance

group before providing anything

of value to a public official.

KnOW THE CODE


WhO Is a “puBLIC OFFICIaL”?

this is a broad category that

includes:

� elected and appointed government officials (at any level, even if part-time)

� employees of government agencies

� employees of state-owned (and partially state-owned) businesses and institutions (such as banks, hospitals, or universities)

� Political candidates

� Members of a royal family

� employees of international organizations (like the United Nations and the World Bank)

Common examples include:

� Mayors, governors, and members of congress or parliament

� Police officers and firefighters

� Zoning, licensing, and permitting officials

� fire and building inspectors


for more information, please refer to Iron Mountain’s global gifts, hospitality and Charitable

Contributions policy and global anti-Corruption and anti-Bribery policy.

QuICK reFerenCe: giving gifts and HospitalityKnOW THE CODE

giving gifts hospitality

To a Public official

always requires approval (no matter what the value)

always requires approval (no matter what the value)

To an Iron Mountain Customer or Prospective Customer

requires approval if above $100 per recipient

requires approval if above $250 per recipient

ExamPLES Of Reasonable Gifts

ExamPLES Of Reasonable Hospitality

Corporate-branded gifts, like pens or mugs with the Iron Mountain logo

Modest expressions of gratitude, like flowers or chocolates

Inexpensive, non-lavish meals

Limited travel and lodging directly related to the demonstration of iron mountain services

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The laws in this area are complex

and vary widely from country to

country. Please contact the

global Privacy and Compliance

group if you have any questions.

adhering to International Sanctions and Trade Regulations Living our Values

as a company that operates in many countries around the world, we are committed to complying with all applicable trade regulations and restrictions.

Building successMany countries impose controls on the import and export of sensitive equipment and data

(such as computer hardware and encryption technology) or restrict business with certain

groups, individuals, or countries. our customers trust that we recognize and share the

commitment to increasing Safety and Security in international commerce by complying with

all applicable trade laws and regulations.

What It Means, every DayWe pay close attention to how we interact with individuals, companies, and countries to ensure

we don’t violate sanctions or trade regulations. This means that we:

� Do not sell, market to, or partner with organizations or individuals that are on government

sanction or boycott lists

� follow all legal and contractual restrictions on who can access certain customer information

� avoid entering restricted storage areas unless we are authorized to do so

� Work with our customers and the global Privacy and Compliance group to ensure we are

properly authorized to transfer data across borders

� raise our concern if we believe there may be an inappropriate export of sensitive data

or equipment


Contracting with Government Customers Living our Values

governments generate large quantities of sensitive records, and Iron Mountain is committed to complying with the special obligations required to serve these important customers.

Building successgovernments all over the world trust us to manage their vital records. regulations and contractual

requirements mean that when serving governments, we must often provide different, more stringent

service levels and security than for our commercial customers. We may also be required to take extra

administrative steps to ensure public funds are being handled appropriately. at Iron Mountain, we

recognize the obligations involved in providing total Customer Satisfaction to our government

customers and take pride in rising to the challenge.

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I need tO KnOW. I am working the late shift in a records center that holds both commercial and government records, and a rush retrieval order from a government agency came in. I need to act fast, but I’m not authorized to handle government records. there’s nobody else around who is either. What should I do?

What tO dO. serving the government is Iron Mountain’s privilege, and doing so properly involves special training and service levels that are different than most of our other customers.

even though your instinct is to live our Core values of action Orientation and total Customer satisfaction by fulfilling the order immediately, doing so in this case may actually violate our compliance obligations. In this situation, contact your manager or the site’s general manager right away so that the issue can be resolved in a way that doesn’t violate any of our commitments.




government services

standard of Conduct or

contact the Legal Department.

What It Means, every DayMountaineers who market, sell, or provide service to government customers must take responsibility

for understanding and complying with the laws, regulations, policies, and processes associated with

that work. accountability for upholding these special responsibilities is critical. This means that we:

� only sell services or accept terms and conditions that we are fully capable of consistently

providing

� fully express integrity and Candor when communicating with and invoicing our

government customers

� obtain all required security clearances for employees working on government contracts

� Never offer anything of value to public officials without approval

vaLues IN ACTION




refer to Iron Mountain’s global

antitrust and Fair Competition

policy. If you have questions,

please contact the global

Privacy and Compliance group.

Competing the Right WayLiving our Values

We compete vigorously but fairly — winning business by demonstrating superior value, while at the same time adhering to the highest standards of professional conduct.

Building successIron Mountain believes that a free and competitive marketplace offers us the best opportunity to

succeed. By delivering value and providing best-in-class service, we outperform the competition and

build long-term trust with our customers. We recognize that even the appearance of unfairness or

deception in our competitive practices can directly impact our chances of success.

fair competition laws are complex and vary from country to country. They are strongly enforced,

and violations can lead to significant fines, lasting damage to our brand and reputation, and even

prison terms for the employees involved.

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What It Means, every DayWe win business the right way. This means avoiding formal or informal agreements with

competitors to:

� Charge a certain price for a service (price fixing)

� Manipulate a bidding process (bid rigging)

� Divide up markets by geography or customer (market allocation)

It also means:

� avoiding disparaging remarks about our competitors or their services

� only making honest, accurate, and unexaggerated claims about our own services

� Never improperly interfering with our customers’ existing business contracts

KeepIng QuIet WIth

COMpetItOrs

Unless you’ve discussed it first

with the global Privacy and

Compliance group, do not talk

about any of the following topics

with competitors:

� Pricing and costs

� Contract terms and

conditions

� Bids

� Markets and territories

� Customers

� storage capacity

What TO AVOID

I need tO KnOW. I was recently attending a records management trade association meeting, and during a break I spoke with representatives from several of our competitors. One of them brought up pricing, which I know is a sensitive subject. I politely excused myself and returned to our booth. Was there something else I should have done?

What tO dO. you did the right thing by excusing yourself. however, it’s best to actually state your reasons for leaving out loud, so there’s no doubt about Iron Mountain’s belief that it’s an inappropriate discussion that we want no part of.

remember that the mere appearance of anti-competitive conduct could lead to investigations, disruption of business activities, and serious harm to our brand and reputation.

I need tO KnOW. My team has been working hard on acquiring a records management company that operates in another part of the country. It looks like we’re going to move forward with the deal. Is there anything I need to look out for from a competition law standpoint?

What tO dO. We manage our growth and acquisition strategy responsibly. When considering an acquisition, it’s important to consult the global privacy and Compliance group at an early stage to assess whether we may need to obtain government approval. It’s also important to obtain guidance from the Legal department on integration planning and to avoid exercising control over the other company until the deal is officially closed.

vaLues IN ACTION


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Selling and Marketing with integrityLiving our Values

as Mountaineers, we are proud of the quality of our services and the value we bring to our customers. By conveying this honestly and without exaggeration, we build trust in our brand and confidence in the marketplace.

Building successIn addition to security, confidence, and trust, the Iron Mountain brand stands for best-in-class innovation and global solutions. Wherever we operate, customers are turning to us for more than records and information management: they are looking for peace of mind. as Mountaineers, we provide that by never straying from our Core Values and always delivering on our commitments. Whether or not you are in a sales or marketing role, remember that every interaction outside of our

company is an opportunity to leave a positive, lasting impression of Iron Mountain.

What It Means, every DayWe earn trust in the market and win against the competition by communicating with integrity and delivering total Customer Satisfaction every day. opening doors with prospective customers can be difficult, which is why we need to be creative in our approach while never bending the rules or compromising our Core Values. This means that we:

� Highlight our strengths, instead of disparaging our competitors

� Never use rumors, false information, or illegal documentation to engage with customers

� Do not misrepresent or exaggerate the attributes of our services

� only promise terms and conditions that we know we can deliver

� respect copyrights, logos, and other intellectual property in our advertisements

� abide by all applicable marketing laws and company policies concerning customer communications

I need tO KnOW. I am working on a great opportunity with a customer that has locations all over the country. Because some of the locations are in rural areas, the customer is very concerned about our delivery times. to be honest, I’m not sure that we can satisfy the customer’s requirements all the time. they are not asking for a specific commitment in the contract, so can I just tell them that we’ll do our best?

What tO dO. We may only commit to providing services we know we can consistently and reliably deliver. Overpromising on delivery timeframes could place an undue burden on operations staff and cause a dispute with the customer down the road. While it might make the difference in winning this deal, making a promise we can’t keep could do more harm than good in the long run. In this situation, it’s best to be completely transparent by incorporating our standard language on service levels into the customer agreement. We believe that Iron Mountain’s service levels are the best in the industry, and we should educate our customers about them and how they compare to the competition.

I need tO KnOW. there’s a customer in my market that is vended with a competitor, and I know that if I can inform them of how great our services are, we could win them over. I have their head of procurement’s email address, but I see that it’s on our “do not email” list. Can I reach out to him from my personal email account instead of my Iron Mountain account?

What tO dO. probably not. While there are some exceptions to “do not contact” restrictions (such as when the communication relates to a specific business transaction with an existing customer), in general, we must strictly abide by our customers’ or potential customers’ marketing preferences. In this situation, it doesn’t matter if the communication comes from our personal email account, our business email account, a direct marketing system, or a service provider. If the purpose of the message is to sell or promote Iron Mountain services, the email cannot be sent. please contact the global privacy and Compliance group to discuss other ways to reach the individual in a legal and compliant manner.

vaLues IN ACTION


Gathering Competitive IntelligenceLiving our Values

appropriately gathering information on market trends and customer needs allows us to enhance our solutions and compete more effectively.

Building successMonitoring industry developments and understanding the competitive landscape is vitally important to

our continued success. But no competitive information is worth jeopardizing Iron Mountain’s reputation

or our integrity. Whenever we gather competitive intelligence, we must follow our Core Values and

treat competitors in the same fair way that we expect them to treat us.

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What It Means, every DayWe are careful and honest when gathering, receiving, and using competitive intelligence. This

means that we:

� Never misrepresent or disguise our identity to acquire information

� Do not use third parties to engage in actions we would not engage in ourselves

� avoid asking employees (or prospective employees) to reveal confidential information about

their former employers

� only accept feedback on competitors’ pricing or other terms when it’s provided by a customer

during normal discussions or negotiations

� Contact the global Privacy and Compliance group if there’s any uncertainty about whether

to gather or use competitively sensitive information


for more information, please refer to Iron Mountain’s global antitrust and Fair Competition

policy and Competitive Intelligence guidelines.

sOurCes OF COMpetItIve

InteLLIgenCe?

aCCeptaBLe to use

� Websites and social media

� Newspapers and trade journals

� Public financial filings

� Marketing materials

� Third-party market research

and analysis

dO nOt use Without Consulting the global privacy and Compliance group

� emails intended for others

� “found” documents

� Confidential documents like:

• Bids or proposals

• Price sheets

• strategy documents

I need tO KnOW. My team is in a competitive bidding process for a new business opportunity. In response to one of our questions, the prospective customer inadvertently attached a competitor’s bid documentation, which was marked “COnFIdentIaL.” the customer later called and told us about the mistake and asked us to destroy the document. since we have not done anything wrong, can we use the information we were sent to improve our proposal?

What tO dO. no. even though you didn’t seek or request it, the information is confidential, and it would be inappropriate to take action based on it. If the situation was reversed and it was our documentation that mistakenly fell into our competitor’s hands, we would consider it wrong if they used that information to gain an unfair advantage.

Our Core value of Candor tells us to speak up and report the incident. If you come upon confidential information from another company, contact the global privacy and Compliance group to discuss the situation confidentially.

vaLues IN ACTION

KnOW THE CODE


Iron Mountain is a positive force for

change in the communities where

we work and live.

We will move mountains to make a

difference.

OuR COMMuNITIESLiving values, Building success in Our Communities

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Protecting the Environment and Building SustainabilityLiving our ValuesWe are dedicated to reducing our environmental impact and building sustainable business operations. This makes us a better partner to our communities and a more responsible choice for our customers.

Building successour commitment to responsible, sustainable growth is critical to Iron Mountain’s success. In addition to

reducing our impact on the environment, it inspires us to innovate and develop new ways to become

more efficient. as we expand around the globe, our sustainable practices will continue to differentiate

us from the competition and give customers yet another good reason to choose Iron Mountain.


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What It Means, every DayLiving our Core Value of accountability means taking responsibility for protecting and preserving the

environment. This is why we are dedicated to reducing energy consumption and minimizing waste and

pollution in all of our activities. We are also committed to complying with all environmental laws and

regulations wherever we operate.

There are things that every Mountaineer can do to protect our environment and help build sustainability.

In the FIeLd:

� Turn off our engines while making pickups or deliveries.

� always follow the most efficient routes, to save time and fuel.

� safely dispose of hazardous waste (such as motor oil).

� recycle used boxes and other equipment.

In the OFFICe:

� Print documents only when necessary.

� Dispose of paper in our secure shred bins.

� recycle or reuse whatever we can.

� Turn off lights and electronics when not in use.

� Dispose of electronic equipment safely and responsibly.

I need tO KnOW. My team is evaluating several suppliers, and one proposal is 10 percent cheaper than their closest competitor. however, I read a recent news story about that company breaking environmental laws at one of their factories. What should we do?

What tO dO. While price is an important factor in choosing the right supplier, it’s not the only factor. Live our Core values of Candor and action Orientation by openly raising your concerns with the prospective supplier. If you’re not comfortable that they can live up to our expectations for environmental responsibility, they are probably not a good choice to be our business partner.

vaLues IN ACTION


Contributing to Our CommunitiesLiving our Values

Iron Mountain’s strength is rooted in our engagement with local communities and our commitment to helping them thrive.

Building successBoth as a company and as individual Mountaineers, we work to improve our communities and

make them better places to live and work. supporting and contributing to worthy causes through

volunteering and other charitable actions enriches lives, strengthens bonds with neighbors, and

enhances our reputation as a socially responsible company.

FOr MOre InFOrMatIOnfor more information, please refer

to Iron Mountain’s global gifts,

hospitality and Charitable

Contributions policy and

Corporate responsibility report.


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I need tO KnOW. I’d like the company to make a donation to a charity golf tournament that’s being sponsored by one of our customers. It’s a worthy cause. Is there anything I should be concerned about?

What tO dO. Iron Mountain is proud to support local charities, and it is very likely that we can make this donation — but we must take steps to ensure that the funds are not used to improperly influence business decisions. the value of the contribution should be reasonable and appropriate under the circumstances, and it must be approved in accordance with our Global Gifts, Hospitality and Charitable Contributions Policy.

vaLues IN ACTION

“ We were honored to

provide our resources

and expertise to the city

of Boston after the tragic

events of april 2013. It

afforded us an opportunity

that is grounded in the

principles Iron Mountain

was founded upon over

sixty years ago: protecting,

preserving, and creating

access to some of the

world’s most treasured

ideas, information, and

memories. rest assured

these precious items are

safe with us.”

Bill Meaney, Iron Mountain’s CEO

What It Means, every DayWe actively support Mountaineers in making a positive and meaningful impact on our communities.

This means that we:

� encourage employees to take time off to volunteer

� Help plan and organize activities for community service and volunteering

� offer Iron Mountain’s resources and expertise to help communities preserve their cultural heritage

IrOn MOuntaIn In the COMMunItyMountaineers around the world contribute their talent and resources in support of a wide range of

charitable initiatives. Iron Mountain’s expertise in information management and secure storage is

helping to preserve and protect our cultural heritage.

� The John f. Kennedy Presidential Library in Boston, Massachusetts, is home to one-of-a-kind

papers, photos, films, and other records of the U.s. president’s time in office. Iron Mountain

created a digital archive of these records and keeps the data safe in one of our underground

facilities. The digital archive is available on the library’s website, so people from all over the world

can enjoy and learn from it.

� following the 2013 Boston Marathon terrorist attack, a makeshift memorial grew near the finish

line in Boston’s Copley square. Iron Mountain was privileged to work with the city to permanently

safeguard items from the memorial by storing many of the objects left by visitors and digitizing

hundreds of letters of condolence.


Respecting Human RightsLiving our Valuessupporting and respecting human rights is part of the promise we make to our people and to our global communities. It is an important commitment for Iron Mountain and one that we expect of our business partners.

Building successWe believe that all individuals have the right to be treated with dignity and respect and that unfair

or unsafe labor practices have no place in our society. Being a responsible corporate citizen

means living our Core Values, and teamwork means respecting and protecting human rights — not

just within our company but within our communities and throughout our supply chain. This is one

of the reasons customers choose us: we do what’s right, not just what’s legal.

I need tO KnOW. I’m a courier working in a fast-growing emerging market. I make regular pickups at a supplier’s factory, and to me their employees look extremely young. I have no proof that they are underage, but I’m very uncomfortable about it. What should I do?

What tO dO. Just as we hold ourselves personally accountable for our actions, commitments, and results, we require our business partners to do the same. Iron Mountain will not do business with organizations that use child labor. action Orientation means alerting your manager or the procurement department immediately. you can also raise your concern through the Iron Mountain ethics Line.

vaLues IN ACTION

FOr MOre InFOrMatIOnfor more information, please


Corporate responsibility

report and supplier Code of

Conduct.

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What It Means, every DayWe treat others the way we expect to be treated, and we take meaningful steps to ensure that we

uphold and protect human rights in all of our business operations. This commitment extends to our

business partners as well. We will not work with companies or individuals that do not share the same

commitment to human rights that we do.

This means that we:

� Provide proper working conditions, hours, and compensation to all Mountaineers

� Never use child, prison, or slave labor

� require that third-party service providers accept and abide by our Supplier Code of Conduct

� raise our concern if we witness or suspect human rights violations


Safeguarding Our Vehicles and FacilitiesLiving our Values

Protecting our customers’ valuable information depends on keeping our vehicles, facilities, and other property safe from harm.

Building successour Core Value of Safety and Security is at the heart of the promise we make to our customers.

By keeping our facilities, vehicles, and equipment secure and free from damage, we help preserve

the trust we’ve built and deliver on our promises.

What It Means, every Dayat Iron Mountain we’re constantly assessing our risks and improving how we keep our physical assets

secure. as a Mountaineer, there are several ways you can help:


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I need tO KnOW. every day when my coworker pulls out to start his route, he lights a cigarette. I told him it was a bad idea because sooner or later he’s going to start a fire or get distracted and cause an accident. he laughed and told me to mind my own business. I know it’s something I should report, but he’s a senior employee and is friends with the general manager. What should I do?

What tO dO. even though there’s been no damage so far, we might not be so lucky in the future. discussing it with your coworker was the right thing to do, but if the activity continues, it is your duty to report the unsafe condition. smoking in a company vehicle puts our people and our customers’ information at risk, and it could even endanger the public. action Orientation in this situation is the best way to put an end to this risky behavior and help keep our people and our assets safe and secure.

I need tO KnOW. the other day, a supervisor let his friend into our records center without signing him in. It was only a short visit, and nothing seemed to go wrong. do I still have to report it?

What tO dO. yes. Iron Mountain needs to be aware of everyone entering our facilities so that if something is later discovered to be damaged or missing, we will have the information we need to determine what happened. If you are uncomfortable reporting it to your management, please raise your concern through the Iron Mountain ethics Line.

vaLues IN ACTION


refer to Iron Mountain’s global

physical security policy.

� ensure that all fire protection and security equipment is inspected, tested, and in good working order.

� Promptly respond to all alarms (even after normal business hours).

� Keep unauthorized individuals out of our facilities, and contact your manager or global safety, risk

and security if there is an intruder.

� Wear your Iron Mountain identification badge at all times, and make sure others do, too.

� Do not prop open doors or let people follow you into our facilities.

� Do not give anybody your keys, badge, or alarm codes.

� Lock the door to your office or vehicle.

� Promptly report leaks, broken equipment, or other maintenance issues to management.

� Call local law enforcement or the fire department if there is imminent danger.

Respecting PrivacyLiving our ValuesData protection and privacy are integral parts of our culture and operations. Whether it is employee, customer, or supplier data, we handle it with the utmost care and respect — and never deviate from our legal and ethical obligations.

Building successPrivacy and data protection form the foundation of Iron Mountain’s reputation of trust. We recognize

and appreciate that protecting the data in our care is fundamental to who we are as a company and to

our value in the marketplace. This is why we are committed to ensuring that all personal data —

regardless of its source or format — is protected with the highest industry standards and in compliance

with all applicable legal, contractual, and policy obligations.

What It Means, every DayThere are numerous laws around the world that regulate the collection and processing of personal

data, which is why handling and protecting it requires constant vigilance and attention.

This means that we:

� Clearly inform individuals about why we’re collecting their personal data and how it will be used

� only collect and use personal data for legitimate business purposes (such as to provide services to

customers or benefits to employees)

� ensure we always follow contract commitments when handling customer data

� Disclose personal data only to those who need to know

� always store and transmit personal data in a secure and responsible manner

� Destroy or return personal data when it is no longer needed (in accordance with applicable law

or policy)

KnOW THE CODE


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vaLues IN ACTION

I need tO KnOW. I work in Marketing and have been assigned a project that involves analyzing customer transactions. the goal is to improve our services and enhance our ability to provide total Customer satisfaction. to make the project a success, I need to add tracking cookies to one of our systems to get a more detailed picture of our customers’ behavior. Is that OK?

What tO dO. the key in this situation is living our Core value of Candor. One of the reasons customers choose Iron Mountain over the competition is that they can trust us to be open and honest about how we use their information. even if applying tracking cookies to our system is legal and permitted by our policies and customer contracts, we should still inform our customers of the change. this reinforces the relationship of trust we have with our customers and upholds the spirit of our Core values.

to confirm whether a method of collecting or processing personal data is legal, please consult the global privacy and Compliance group.

I need tO KnOW. We recently acquired a company in europe and would like to perform background investigations on all of the employees. Can we email scanned copies of the employees’ identification cards to our background investigations vendor in the united states?

What tO dO. the safety and security of our employees and of our data is a top priority, and performing background investigations is an important way to help achieve that. however, before getting started, we must determine if the type of background check and method of collecting and transferring this type of personal data is permissible under law and policy.

this is a complicated question with a variety of factors to consider. please contact the global privacy and Compliance group to discuss the best way to achieve the goal in a legal and compliant manner.

FOr MOre InFOrMatIOnfor more information, please refer to Iron Mountain’s global privacy policy, hIpaa policy, and

european employment data protection guidelines.

� Check with the global Privacy and Compliance group before transferring personal data across

borders

� Immediately report any misuse or loss of personal data to a manager; global safety, risk and

security; or the global Privacy and Compliance group What Is persOnaL

InFOrMatIOn?

The legal definition of “personal information” or “personal data” varies around the world, but it is generally considered to be data related to an identified or identifiable individual.

This can include a person’s:

� full name

� Home address

� email address

� National identification number

� IP address

� Driver’s license number

� Photograph

� Credit card number

� genetic information

� Telephone number

� Login ID or online screen name

Because privacy law is complex and varies widely by jurisdiction, please consult the global Privacy and Compliance group to be sure we’re processing personal data in accordance with applicable legal, contractual, and policy requirements.


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social Media guidelines and

acceptable use policy. If you

have additional questions,

please contact the Corporate

Communications Team or

the global Privacy and

Compliance group.

Effective and Responsible use of Social MediaLiving our Values

social media is a powerful tool for enhancing communication and collaboration. By embracing and encouraging its use, we help build stronger teams and foster more meaningful connections with our customers and communities. Misuse, however, can cause harm to our people, our information, and our reputation.

Building successsocial media has changed the way we work — enabling us to share information more efficiently,

engage more effectively with our customers, and better express our value in the marketplace.

Whether it’s across continents, industries, or corporate functions, social media facilitates the

exchange of ideas and helps maximize every Mountaineer’s contribution to our success.

I need tO KnOW. I read an article on the Internet that quotes a competitor saying that their company offers superior service to Iron Mountain’s. the website allows readers to post comments. since I know our service is better, can I respond?

What tO dO. yes. however, if you choose to express an opinion about Iron Mountain online, you must disclose that you are an Iron Mountain employee and make it clear that your views are your own and not the official views of Iron Mountain. you should also make sure that the information you provide is 100 percent accurate and does not exaggerate any aspect of our company or our services. It is always OK to link to information on our website or official company social media sites.

vaLues IN ACTION

What It Means, every Dayas social media plays an increasingly vital role at Iron Mountain, it is

important to both be aware of and stay ahead of the risks. The content

we share on social media can be misinterpreted or taken out of context,

and it can reach a far wider audience than we may have intended,

including coworkers, customers, and the media. once posted online,

information can be difficult or impossible to remove. so before we

express ourselves on social media, it is important to pause and consider

all of the possible consequences.

To use social media effectively and responsibly, we:

� Identify ourselves as Iron Mountain employees when posting

opinions about the company or our services

� Make it clear that the opinions we’re expressing are our own and

not those of the company

� Keep confidential information (about our company, customers,

and other business partners) private and secure

� Maintain courtesy and professionalism in online exchanges

� Never engage in illegal activity, such as harassment or

cyberbullying

� acknowledge customers when they contact us on social media,

but refer them to Customer service to resolve specific issues

� avoid using social media in employment decisions, unless you are

a member of Human resources and your use is within legal and

policy standards


avoiding Insider Trading Living our Values

Insider trading would breach the confidence of our investors and the marketplace — which is why it is vitally important that we avoid improper use or disclosure of material nonpublic information.

vaLues IN ACTION


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refer to Iron Mountain’s Insider

trading policy.

I need tO KnOW. My father-in-law asked me if it would be a good idea to buy Iron Mountain stock. I know we’re on the verge of acquiring a big company, and the news could drive up the share price. What should I tell him?

What tO dO. this is insider information. It is against company policy and might even be illegal to share it. providing your father-in-law with a tip that could influence his decision to buy or sell Iron Mountain stock could lead to serious consequences, including government investigation, prosecution, and fines.

exaMpLes OF MaterIaL

nOnpuBLIC InFOrMatIOn

� Potential mergers and

acquisitions plans

� Projected earnings or losses

� significant product or service

launches

� executive management

changes

� significant lawsuits or legal

settlements

� Changes in dividend or tax

policy

Building successas employees, we may have access to information that could be used to influence investment

decisions — whether it involves Iron Mountain or other companies. While our Core Value of Safety

and Security means that we take great care in protecting our customers’ information, it also

means taking equal care in protecting insider information: handling it properly and keeping it from

being misused.

What It Means, every DayInsider trading occurs when an individual uses insider information for personal benefit or shares it with

others so that they can do so. even if the information isn’t relied upon, just possessing it when making

an investment decision can be considered a violation. This can lead to serious legal consequences and

put our investors’ faith in us in serious jeopardy.

We prevent insider information from being improperly used or disclosed by:

� Keeping it secure — whether that means locking drawers or office doors or keeping laptops and

mobile devices protected

� sharing it only with those who need to know

� Not talking about it with family or friends

� Never discussing it in public or on social media

KnOW THE CODE

Participating in Politics and Government AffairsLiving our Values

engaging in the political process can benefit our business and bring positive change to our communities, but it’s important not to bring personal politics into the workplace.


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I need tO KnOW. the mayor of my city is holding a fundraising dinner for her reelection and asked me if Iron Mountain would be a sponsor. the city is one of the largest customers in this market, and it would look very good for us to participate. Can I sponsor the event in the name of Iron Mountain and submit the expense for reimbursement?

What tO dO. no. In general, we may not use corporate funds for political fundraising activities. While sponsoring the dinner seems like a good idea, it could be seen as an attempt to improperly influence our business relationship with the city. this could lead to serious damage to our brand and reputation and exposure to legal liability. If you are unsure about whether a donation is appropriate, please contact the global government affairs group.

vaLues IN ACTION

Building successWe believe that an open and robust political process makes for a fairer, more productive society. We also believe that everybody has a right to express their own beliefs and participate in civic affairs. It’s one of the ways we live our Core Value of action Orientation. But while at work,

Mountaineers should avoid advocating for personal political causes.

What It Means, every DayCompany resources, including our time at work and Iron Mountain funds, should not be used to further

personal political causes. even while outside of work, we should take steps to ensure that our personal

political beliefs are not perceived to be the official beliefs of the company. This means that we:

� Do not campaign, fundraise, solicit, or advocate for political candidates or causes while at work

� speak up if someone is using Iron Mountain’s name to promote a personal political position

� avoid wearing Iron Mountain-branded clothing when attending political events

� Use personal (not Iron Mountain) contact information when contributing to a political cause

or candidate

www.IMEthicsLine.com | 0064 | Living Values, Building Success

Live Our Values, Build Our Successas Mountaineers, we all have a stake in following our Code and living our Core Values. How we

interact with Our People and Our Communities, and how we keep Our Promise to customers and

shareholders, enables our success today and will continue to enable our success in the future.

In the course of your career at Iron Mountain, you may face difficult ethical dilemmas. If the

answers cannot be found in the Code, a variety of additional resources is available to help provide

guidance and counsel.

If you have a question or concern, raise it. We will listen and help. If you report a violation, be

confident that it will be fully investigated and that retaliation for reports made in good faith will

not be tolerated.

pOLICIes and prOCedures The Code of ethics and Business Conduct provides guidance on many of the ethics and compliance

issues you might face as an Iron Mountain employee. In addition to reading the Code, you should

consult our company policies and procedures, which may contain more detailed information.

WaIvers There may be circumstances where you believe it is not possible to abide by a provision of the

Code. In rare situations, waivers may be granted by applying to the office of the general Counsel.

The U.s. government may require that waivers granted to members of the Board of Directors and

others in Iron Mountain leadership be disclosed to the securities and exchange Commission or

other regulatory authorities.

argentina 0.800.555.0906

argentina 0.800.444.8084

australia 1.800.339276

austria 0800.291870

Belgium 0800.77004

Brazil 0800.8911667

Canada 866.668.3837

Chile 1230.020.5771

China (Northern) 10.800.712.1239

China (southern) 10.800.120.1239

Colombia 01800.9.155860

Czech republic 800.142.550

france 0800.902500

germany 0800.1016582

greece 00800.12.6576

Hong Kong 800.964214

Hungary 06.800.17199

India 000.800.100.1071

Ireland 1.800615403

Mexico (M1.M5) 001.8008407907

Mexico (NeW) 001.866.737.6850

Netherlands 0800.0226174

Norway 800.15654

Peru 0800.52116

Poland 0.0.800.1211571

romania* +1.503.726.2429

russia 8.10.8002.6053011

serbia* +1.503.726.2429

slovakia 0800.001.544

spain 900.991498

switzerland 0800.562907

Turkey* +1.503.726.2429

Ukraine* +1.503.726.2429

United Kingdom 0800.032.8483

United states +1.866.668.3837

United states +1.503.726.2429

*reverse Charge Call

The Iron Mountain ethics LineYou may report ethical concerns or violations and ask questions, 24 hours a day, 365 days a year, by contacting the Iron Mountain ethics Line. The ethics Line is operated by an independent company, and (where permitted by law) you can choose to remain completely anonymous.

tO repOrt By phOne: Call the toll-free number for your country listed below.

tO repOrt OnLIne: file a report by visiting: www.IMethicsLine.com.


Living Values, Building Success

one federal streetBoston, Ma 02110+1.800.899.4766

ironmountain.com

© 2015 Iron Mountain Incorporated. all rights reserved. Iron Mountain and the design of the mountain are registered trademarks of Iron Mountain Incorporated in the U.s. and other countries. all other trademarks and registered trademarks are the property of their respective owners.

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Living Values,BuildingSuccess€¦ · Living Values, Building Success, Iron Mountain’s Code of ethics and Business Conduct, provides guidance and resources to help make legal and