Sustainability Policy — UPGREAT AI

Version 1.0 — Effective 12 June 2026

SustAInable BV ("UPGREAT AI") builds and operates sustainable, sovereign AI compute infrastructure in Europe. Sustainability is not a marketing layer on top of our product — it is the founding premise of the company and is embedded in its name. This policy describes our commitments, how we implement them today, and how we measure progress.

1. Part of the Upgrade Estate group

UPGREAT AI is part of the Upgrade Estate group (Upgrade Estate NV, Ghent). The group is committed to ecological, social and economic sustainability, uses the United Nations Sustainable Development Goals as the guideline for its activities, and aims to be carbon neutral on scope 1, 2 and 3 by 2035, following the Science Based Targets initiative (SBTi) method: maximum reduction first, qualitative offsetting of only a small residual fraction.

The group's sustainability charter is co-signed by its partners and suppliers; UPGREAT AI subscribes to this charter and applies the same supply-chain due diligence expectations to its own suppliers. The group's sustainability actions are externally validated (among others annually certified by VOKA through the Charter for Sustainable Entrepreneurship, recognised as Unitar SDG Ambassador, and benchmarked using the Future-Fit Business Benchmark). Within the group, the sustainable spin-off Limoengroen focuses on energy transition, data monitoring, renewable technologies and sustainable construction — expertise that flows directly into the design and operation of UPGREAT AI's infrastructure. The group connection is also physical: UPGREAT AI deploys its edge datacenters inside Upgrade Estate group buildings, turning compute waste heat into building heat (see 3.3).

Full details: upgrade-estate.be/en/sustainability

2. Why AI compute needs a different approach

AI workloads are energy-intensive. We believe the answer is not to outsource that footprint to opaque hyperscale regions, but to operate transparent, efficient infrastructure close to home — and close to where the energy can be reused. Our model: edge datacenters deployed inside Upgrade Estate group buildings, where the waste heat of AI compute directly serves the building it lives in; maximum energy efficiency per unit of compute; renewable energy supply; and full transparency about where workloads physically run.

3. Our commitments

3.1 Energy-efficient infrastructure

High-efficiency cooling. Our GPU infrastructure — in our Belgian datacenter facility and in edge deployments within Upgrade Estate group buildings — uses advanced liquid cooling with a design partial PUE (pPUE) of 1.02–1.05, a fraction of the cooling overhead of conventional air-cooled datacenters. Full site-level PUE figures will be published once a complete year of seasonal operation has been measured. The cooling design captures waste heat in a form suitable for direct reuse (see 3.3).
High utilisation. We maximise useful work per watt through high utilisation of modern accelerators; newer hardware generations are deployed where they deliver better performance per watt.

3.2 Renewable energy

Our Belgian sites are powered by renewable electricity supplied through the group's energy activities: the group's sustainable spin-off Limoengroen operates multiple solar farms today and is developing its own wind turbines, working towards the group's goal of providing 100% renewable energy for consumption within its projects.
Our capacity in Iceland runs on the Icelandic grid, which is supplied almost entirely by geothermal and hydroelectric power, in a naturally cold climate that minimises cooling energy.

3.3 Edge datacenters with heat recovery in group buildings

This is where being part of the Upgrade Estate group becomes a structural sustainability advantage rather than a corporate footnote. UPGREAT AI deploys edge datacenters inside buildings of the Upgrade Estate group (student residences, co-living and office projects). Our liquid-cooled infrastructure captures GPU waste heat at temperatures suitable for direct reuse, feeding it into the building's energy systems — space heating and domestic hot water — designed and integrated with Limoengroen's expertise in heat pumps, energy monitoring and renewable techniques.

The result is a symbiosis: the building replaces fossil heat demand with compute heat, supporting the group's gas-free building strategy (gas-free construction since 2020) and its 2035 net-zero trajectory, while the datacenter avoids rejecting heat to the atmosphere. Instead of building cooling capacity to destroy energy, we place compute where the energy is needed. The first edge deployments are live; recovered-heat volumes and targets will be published as the rollout progresses.

3.4 Circularity and hardware lifecycle

Hardware is selected for longevity and operated for its full economic life; our cooling approach reduces thermal and mechanical stress, extending component lifetime.
Decommissioned hardware is reused, resold or responsibly recycled via certified WEEE channels; storage media are sanitised or destroyed under documented procedures.
We avoid overprovisioning: capacity grows with demand.

3.5 Digital sustainability and sovereignty

Efficiency and sovereignty reinforce each other: all workloads run on infrastructure we own and operate within the EEA (Belgium and Iceland), so our sustainability claims cover the entire delivery chain of the service — there is no hidden hyperscale footprint behind our API.

3.6 Transparency and reporting

We report datacenter energy indicators in line with the EU Energy Efficiency Directive (EU/2023/1791) obligations applicable to our facilities.
We will publish key indicators (energy consumption, PUE, renewable share, heat reuse) on upgreat.ai as our reporting matures, and contribute to the group's sustainability reporting (upgrade-estate.be).

In line with the group's philosophy, we invest in local talent and education (including collaboration with students and schools around AI and infrastructure), fair and transparent dealings with customers and suppliers, and European digital autonomy as a societal good in itself.

4. Governance

This policy is owned by the management of SustAInable BV and reviewed at least annually. Suppliers and partners are expected to act in accordance with the group's sustainability charter. Questions or suggestions: sustainability@upgreat.ai.