Supplier code of conduct

Purpose

Colt is committed to the highest possible standards of corporate governance and responsibility. Our policy is not merely to comply with the letter of laws or regulations, but rather to instil and maintain a true culture of compliance wherever we do business. In consequence, Colt expects that all Suppliers will embrace the letter and spirit of its commitment to integrity.

This Supplier Code of Conduct incorporates the same standards of ethical conduct and integrity as the Colt internal Code of Business Conduct. Suppliers are requested to adhere to this code and to remain mindful that their activities may have an influence on Colt’s reputation and relationship of trust with customers, employees and shareholders. We expect that the utmost of care is taken to protect these assets.

Application

Suppliers shall ensure that all their representatives (including employees, agents, suppliers and subcontractors and collectively referred to as “the Supplier”) conduct business with and/or on behalf of Colt in accordance with this Supplier Code of Conduct.

Compliance with the law and regulations

The Supplier has an unqualified responsibility to comply with all applicable laws and regulations. The specific areas of compliance highlighted for attention in this document shall not be considered fully definitive.

Anti-bribery - Kickbacks, bribes and payoffs

Suppliers must comply with anti-bribery legislation and avoid all forms of corruption. Suppliers must not offer or accept anything of value to secure an improper advantage or benefit.

The Supplier shall not offer or accept, either directly or indirectly, kickbacks, bribes or payoffs in cash or any other form. It does not matter that a prohibited payment may be demanded by a public official, the prohibited payment still may not be made.

Any incident of such a claim being made on a Supplier with regard to the business they are doing, or hoping to do, with Colt must be reported.

Facilitation payments, paid to speed up the performance of a function or activity to which the payer is legally entitled (e.g. releasing goods held in customs, issuing permits), are prohibited unless permitted under the local legislation of the country in which they are made and received.

We do not authorise any person to make facilitation payments on our behalf and we seek to ensure that our agents and other intermediaries do not make facilitation payments on our behalf. If you have doubts about a payment and suspect that it might be considered a facilitation payment, only make thepayment if the official or third party can provide a formal receipt or written confirmation of its legality. If you are in any doubt whether a payment can be made, consult the Compliance Committee below.

Record accuracy and retention

The Supplier shall ensure that business records pertaining to Colt are retained for the period required by law, and that they accurately and fairly reflect all business transactions. Disposal shall be performed with adequate attention to the confidentiality of the information concerned.

Data protection

The Supplier shall ensure compliance with laws and directives providing for the protection, transfer, access and storage of personal information.

Confidential information

A standard Non Disclosure Agreement must be signed between Colt and the Supplier or prospective Supplier prior to discussing any confidential information. The Supplier shall not utilise or disclose Colt confidential information and vice versa. This includes, but is not limited to, customer information, supplier information, knowledge of business plans or projections, sales or marketing programmes, customer lists, significant legal or regulatory action or strategy, new products or price changes, changes in senior management, divestitures or mergers and acquisitions.

Government, Media and Investor Relations

The Supplier shall not instigate any form of publicity or make any statement or submission to investors, the media or government referring to Colt without first obtaining prior written permission from Colt (except where required by government or under the law). The Supplier may submit any such request to its primary contact at Colt to be directed for appropriate authorisation.

Fair competition

Colt believes in vigorous yet fair competition and supports the development of appropriate competition laws. The Supplier shall not engage in collaboration or other activity that reduces competition.

Insider trading

The Supplier shall ensure that any unpublished, inside information it is party to regarding Colt is not used to either engage in or support insider trading (which is the use of material non-public information to attempt to profit through dealing in securities).

Gifts and hospitality

The Supplier shall not offer gifts in the form of cash, cash equivalent gifts, cheques, or other negotiable funds, nor shall it offer to any individual gifts or gratuities with a value of more than €150 (or equivalent) per calendar year. Colt permits employees to accept gifts of modest value or reasonable business-related hospitality (e.g. dining or attending sports or social events) in accordance with internal guidelines, however the acceptance of a gift or hospitality must never be understood to imply that a benefit will be awarded to the Supplier.

If a gift is considered to breach internal guidelines and it is considered inappropriate to return it e.g. for cultural reasons, it will be used for charitable purposes as part of Colt’s Corporate Social Responsibility (CSR) activity.

Security, health and safety

Elements of Colt’s business are ISO 27001 certified and Colt expects the Supplier to operate in line with this standard. In general, the Supplier shall ensure that it adheres to Colt’s policy and procedures on security, health and safety whilst in attendance at Colt/Colt customer sites, and in accessing Colt systems or information.

Promoting sustainable development

Colt recognises the important role that business, particularly the information communications and technology sector, has to play in driving growth in the global marketplace. Colt believes that business must accept the responsibility to ensure that growth is achieved in a sustainable manner, promoting socio economic development to try to tackle poverty whilst protecting and enhancing quality of life and avoiding detrimental impacts on any part of the global population or environment.

Colt looks to the supply chain as a key area through which to secure sustainability and requires the Supplier to take these issues seriously by abiding by relevant international, European or national standards or commitments and being able to prove its sustainability credentials if asked.

Employment practices

The Supplier shall respect the UN Universal Declaration of Human Rights and ILO Conventions and comply with national human rights and employment legislation. As a minimum, the Supplier shall uphold the following standards in its own organisation and work to do so within the supply chain:

  • provide a safe working environment for staff and subcontractors
  • avoid use of slaves, forced or bonded labour and child labour
  • validate that all employees and the employees of subcontractors have the legal right to work in the country where services are performed
  • support fair labour practices, including the right to belong to a trade union, the payment of at least the legal minimum wage where such exists and a fair living wage where it does not
  • ensure respect for the dignity of individuals at work and zero tolerance for the harassment of individuals in any form and for any reason
  • provide a confidential and secure mechanism for employees to raise grievances
  • avoid discrimination against employees or potential employees on the basis of their race, colour, nationality, ethnic origin, caste, gender, gender reassignment status, marital status, disability, age, religion, belief, membership or non-membership of a trade union or sexual orientation. Issues of disability should only be considered against the particular requirements of the job.

Environmental practices

Colt prefers to work with Suppliers who have a clear environmental policy and targets, and who can demonstrate a commitment to environmental protection going well beyond the minimum standards set by environmental legislation and EU directives.

The Supplier shall act responsibly towards the environment and provide data on the environmental footprint of their production processes and their products and services upon request. The Supplier is encouraged to adopt the principle of continuous improvement in regard to the environmental sustainability of ifs products. Colt is keen to learn about relevant developments from the Supplier and to share experience in this area.

Reporting breaches of the code

The Supplier is expected to self-monitor its compliance with this Code. In the first instance, known or potential breaches should be reported to the Supplier’s Colt procurement contact.

If the Supplier believes that it is inappropriate to raise a concern to Procurement, it may report it directly to the Colt Corporate Compliance Committee, which assesses matters of legal and regulatory compliance and proper business conduct. The Compliance Committee can be contacted:

  • by e-mailing compliance.committee@colt.net
  • by writing to The Corporate Compliance Committee, c/o The Company Secretary, Colt Technology Services Group Limited, Beaufort House, 15 St Botolph Street, London EC3A 7QN.

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