Caroline Griffin Pain

Chief Legal Officer, Colt

“Colt is committed to the highest possible legal and ethical standards. It is the policy of Colt to instil and to maintain a true culture of compliance with all laws, rules and regulations wherever we do business. We hold our people to the highest standards when it comes to governance, ethics and regulations. We do this by consistently providing them with the tools and training they need.”

Governance and our board

We are fully committed to clear governance structures that ensure Colt Group is well run, providing a solid platform for our ever-improving ESG performance and to look after the people who work for, with and around our business. Colt Group’s Code of Business Conduct and policies provide guidelines for our business practices and set out how we operate in an accountable way with consistency across all markets.

The Board of Colt Group Holdings Limited makes decisions affecting Colt and Colt DCS. The Colt Board has four directors, one man and three women.

The Board has four subcommittee's: the DCS Board, the Audit committee and the Colt and DCS Remuneration Committees. The Audit Committee and the Remuneration Committee members are exclusively non-executive directors.

The Environmental Sustainability Steering Committee (SteerCo) oversees our sustainability programme. It is an executive level committee co-chased by the CEOs of Colt and Colt DCS, and it is responsible for agreeing and approving the global sustainability strategy and policies, and for the delivery against annual targets.

  • Code of Business Conduct training completion


In 2022, 99.3% of Colt Group Employees completed the Code of Business Conduct training*

* Data includes active and inactive employees and excludes Contractors Ongoing. The completion rate for new joiners was 95.7%. The completion rate for new Colties from Lumen was 94.9%. 

Business ethics, anti-corruption and whistle-blower mechanism

We run our business responsibly and to the highest ethical principles. It is not our policy to merely comply with the letter of the law, rather it is our policy to instill a true culture of compliance with all laws, rules and regulations wherever we do business.

Employees are encouraged to raise breaches of the Code of Business Conduct through an independent  Business Ethics Line or by reporting to the Corporate Compliance Committee. Anonymous whistle blowing is possible wherever permitted by local law.

Human rights

We maintain the highest principles in respect to human rights. We do not tolerate slavery and human trafficking within our own operations or within our supply chain. We ensure that everyone that works for Colt Group benefits from a working environment in which their fundamental rights and freedoms are respected.

Our basis for this is the International Labour Organisation (ILO) five fundamental principles:

  1. Freedom of association and the right to collective bargaining
  2. Elimination of all forms of forced or compulsory labour
  3. Abolition of child labour
  4. No discrimination
  5. Safe and healthy working environment


The Colt Board annually approves our Modern Slavery Act statement which is published on our website and demonstrates our commitment to running our business responsibly and sets out our overall approach.

  • Covered by Collective Bargaining Agreements


In 2023, 64.7% of our employees in mainland Europe were covered by Collective Bargaining Agreements*, which include working conditions and terms of employment, and provide elected employee representations in line with national laws.

*This percentage includes; Employee, Fixed Term Employee and Grads or all employees with active and inactive payroll at Colt Group.

For employees not covered by collective bargaining agreements, working conditions and terms of employment are confirmed in the employment contracts, global and local HR policies and the employee handbook.

We have an active dialogue with our employees through the European Works Council (EWC) and the National Works Council (NWC). In countries where there is no national Works Council or union representation, we have other forms of information and consultation forums, including elected employee representatives and Colt Ambassadors.  

Our Social Dialogue Statement is designed to provide a global framework for social dialogue in line with Colt's values, our diversity, equity and inclusion goals, our people agenda and global ESG strategy which is supported by local legislation in each of our jurisdictions. The statement reflects Colt's commitments to promoting consensus and democratic involvement among the main stakeholders such as our European Works Council, National Works Council and employee representatives in the workplace to protect labour rights. The statement confirms our commitment to upholding the fundamental human rights set out by the International Labour Organisations (ILO). 

Risk management

The Colt Group Enterprise Risk Management Framework (ERM) assesses all risks relevant to our business, including those related to environmental sustainability and our social impact. The risk management process is guided by ISO 31000 standards and follows a five-stage process of identifying risks, assessing them, deploying the appropriate measures and on-going monitoring.

Within Colt’s ERM framework, there are a number of processes for ESG-related risks to be identified and assessed. Risks can be identified via the annual update of the Climate Change Risk Register, or via country specific, functional specific risk registers or the ESG risk register. Project risk registers could also, under specific circumstances, include some ESG-related risks.  

Additionally, we proactively manage social risks related to DEI; and business accessibility, which are tracked through the HR functional risk register which is updated bi-annually.  

Beyond ESG-related risks, we operate a group enterprise risk management programme and analyse a broad range of financial, project, operational, regulatory and strategic risks that impact our business. This expands to specialist areas such as anti-bribery and corruption, where the Colt Group periodically undertakes an assessment of risk across its business activities, benchmarking itself against the principals of the UK Bribery Act, considered one of the most stringent anti-corruption regulatory regimes in the world. This ensures adequate procedures are in place to prevent bribery 

For more information on Risk Management, see page 60-61 of our 2023 Sustainability Report. 

Data privacy and cybersecurity

The Group's Data Privacy Statement enables us to manage privacy, and protect personal and corporate data. We apply the joint principles of Privacy by Design and Privacy by Default at the inception of every new product, application, policy and system, and ensure those principles are the basis for decision-making throughout their entire lifecycle.

We have implemented a data breach complaints procedures for employees, customers, and third parties. Annual training in Data Breach and Data Privacy compliance is provided to all Colt Group employees.

  • Data Protection Training in 2023


In 2023, 99.4% of Colt Group employees completed Data Privacy training*

*Data includes active and inactive employees and excludes Contractors Ongoing. The completion rate for new joiners was 99%. The completion rate for new Colties from Lumen was 95.5%.

Colt Group applies the principles of Privacy by Design and Privacy by Default at the very first stage of every product, application, policy, or system and along the lifecycle of the relevant data processes. This means all policies, procedures and systems will need to comply with the General Data Protection Requirements (GDPR) and any other applicable Data Protection legislation from the inception of the products and processes development.

Colt’s Binding Corporate Rules (BCRs) set the rules for data protection and data transfer and were approved by the European Data Protection Board (EDPB) in August 2021. Colt Group was the first telecommunications company under the General Data Protection Regulation (GDPR) system to be given the BCR accreditation. The BCRs are the “gold standard” in privacy certification, providing us with the highest recognition in privacy that a group of companies can have.

In 2023, Colt was awarded the ISO27701 certification for its privacy information management system, which is an extension of ISO27001. This global standard provides the framework for organisations looking to put in a system to support the compliance with the EU GDPR and other Data Privacy Requirements. For more information see page XX of our 2023 Sustainability Report.