Governance
We're committed to the highest possible legal and ethical standards, and it is our policy to instill and to maintain a true culture of compliance with all laws, rules and regulations wherever we do business.
1. 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.
The Colt Board makes decisions affecting Colt and the Colt Group. The Colt Board comprises of non-executive directors and senior management. The Audit Committee and the Remuneration Committee do not include executive directors.
The Board of Colt Group Holdings Limited (Colt Board) comprises of eight directors. Our approach to diversity is reflected in the Colt Board's composition.
The ESG Steering Committee is an executive-level committee that addresses all aspects of Environmental, Social, and Governance (ESG) factors. Co-chaired by the CEOs of Colt and Colt DCS, it is responsible for setting and meeting annual sustainability targets and ensuring Colt employees achieve their sustainability goals. The committee meets at least twice a year to agree on and approve Colt's overall sustainability strategy and policies
2. Business ethics, anti-corruption and whistle-blower mechanisms
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.
In 2024, 97.2% of Colt Group Employees completed the Code of Business Conduct training*
The completion rate for new joiners was 99.4%.
Our central Compliance team is responsible for embedding compliance governance into our high-performance culture, integrating it into our business-as usual processes and frameworks, and driving ownership of compliance to ensure proactive adherence to both internal and external regulations.
3. Responsible value chain
When working with suppliers, we set forth expectations in our Supplier Code of Conduct, which incorporates the same standards of ethical conduct and integrity as our Code of Business Conduct.
In 2024, 90.9% of our supplier spend was with suppliers who had contracts that included clauses on environmental, labour and human rights requirements.
Guided by our Sustainable Procurement Policy, we consider sustainability criteria in the selection, management and evaluation of our suppliers and use Request for Proposal (RFP) scoring to evaluate supplier ESG performance.
We actively engage with our suppliers via our Vendor Risk Management system (VRM) on a wide range of ESG matters, including environment, health and safety, anti-bribery and corruption, data protection, cybersecurity, human rights and modern slavery protection. We also assess our suppliers’ approach to DEI and digital accessibility and have made notable strides in our work with our suppliers to reduce our supply chain emissions.
3. Human rights
We maintain the highest ethical principles and to respect human rights. We have zero tolerance for slavery and human trafficking and will not tolerate such activities within our operations or supply chain.
We take appropriate steps to ensure that everyone who works for Colt benefits from a working environment where fundamental rights and freedoms are upheld.
Our basis for this is the International Labour Organisation (ILO) five fundamental principles:
- Freedom of association and the right to collective bargaining
- Elimination of all forms of forced or compulsory labour
- Abolition of child labour
- No discrimination
- Safe and healthy working environment
The Colt Board annually approves our Modern Slavery Act statement which demonstrates our commitment to running our business responsibly and sets out our overall approach.
In 2024, 58.6% 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; Employees, Fixed Term Employees, apprentices, trainees and graduates with active payroll at Colt Group. For employees not covered by collective bargaining agreements, working conditions and terms of employment are specified in their employment contracts, as well as in our global and local HR policies and the employee handbook.
We maintain active communication with our employees through the European Works Council (EWC) and the National Works Council (NWC). In countries without a national Works Council or union representation, we offer alternative forums for information and consultation, such as elected employee representatives and Colt Ambassadors.
Our Social Dialogue Statement establishes a global framework for social dialogue that aligns with Colt’s values, diversity, equity and inclusion goals, our people agenda and global ESG strategy, all supported by local legislation across our jurisdictions. This Statement underscores Colt’s commitment to fostering consensus and democratic involvement among key stakeholders, including the EWC, NWCs, and employee representatives, to protect labour rights. It also reaffirms our dedication to upholding the fundamental human rights outlined by the International Labour Organisation (ILO).
4. Risk management
Colt Group applies an Enterprise Risk Management (ERM) Framework to evaluate risks to our business. Environmental and social considerations are included in this process.
ISO 31000 standards guide our risk management approach, following a four-stage continuous process: identifying risks, assessing risks, implementing appropriate measures and ongoing monitoring.
Colt’s ERM framework identifies and assesses sustainability risk using our Climate Change Risk Register, country-specific or function-specific risk registers, and the ESG risk register. Additionally, under certain circumstances, project risk registers may 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.
Colt Group manages and analyses 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 70 of our 2024 Sustainability Report.
5. 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.
Our approach includes certifications such as ISO 27001, ISO 22301 and Cyber Essentials Plus, reflecting our commitment to robust cybersecurity standards. Our cybersecurity programs and risks are regularly reviewed by Management, covering our people, processes, applications, IT infrastructure and network.
We have implemented a data breach complaints procedures for employees, customers, and third parties.
In 2024, 99.3% 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 joiners was 100%.
We use the principles of Privacy by Design and Privacy by Default as the basis of decision-making for every product, application, policy and system. 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 2024 we updated our rules for data protection and data transfer as defined in Colt’s BCR with the EDPB’s approval. We are continuing the process of mapping BCR data for Lumen EMEA and we are on track to complete this process by 2025.
Colt made significant progress in the exchange of documentation with the Information Commissioner's Office (ICO) throughout the year, paving the way for the approval of UK BCRs, with the final approval expected in 2025.
In 2024, Colt became one of the only digital infrastructure companies to be awarded the ISO 27701 certification on a country-by-country basis. ISO 27701 is a privacy extension to ISO 27001 and provides a comprehensive framework for managing PII. By implementing ISO 27701, we have established a robust PIMS that enhances our ability to comply with various data privacy regulations.
Our approach includes certifications such as ISO 27001, ISO 22301 and Cyber Essentials Plus, reflecting our commitment to robust cybersecurity standards. Our cybersecurity programs and risks are regularly reviewed by management, covering our people, processes, applications, IT infrastructure and network.
For more information, see page 71 of our 2024 Sustainability Report.
“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.”
Caroline Griffin Pain, Chief Legal Officer
