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 committed to ensuring that our ESG commitments are converted to positive impacts through ambitious targets and dedicated action. 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 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 seven directors. Our approach to diversity is reflected in the Colt Board's composition.
In 2022, 97.7% of Colt Group Employees completed the Code of Ethics training*
* Data includes active and inactive employees and excludes Contractors Ongoing. The completion rate for new joiners was 89.4%
In 2022, 514 employees had additional Anti-Bribery and Corruption training*
* Number as of 31/12/2022
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
Colt Group is committed to upholding the fundamental human rights set out by the International Labour Organisation (ILO) and requires all employees to comply with all of the ILO’s Fundamental Principles through their conduct and responsibilities.
We have zero tolerance for slavery and human trafficking. We will not tolerate any such activities within our operations or supply chain. 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. We maintain the highest ethical principals in respect to human rights.
We are committed to taking appropriate steps to ensure that everyone who works for Colt Group – in any capacity, anywhere in the world – benefits from a working environment in which their fundamental rights and freedoms are respected.
In 2021, 63% of Colt Group employees in Europe are covered by Collective Bargaining Agreements*
*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 employment terms are confirmed in the employment contracts, global and local HR policies, country-specific employee handbooks or collective agreements at company level.
Colt Social Dialogue Statement Colt recognises the importance of social dialogue in addressing social issues and achieving sustained economic and business success. Colt has established listening strategies, employee networks, and partnerships with existing employee representative bodies to truly understand employee feedback, promote key messages, drive initiatives, and improve the overall employee experience and engagement. The company’s Social Dialogue Statement provides a framework for sustainable collective relationships through all types of dialogue and information exchange on issues of common interest. Social dialogue helps Colt make better-informed business decisions, giving employees a voice, supporting meaningful dialogue, and sharing knowledge and feedback to influence strategic decisions and improve the quality of working life and culture within the organisation.
Risk management
Managing our risks and opportunities is a key factor in the continued business success of Colt Group. We strongly believe that good risk management creates a more resilient and sustainable business. Colt Group operates an Enterprise Risk Management Framework covering all types of risks, including sustainability risks. The risk management process at Colt Group is based on the ISO 31000 principles and follows a 4-step cycle: identify, assess, respond and monitor. The impact of potential risks cover quantitative and qualitative measures such as financial exposure, people and safety, business disruption, compliance, customers and reputation. An inability to spot, analyse and mitigate potential risks - whether business or societal - may harm our ability to adapt and grow our business. Climate risks at Colt Group are integrated into our companywide risk management process.
Data privacy and cybersecurity
We must do this with integrity and transparency as we drive digital transformation to unlock commercial value across the entire value chain. We continue to strengthen our capabilities to protect personal data belonging to individuals, such as our employees, partners and customers, and commercially sensitive data.
Colt Group’s Privacy Goals and Global Privacy Policy enable us to effectively protect personal data and manage privacy risk. Having robust privacy and cybersecurity policies and processes ensures that our customers and other stakeholders can trust us with their data. The Data Privacy Statement is published on the Colt website.
We have implemented data breach procedures as well as a complaints procedure for employees, customers, and third parties, and all employees take an annual training in Data Breach and Data Privacy compliance. Annual and recurrent mandatory training in Data Breach and Data Privacy compliance is provided to all Colt Group employees.
In 2022, 98.3% of Colt Group employees have completed training on Data Protection*
*Data includes active and inactive employees and excludes Contractors Ongoing. The completion rate for new joiners was 87.4%.
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.
