Governance and our board

We maintain clear governance structures to ensure Colt Group is well run and supports strong ESG performance.

The Colt Board, made up of non-executive directors and senior management, oversees decisions affecting Colt and Colt Group. The Audit and Remuneration Committees exclude executive directors. The Board has nine directors, reflecting our diversity approach.

The ESG Steering Committee, an executive-level committee co-chaired by the CEOs of Colt and Colt DCS, sets annual sustainability targets and meets at least twice a year to approve strategy and policies.

Business ethics, anti-corruption and whistle-blower mechanics

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 2025, 99% 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.

Responsible value chain

Our Supplier Code of Conduct sets our expectations and ethical standards for suppliers.

In 2025, 94% 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 assess suppliers on ESG performance through Request For Proposal (RFP) scoring and engage them via our Vendor Risk Management system on issues such as environment, health and safety, anti-bribery and corruption, cybersecurity, data protection, human rights, modern slavery protection.

We also assess our suppliers’ approach to DEI and digital accessibility and work with our suppliers to reduce our supply chain emissions.

Human rights

We uphold human rights and have zero tolerance for slavery and trafficking within our operations or supply chain. Our approach is based on the International Labour Organisation (ILO) principles: freedom of associationand the right to collective bargaining, elimination of forced labour, abolition of child labour, non-discrimination, and safe and healthy working conditions. The Colt Board annually approves our Modern Slavery Act statement.

In 2025, 59% of mainland Europe employees were covered by Collective Bargaining Agreements. For those not covered by collective bargaining agreements, terms are set in employment contracts and HR policies.

We maintain dialogue through European and National Works Councils, and alternative forums where councils are absent. Our Social Dialogue Statement provides a global framework aligned with our values, people agenda, DEI goals and ESG strategy, supporting consensus and protecting labour rights.

In 2025, 59% 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.

Risk management

We apply an Enterprise Risk Management (ERM) framework, guided by ISO 31000, to identify, assess, manage and monitor risks, including environmental and social risks. We also assess risks such as anti-bribery, benchmarking against the UK Bribery Act, considered one of the most stringent anti-corruption regulatory regimes in the world, to ensure strong prevention measures.

Data privacy and cybersecurity

Colt’s Data Privacy Statement ensures protection of personal and corporate data, applying Privacy by Design and Default principles at the inception of every new product, application, policy and system. We hold certifications including ISO 27001, ISO 22301, ISO 27701 and Cyber Essentials Plus. Cybersecurity programmes are regularly reviewed across people, processes, applications, IT and networks. We have procedures for data breach complaints for employees, customers, and third parties.

In 2025, 99% of Colt Group employees completed Data Protection 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%.}

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Colt’s Binding Corporate Rules, approved by the European Data Protection Board in 2021 and updated in 2024, set high standards for data transfers. With UK approval secured in 2025, we are among a small number of companies with BCR frameworks in both the EU and UK, reinforcing our strong commitment to data protection excellence.

Colt is committed to the highest possible legal and ethical standards. It is the policy of Colt to instill 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

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