In the table set out below, you will find details of each of the trading companies within the Colt group of companies (of which the ultimate parent company is Colt Group Holdings Limited, an English domiciled company, which is not itself a trading company.)
If you are a customer or supplier of a member of the Colt group of companies (or have another form of legal relationship with a member of the group), the details of the precise company with whom you enjoy a contractual relationship will be set out on your particular contract or order form. You can also find details of the appropriate company on the relevant purchase orders, invoices, statements of account or other documentation.
Colt is committed to the highest possible standard 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 Colt's reputation and relationships.
Colt has an excellent reputation with customers, employees, shareholders and business partners. Each of us must take responsibility for maintaining and enhancing our reputation. This Code of Business Conduct helps you to understand your role in doing this. It is critical to our success. It is intended to help all employees to understand and follow the high standards of conduct to which Colt is committed in respect of conducting business. It covers a wide range of issues such as how we treat our customers, suppliers and employees and seeks to ensure that our actions are not affected by conflicts of interest.
This tax policy applies to Colt Group Holdings Ltd and its subsidiaries. The policy has been reviewed by the Audit Committee and approved by the Board of Directors.
Colt provides high bandwidth network services, voice services and data centre services for enterprises and wholesale customers in Europe, Asia and North America’s largest business hubs. We enable the digital transformation of businesses through our intelligent, purpose-built, cloud-integrated network, connecting over 700 data centres around the globe.
Colt takes its legal obligations seriously and is committed to the highest possible level of both legal and ethical standards. We fully comply with tax law in all the territories in which we operate, including the UK, and pay the right amount of tax, at the right time and in the right place. Nevertheless, Colt is a large organisation and it is inevitable that risks, including tax risks, will arise. As with any risk we carefully manage tax risk including in respect of UK taxation through an established framework of systems, processes and controls which have been approved by the board of directors. This framework seeks to proactively identify and mitigate tax risk. Such risks are communicated to the board of directors who have ultimate responsibility for tax governance.
It is not the group’s policy to simply comply with the letter of the law, but also the spirit of the law and due consideration is given to protecting the group’ reputation and its brand. We will only undertake transactions that have a strong underlying commercial rationale; we do not undertake transactions that are artificial or contrived or that are designed to avoid taxation. All transactions between legal entities of the Colt group are conducted on an arm’s length basis.
Colt is a large and dynamic organisation and operates against a background of rapidly evolving tax law. We seek to minimise tax risk and we seek professional advice where necessary and apply for tax rulings where the interpretation of tax law is unclear.
We engage with tax authorities, including HM Revenue & Customs, with openness and transparency including full disclosure of all relevant facts. Colt believes in engaging with tax authorities in a proactive discussion to resolve disputes but we will consider litigation where we disagree with a tax authority on a point of law or a matter of interpretation.
Colt regards the publication of this policy as complying with our duty under para 16(2), Sch 19 FA16.
Colt Group Modern Slavery Act Statement
This statement is made by Colt Group Holdings Limited as the ultimate parent company of the Colt Group of Companies. At Colt, we are committed to running our business responsibly. We strive to maintain the highest ethical principles and to respect human rights. Our Code of Business Conduct sets out the overall standards and commitments towards ethical conduct, anti-corruption and legal compliance.
These standards extend to Colt’s suppliers, partners, agents, directors, employees and subcontractors.
Our organisation and our supply chain
Colt is a global network, voice and data centre services provider, with over 27,500 on-net buildings spanning over 200 cities in over 30 countries. In order to provide our services, we need to procure a range of goods and services to meet our customers’ needs.
Our stance on modern slavery
We have a zero tolerance to slavery and human trafficking. We will not tolerate any such activities within our own operations or within our supply chain and are committed to taking appropriate steps to ensure that everyone who works for Colt – in any capacity, anywhere in the world – benefits from a working environment in which their fundamental rights and freedoms are respected.
Colt has undertaken external due diligence checks on a representative proportion of its suppliers, in order to ensure compliance with the Modern Slavery Act. In addition, checks were also performed on Colt’s suppliers in those industries and geographies where non-compliance is deemed more likely, even though they represent a minimal percentage of Colt’s overall expenditure. Since 2017, each new supplier is required to provide information on its compliance with the Act before being accepted as part of Colt’s supply chain. In 2017, over 99.3% of new suppliers (296 out of 298) were deemed compliant, and the remaining 0.7% was being monitored, albeit being judged low-risk.
Monitoring, Compliance and Training
We also aim to ensure an ongoing high level of understanding amongst our workforce of the risks of modern slavery and human trafficking in our supply chains and our business. Accordingly, all employees and contractors undertake Code of Business Conduct e-training once per year.
All employees, suppliers and subcontractors are also provided with the details of an independent whistleblowing hotline to whom they can make disclosures anonymously.
Evaluating our progress
We are committed to the prevention of modern slavery and human trafficking. We will continue to analyse the various parts of our business, to re-assess risks, and ensure our risk management policies are adequate.
This statement is made pursuant to section 54(1) of the Modern Slavery Act and constitutes Colt Group’s slavery and human trafficking statement for the financial year ending December 31, 2017, and has been approved by the Board of Colt Group Holdings Limited.
Caroline Griffin Pain
Before filing or continuing to prosecute any legal proceeding or claim (other than a Defensive Action) arising from termination of a Covered License, Colt commits to extend to the person or entity (“you”) accused of violating the Covered License the following provisions regarding cure and reinstatement, taken from GPLversion 3. As used here, the term ‘this License’ refers to the specific Covered License being enforced.
However, if you cease all violation of this License, then your license from a particular copyright holder is reinstated (a) provisionally, unless and until the copyright holder explicitly and finally terminates your license, and (b) permanently, if the copyright holder fails to notify you of the violation by some reasonable means prior to 60 days after the cessation.
Moreover, your license from a particular copyright holder is reinstated permanently if the copyright holder notifies you of the violation by some reasonable means, this is the first time you have received notice of violation of this License (for any work) from that copyright holder, and you cure the violation prior to 30 days after your receipt of the notice.
Colt intends this Commitment to be irrevocable, and binding and enforceable against Colt and assignees of or successors to Colt’s copyrights.
Colt may modify this Commitment by publishing a new edition on this page or a successor location.
- ‘Covered License’ means the GNU General Public License, version 2 (GPLv2), the GNU Lesser General Public License, version 2.1 (LGPLv2.1), or the GNU Library General Public License, version 2 (LGPLv2), all as published by the Free Software Foundation.
- ‘Defensive Action’ means a legal proceeding or claim that Colt brings against you in response to a prior proceeding or claim initiated by you or your affiliate.
- ‘Colt’ means Colt and its subsidiaries.
This work is available under a Creative Commons Attribution-ShareAlike 4.0 International license.
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