Colt Group of Companies

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 S.A., a Luxembourg 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.

Company namePlace of incorporationRegistered officeTelephoneRegistered number/
Commercial registry number
VAT/Tax
registration no.
Colt Technology Services GmbHAustriaKärntner Ring 10-12
A1010 Vienna
Austria
+43 1 20 500 0FN 175379KATU 45766309
Colt Technology Services NVBelgiumColt Technology Services NV
Culliganlaan 2H
1831 Diegem
Belgium
+32 2 790 16 16VAT BE 0461.455.625
RPR Brussels
BE 0461455625
Colt Technology Services A/SDenmarkBorgmester Christiansens Gade 55
2450 Copenhagen SV
Denmark
+45 70 21 23 3025760352DK 25 76 03 52
Colt Technology ServicesEngland & WalesColt House
20 Great Eastern Street
London EC2A 3EH
United Kingdom
+44 20 7390 390002452736GB 645 4205 50
Colt Technology Services OyFinlandAccounting Services Tilimatic
Mannerheimintie 16 A 3
Helsinki 00100
Finland
+46 8 781 80 001776465-6FI 17764656
Colt Technology ServicesFrance23-27 rue Pierre Valette
92247 Malakoff Cedex
France
+33 1 70 99 55 00B402 628 838FR 404 0 262 883 8
Colt Technology Services GmbHGermanyGervinusstrasse 18-22
60322 Frankfurt/Main
Germany
+49 69 56606 0HR-NR.: HRB46123USt.-IdNr. DE 197 498 400
Colt Technology Services LimitedIreland15-16 Docklands Innovation Park
East Wall Road
Dublin 3
Ireland
+353 1 436 5900324439IE 63 444 39 R
Colt Technology Services
Limited (formerly KVH Co. Ltd.)
Hong KongSuites 2912-16, Tower Two,
Times Square, 1 Matheson Street,
Causeway Bay,
Hong Kong
+852 800 903 246
Colt Technology Services Co., Ltd.JapanIzumi Garden Tower, 27F
1-6-1, Roppongi, Minato-ku
Tokyo, 106-6027, Japan
0120-525-135 (Toll Free), 03-5617-2342
Colt Technology Services S.p.A.ItalyViale E. Jenner 56
20159
Milan
Italy
+39 02 30 333 112286350157IT 122 863 501 57
Colt Technology Services
(Formerly KVH Korea)
KoreaColt Technology Services Ltd.
(Yeoido-dong, Kyobo Securities Building)
10F, 97, Uisadang-daero,
Yeongdeungpo-gu
Seoul
Colt Technology Services B.V.The NetherlandsVan der Madeweg 12-14a
1114 AM
AMSTERDAM-DUIVENDRECHT
Postbus 94014 1090 GA AMSTERDAM
+31 20 888 202033303165NL 806825790 B 01
Colt Technology Services ASNorwayc/o Wiersholm Mellbye & Bech
Ruselokkveien 26
0115 Oslo
Norway
+45 70 21 23 30982 792 924982 792 924
Colt Technology Services,
Unipessoal Lda
PortugalEstrada da Outurela
118 – Edificio B
2790 – 114 Carnaxide
Portugal
+351 21 120 00 0015061PT 505 289 385
Colt Technology Services,
Pte Ltd. (Formerly KVH Pte Ltd.)
SingaporeColt Technology Services Pte. Ltd.
8 Temasek Boulevard
#17-01, Suntec Tower Three
Singapore (038988)
+65 800 852 3528
Colt Technology Services, S.A.U.SpainC/Telémaco 5
28027 Madrid
Spain
+34 91 789 9000A81626905ES A81626905
Colt Technology Services ABSweden
Sveavägen 56 C
Box 3458,
SE – 111 34, Stockholm
Sweden
+46 8 781 80 00556576-8958SE 556 576 8958 01
Colt Technology Services AGSwitzerlandAlbulastrasse 47
8048 Zürich
Switzerland
+41 58 560 16 00CH-020.3.019.963-5CHE-106.834.429
Colt US Internet CorpDelawarec/o Corporation Service Company,
2711 Centerville Road, Suite 400, Wilmington, Delaware 19808
US43500566EIN-04-3500566

Colt Supplier Code of Conduct

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. Supplies 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 these assets.

Application

Suppliers shall ensure that all their representatives (including employees, agents, suppliers and subcontractors and collectively referred to as “the Supplier”) conduct business with and/or on behalf of Colt in accordance with this Supplier Code of Conduct.

Compliance with the Law and Regulations

The Supplier has an unqualified responsibility to comply with all applicable laws and regulations. The specific areas of compliance highlighted for attention in this document shall not be considered fully definitive.

Anti-Bribery – Kickbacks, Bribes and Payoffs

Suppliers must comply with anti-bribery legislation and avoid all forms of corruption. Suppliers must not offer or accept anything of value to secure an improper advantage or benefit.

The Supplier shall not offer or accept, either directly or indirectly, kickbacks, bribes or payoffs in cash or any other form. It does not matter that a prohibited payment may be demanded by a public official, the prohibited payment still may not be made.

Any incident of such a claim being made on a Supplier with regard to the business they are doing, or hoping to do, with Colt must be reported.

Facilitation payments, paid o speed up the performance of a function or activity to which the payer is legally entitled (e.g. releasing goods held in customs, issuing permits), are prohibited unless permitted under the local legislation of the country in which they are made and received.

We do not authorise any person to make facilitation payments on our behalf and we seek to ensure that our agents and other intermediaries do not make facilitation payments on our behalf. If you have doubts about a payment and suspect that it might be considered a facilitation payment, only make the payment if the official or third party can provide a formal receipt or written confirmation of its legality. If you are in any doubt whether a payment can be made, consult the Compliance Committee below.

Record Accuracy and Retention

The Supplier shall ensure that business records pertaining to Colt are retained for the period required by law, and that they accurately and fairly reflect all business transactions. Disposal shall be performed with adequate attention to the confidentiality of the information concerned.

Data Protection

The Supplier shall ensure compliance with laws and directives providing for the protection, transfer, access and storage of personal information.

Confidential Information

A standard Non Disclosure Agreement must be signed between Colt and the Supplier or prospective Supplier prior to discussing any confidential information. The Supplier shall not utilise or disclose Colt confidential information and vice versa. This includes, but is not limited to, customer information, supplier information, knowledge of business plans or projections, sales or marketing programmes, customers lists, significant legal or regulatory action or strategy, new products or prices changes, changes in senior management, divestitures or mergers and acquisitions.

Government, Media and Investor Relations

The Supplier shall not instigate any form of publicity or make any statement or submission to investors, the media or government referring to Colt without first obtaining prior written permission from Colt (except where required by government of under the law). The Supplier may submit any such request to its primary contact at Colt to be directed for appropriate authorisation.

Fair Competition

Colt believes in vigorous yet fair competition and supports the development of appropriate competition laws. The Supplier shall not engage in collaboration or other activity that reduces competition.

Insider Trading

The Supplier shall ensure that any unpublished, inside information it is party to regarding Colt is not used to either engage in or support insider trading (which is the use of material non-public information to attempt to profit through dealing in securities).

Gifts and Hospitality

The Supplier shall not offer gifts in the form of cash, cash equivalent gifts, cheques, or other negotiable funds, nor shall it offer to any individual gifts or gratuities with a value of more than €150 (or equivalent, and €50 or equivalent in the case of a government-related supplier) per calendar year. Colt permits employees to accept gifts of modest value or reasonable business-related hospitality (e.g. dining or attending sports or social events) in accordance with internal guidelines, however the acceptance of gifts or hospitality must never be understood to imply that a benefit will be awarded to the Supplier.

If a gift is considered to breach internal guidelines and it is considered inappropriate to return it e.g. for cultural reasons, it will be used for charitable purposes as part of the Colt’s Corporate Social Responsibility (CSR) activity.

Security, Health and Safety

Elements of Colt’s business are ISO 27001 certified and Colt expects the Supplier to operate in line with this standard. In general, the Supplier shall ensure that it adheres to Colt’s policy and procedures on security, health and safety whilst in attendance at Colt/Colt customers sites, and in accessing Colt systems or information.

Promoting sustainable Development

Colt recognises the important role that business, particularly the information communication and technology sector, has to play in driving growth in the global marketplace. Colt believes that business must accept the responsibility to ensure that growth is achieved in a sustainable manner, promoting socio economic development to try to tackle poverty whilst protecting and enhancing quality of life and avoiding detrimental impacts on any part of the global population or environment.

Colt looks to supply chain as a key area through which to secure sustainability and requires the supplier to take these issues seriously by abiding by relevant international, European or national standards or commitments and being able to prove its sustainability credentials if asked.

Employment Practices

The supplier shall respect the UN Universal Declaration of Human Rights and ILO Conventions and comply with national human rights and employment legislation. As a minimum, the Supplier shall uphold the following standards in its own organisation and work to do so within the supply chain:

• Provide a safe working environment for staff and subcontractors
• Avoid use of slaves, forced or bonded labour and child labour. In particular the supplier should confirm which steps it has taken to ensure that slavery and human trafficking are not taking place in any part of its business or its supply chain. The supplier shall also, if required to do so under the Modern Slavery Act, provide a statement in that respect,
• Validate that all employees and the employees of subcontractors have the legal right to work in the country where services are performed
• Support fair labour practices, including the right to belong to a trade union, the payment of at least the legal minimum wage where such exists and a fair living wage where it does not
• Ensure respect for the dignity of individuals at work and zero tolerance for the harassment of individuals in any form and for any reason
• Provide a confidential and secure mechanism for employees to raise grievances
• Avoid discrimination against employees or potential employees on the basis of their race, colour, nationality, ethnic origin, caste, gender, gender reassignment status, marital status, disability, age, religion, belief, membership or non-membership of a trade union or sexual orientation. Issues of disability should only be considered against the particular requirements of the job.

Environmental Practice

Colt prefers to work with Supplies who have a clear environmental policy and targets, and who can demonstrate a commitment to environmental protection going well beyond the minimum standards set by environmental legislation and EU directives.

The Supplier shall act responsibly towards the environment and provide data on the environment footprint of their production processes and their products and services upon request. The Supplier is encouraged to adopt the principle of continuous improvement in regards to the environment sustainability of its products. Colt is keen to learn about relevant developments from the Supplier and to share experience in this area.

Reporting Breaches of the Code

The Supplier is expected to self- monitor its compliance with this Code. In the first instance, known or potential breaches should be reported to the Supplier’s Colt procurement contract.

If the Supplier believes that is inappropriate to raise a concern to Procurement, it may report it directly to the Colt Corporate Compliance Committee, which assesses matters of legal and regulatory compliance and proper business conduct. The Compliance Committee can be contacted:

• By emailing CorporateComplianceCommittee@colt.net
• By writing to The corporate Compliance Committee, c/o The Company Secretary, Colt Technology Services Group Limited, Colt House, 20 Great Eastern Street, London, EC2A 3EH.

Colt Group Modern Slavery Act Statement

This statement is made by Colt Group S.A. 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 which is integral to all supplier contracts, 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 4,000 employees, operating in 28 countries and serving more than 25,000 customers worldwide. In order to provide our services, we need to procure a range of goods and services to meet our customer’s needs.

Tax Policy

This tax policy applies to Colt Technology Services Group 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.

Modern Slavery Act Statement

Colt Group Modern Slavery Act Statement
This statement is made by Colt Group S.A. 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 25,600 on-net buildings
spanning over 200 cities in nearly 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.

Risk Assessment
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 S.A.

Caroline Griffin Pain
Company Secretary