Code of Business Conduct
The way we do business
On this page:
Overview
Anti-bribery
Anti-fraud
Hospitality & gifts
Conflicts of interest
Fair competition
Confidentiality
Appropriate use
Data protection
Environment
Gov, media & investor relations
Integrity of transactions
Undisclosed funds
Employees
Suppliers
Acting on behalf of Colt
Political payments
Prohibited conduct
Enforcement & compliance
Introduction:
Doing the right thing
Colt has an excellent reputation with customers, employees, shareholders and business partners. Each of us must take responsibility for maintaining and enhancing our reputation and this Code of Business Conduct helps you to understand your role in following the high standards of conduct to which Colt is committed. Compliance is critical to our success: at Colt, it is paramount to do the right thing.
1. Overview
Colt is committed to the highest possible legal and ethical standards. It is not our policy to merely comply with the letter of the law, but rather to instil and maintain a true culture of compliance with all laws, rules and regulations wherever we do business.
Every employee and person acting for Colt has an unqualified responsibility to observe and comply with all applicable laws, rules, regulations, sanctions and commonly accepted business standards of conduct and courtesy. We must ensure that our conduct always sets the best possible example, and even a mistaken inference of wrongdoing must be avoided. Every employee and person acting for Colt is expected to demonstrate high standards of personal and professional conduct when dealing with customers, suppliers, regulators and other stakeholders including honesty, integrity, personal responsibility and professionalism.
Conduct which damages Colt’s reputation is prohibited. Colt reserves the right to take any action that is deemed appropriate in the following situations:
- Employee behaviour or actions outside working hours or away from Colt's premises, which may bring Colt into serious disrepute or materially damage Colt's interests
- Behaviour or actions which could create a hostile or intimidating envioronment during working hours and when conducting business away from Colt's premises
- Conduct which could have an adverse effect on a person's ability to perform properly their duties of employment
- Criminal behaviour (e.g. the use of illegal drugs). Colt has a zero tolerance approach to the use of illegal drugs.
2. Anti-Bribery: Prohibition of kickbacks, bribes and payoffs
All Colt employees must comply with anti-bribery legislation, and avoid all forms of corruption. Where the Colt standard is more stringent than local legislation, the Colt standard will always apply.
Employees must not directly or indirectly offer or accept kickbacks, bribes or payoffs in cash or anything of value, to secure an improper advantage or benefit; such as win orders, gain insider information, to accelerate or otherwise influence the grant of a regulatory approval (e.g., planning permission) or influence tenders.
“Anything of value” can be any object, favour, service, cash or cash equivalent, entertainment, gift, property, or anything else. It does not matter that a prohibited payment may be demanded by a public official, the prohibited payment still must not be made.
Here are some examples (but not an exhaustive list) of bribery risk scenarios that a Colt employee could possibly encounter:
- a request for contribution to a political party or favourite charity of a public official or business partner (indirectly offering cash equivalent),
- an offer of employment or an internship to a relative of a public official or business partner (indirectly offering something of value),
- an invite to an all-expenses paid trip or major sporting event (directly accepting gift or entertainment),
- entertainment during contract negotiations, even if the cost involved is within budget (directly accepting entertainment), or
- actions taken out by third parties who act as intermediaries including requests for pre-payment without justification and invoice (indirect offer).
Colt employees, agents, suppliers and other intermediaries are strictly prohibited from making facilitation payments (i.e. payments which speed up, rather than influence, an outcome e.g. releasing goods from customs, issuing planning permission or regulatory authorisation). Colt never requests pre-payment solely in order to speed up the provision or delivery of services.
Any actual or suspected non-compliance by employees, suppliers, agents, or anyone claiming to act for Colt must be reported immediately: how to report. Failure to report is a violation of this Code of Business Conduct and may result in disciplinary procedures.
3. Anti-fraud, tax evasion & money laundering
Any involvement with parties involved in fraudulent activities, tax evasion or money laundering is strictly prohibited.
- Fraud is criminal deception or the use of false representation to gain an unjust advantage (e.g. falsifying the goods or services received on a supplier invoice).
- Money laundering is the process of taking the proceeds of criminal activity and making them appear legal.
- Tax evasion is the use of illegal methods to pay less tax, or no tax at all.
It is our duty to ensure that Colt complies with the processes, procedures, systems and checks required by EU and local regulation related to the prevention of fraud, tax evasion and money laundering. Any suspicion of fraudulent activity, tax evasion or money laundering, whether by a Colt employee or a third party, must be reported immediately: how to report.
4. Hospitality & gifts
Colt does not prevent employees giving or receiving gifts of modest value or reasonable business-related hospitality (e.g. dining or attending social events) subject to the following guidelines:
- You must not accept any form of hospitality, gift or service, directly or indirectly which might lead the giver to believe that they are going to benefit in some form.
- You must not offer any form of hospitality, gift or service, directly or indirectly which might lead the receiver to believe Colt is going to benefit in any form.
- Inappropriate gifts and entertainment is strictly prohibited (i.e. adult themes, visits to casinos etc).
Unique, unusual, frequent or lavish gifts or hospitality may raise questions of impropriety. Example: Tickets to attend the finals or semi-finals of highly regarded sports events.
Hospitality
Hospitality must not exceed the following EUR (or local currency equivalent) amounts:
| Hong Kong, South Korea, Japan, USA | €150 | €0 |
| India | €50 | €0 |
| All other Colt countries | €150 | €50 |
Any hospitality exceeding these thresholds requires pre-approval from the Ethics Committee or DCS Governance Committee: how to report.
Hospitality within these thresholds requires pre-approval from line manager/cost centre owner or other designated approver under the Colt Authorities Matrix.
Please note:
- You must not offer or accept hospitality whilst any contractual negotiations are ongoing.
- Light refreshments e.g. tea, coffee, light snacks etc. during business meetings with private or public sector third parties are not considered business hospitality, and do not require approval under this policy.
- The person providing hospitality must attend the event with the recipient and the primary purpose of attending should be to discuss business or build a business relationship. If you give or accept hospitality but do not attend the event, then the transaction is considered a gift and is subject to the below gift thresholds..
- Resale of tickets is expressly forbidden.
- High regarded sporting events with an excessive value are unlikely to be pre-approved by the Ethics Committee or DCS Governance Committee.
- The below Close Succession rule applies to hospitality.
Gifts
Gifts must not exceed the following EUR (or local currency equivalent) amounts:
| Hong Kong, South Korea, USA | €150 | €0 |
| Japan | €150, or for gifts of flowers to corporations (not individuals) to celebrate significant events: €450 | €0 |
| India | €50 | €0 |
| All other Colt countries | €150 | €50 |
Any gifts exceeding these thresholds requires pre-approval from the Ethics Committee or DCS Governance Committee: how to report.
Gifts within these thresholds requires pre-approval from line manager/cost centre owner or other designated approver under the Colt Authorities Matrix.
Regardless of value, you must not engage in any of the following activities in connection with your status as en employee of Colt:
- Offer or accept gifts whilst any contractual obligations are ongoing.
- Give or receive cash, cash equivalent gifts (e.g. vouchers), cheques or other negotiable funds.
- Solicit any gift, favour or other form of preferential treatment.
- Borrow or lend money (other than from an entity that is in the business of lending, on normal terms generally available).
In dedicing whether to give or receive a gift, consider whether disclosure of the full details of the gift would damage Colt's integrity or reputation in any way. Please not the Close Succession rule applies to gifts.
Close succession
If hospitality or gifts are given to or received by the same customer/supplier in close succession (within three months), the collective value given or received in the three month period will be considered by the Ethics Committee or DCS Governance Committee. Approval requests may be declined as a result of the combined value exceeding the thresholds.
Any questions regarding value, pre-approval or permissibility of gifts or hospitality, should be reported to Colt: how to report.
5. Conflicts of interest
Colt expects all employees to display a high degree of business loyalty to the Company and in turn Colt is loyal to, and supportive of, its employees. Employees must not engage in business activities that cause, or may reasonably be thought to cause, a conflict with the interests of the Company. A conflict of interest may arise when an employee is influenced by considerations of gain or benefit for themselves or a family member. In the event that a conflict of interest may arise or appear to exist, despite best efforts to avoid, it is imperative that the conflict is promptly disclosed to your manager and the Ethics Committee or DCS Governance Committee: how to report.
To facilitate the disclosure process, please refer to the declaration as seen via the following link: Conflicts of Interest_ Employee Declaration Form.pdf. Please complete the declaration and email a copy to your manager and local HR.
Conflicts of interest take many forms. The following examples are a non-exhaustive list of conflicts of interest that must be avoided:
Secondary employment
A Colt employee who wishes to also serve as an employee or consultant for another business must seek prior permission from HR and their manager, with submission of the declaration accessed here, to ensure it avoids conflict of interest and does not dilute their ability to fulfil their Colt role. If a conflict does arise or there is risk to fulfilling their Colt role, then the employee must not pursue the interest external to Colt. Any queries in relation to prospective or currently held secondary employment must be raised to HR.
Proprietor / partnership business
An employee who manages or wishes to start up any proprietor / partnership business must seek prior permission from HR and their manager, with the submission of the accessed here. The proprietor / partnership business must not interfere or conflict with the employee's duties to Colt. However, if a conflict does arise, the employee must inform HR & their manager.
External directorships
An employee who holds or wishes to hold any external directorship positions must seek prior permission from HR and their manager, with submission of the declaration accessed here, to ensure it avoids conflict and the directorship in question must not interfere with the employees duties to Colt. If a conflict does arise, the employee must inform HR and resign immediately or must not pursue the external interest. Any employee subject to an advanced background screening check will automatically undergo a Directorship check, which would highlight any ongoing Directorships.
6. Fair competition
Colt believes in vigorous yet fair competition and supports the development of appropriate competition laws.
Many countries prohibit collaboration with competitors, or competitors’ representatives and other activities that reduce competition. Participating in these actions can result in criminal penalties for both you and Colt. The following are some examples of prohibited conduct:
- Any discussion with a competitor about the setting of any terms of sale (e.g., discounts, prices, credit terms, etc.), the setting of production levels, dividing customers or territories or boycotting any customer.
- Any discussion or attempt to influence customers regarding their resale prices.
Competition laws can be breached in conversations, or with behaviour, that may appear harmless. For example, if the prohibited conduct or statement:
- Was made at a social occasion. Note it is irrelevant that the statement was not made at a business meeting or in a formal setting;
- Was made as a joke or light-hearted remark;
- Was made by a junior employee. Note the seniority of the person making the statement is irrelevant.
If you are the recipient of a statement suggesting collaboration or collusion and remain silent, or fail to take any explicit action to distance Colt and yourself from any suggestion of collaboration or collusion made by another party, this would be taken to imply your consent and could therefore expose Colt and yourself to breaches of competition laws and criminal sanctions.
If you suspect that a Colt employee has made a statement suggesting collaboration or collusion, or if an employee or representative of a competitor makes such a suggestion to you or another Colt employee, the matter should immediately be reported to the Ethics Committee or DCS Governance Committee: how to report.
7. Confidentiality
You may have access to confidential information due to your employment. Such information must not be shared with others outside Colt or used for personal gain.
You may not trade securities based on inside information you have received. Confidential information includes customer information, supplier information, knowledge of business plans or projections, sales or marketing programmes, customer lists, significant legal or regulatory action or strategy, new products or price changes, changes in senior management, divestitures or mergers and acquisitions.
8. Appropriate use of electronic and other company resources
You are expected to use all Colt resources in a responsible manner. Although incidental or occasional personal use of such assets is permitted so long as it does not interfere with the conduct of Colt business, misapplication or waste of such assets is prohibited and may amount to a criminal act.
All electronic resources of the Company are assets belonging to Colt.
- You should protect your own passwords, and not use anyone else’s ID to access records.
- Do not alter records or software unless you are authorised to do so and always ensure that any software you use has been obtained from authorised Company suppliers.
- Only install software if you are authorised to do so.
- You must not use Colt assets to access inappropriate websites including those devoted to pornography, terrorism or other criminal, unethical or inappropriate activities inconsistent with Colt’s values.
- You must make every effort avoid opening spam mail.
In most countries the above will supplement other guidelines for the use of electronic and other Company resources. See the Information Risk Management intranet site for more details.
9. Data protection
GDPR, EU directives and local laws provide for the protection, transfer, access and storage of personal information on customers, employees, contacts and other individuals.
To achieve compliance with these provisions you must comply with Colt’s Data Protection and Compliance Policy and related procedures and information. This policy, and other relevant policies and procedures which relate to your function, should be familiar to Colt employees. Colt shall only process your personal data for the purposes permitted under applicable law. The processing of your personal data by Colt for the purposes described hereunder is based on your explicit consent or on the necessity to process your personal data for the purposes of our legitimate interests, as provided by Article 9, 2., (a) and (f) of the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (“GDPR”).
Binding coprorate rules
The Binding Corporate Rules (“BCRs”) are a certification awarded by the European Data Protection Board (“EDPB”) which demonstrates that Colt’s privacy programme is compliant with the General Data Protection Regulations (“GDPR”) worldwide. BCRs allow safe transfers of personal data outside the EU. This certification is recognised globally and must be enforced by every member of the Colt Group, therefore compliance with the BCRs by all Colt employees is critical.
10. Environmental sustainability
Colt’s environmental approach is articulated in our Environmental Sustainability Commitment Statement and is characterised by a comprehensive focus on reducing our Scope 1, 2 and 3 emissions, minimising the waste we produce and embedding circular economy practices in the way we deliver our products and services.
Our Sustainability Report includes sustainability performance environmental data, GHG emission reduction targets and key initiatives we implement to minimize our impact. All employees are required to take annual environmental mandatory training to improve their knowledge on this important topic and to help embedding our environmental strategy across the business.
Colt is committed to honest public reporting on non-financial information. We demonstrate this by aligning our reports to international non-financial reporting standards such as Global Reporting Initiative (GRI) Standards and applicable guidance in those jurisdictions for which non-financial reporting is mandatory. All Colt non-financial reports are verified by independent verification bodies to ensure accuracy and alignment with ESG best practices.
11. Government, media & investor relations
You must refer all media and investor inquiries to the External Communications Team.
Wherever possible, please contact a communications specialist before agreeing on any activities with third parties. Please refer to the Media Relations Policy and Social Media Policy.
12. Integrity of transactions and accuracy of books and records
The integrity of Colt depends on only entering into legitimate business transactions and engagements that have been appropriately approved and properly documented.
All accounting records, employee records, employee expense claims, application forms and other corporate books and records must accurately and fairly reflect all underlying transactions. It is every Colt employee’s responsibility to make sure that correct authority for each transaction has been obtained, documented and that receipts, disbursements, journal entries and similar records are accurate. These documents must contain wording that clearly describes the reason and purpose for each transaction and must be appropriately retained in compliance with Colt’s Document Retention and Destruction Policy. You are prohibited from making any false or fictitious entry in any of the books and records of Colt or its affiliates or subsidiaries.
No payment on behalf of any corporate entity shall be approved or made with the express or implied agreement or intent that any part of such payment is to be used for any purpose other than that described by the documents supporting the payment. Accordingly, any agreement for the employment of a sales agent, business consultant or promoter or for the payment of a finder’s fee shall be based upon documentation that accurately reflects the true nature of the arrangement. Policies with respect to retaining agents and other third parties are discussed in more detail below.
Examples of transactions that would violate the Code of Business Conduct include the following:
- Payments that are falsified or not recorded in the Company's accounting records
- Claiming reimbursement of expenses which are not incurred in the furtherance of Colt’s business or are outside of the policies or procedures on the payment of such expenses
- Payments that are made through backdated or altered invoices
- Any transaction in which invoices do not set forth the true transaction purchase or sale price
- The creation or maintenance for Colt of any bank account in a name other than the name of the Company
13. Undisclosed funds
Colt will not create or maintain any secret or unrecorded fund or asset.
Any employee having knowledge of any secret or unrecorded fund or asset should immediately report the matter to the Ethics Committee or DCS Governance Committee: how to report.
14. Employees
Colt is committed to attracting and retaining the best people based upon ability and merit, as well as maximising every opportunity for employees to share in its success.
Colt’s committed to developing its people and therefore makes available a number of training courses and opportunities to make this possible for all employees. Through its internal information systems and consultation processes, Colt maintains good communication with all employees. Colt seeks to engender a culture of openness and honesty, with individuals expected to treat each other properly and with respect and consideration at all times. Employee wellbeing is important to Colt’s current and future employees, and Colt has a number of initiatives and tools available to employees to protect their mental and physical wellbeing.
Colt takes a holistic approach to accessibility, defined as the ability for people with disabilities and impairments to access all information and opportunities, as well as physical and digital spaces without requiring undue additional time or effort. Colt ensures compliance with accessibility standards and works towards continual improvement of accessibility across its products and services.
Colt makes best efforts to be a good corporate neighbour in all the communities we operate in and we have various local links to charities. Colt actively encourages employees in this initiative and provides employees with volunteering days each year, which can be taken by employees to participate in charity events or community project activities.
Colt does not tolerate harassment, bullying or inappropriate behaviour of any form, whether physical, verbal or non-verbal, that has the purpose or effect of violating a person’s dignity or creating an offensive, intimidating or hostile environment. Sexual harassment and harassment based on someone’s age, disability, gender, marital status, pregnancy/maternity, race, religious or other beliefs, sexual orientation, gender expression or sexual identity is unacceptable. Apart from being unlawful in most of the countries in which Colt operates, such harassment is disruptive and contrary to Colt’s values.
The following items are some examples of what could be perceived as unacceptable behaviour:
- Unwanted physical contact or intrusion by pestering and stalking
- Unwelcome remarks about a person’s age, dress, appearance, race, marital status, sexual orientation or sexual identity
- Sending offensive text messages or unwanted emails or attachments
- Telling or circulating inappropriate jokes, gossip, slander, malicious rumours
- Undue pressure to participate in political/religious groups
- Making offensive, insulting abusive remarks or using offensive language
- Any abuse of power including persistent unwarranted criticism
- Verbal or physical threats, violence or aggressive behaviour
- Deliberate withholding of knowledge or information (without good reason)
- Deliberate sabotaging of, or impeding, work performance
- Setting unrealistic targets or impossible deadlines or constantly undervaluing efforts (without good reason)
- Ridicule of the recipient’s work, ideas, opinions, appearance or behaviour
- Deliberate isolation or ‘cold-shouldering’ of individuals
- Non-cooperation to make someone feel uncomfortable
Discrimination on the grounds of age, disability, gender, marital status, pregnancy/maternity, race, religious or other beliefs or sexual orientation is not acceptable. Violations of this policy will result in disciplinary action including termination of employment where appropriate. Colt has an effective grievance procedure in all countries we operate in, to ensure the principles are adhered to by everyone. Incidents of harassment or discrimination should be reported to your local Human Resources Manager.
Rights at work
Colt is committed to upholding the fundamental human rights set out in the eight conventions published in 1998 by the International Labour Organisation and requires all employees to ensure, through their conduct and responsibilities that the Company complies with all of the ILO’s Fundamental Principles.
These conventions cover the areas of:
- freedom of association and the effective recognition of the right to collective bargaining
- the elimination of all forms of forced or compulsory labour
- the effective abolition of child labour
- the elimination of discrimination in respect of employment and occupation
Further, Colt is committed to ensure that it and its suppliers adhere to the following:
- Providing a safe working environment for staff and subcontractors.
- Validate that all employees and the employees of subcontractors have the legal right to work in the country where services are performed.
- Commit to 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.
- Provide a confidential and secure mechanism for employees to raise grievance.
Colt is committed to ensure that both its own operations and those of its suppliers prohibit the use of slaves, of forced or bonded labour and of child labour. In particular, suppliers should ensure that slavery and human trafficking are not taking place in any part of their business or their supply chain, and if required to do so under the Modern Slavery Act, should provide a statement in that respect.
Creating a safe working environment
You are obliged to carry out your work in a safe manner, not to cause harm either to yourself or to others, and you can report any potentially unsafe or unhealthy situations to the Health & Safety team using the Health and Safety Portal incident reporting system on the Intranet. You must observe all health and safety and environmental regulations. These vary from country to country, you must familiarise yourself with local rules and follow them.
15. Suppliers
Colt’s aim is to build long-term relationships with our suppliers and Colt has clear, specific criteria to select its Suppliers on an inclusive non-discriminatory basis and with objective criteria.
We integrate sustainability criteria in the selection process (through our Vendor Risk Management system and our RFP Scoring), onboarding and ongoing management of our suppliers Our Supplier Code of Business Conduct and our Sustainable Procurement Policy set out the standards of corporate governance and sustainability efforts that we expect from our suppliers. Further information on sustainability can be found in Colt’s Sustainability report.
16. People acting on behalf of Colt
From time to time, employees retain third parties to act on behalf of Colt.
Such third parties include agents, sales representatives and consultants. Any employee involved with the retention of a third party has a responsibility to satisfy himself or herself that appropriate safeguards have been established to ensure that the third party will comply with this Code of Business Conduct, and all relevant laws. Please consider initiating background and credit checks where appropriate and seek advice from both the procurement and legal team. All contracts with third parties must be reviewed and approved in advance by the relevant Colt legal advisor and procurement team.
17. Political payments
No Colt business unit, entity or employee shall pay any Colt funds or provide any Colt facilities or services to any political party, or to any political office holder or candidate, or to any initiative or referendum campaign, except with the prior written approval of the Board of Directors of Colt Group Holdings Limited.
18. Reporting prohibited conduct
You must not act in any manner that will violate any Company policy, and you may not ask any other employee or person acting on behalf of Colt to commit a violation.
In addition, if you have information or knowledge of any conduct or transaction prohibited by this Code of Business Conduct, you must promptly report such matter to your manager and to the Ethics Committee or DCS Governance Committee and/or to the Colt Business Ethics Line: how to report.
A failure to report a known violation may subject you to disciplinary action. All reports must be truthful, accurate and made in good faith. Colt encourage employees to bring any concerns in regard to suspected or actual breaches of the Code of Business Conduct to the Ethics Committee or DCS Governance Committee, or to be discussed with line managers, at the earliest opportunity, even if you doubt the nature of the issue: how to report.
No person reporting a suspected violation will be subject to retaliation because of a good faith report. All reports will be maintained in complete confidence to the extent possible. Identity of the reporter and third parties involved in a report made, is kept highly confidential by the Ethics Committee, DCS Governance Committee and relevant investigators, on a need-to-know basis with a limited group of individuals. The only exception to strict confidentiality is where disclosure is necessary and proportionate for court proceedings or investigation by regulatory authorities.
19. Discipline
Violations of the policies described in this Code of Business Conduct or of any other applicable policy of Colt, may result in disciplinary action.
Depending on the circumstances, including the nature and severity of the violation, disciplinary action may include termination of employment.
20. Enforcement & compliance
All employees are required to confirm that they have read and will comply with this Code of Business Conduct.
The Code of Business Conduct is subject to and does not replace local legislation or regulation. It is your responsibility to be aware of and understand the provisions of the Code of Conduct.
The Human Resources executive responsible for providing your joining documentation should provide you with this Code of Business Conduct for signature as part of the on-boarding process. You are required to acknowledge that you have read, understand and are in compliance with the Code of Conduct and that you agree that, as a condition of your employment, you will abide by the Code. Failure to acknowledge the Code of Conduct will not affect the applicability of the Code or any of its provisions to you.
If in doubt about the interpretation of this Code of Business Conduct or its applicability, please contact the Ethics Committee or DCS Governance Committee: how to report. This includes any actual or suspected violation of this Code of Business Conduct and any questions or exceptions of this Code of Business Conduct.
The Ethics Committee and DCS Governance Committee is responsible for supervising and administering this Code and any whistle-blower reports made for actual or suspected breaches of the Code. When necessary, the Ethics Committee and DCS Governance Committee acts in consultation with other members of senior management and reports quarterly to the Audit Committee of the Board of Colt Group Holdings Limited.
The Chair of the Ethics Committee or DCS Governance Committee shall notify the Chair of the Audit Committee and the Chair of the Board of the following alleged breaches of the Code of Conduct as soon as possible:
- Incidents that pose reputational, legal, compliance, regulatory risks to Colt.
- Incidents that may amount to gross misconduct permitting summary dismissal such as theft or violence.
- Any matters that may have a material impact on the financial statements.
- Any criminal activities.
- Any allegations against a member of the senior management team.
- Any similar serious allegation or incident.
Members of the Ethics Committee or DCS Governance Committee can be contacted by e-mail or in writing. In person local meetings can also be requested by reporters to raise a breach of the Code. All employees and people acting for Colt are encouraged to contact the Ethics Committee or DCS Governance Committee when they believe it necessary to do so. The Colt Business Ethics Line has been established as an alternative confidential reporting facility available to all employees and external parties.
21. How to report
Contacting the ethics committee
The Ethics committee can be contacted:
- By emailing [email protected]
- By writing to The Ethics Committee, c/o The Chief Legal Officer, Colt, Colt Technology Services, Colt House, 20 Great Eastern Street, London, EC2A 3EH
Contacting the DCS governance committee
The DCS Governance Committee can be contacted:
- By e-mailing: [email protected]
- By writing to: DCS Governance Committee, c/o The General Counsel, DCS, Colt Data Centre Services, 20 Great Eastern Street, London, EC2A 3EH
If your matter relates to Colt Technology Services (Colt Core) or Lumen EMEA (Colt Neo) please contact the Ethics Committee. If you matter relates to the Data Centre Services Business, please contact the DCS Governance Committee.
If in doubt on which Committee to contact, please contact the Ethics Committee.
Contact to either Committee or the Colt Business Ethics Line can be made by current and former staff, suppliers, contractors, interns, officers and people who facilitate or are connected to the reporter.
Gifts and hospitality pre-approval form
Employees are required to submit the Gift and Hospitality Form under the IT Service Now Portal when seeking prior approval from the Committee members, before giving or receiving gifts or hospitality in line with the Code of Conduct (or declaring at the time of receiving the gift or hospitality). Approval must be sought before a hospitality event. If your gift or hospitality involves both Core and DCS employees, approval must be obtained by both the Ethics Committee and DCS Governance Committee.
Contacting the Colt business ethics line
The Business Ethics Line is a confidential facility for you to raise any concerns you have regarding any breaches of the Code. The Business Ethics Line is provided by Safecall (which is independent of Colt). The line is free and available 24 hours a day 7 days a week for Colt staff1 and external parties to raise any concerns confidentially.
Reports must be truthful, accurate and made in good faith. In most Colt countries you can make anonymous reports if you wish. In some countries anonymous reports are not permitted so you will be asked for your name by the Business Ethics Line – although such details will be kept highly confidential.
You can raise a report online at www.safecall.co.uk/report/ or by telephoning the following freephone numbers:
| Austria | 00 800 7233 2255 |
| Belgium | 00 800 7233 2255 |
| China | 10800 7440605 (Unicom/Netcom) |
| 10800 4400682 (Telecom) | |
| China (Dalian) | 4008 833 405* |
| Denmark | 00 800 72332255 |
| France | 00 800 72332255 |
| Germany | 00 800 72332255 |
| Greece | 00 800 4414 1966 |
| Hong Kong | 3077 5524 |
| India | 000 800 4401256 |
| Ireland | 1800 812740 |
| Italy | 00 800 72332255 |
| Japan | 0120 921067 |
| Luxembourg | 800 28502 |
| Netherlands | 00 800 72332255 |
| Poland | 00 800 72332255 |
| Portugal | 00 800 72332255 |
| Romania | 0372 741 942 |
| Singapore | 800 448 1773 |
| South Korea | 001 800 7233 2255 (Korea Telecom) |
| 002 800 7233 2255 (DACOM) | |
| Spain | 00 800 72332255 |
| Turkey | 00 800 4488 20729 |
| UK | 0800 9151571 |
| USA | 1 866 901 3295 |
*You will be charged the local rate to make a call.
This Code of Business Conduct document is owned by the Chair of the Ethics Committee.
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