Modern Slavery Act Statement

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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.

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, as non-compliance is deemed more likely in certain industries and geographies, checks were also performed on Colt’s suppliers in industries and geographies, even though they represent a minimal percentage of Colt’s overall expenditure.

Monitoring, Compliance and Training

We aim to prevent modern slavery or human trafficking in our business right from the start of our on-boarding of new suppliers. As part of our new supplier on-boarding, for instance, we require an anti-slavery questionnaire to be completed.

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. Our recruitment policy aligns with our Code of Business Conduct, and once people join our organisation they are expected to adhere to our Code of Business Conduct. All employees and contractors undertake Code of Business Conduct e-training once per year. All employees, suppliers and subcontractors are provided with the details of an independent whistleblowing hotline to whom they can make disclosures anonymously.

Evaluating our progress

Our Code of Business Conduct and related e-learning module have been updated to reflect our commitment to the prevention of modern slavery and human trafficking. We will annually 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, 2016, and has been approved by the Board of Colt Group S.A.

Caroline Griffin Pain
Company Secretary