Section 172 statement

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Unless otherwise stated, defined terms have the meaning assigned to them in the Corporate Governance Statement. References to “Wates, Principle…” are references to the relevant sections of the Corporate Governance Statement.

The Board has had regard to the factors set out in section 172(1)(a)-(f) of the Companies Act 2006 (‘s172’). In 2020, the Company has engaged with its key stakeholder groups, both formally and informally, and has also taken steps to effect changes resulting from 2019 and 2020 stakeholder engagement.

In 2020, the Core Board did not make any Principal Decisions (as set out in Corporate Governance Statement, Wates, Principle 2), as it focused on the ongoing progress of various projects. In 2020, the DCS Board made three Principal Decisions all of which were for significant capex required for strategic expansions.

The key stakeholder groups for the Company have not changed in 2020. Their significance to the Company is set out below:

  • Core and/or DCS area of the business. The Core and DCS parts of the business offer materially different services to customers, have a slightly different supplier base; and are organised differently to reflect both the different types of services and that DCS has a significantly smaller workforce. Accordingly, the impact to each of Core and DCS can be quite different, and the impact to each part of Colt should be carefully considered.
  • Customers. The Company’s vision is focused on customers and being the most customer-oriented business in the industry. As such, the potential impact to customers is a key consideration for Colt to achieve its vision.
  • Suppliers. Successful relationships with suppliers is critical for the day-to-day running of Colt’s business, and supporting Colt’s service provision to its customers. The nature of services for both Core and DCS is closely connected with its supplier relationships.
  • Employees. The engagement and two-way dialogue with the entire workforce (employees or otherwise) is very important for the Company’s purpose and vision to be achieved.
  • Community and Environment. Both the Company’s existing Core and DCS operations, and its network and data centre expansions to new locations can have a significant impact on the environment and community. The Company is committed to reducing its carbon emissions, being powered by green energy, reducing its landfill and improving its impact on the environment and community.
Area of business: Core or DCS Regular ELT and DCS SMT meetings have been held during the year, to consider the requirements and progress of each ELT or DCS SMT member’s function, both as a whole and against specific projects. The outcomes from ELT and DCS SMT meetings have been shared with their respective functions and, where required, across Colt. The Core and DCS Boards receive regular updates from the ELT and DCS SMT respectively, including the identification of new opportunities and emerging risks. The Core and DCS Boards also provide each other with minutes of their respective meetings. In Q1 2020, a Covid-19 Gold Team consisting of senior management, from both Europe and APAC, and from both Core and DCS was formed. The frequency of Gold meetings has been adjusted during the year; between March and June, meetings were held at least twice per week, with the frequency tapering from July onwards. Members of the Covid-19 Gold Team have represented their functions’ interests during Gold meetings, and have also communicated outcomes from the Gold Team meetings to their functions. For example, during Q1 and Q2, across Europe, engineering colleagues were faced with different statutory requirements about travelling in-country and across borders during the lockdown. Gold members from Core and DCS Operations, HR and Legal worked together to address Colt’s approach across the countries, ensuring that employee safety was not compromised and that Colt’s operations continued; and impacted colleagues in all locations had the information and support required.
Customer Customer engagement was both formally and informally conducted during 2020. In late February/early March, Colt categorised all customers into priority levels, based on their criticality to the national Covid-19 response. These priority levels were then applied to service delivery, as countries declared a national lockdown and Colt put in place certain restrictions to protect its workforce and comply with local law (e.g. emergency works only, no new service delivery). Colt’s customer-facing colleagues were provided with clear and transparent information about the changes and priority levels, and so were able to proactively advise customers of these changes, and work together with customers to ensure service delivery continued. Colt received extremely favourable feedback from customers in all countries, manifesting in a record NPS score. In 2020, all customers with new orders or cease requests received a survey from Colt: Colt received ca. 50,000 survey responses and around 120 survey respondent customers were interviewed by a third party for a deep dive of their experience with Colt. The results from these customer interviews were reviewed and discussed by management, to identify any areas for improvement and/or change. At the end of Q4 2020, Colt launched its ‘100 Voices Programme’ – a summary of customer feedback and actions to be transparently shared with the business every time 100 customer interviews have been conducted. In 2020, Colt also introduced a new ‘red flag process’ for service-managed customers. Each of these customers is rated against a range of metrics including delivery times, number of tickets raised, incident resolution times etc. A fortnightly internal roundtable with the VPs of all customer-facing, operation and service delivery functions is held, to discuss concerns and actions for any identified ‘red flag’ customers, as well as how actions or fixes might be applied to other customers. This roundtable is one of several internal fora created to review and consider customer requirements, and Colt’s performance towards its customers. Other examples (for specific groups of customers) are the Customer Advisory Board and the Customer Experience Leadership Group.
Suppliers The focus in 2020 has been to continue nurturing strategic supplier relationships and ensure business continuity during the lockdown and ahead of potential border delays and changing import/export regulations, as a result of Brexit. The Procurement Team was part of the Covid-19 Gold Team: Colt’s suppliers were able to support ongoing service provision to Colt’s customers. The vast majority of Colt’s suppliers were considered critical services providers in their own right, there were only a few suppliers to whom Colt issued a reference letter. During 2020, Colt has been in regular communication with most critical suppliers, with regard to their business continuity management (BCM) plans – there have been a small number of instances, where Colt has renegotiated pricing with suppliers, in order to ensure their ongoing service provision to Colt BCM has always been an important factor for Colt’s supplier selection – in recent years, the focus has been on scenarios such as a data breach or terrorist events. This year, we have added a pandemic scenario to our BCM questions for suppliers. During 2020, a new ‘vendor relationship management team’ was created within the Procurement team, whose primary objective is to ensure an efficient and effective working relationship with all Colt’s suppliers, to ensure business continuity and best-in-class customer experience. Around 40 suppliers globally have been identified as P1 (criticality of services), and a full review of the relationship has been conducted through regular review meetings with each of these suppliers.
Employees Colt’s leadership’s clear message throughout 2020 was that prioritising the safety and wellbeing of its employees is the only way to ensure Colt’s success. This tone from the top has permeated through the organisation, and employee engagement (and support) has been widespread and consistent throughout the year. The European and National Works Councils have been consulted or notified of material matters at various points throughout the year. The Colt Ambassador and Country Management programmes have continued to provide a forum to engage with the workforce and help ensure a two-way dialogue. In addition, the Company made a series of changes at the end of Q1 and during Q2, as a result of all offices being moved to ‘mandatory work from home’ status and the national lockdowns. A Safe Workplace Allowance was granted to all employees, in order to make changes to their home workspace. The Company also reviewed sick leave entitlement across all jurisdictions – in order to address jurisdictional variances, Colt launched a Special Sick Leave Allowance, to ensure all employees worldwide receive their base salary for up to 90 days if they are unable to work due to contracting Covid-19. In addition, the Company made available a Special Assistance Fund, for employees requiring additional financial assistance e.g. as a result of a partner losing their employment. In certain countries, additional changes were made for local employees e.g. a broadband allowance for all employees in India, towards their internet access at home. Starting in March, Colt quickly planned and implemented a range of informal and formal listening activities – weekly global all-hands chaired by the CEO were held and employees were able to ask questions anonymously.
Environment and Comunity In 2020, an Environmental Sustainability Steering Committee (SteerCo) was set up, in order to agree Colt’s strategy, and recommend carbon emissions aims and targets for approval by the Board. The Company has also launched initiatives: ‘Greening our Vehicles’ and ‘Zero Waste to Landfill’, and made changes to its supplier questionnaires for RFPs. In 2020, Colt has undertaken a review of its energy contracts and by the end of the year, almost all Colt’s European offices are powered by renewable energy. In addition, the DCS senior management team receives reports about the environmental impact of new and existing sites, and considers the viability of making changes e.g. changing to green energy at non-European sites. In 2021, Colt will update its car fleet to a majority of electric vehicles and launch a series of green working from home initiatives. The SteerCo will make recommendations to the Board about a carbon emissions target; zero waste to landfill target; and a global environmental sustainability policy. Colt also regularly raises awareness on environmental and community issues by hosting CSR events – in 2020, Colt’s annual charity bike ride was changed to ‘Colt’s Charity Challenge’ – ‘travelling’ the distance of Colt’s network through any form of activity. The revised format had excellent engagement – a far wider range of participants. Consistent with previous years, Colt has matched the donations raised from the Charity Challenge. In addition, over the course of the year, Colt has run local fundraising initiatives, such as quiz nights and auctions, with funds donated to local charity partners.