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 2021, the Company has engaged with its key stakeholder groups, both formally and informally.

In 2021, the Core Board made one Principal Decisions (as set out in Corporate Governance Statement, Wates, Principle 2), and the DCS Board made five Principal Decisions: four in relation to European land banking opportunities, and one for major capex for a specific customer.

The key stakeholder groups for the Company have not changed in 2021.  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.


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.


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.


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.

The key stakeholder engagement and outcomes for 2021 are set out below:

Key Stakeholder - 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.

The Covid-19 Gold Team consisting of Core and DCS senior management in both Europe and APAC continued to meet at regular intervals in 2021. The main focus during 2021 has been on the workforce: new ways of working, office reopening and increased support for colleagues particularly those in India.

Key Stakeholder - Customers

Customer engagement was both formally and informally conducted during 2021.

Continued NPS excellence in 2021

Through 2021 we achieved record levels of NPS across Europe and Asia customers. This is testament to the strong and healthy customer relationships that we foster with our customers. Through in-depth interviews conducted with customers in the slipstream of the NPS study, customers specifically praised the following aspects of Colt’s business relationship with them.

  • Sales Relationship – Professional and responsive dealings with the customer.
  • Service Delivery Relationship – Improved proactive communication and technical knowledge of colleagues.
  • Network Operations Relationship -Quality of communication and honest/transparent approach in dealing with customers.
  • CRM Relationship – Exceptional personalized services provided by dedicated managers.

Embedding of Net Easy Score (NES) programme in 2021

At the end of 2021 we introduced a new transactional measure for our customer experience: the NES - focused on monitoring and improving ‘ease of doing business’ with Colt. Every month between 500 and 700 customers provide feedback on our transactional performance. In 2021, the NES programme was deeply embedded across all the customer facing areas of the business via a range of activities:

  • Use of machine learning and AI to provide rich insight based on customer feedback
  • Introduction of dynamic NES targets – where business areas were driven to improve performance quarter on quarter;
  • Cross functional monthly NES action planning group - sharing best practice and ensuring specific plans are in place for improvement; and
  • Quarterly function by function deep dive of NES data

Analysis of the latest NES data (January 2022) – shows that all business areas have either matched or outperformed NES scores for the previous quarter.

100 Voices Programme

In addition to our customer exit interview process (offering any customer ceasing service with us the opportunity to share improvement areas), our 100 Voices programme greatly improved over the course of 2021. Customer interviews became a regular part of our customer engagement strategy. Through 2021, we have undertaken detailed interviews with more than 150 customers, exceeding the initial engagement ambitions of the programme. The feedback from this is exercise is being collected and analysed for consumption by business leaders by the end of Q1 2022.

Other engagement areas

Our red flag process is ongoing and driving significant improvements not only for specific red flag customers but also for other customers, as we identify and resolve thematic issues Colt-wide. We also continue with our Customer Advisory Board, which brings customers together regularly to input into elements of our strategy and product development.

Key Stakeholder - Suppliers

During 2021, Colt’s main focus with its suppliers and supply chain has been on sustainability. An internal Sustainable Procurement Policy was launched, and Colt’s Procurement Team engaged with ca. 250 suppliers (reflecting the majority of Colt’s scope 3 emissions) to understand their sustainability journey and current status. Sustainability questions and questionnaires have been fully embedded into RFPs and supplier onboarding. There has also been increased focus on inclusion and diversity (I&D) in our supply chain during 2021, and an I&D programme for suppliers has been launched.

In 2020, there were a small number of instances, where Colt renegotiated pricing or commercial terms with suppliers, in order to ensure their ongoing service provision to Colt. Colt did not receive any such requests during 2021. Colt has kept its suppliers under review in 2021: a D&B review of Colt’s suppliers showed the proportion of high/medium/low risk suppliers was consistent with pre-2020 standards.

The vendor relationship management team created in 2020 continued their regular reviews with Colt’s critical suppliers to ensure an efficient and effective working relationship with them, business continuity and best-in-class customer experience.

Key Stakeholder - Employees

Colt’s leadership’s clear 2020 message has continued throughout 2021: 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 disposal of data centres impacted employees: the Company adhered to the information and consultation processes pursuant to national employee engagement rules and protocols, and additionally, kept the European Works Council informed throughout the project in a transparent and proactive manner, even though this ongoing communication was not mandated by law. 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.

The Covid-19 support set up in 2020 continued in 2021: The Special Assistance Fund, Safe Workplace Allowance and Special Sick Leave Allowance. For colleagues in India, Colt worked with International SOS for doctor consultations, PCR testing, home ICU care, hotel quarantining, hospital beds, oxygen, plasma, medication and vaccinations – Colt provided financial support for all these services, although the availability of most services could not be guaranteed due to the circumstances in India. Additionally, Colt worked with Fidelity Investments to jointly use office spaces as vaccination centres in different parts of India.

Mental Health and Wellbeing has been a focus area: in addition to webinars and training, in most locations from late Q2 onwards, colleagues have been able to submit ad-hoc or ongoing wellbeing requests to work from a Colt office. Throughout 2021, there have been company-wide monthly no-meetings ‘clear your plate’ days, as well as three wellbeing days during 2021.

Management has continued to monitor revised ways of working and intends to launch a pilot hybrid working scheme for employees who wish to participate in 2022. The hybrid working pilot’s launch is subject to final agreement with the European and National Works Councils.