Colt Supplier Code of Conduct
The way we do business
Introduction
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. Suppliers 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 Colt's reputation and relationships.
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, regulations and sanctions. Accordingly, the following areas of compliance shall not be deemed to be an exclusive list.
1. Anti-Bribery: Prohibition of kickbacks, bribes and payoffs
Suppliers 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.
Suppliers must not offer or accept, either directly or indirectly, kickbacks, bribes or payoffs in cash or anything of value to secure an improper advantage or benefit; such as win orders, gain insider information or influence tender specifications.
“Anything of value” can be any object, favour, service, cash or cash equivalent, entertainment, gift, property, or anything else, including a charitable donation, sponsoring an event, a political contribution, and employment or an internship, whether paid for personally or by the company. It does not matter that a prohibited payment may be demanded by a public official, the prohibited payment still may not be made.
Here are some examples (but not an exhaustive list) of bribery risk scenarios that a Colt supplier could possibly encounter:
- a request for contribution to a political party of a government official or to the favourite charity of that official or a business partner, even though no payment was made to the government official or business partner,
- an offer of employment or an internship to a relative of a government official or business partner – this could appear to be a bribe,
- an invite to an all-expenses paid ski trip or major sporting event, or
entertainment during contract negotiations, even if the cost involved is within budget.
Note: The definition of a government official refers to any individual that is an elected or appointed government official, employed by a government agency or entity, or employed by a company that is owned or controlled by the government (e.g. public university, telecommunications company, or any other state-owned entity).
Any incident of such a claim being made to a Supplier with regard to the business they are doing, or hoping to do with Colt, must be reported. For the avoidance of doubt: any request for payment or for pre-payments, from any Colt employee or any individual claiming to act on behalf of Colt, should be immediately reported as mentioned below, to the Colt contact or the Ethics Committee. Failure to report a prohibited payment is itself a violation of this Code of Business Conduct and may result in disciplinary procedures being implemented.
Facilitation payments, which are small payments made to speed up the performance and not the outcome, of a function or activity to which the payer is legally entitled (e.g. releasing goods held in customs, issuing permits or obtaining phone service or some other necessary service from the government or a government-owned or controlled entity), are strictly prohibited.
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 Ethics Committee via details as seen below.
2. Record accuracy & 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. Destruction must be performed with adequate attention to the confidentiality of the information concerned.
3. Data protection
The Supplier shall ensure compliance with laws and directives providing for the protection, transfer, access and storage of personal information.
4. 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 any 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.
5. Government, media & investor relations
The Supplier shall not make any statement or submission to investors, the media or government referring to Colt without 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.
6. Fair competition
Colt believes in fair competition and supports the development of appropriate competition laws. The Supplier shall not engage in collaboration or other activity that reduces competition.
7. Insider trading
The Supplier shall ensure that any unpublished, inside information to which it is party, 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).
8. Gifts & 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.
9. Security, health & 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.
10. 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 its supply chain as a key area through which to secure sustainability and requires its suppliers to take these issues seriously by abiding by relevant international, European or national standards or commitments and being able to provide evidence of its compliance with such standards, if requested.
11. Conflict minerals
Colt is committed to the responsible sourcing of minerals, that has to be done in an ethical and sustainable manner, respectful of the environment and human rights.
Colt expects its supplier to have in place due diligence measures and policies enabling to assure that our services are delivered through products containing no conflict mineral components. We expect our suppliers & their upstream suppliers to only source material which do not originate from conflict regions.
12. 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, sexual identity oror sexual orientation. Issues of disability should only be considered against the particular requirements of the job.
13. Environmental practice
Colt is reducing its environmental impact, including setting Science Based Targets for drastic emissions reduction across all 3 Scopes (see our committments).
A key part of our strategy is working with suppliers who share the same commitment towards environmental protection. With this in mind, suppliers must ensure compliance with mandatory local and international environmental standards and legislation.
Additionally, Colt expects suppliers to have or support:
- A clear environmental policy and targets are available.
- Emissions reduction goals, ideally aligned with the Science Based Targets Initiative (SBTi) and their Net Zero Standard, should form part of a supplier’s environmental targets.
- Environmental data, such as sustainable resources usage, waste and emissions of the supplier and/or services provided to Colt are available.
Colt is committed to knowledge sharing and working with suppliers in the environmental sustainability area.
14. How to report
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 contact.
Alternatively, the Supplier may report it directly to the Colt Ethics Committee, which assesses matters of legal and regulatory compliance and proper business conduct. The Ethics Committee can be contacted:
- By emailing [email protected]
- By writing to The Ethics Committee, c/o The Company Secretary, Colt Technology Services Group Limited, Colt House, 20 Great Eastern Street, London, EC2A 3EH, United Kingdom.
