# MODERN SLAVERY ACT STATEMENT

#### COLT GROUP MODERN SLAVERY ACT STATEMENT

This statement is made by Colt Group Holdings Limited 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 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 25,600 on-net buildings spanning over 200 cities in nearly 30 countries. In order to provide our services, we need to procure a range of goods and services to meet our customers’ 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, checks were also performed on Colt’s suppliers in those industries and geographies where non-compliance is deemed more likely, even though they represent a minimal percentage of Colt’s overall expenditure.

#### MONITORING, COMPLIANCE AND TRAINING

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. Accordingly, all employees undertake Code of Business Conduct e-training once per year.

All employees, suppliers and subcontractors are also provided with the details of an independent whistleblowing hotline to whom they can make disclosures anonymously.

#### EVALUATING OUR PROGRESS

We are committed to the prevention of modern slavery and human trafficking. We will continue to 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, 2023, and has been approved by the Board of Colt Group Holdings Limited.*

**Caroline Griffin Pain**\
Company Secretary


---

# Agent Instructions: Querying This Documentation

If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question.

Perform an HTTP GET request on the current page URL with the `ask` query parameter:

```
GET https://docs.colt.net/legal/modern-slavery-act-statement.md?ask=<question>
```

The question should be specific, self-contained, and written in natural language.
The response will contain a direct answer to the question and relevant excerpts and sources from the documentation.

Use this mechanism when the answer is not explicitly present in the current page, you need clarification or additional context, or you want to retrieve related documentation sections.
