GC of Colt on Navigating the Sanction Regimes, Supporting the People of Ukraine

Marion Steward

Caroline Griffin Pain, general counsel and company secretary of Colt, a multinational telecommunications company headquartered in London, spoke to Corporate Counsel Advance about how her organization has navigated the sanction regimes and how the legal department can help the business pivot as and when sanctions develop. She also discussed the pro bono initiatives that they have launched including supporting their customers with communications to Ukraine by extending their free of charge calls to fixed lines and mobiles until the end of April.

Corporate Counsel Advance: Has your organization been impacted by the sanctions on Russia? 

Caroline Griffin Pain: We have very few Russian customers and no assets in Russia but a handful of customers have been the subject of sanctions or have had operating licenses withdrawn.

CCA: How are you navigating the sanction regimes and how can the legal department help the business pivot and change as and when sanctions develop? 

Caroline Griffin Pain: We immediately formed a Sanctions Committee chaired by the General Counsel comprising members of the senior management team and advised by key members of the legal and regulatory teams. We agreed a process and governance and then convened on an ad hoc basis to consider individual cases. We have been ably advised by Baker McKenzie.

CCA: What are your top tips on leading a team during a difficult situation?

Caroline Griffin Pain: Identify the issues and objectives up front, clarify roles and responsibilities, over communicate, invite colleagues to share concerns and ideas and listen with care. Always remember change and difficult times are stressful and priorities your team’s welfare.

CCA: How has your organization or the in-house team supported the people of Ukraine? 

Caroline Griffin Pain: We have many fundraising activities in progress including auctions, donations etc. in every Colt country and Colt will match the money raised for the Disasters Emergency Committee, proceeds will help refugees from the Ukraine and beyond. Some of my wonderful colleagues in the GC team in Germany and Romania are providing accommodation to refugees. We will continue to consider how best we can support.

CCA: Are you part of any pro bono initiatives. If so which initiative has been the most successful and why? 

Caroline Griffin Pain: As a telco we are continuing to support our customers with communications to Ukraine by extending our free of charge calls to fixed lines and mobiles until the end of April. This applies to our SIP Trunking, Colt Intelligent Communications, Voice Line and Voice Line(v) services. We understand the importance of staying in touch during these difficult times.


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