Alex Galtieri explains how his work as in-house counsel at an ISP is adapting to environmental concerns
Unlike lawyers working in industries which are easily identifiable as having large carbon emission, such as fossil fuel or automotive, Computers & Law readers may not have considered the carbon footprint of their organisation. This article seeks to encapsulate the experience of a telecommunications company in its journey to carbon neutrality, with particular focus on its supply chain.
The ICT sector has traditionally been seen as low-emission. This changed between ten and five years ago, when we all became aware of the increasing carbon footprint of the ever larger data centres, which now host the content and the applications that constitute so much of our daily lives. Since then, the awareness about the whole ICT sector’s emissions has grown, and some estimates put the total emissions at 4% of the global total.
As our appetite for data and connectivity seems not to have limits, it would be easy to become pessimists about our ability to change things. I am quite pleased to be able to offer one piece of good news, discovered while researching this article: the sector’s emissions are not growing as much as we thought, and in certain respects they have actually decreased. For instance our use of smartphones has eclipsed that of old-style desktop computers, and smartphones are much more power-efficient.
It is however undeniable that the tech sector has a quite large carbon footprint, and we should all make efforts to reduce it.
Colt is a B2B network operator in Europe and Asia, providing high-bandwidth connectivity services through its optic fibre network, the largest in Europe, with almost 30,000 buildings connected to it. Colt is present in 30 countries and employs around 5,000 people.
Colt’s starting point in its journey to carbon emission reduction and Net Zero was a wider focus on sustainability. The leadership took the deliberate decision to reduce our environmental impact globally and made sustainability a key strategic driver. Sustainability matters at all levels of the organisation, and carbon emission reduction targets are part of a much wider environmental sustainability strategy that encompasses many other aspects.
The next sections will summarise our experience with our Net Zero targets, as well as some other sustainability initiatives.
The real issue: Scope 3 and Colt’s targets
Greenhouse gas emissions are categorised into three groups or 'Scopes' by the most widely used international accounting tool, the Greenhouse Gas (GHG) Protocol. Examples are shown in Table 1.
Table 1 – Examples of emissions in Scope 1, 2, and 3
Scope 1 emissions are direct emissions from company-owned and controlled resources. In other words, emissions released into the atmosphere as a direct result of a set of activities, at a firm level. Example :
Scope 2 emissions are indirect emissions from the generation of purchased electricity, from a utility provider. In other words, all greenhouse gas (GHG) emissions released in the atmosphere, from the consumption of purchased electricity, steam, heat and cooling.
Scope 3 emissions are all indirect emissions, not included in Scope 2, that occur in the value chain of the reporting company, including both upstream and downstream emissions. In other words, emissions that are linked to the company’s operations.
It is therefore clear that Scope 3 emissions are usually the greatest share of the carbon footprint of any organisation, for instance covering emissions associated with business travel, procurement, waste and water.
It is for this reason that some organisations do not disclose their scope 3 emissions, or do not consider them in their targets. Colt decided instead that doing so would not really address the problem and opted for a comprehensive set of targets.
Colt worked together with the Science Based Targets initiative (SBTi, a collaboration between the CDP (Carbon Disclosure Project), the United Nations Global Compact, World Resources Institute (WRI) and the World Wide Fund for Nature (WWF)) to set a science-based climate target. Colt’s near-term Science Based Targets (SBTs) ensure that its emissions reduction activity will occur across all departments and our value chain, with these targets:
The role of green sustainable procurement
Given the importance of Scope 3 emissions, it is crucial to have a holistic approach to carbon neutrality, that needs to engage the whole supply chain.
|Extracts from Colt’s Sustainable Procurement Policy|
|The selection of the winning tender will be made based on a balanced assessment of the solutions and commercial propositions put forward. If a reasonable opportunity to improve the sustainability performance of the winning solution is identified during the tender evaluation process, appropriate measures should be agreed with the supplier and built into the contract / statement of work (SOW) so that they can be subsequently monitored for achievement.|
|Amongst the supplier selection and contract award criteria, certain aspects such as carbon emission reduction schemes are assessed. Providing the supplier’s commercial and technical proposal is competitive, the supplier which demonstrates the most suitable and effective carbon emission reduction scheme is then awarded the contract.|
|Contract Review and Monitoring|
|Sustainability performance and development must be a standing agenda item at any supplier performance review meetings (for example QBR – Quarterly Business Review).|
|All QBRs shall be a trigger to discuss a supplier’s position on their sustainability approach, United Nations Sustainable Development Goals (UN SDGs), Carbon Disclosure Project (CDP) Scoring and discuss potential improvement areas.|
What follows briefly outlines Colt’s activities related to Sustainable Procurement. We are all on a learning journey on how our organisations can reduce their impact on the environment and our carbon emissions, so this is only one possible approach. It is offered to the reader to stimulate further thoughts and encourage other organisations to develop their own policies and approaches.
In 2021, Colt issued a sustainable procurement policy. The policy states that Colt prefers to work with suppliers who share the same values as Colt. In order to do so, Colt undertook a number of actions:
Table 2 – Part of Colt’s supplier questionnaire, and suppliers’ answers
Colt procures significant amount of telecommunications equipment each year. Until a few years ago, there was little mention of the potential to recycle or reuse such equipment. There was also a technological “race”, which meant that a certain proportion of the IT would be substituted before it was obsolete, just because there was a newer version. Now we are working with equipment manufacturers to build equipment that runs not on proprietary firmware, but on open source software that can be remotely updated, extending the useful life of the kit. We also ensure that old equipment is re-used where possible, and if not, at least disposed in a way that allows for the materials (often very expensive, such as rare earth minerals) to be collected and recycled.
This is part of Colt’s Zero Waste to Landfill policy, which is a concerted effort to ensure all our waste is prevented where possible, reused or recycled. This includes waste from our network equipment, IT equipment, office equipment and our supply chain. The impact of trivial things does really add up, and it is only by looking at everything through a sustainability lens that it is possible to make small but tangible advances. For instance, readers may not consider the packaging that their new laptop comes in. If your organisation is “refreshing” laptops regularly, and you have several thousand employees…that ends up being a lot of cardboard.
Colt’s laptop replacement program removes outdated assets from the business but also extends the life of them by sending to local schools – with positive broader impact in Corporate Social Responsibility and digital inclusion. The new devices contain 65% post-consumer recycled material as well as being more energy efficient, and are delivered in boxes made from 75% recycled fibres and bamboo – something that we may not have considered a few years ago, but that means extending the life of key materials and reducing the need for virgin resources, which ties into the circular economy model.
All these initiatives are mentioned here because the circular economy model, and the efforts to consume less or consume “smarter”, also has effects on carbon emissions: equipment manufacturing, as well as production of cardboard, are sources of carbon emissions. If some of these activities can be reduced, there is an undisputable benefit in terms of carbon emission. Another example of the advantages of a comprehensive, holistic approach.
Supply chain management
Each of Colt’s suppliers has a supplier profile page in Colt’s systems, which are used for any procurement decision. Increasingly, sustainability matters are an important part of it. A redacted example is in Table 3.
Table 3 – An example of a supplier’s dashboard, with key sustainability metrics
One thing to note is that Colt’s procurement policy scores suppliers across a number of categories, including some that may fall under the umbrella of ESG considerations, such as the presence of an antibribery and corruption policy or a whistleblowing procedure.
The effect of all these efforts is to provide Colt with a clear picture of its supply chain, including key information, such as the Ecovadis score, so that procurement’s sustainability efforts can be measured. Table 4 provides an example.
Table 4 – Colt’s supply chain and sustainability metrics
Whilst it is true that every organisation is different, I hope that what I have briefly shown in this article can provide some food for thought and an encouragement for readers to consider what their organisation could do more, or differently, to contribute to our collective Net Zero target – saving the planet.
Alessandro Galtieri is Deputy General Counsel and Group Data Protection Officer at Colt, a network and data centre services company active in more than 30 countries globally. Since 2012, he serves on the Law Society Technology and Law Committee, which provides guidance on the impact of new technologies on the legal profession.