This statement is made pursuant to Modern Slavery Act 2015 (“MSA 2015”), S 54(1), Part 6. Modern slavery is
a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced
and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty
by another in order to exploit them for personal or commercial gain.


ANDigital Limited (“AND Digital”, “we”, “us” or “our”) is committed to preventing acts of modern slavery and
human trafficking from occurring within its business and supply chain, and imposes the same high standards
on its suppliers.

We believe our people to be our greatest asset. Our principle - to always put the wellbeing of

our people first - also applies to the way we engage with our suppliers and clients.

1. Structure of the organisation

AND Digital is the parent company of the group and employs over 1,600 people. We have business operations
in the United Kingdom, the Netherlands and since June 2023 the United States of America. In order to
accelerate our clients' digital capabilities by developing their technological expertise and upskilling their
people, we work with a range of suppliers including usable goods, property and professional services.

2. Policies

As part of our commitment to combating modern slavery, we have continued to keep our Anti-Slavery and
Human Trafficking Policy under review and anti-trafficking training remains an onboarding requirement for all
AND Digital employees (“ANDis”). Our ANDis must ensure that they have read, understood and comply with
this policy at all times. The prevention, detection and reporting of modern slavery in any part of our business or
supply chains is the responsibility of all those working for us or under our control.

Alongside our Anti-Slavery and Human Trafficking Policy, we also have policies relating to grievances,
disciplinary issues and whistleblowing to encourage all people working for us or on our behalf to come forward
with any concerns without fear of retaliation and to allow AND Digital to take any necessary corrective action
as appropriate.

Our policies are clearly defined and communicated to ANDis. All our ANDis are treated fairly and equally and
are paid above the national minimum wage. Our ANDis will not be required to work in excess of the number of
hours permitted in law, and normal working hours will not exceed 48 hours per week average unless the
employee agrees in writing.

Our values alongside our culture make clear to our ANDis the actions and behaviours expected of them, and
we strive to maintain the highest standards of conduct and behaviour across our business.

3. Due diligence, Risk and Compliance

Our due diligence procedures are designed to reduce the risk of slavery and human trafficking occurring
within our supply chains. AND Digital buyers are responsible for evaluating the modern slavery and human
trafficking risks of each new supplier and carrying out appropriate checks / investigations as part of the
procurement process.

We have introduced a supplier questionnaire to help us to assess suppliers’ policies and practices on modern
slavery. This information is designed to assist us in working with suppliers to identify and assess possible
modern slavery risks in our supply chains across our business. Through effective use, the questionnaire
assists us in learning more about our suppliers’ operations and their strengths and weaknesses when it comes
to addressing modern slavery risks.

We continue to evaluate our due diligence checks on an ongoing basis to ensure that they are robust enough
to identify any issues. We also impose contractual obligations on suppliers to ensure that our supply chain and
contractors are compliant with the legislation.

If a supplier or a client is deemed to be higher risk by country of origin and/or lack of suitable policy/processes,
an investigation will be raised and the supplier or client assessed by senior members of AND Digital which can
result in the supplier or client being inactivated. We are glad to report that we have had no findings of
inappropriate suppliers due to modern slavery and human trafficking concerns and we have processes in
place to invoke sanctions should any issues ever arise in the future.

We do not tolerate violations to the UK’s anti-human trafficking and anti-modern slavery laws. This has led us
to introduce standard non-negotiable clauses into our terms of business and to ensure they are included in all
other contracts we sign. It is often the case that we have the right to terminate the agreement for any failure to
comply, however in the first instance we would work together with the client/provider to support and guide
them in tackling the issue.

In the preparation of this statement, we have considered AND Digital’s supply chain and to the best of our
knowledge, we are not aware of any instances where our clients, business suppliers, or partners are acting in
ways that could be construed as modern slavery. We keep our processes under review so that, where
applicable, they are adapted and enhanced to meet our obligations under the legislation.

4. Effectiveness and KPIs

We have teams across AND Digital to ensure our compliance with law, policies and procedures. As part of our
commitment to continuous improvement, those teams review our Ethical Client, Anti-Slavery, Human
Trafficking and Whistleblowing policies annually as a minimum. It is vitally important to ensure our ANDis,
clients and suppliers act with integrity and in line with ethical business principles.

We have not identified any high-risk modern slavery concerns in this financial year.

5. Training

We invest in educating our ANDis to recognise the risks of modern slavery and human trafficking in our
business and supply chains. Through our training, ANDis are encouraged to identify and report any potential
breaches or concerns relating to our anti-slavery and human trafficking policy and procedures. ANDis are
taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences
of failing to eradicate slavery and human trafficking from our business and supply chains. Our ANDis must
complete an online course and pass it in order to test their knowledge on the Anti-Slavery and Human
Trafficking Policy. This is repeated on an annual basis.

6. Sign-off

This statement applies to the financial year ending 31st December 2023 and was approved by the board of
directors on 13th February 2024.


PU Signature

Paramjit Uppal

Director, AND Digital