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
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, Human Rights and Labour Standards Policy (the “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 the 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 the 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.
A supplier questionnaire helps 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
AND Digital maintains a robust governance structure to ensure comprehensive compliance with all applicable laws, regulations, policies and procedures. Our Risk & Audit Committee oversees this framework, with the Board holding ultimate approval authority for all core high-level policies. These critical policies include, but are not limited to, those addressing modern slavery, whistleblowing, our Code of Conduct and ethics and anti-bribery and corruption. Furthermore, our commitment to continuous improvement extends beyond policy documentation. Dedicated teams across AND Digital actively promote and monitor compliance through mandatory training programs, rigorous internal controls and established reporting mechanisms within key operational areas. 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 the 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 Policy. This is repeated on an annual basis.
6. Sign-off
This statement applies to the financial year ending 31st December 2024 and was approved by the board of
directors on 11th July 2025.
Signed
Paramjit Uppal
Director, AND Digital