This statement is made pursuant to Modern Slavery Act 2015 (“MSA 2015”), S 54(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”) 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
operations in the UK, and from June 2021 in the Netherlands. In order to accelerate our client’s 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, 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 is deemed to be higher risk by country of origin and/or lack of suitable policy/processes,
an investigation will be raised and assessed by senior members of the organisation which can result
in the vendor 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.
Our zero tolerance position on violations to the UK’s anti-human trafficking and anti-modern slavery
laws has also 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 the AND Digital supply chain and to the best
of our knowledge, we are not aware of any instances where our business suppliers or partners are
acting in ways that could be construed as examples of 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
Our dedicated Social, Ethics and Inclusion (SEI) Committee exists to ensure AND Digital is operating by its values and business principles. The members, chaired by an independent chairperson and reporting to the main board, oversee compliance of the committee’s principles, and make recommendations to the Executive Team where appropriate.
The Committee reviews the Company’s Ethical Client Approach, Anti-Slavery, Human Trafficking and Whistleblowing polices annually as a minimum. It is vitally important to ensure our ANDis, clients and suppliers act with integrity and in line with the Committee’s 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 before engaging with any suppliers.
This is repeated on an annual basis.
6. Sign-off
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and applies to the
financial year ending 31st December 2022 and was approved by the board on 17th July 2023.
Signed
Paramjit Uppal
Director, AND Digital
17th July 2023