Modern Slavery Act Statement

As a company, we have a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all of our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

AND Digital is a company incorporated, based and operating in the UK. We are a service provider of digital services in the IT sector with an annual turnover of in excess of £36 million for the financial year 2020. Our business portfolio is focused on creating partnerships with clients to accelerate their digital capabilities – from technology expertise to upskilling of people. 

Our business is organised as a series of Clubs (Lines of Business), with other client-facing and enabling Lines of Businesses. For the year 2020, this consists of 9 Clubs (grouped into 3 Hubs across the UK), AND Consulting, AND Cloud Engineering; alongside the Link, the 6 BHAG Growth Teams, and the Company functions team.

Our supply chains are limited in number; but include useable goods, property and professional services.

In the preparation of this statement, we have considered the AND Digital supply chain and 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. 

Nevertheless, in any case that we do become aware of any such instances, the Board of Directors takes overall responsibility for dealing with any modern slavery issue, and ensuring that we address and resolve the situation efficiently.

AND Digital is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy reflects our commitment to this and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our business or supply chains. 

Our Anti-Slavery and Human Trafficking Policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. It clearly outlines all obligations and expectations in complying with the Policy, training and communication of the Policy, and implications of any breach of the Policy.

All employees of AND Digital 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. They are required to avoid any activity that might lead to, or suggest, a breach of this policy; and raise any concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage. 

Our zero-tolerance approach to modern slavery in our business and supply chains, as outlined in our Anti-Slavery and Human Trafficking Policy, is also communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Alongside our Anti-Slavery and Human Trafficking Policy, we also have policies and procedures in place relating to grievances, disciplinary issues and whistleblowing. They allow and encourage any person working for us or on our behalf to come forward on any matter relating to modern slavery or human trafficking, without fear of retaliation; and allow AND Digital to take any necessary corrective action appropriately.

AND Digital has not identified any salient modern slavery risks in any of our business or supply chains.

However, as part of our initiative to identify and mitigate risk, we have in place systems to:

• Identify and assess potential risk areas in our supply chains;

• Mitigate the risk of slavery and human trafficking occurring in our supply chains;

• Monitor potential risk areas in our supply chains;

• Protect whistle-blowers.

These systems are monitored and reviewed on an appropriate basis.

As made clear from the above mentioned policies and procedures, AND Digital is committed to not tolerating any instances of modern slavery or human trafficking within any part of our business or supply chains. We are committed to ensuring there is transparency in our own business operations and in our approach to tackling modern slavery throughout our supply chains, and we expect the same high standards from all our contractors, suppliers and other business partners.

As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.  

We have zero-tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme. This consists of background checks and right to work in the UK.

We have a dedicated and appointed Social Ethics and Inclusion (SEI) Committee, who ensure that our policies are complied with; and can routinely monitor and measure the effectiveness of the policies and procedures we currently have in place.

The SEI Committee has primary and day-to-day responsibility for implementing our Anti-Slavery and Human Trafficking Policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. 

Alongside the measures already in place, to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to all employees.

Training on the Anti-Slavery and Human Trafficking Policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, together with an online course which all employees must complete and pass in order to test their knowledge on the Anti-Slavery and Human Trafficking Policy we have in place.

Management at all levels are responsible for ensuring all employees reporting to them understand and comply with the Policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Signed

Paramjit Uppal

Director, AND Digital

22nd September 2020