NTT DATA UK Limited has a zero-tolerance approach to modern slavery and human trafficking, and all forms of corruption and bribery associated with these criminal acts. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and adequate controls aimed at preventing any form of modern slavery within our business and our supply chain.
NTT DATA UK Limited will ensure that we do not knowingly participate in any activity that involves any form of modern slavery or enter into business with any organisation which knowingly supports or is found to be involved in slavery, forced or compulsory labour, or human trafficking.
This statement highlights the key activities we have undertaken during this financial year to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
This Modern Slavery and Human Trafficking Statement is published in line with section 54(1) of the Modern Slavery Act 2015 and relates to the financial year ending 31st March 2024.
Signed and approved by NTT DATA UK’s Chief Financial Officer and Deputy CEO
Rajul Modi
25th July 2024
NTT DATA UK Limited is a trusted global innovator of IT and business services. It is part of the NTT Group, a leading, global technology services company headquartered in Tokyo.
With over 1,500 employees in UK and Ireland, NTT DATA UK Limited enables clients, as well as society, to move confidently into the digital future.
Our mission is to use information technology to create new paradigms and value that help contribute to the achievement of a more affluent and harmonious society. As we help clients to transform through consulting, industry solutions, business process services, IT modernisation and managed services, we always seek to ensure our work contributes to building a better world through responsible technology.
Our people are our most valued asset and NTT DATA UK is committed to cultivating an environment where every individual feels appreciated, encouraged, and empowered to thrive. Our dedication to upholding high ethical standards includes promoting transparency, accountability, and nurturing a culture of integrity.
Our Code of Ethics and Professional Conduct applies to all NTT DATA UK employees and guides our actions in conducting business, highlights our support and respect for human rights, including our commitment to ensure that modern slavery and human trafficking is not taking place in our supply chains or in any part of our business, and encourages reporting of any suspected breaches through the NTT DATA EMEAL Group Whistleblowing Reporting System.
NTT DATA UK Limited expects all our employees to act in accordance with the principles and values outlined in our Code of Ethics and Professional Conduct and other internal Policies and training resources. The company also expects the same high standards from all our suppliers, sub-contractors, and other business partners.
NTT DATA UK is committed to the principles of the Modern Slavery Act 2015 and there are several Policies that help us manage our modern slavery risk:
All the Policies are readily available to all NTT DATA UK employees on our Compliance Intranet page. We regularly review and update our Policies to ensure they remain compliant, consistent, and effective.
NTT DATA UK Limited expects all our employees to act in accordance with business values and principles outlined in our Code of Ethics and Professional Conduct and other internal Policies.
Failure to comply with any of these Policies is taken very seriously and can result in disciplinary action
Our supply chains provide us with goods, works, and services and include original equipment manufacturers, cloud software companies, distributors, professional services firms, and independent contractors through recruitment agencies.
Together with our suppliers, we strive to ensure that our supply chains operate in an honest, fair, and transparent manner, free from forced labour, slavery, and servitude.
To date, we have not been made aware of any complaints or allegations of human trafficking or slavery activities against any of our suppliers, through the NTT DATA EMEAL Group Whistleblowing System or otherwise. Should NTT DATA UK Limited become aware of an incident of modern slavery or human trafficking within its supply chain, NTT DATA UK Limited will work with the relevant supplier to implement swift remedial actions.
All suppliers, sub-contractors, and business partners we engage must agree to our position on human rights and commit to not using any form of forced labour. They must comply with the NTT DATA UK Procurement Policy, all applicable modern slavery laws and regulations, and have adequate controls in place to ensure that they are not exposed to or complicit in human trafficking and modern slavery.
Under NTT DATA Corporation Suppliers Code of Conduct (NTT DATA Group Guidelines for Sustainability in Supply Chain), we require that our suppliers:
As a professional services firm, the risk of modern slavery or human trafficking occurring within our business is low, when compared to other industries. However, NTT DATA UK Limited recognises the challenges around modern slavery in complex global supply chains and is committed to operate an effective supply chain governance framework and minimise the risks of modern slavery associated with goods, works, and services we purchase.
As part of our approach to maintaining a supply chain that is free of modern slavery, NTT DATA UK Limited carries out due diligence throughout the supplier selection process to avoid complicity in human rights abuses, slavery, forced or compulsory labour, or human trafficking.
NTT DATA UK Limited also incorporated the terms requiring compliance with all applicable laws, rules and regulations including those related to modern slavery and human trafficking in our standard contracts. We would regard any confirmed instance of modern slavery or human trafficking as a breach of contract and reserve the right to take appropriate action, including the ability to terminate such contracts immediately.
NTT DATA UK Limited Procurement Department is responsible for ensuring all suppliers of NTT DATA UK Limited have been vetted as part of the onboarding process and all supply chain supplier issues are escalated and resolved in an effective, timely, and appropriate manner.
We are committed to continuously improving our risk assessment process to ensure we are in a position to timely identify and remediate any modern slavery concerns that could be connected to both our business and supply chain.
All NTT DATA UK Limited employees are required to read and comply with our Code of Ethics and Professional Conduct which provides a clear set of principles for the way we conduct business as well as guidance on how to put these principles into action in their day-to-day work.
Our Code of Ethics and Professional Conduct makes it clear that all our employees have a responsibility to use our NTT DATA EMEAL Group Whistleblowing Reporting System to report any genuine suspicion of criminal conduct, or a breach of legal or regulatory statutes, including instances of modern slavery or human trafficking without fear of retaliation.
To raise awareness of modern slavery, we have implemented mandatory employee training with a focus on the principles outlined in our Code of Ethics and Professional Conduct and other mandatory Policies. In addition, NTT DATA UK requires all new employees to undertake mandatory induction training.
NTT DATA UK Limited is committed to ensuring that the teams within the business that are considered most likely to observe potential modern slavery risks are fully aware of human rights and modern slavery risks, modern slavery indicators, and are equipped to identify instances of possible slavery and human trafficking within our business and supply chains.
Responsibility for compliance with the Modern Slavery Act 2015 rests with the NTT DATA UK Limited Leadership Team, with the responsibility for the Modern Slavery & Human Trafficking Statement assigned to the Head of Legal and Compliance.
NTT DATA UK&I Compliance Team works with the following key risk areas departments to monitor modern slavery and human trafficking risk: Legal, People & Culture, Supply Chain, People & Culture, and Sales.
We encourage our employees, suppliers, sub-contractors, and business partners to speak up about any concerns regarding human rights, modern slavery or human trafficking in our operations or supply chain.
NTT DATA Group has established an external NTT DATA EMEAL Group Whistleblowing Reporting System so that anyone who discovers any alleged or potential wrongdoing can report the details of it without being subjected to any disadvantageous treatment.
NTT DATA UK Limited is committed to investigating all the reported matters in an appropriately robust and timely manner.
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