NTT DATA, Inc. 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.
We maintain a long-standing commitment to respecting human rights, including the elimination of slavery and human trafficking in our supply chain and business operations. We welcome the transparency that the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018 encourages.
NTT DATA, Inc. 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 labor, or human trafficking.
We encourage any individual who has concerns about the alignment of our operations to this Modern Slavery and Human Trafficking Statement or unethical behavior in any part of our business or operations to speak up, and to do so without fear of retaliation.
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 joint statement is published in line with section 54(1) of the UK Modern Slavery Act 2015 and section 19 of the Australian Modern Slavery Act 2018 (Cth) and relates to the financial year ending 31st March 2025. It covers NTT DATA, Inc. and the subsidiaries listed in Appendix A.
We fully support the aims of the aforementioned Acts and associated standards, such as the UN Guiding Principles on Business and Human Rights and are committed to tackling slavery and human trafficking wherever we can.
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Abhijit Dubey
President & CEO | Chief AI Officer, NTT DATA, Inc.
26 August 2025
NTT DATA, Inc. is a trusted global IT innovator of digital business and technology services. NTT DATA, Inc is part of the NTT Group, a leading, global technology services company headquartered in Tokyo, Japan, and is part of the NTT DATA Group with parent company NTT DATA Group Corporation, also headquartered in Tokyo, Japan.
With over 140,000 employees globally, NTT DATA, Inc. enables clients, as well as society, to move confidently into the digital future.
Our mission is to accelerate client success and positively impact society through responsible innovation. As we help clients to transform through consulting, industry solutions, business process services, IT modernization and managed services, we always seek to ensure our work contributes to building a better world through responsible technology.
The scope of this Modern Slavery & Human Trafficking Statement has been designed to meet NTT DATA, Inc.’s obligations for reporting under the UK Modern Slavery Act of 2015, and the Australian Modern Slavery Act 2018 (collectively “Acts”).
NTT DATA, Inc. and its subsidiaries (“NTT DATA”) share core business operations, supply chains, policies prohibiting modern slavery, and the supporting processes further described in this statement.
This is a joint statement provided by NTT DATA, Inc. for itself and on behalf of its subsidiaries that are covered by disclosure obligations in the United Kingdom and Australia and that are listed in Appendix A (“NTT DATA Companies”). In preparing this statement the NTT DATA Companies were consulted.
The reporting period for the statement covers NTT DATA fiscal year starting 1 April 2024, and ending 31 March 2025 (“FY24”).
Our people are our most valued assets and NTT DATA 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 Business Ethics applies to all NTT DATA 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 our Whistleblowing Reporting System.
NTT DATA expects all our employees to act in accordance with the principles and values outlined in our Code of Business Ethics and other internal Policies and training resources. We further expect the same high standards from all our suppliers, sub-contractors, and other business partners.
NTT DATA is committed to the principles of the Acts and there are several Policies that help us manage our modern slavery risk:
We regularly review and update our Policies to ensure they remain compliant, consistent, and effective. NTT DATA expects all our employees to act in accordance with the business values and principles outlined in our Code of Business Ethics 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 labor, slavery, and servitude.
To date, we have not received any complaints or allegations of human trafficking or slavery activities against any of our suppliers, through the NTT DATA Whistleblowing System or otherwise. Should NTT DATA become aware of an incident of modern slavery or human trafficking within its supply chain, we will fully investigate the incident and work with the relevant supplier to implement swift remedial actions.
All suppliers, sub-contractors, and business partners we engage with must agree to our position on human rights and commit to not using any form of forced labor and must comply with all applicable modern slavery laws and regulations. In line with the NTT DATA Group Corporation Procurement Policy, all suppliers, subcontractors, and business partners must have adequate controls in place to ensure that they are not exposed to or complicit in human trafficking and modern slavery.
Under the NTT DATA Group Corporation’s Guidelines for Sustainability in Supply Chain, we require that our suppliers:
As a global technology services company, NTT DATA acknowledges the importance of addressing modern slavery risks within our organization. We believe that the risk of modern slavery in our operations is medium to low. This assessment is based on the fact that the majority of our workforce consists of skilled workers, and our supply chains are relatively straightforward, primarily involving direct relationships with original equipment manufacturers. The presence of unskilled labor among our suppliers is minimal. While we do operate in regions that may have a higher exposure to modern slavery risks, we maintain that the overall risk remains low due to our limited reliance on unskilled labor. However, NTT DATA is fully aware of the complexities and challenges associated with modern slavery in global supply chains. We are committed to implementing an effective supply chain governance framework to minimize the risks of modern slavery in the goods, works, and services we procure.
To ensure our supply chain remains free from modern slavery, NTT DATA conducts thorough due diligence during the supplier selection process. This helps us avoid any complicity in human rights abuses, slavery, forced or compulsory labor, or human trafficking. We contractually require our suppliers to comply with all applicable laws, rules, and regulations related to modern slavery and human trafficking. Any confirmed instance of modern slavery or human trafficking will be taken extremely seriously, and we will take immediate and appropriate action, including termination of contracts.
We vet all suppliers as part of the onboarding process and ensure that any supply chain issues are escalated and resolved effectively and promptly.
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. By maintaining vigilance and fostering a culture of transparency and accountability, NTT DATA strives to uphold the highest standards of ethical conduct and human rights throughout our operations and supply chains.
NTT DATA maintains a strong governance framework to support its commitment to ethical conduct, legal compliance, and the prevention of modern slavery across its operations and supply chains. Over the past year, we have continued to enhance our governance, risk, and compliance practices, including regular policy reviews, internal training, and risk assessments. These efforts are designed to ensure that our business activities remain aligned with the requirements of the Acts.
In anticipation of the EU Corporate Sustainability Due Diligence Directive (CSDDD), we have actively supported our parent company, NTT DATA Group Corporation, through a dedicated readiness program. This program focuses on strengthening due diligence processes across the NTT DATA Group, with particular attention to human rights risks in both internal operations and external supply chains. Our participation in this program reflects our commitment to continuous improvement and alignment with emerging international standards.
To further embed human rights governance, we have established two thematic working groups (TWGs):
These TWGs play a key role in supporting our CSDDD readiness and strengthening our overall human rights governance.
We assess the effectiveness of our actions through regular internal audits, supplier engagement feedback, and monitoring incident reports. These assessments inform updates to our Policies, training programs, and risk mitigation strategies.
NTT DATA, Inc. has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organization and supply chain. These include:
All NTT DATA employees are required to read and comply with our Code of Business Ethics 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 Business Ethics makes it clear that all our employees have a responsibility to use our NTT DATA 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 Business Ethics and other mandatory Policies. In addition, NTT DATA requires all new employees to undertake mandatory induction training.
NTT DATA is committed to ensuring that our employees 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 Acts rests with the NTT DATA, Inc. Corporate Sustainability Team, with the responsibility for the Modern Slavery & Human Trafficking Statement assigned to the Senior Team Lead: Human Rights Compliance.
NTT DATA, Inc. Corporate Sustainability Team works with the following key risk areas departments to monitor modern slavery and human trafficking risk: Human Rights, Legal, Risk & Compliance, People & Culture, Procurement, 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 has established an external 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 is committed to investigating all the reported matters in an appropriately robust and timely manner.
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