Introduction

Node DT Group Ltd (and its subsidiary undertakings) and related party companies (“NodeDT”) 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, contractors and other business partners. NodeDT takes its responsibilities seriously and this statement constitutes its compliance pursuant to section 54 (1) of the Modern Slavery Act 2015 (the Act).

Structure of the organisation

NodeDT is a company incorporated under English Law, it heads up a number of subsidiary undertakings and has related parties operating the same or similar brands in other jurisdictions. It is a digital transformation and global IT technology services company.

In delivering various technology services its works with a range of suppliers, the vast majority of whom are considered to be based in low-risk jurisdictions. The Act defines modern slavery as “slavery, servitude and forced or compulsory labour” and “human trafficking” (Modern Slavery). The Act requires commercial organisations operating in the UK (i.e. that supply goods or services from or to the UK) and have a global turnover above £36 million, to publish a statement each financial year, which sets out the steps they have taken to ensure there is no Modern Slavery in their business or supply chains.

Policies

As part of our commitment to combating Modern Slavery, our Modern Slavery statement and code of conduct sets out our zero-tolerance approach to Modern Slavery in our organisation and supply chain. We expect all our partners and suppliers to embrace our core principles and match the high standards that we set ourselves. All new suppliers sign up to our code of conduct and existing suppliers are reminded of our code of conduct when renewed.

Our due diligence processes and supply chain

As a high tech digital solutions provider, we consider the risk of Modern Slavery existing within our business to be low. However, due diligence and monitoring is completed on our supply chain based on our zero-tolerance approach to Modern Slavery in our organisation.

We endeavour to do business with suppliers that adopt the same strict standards that we ourselves adhere to. In turn, we expect our suppliers to operate fairly and ethically, where workers are treated with respect and dignity, and the highest standards of human rights are maintained.

NodeDT has developed a risk-based approach to assess the possibility of Modern Slavery within our supply chain. The factors considered for this approach include; the country of origin and the nature of, and location from which, services are provided.

Suppliers are onboarded through a managed internal process which identifies flags, and when it does so involve other managers or in some cases requires third party search and due-diligence information to be carried out. This information is all stored and reviewed by a risk-assessment manager. Any potential risks identified are documented along with mitigation action taken against them (or further enquires, it is investigated and mitigated through activities such as enhanced due diligence.

The contractual terms and conditions that we put in place with our suppliers require a standard of operating (including controls of their own). Information is set out in our Company Values.

We enforce a strict code of compliance and do not tolerate Modern Slavery within our supply chains. In the rare event that we become aware of a case of Modern Slavery; we will work with the supplier to implement remedial action. We expect our suppliers to engage with us constructively and responsibly, and to demonstrate their willingness to remedy issues in a timely manner. If we find evidence of a failure to comply with our policies, we will immediately seek to terminate our relationship with the relevant supplier.

Training

General awareness training is provided to staff involved in supplier onboarding, including now a specific marker that they are satisfied as to compliance.

Approvals

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes NodeDT’s slavery and human trafficking statement for the financial year ending 31st March 2024.

This statement has been signed off by the Group Board of Directors.

Victoria Gardner
Group Finance and Operations Director
Node DT Group Ltd

Christopher Evans
Group Executive Director
Node:Tokyo (Asia) Pte Ltd.

April 2024