NTT DATA UK LIMITED

Policies described

Freedom of workers to terminate employment Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents

Training described

Your whole organisation

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Workers within your organisation

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Demonstrated progress

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. We also track four KPIs: Number of employees trained on Modern Slavery, Number of incidents reported related to ethical matters, Number and type of remedial action taken, and related risk assessments conducted.

Reported risks and mitigations

• Risk: Presence of unskilled labor
• Area: Within your supply chains
• Tier: Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Migrants Refugees Children Other vulnerable groups
• Location: United Arab Emirates Brazil India Kenya Morocco Myanmar (Burma) Malaysia Qatar Saudi Arabia Uganda Vietnam
• Mitigation: 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.
• Risk: Third parties
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Location: United Kingdom
• Mitigation: An agreed TPRM Execution Plan is in place, at Group level key deliverables include: • The development of the NTT DATA Group TPRM Policy and minimum standards. • Refinement of the TPRM methodology as required, with simplification of the Inherent Risk Questionnaire and Third Party Questionnaires across all Risk Domains. • Issuing a TPRM Maturity Assessment to all region and business unit Chief Risk Officers as requested by the NTT DATA, Inc. Group Risk Management Advisory Board (RMAB)
• Risk: Reporting / whistleblowing
• Area: Both
• Mitigation: NTT DATA Group wide Whistleblowing Platform (SpeakUp) launched globally. Our aim is to encourage openness, and we ask our employees to report any knowledge or suspicion of modern slavery or human trafficking using our Whistleblowing System. NTT DATA. operates a strict non-retaliation policy and will not, in any way, retaliate against a whistleblower acting in good faith.