Global Policy Against Trafficking in Persons and Slavery

Summary

This policy establishes global standards regarding the United Kingdom Modern Slavery Act 2015 (MSA) and other similar laws/regulations for NTT DATA Services¹  (the “Company”).  If local laws or regulations have stricter requirements, these supersede the requirements stated in this policy.

Scope

This policy applies to the entire Company workforce, operations and subsidiaries, in terms of all dealings and transactions in all countries where the Company operates.  The entire Company workforce including others acting on behalf of the Company, are required to read, understand, and abide by the provisions referenced in this policy, including its suppliers.

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights.  The Company is fully committed to a work environment and supply chain that is free from human trafficking and slavery.  The Company will not tolerate or condone human trafficking or slavery in any part of our global organization. It is for this reason that a Global Policy against Trafficking in Persons and Slavery has been adopted and this policy and the statement contained herein is consistent with the Company’s Global Code of Business Conduct and our core values to protect and defend human dignity and human rights in our global business practices and supply chain.

Organization

The Company provides consulting, managed services, outsourcing, and cloud-based solutions to mid-sized and large enterprises in all major industries.

The Company has given careful consideration to Section 54 “Transparency in Supply Chains” of the MSA and other similar legislation.  Our review has concluded that the services we provide are unlikely to be associated with slavery or human trafficking.

Scope

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees are further encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chain of any supplier tier at the earliest possible stage.

If employees believe or suspect a breach of this policy has occurred or that it may occur they must notify their manager or report it as soon as possible by calling the Ethics Hotline at 1-877-888-0002 (outside the US call collect at 001-770-810-1147).

If an employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, the matter should be raised with their manager or by calling the Ethics Hotline.

Our aim is to encourage openness and we will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any retaliation as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

Responsibility for the policy

The Chief Procurement Officer has primary and day-to-day responsibility for implementing this 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.

Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy as part of the Global Code of Business Conduct.

Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Training

Training on this 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, and regular training will be provided as necessary.

Employees in the supply chain organization are given additional training on the process of performing the necessary due diligence and inclusion of the necessary language into supplier contracts to ensure that our supply chain is free from slavery and human trafficking.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.

This Global Policy Against Trafficking in Persons and Slavery is part of the Company’s Global Code of Business Conduct which is annually reviewed and approved by the Board of Directors.

Supporting Documents

NTT Group Human Rights Charter
Global Compliance Policy
Corporate Social Responsibility
NTT Data International L.L.C. Global Code of Business Conduct
Ethics Hotline

¹ NTT DATA Services includes NTT DATA Americas, Inc. and NTT DATA Services International Holdings B.V. and their respective subsidiaries.  It also includes NTT DATA (China) Co. Limited, Dalian Branch and PT NTT DATA Indonesia, to the extent related to NTT DATA Services.