Modern Slavery Statement

First Technology Holdings (Ltd)
Company Number: 13712088 (“First Technology”)

1. Introduction
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “MSA”) and constitutes the slavery and human trafficking statement of First Technology.

We are committed to improving our practices to combat slavery and human trafficking and are committed to ensuring that slavery and human trafficking are not taking place in our supply chains or in any parts of our business.

2. Our organisation's structure
First Technology is a private company duly incorporated in terms of the laws of England. Our operations are primarily based within the United Kingdom. First Technology is supported by a centralised procurement. We are part of the larger First Technology Group which comprises of all wholly owned subsidiaries of First Technology Investments (Pty) Ltd.

3. Our supply chains
Our main supply chains are:
        • Information Technology equipment and services
        • Professional services

Within these categories we believe the following types of goods and services contract are likely to carry the highest risks in relationto modern slavery and human trafficking:
        • IT
        • Temporary labour

Many of the above are purchased through First Technology central procurement department, who fully support and adhere to the MSA.

4. Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

First Technology’s Purchasing policy has been updated and approved by the Executive Board. This policy reflects our commitment to act with integrity and ethically in all our business relationships and to implement and enforce effective systems and controls, including in relation to combatting modern slavery and human trafficking in our supply chains.

We intend to include slavery and human trafficking policy provisions in a future update to our Human Resources Policies & Procedures (HRPP). Additional updates will include amendments to the following sections of the HRPP:
        • Recruitment Policy
        • Training Policy
        • Whistleblowing Policy

3RD Party Vendor Management Policy will be updated to include:
        • Requirement for appropriate due diligence for new suppliers with whom we contract, which will include modern slavery checks
        • Updated standard terms and conditions of purchasing, which will include provisions concerning compliance with applicable modern slavery laws.
        • A modern slavery working group exists for:
                • Continuing to identify and assess potential risk areas in our supply chains.
                • Continuing to establish how to mitigate the risk of slavery and human trafficking occurring in our supply chains.
                • Continuing to monitor potential risk areas in our supply chains and consider proportionate ways to ensure compliance by our suppliers.
                • Continuing to commit to the protection of whistle blowers and to encourage the reporting of genuine concerns, including in respect of modern
                  slavery and human trafficking.
                • Considering appropriate, effective and proportionate ways of raising staff awareness.
                • Providing input on the above referred to policies which are in development.

This statement was approved by the Executive Board of First Technology on 1 June 2022.

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