MODERN SLAVERYSTATEMENT

Computacenter PLC
Modern slavery
statement 2023
We are committed to ethical, responsible, and sustainable corporate
management and continue our commitment to upholding theinternationally proclaimed human rights of all people in all ourbusiness interactions. This means we expect all our suppliers to takeactions to ensure that their practices support and protect individual
human rights.
We are against all forms of modern slavery, human trafficking,bonded and forced or compulsory labour and believe these practices
have no place in society.
We are committed to making certain that we are not complicit in any
human rights violations and require our suppliers and partners toadhere to this same high standard.

This statement fulfils the requirements of Section 54 (Transparencyin Supply Chains) of the Modern Slavery Act 2015 and covers theperiod of 1 January 2023 to 31 December 2023. This statement
outlines the steps taken by Computacenter PLC and all its
subsidiaries to prevent modern slavery and human trafficking in its
supply chain.

MODERN SLAVERYSTATEMENTOUR ORGANISATION,ITS BUSINESSAND ITS SUPPLY CHAINSBuilding long-term value
based on trust
Who we areWe are a leading independent
technology and services provider,trusted by large corporate and public
sector organisations. We are a
responsible business that believes inwinning together for our people andour planet.

What we do
We help our customers to Source,
Transform and Manage theirtechnology infrastructure todeliver digital transformation,
enabling people and theirbusiness.

Computacenter is one of the world’s
six largest Value-Added Resellers (VAR)
of Information Technology. We are alsoa major international IT servicescompany.

SOURCECIO
PEOPLE
BUSINESSMANAGE
TRANSFORMOur Purpose

Helping our customers change the world
Our customers are some of the world’s greatest organisations, in both thecorporate and public sectors. They make world-changing decisions andinvestments and, while we do not change the world ourselves, we enable successfor our customers so that they can realise the transformative benefits ofinformation technology for their organisations, people, and the world. We work
hard to get to know our customers, understand their needs and put them at theheart of everything we do.

Our business is diversified across our main territories and our three business areas. These business areas are distinct, but synergistic, ascustomers increasingly look to buy end-to-end services and solutions, including consulting, product supply, life cycle services, integrationand managed services.

MODERN SLAVERYSTATEMENT

Computacenter is headquartered in the UK, within the Computacenter group, we have over 20,000 people based across Europe, North
America, Mexico, South Africa, and Asia Pacific.
We have developed a global coverage to mirror our customer’s requirements.

We Source, Transform and Manage technology for our customers in over 70 countries worldwide
We sell to customers in eight countries

We have nearshore and offshore operationsin another eight countries

We have support operations in another sevencountries/territories

Belgium
CanadaFranceGermany

HungaryIndia
Malaysia
MexicoAustralia
BrazilChina
Hong Kong (SAR)

Netherlands
Switzerland
United Kingdom
United States

PolandRomaniaSouth Africa
Spain

IrelandJapan
Singapore

MOORDRECHT, NETHERLANDS
BRUSSELS, BELGIUM

POZNAN, POLAND
CLUJ, ROMANIA

MARKHAM, ON, CANADAHATFIELD, MILTON KEYNES,NOTTINGHAM, SHEFFIELD, UK

INDIANAPOLIS, IN, US

HATFIELD, UKBUFFALO GROVE, IL, US

BRAINTREE, UK

BUFFALO GROVE, IL, US

HATFIELD, UK, EMEASAN FRANCISCO, CA, US

LIVERMORE, CA, US
DALLAS, TX, USMEXICO CITY, MEXICOBARCELONA, SPAIN
GONESSE, PARIS, FRANCEBANGALORE, INDIABANGALORE, INDIA

LYON, MONTPELLIER,PARIS, PERPIGNAN, FRANCEBANGALORE, INDIAATLANTA, GA, US

KUALA LUMPUR, MALAYSIA

ALPHARETTA, GA, US

BUDAPEST, HUNGARYKUALA LUMPUR, MALAYSIA, APACBERLIN, DRESDEN, ERFURT,KERPEN, GERMANYKERPEN, GERMANYCAPE TOWN, SOUTH AFRICAGUSTAVSBURG, GERMANYCOMPUTACENTER’S
COVERAGECOMPUTACENTER’SCOVERAGEREGIONAL HEADQUARTERS
REGIONAL HEADQUARTERS
INTEGRATION CENTERSINTEGRATION CENTERSSERVICE CENTERS

PROFESSIONALSERVICECENTERS SERVICESDELIVERY CENTERS

PROFESSIONALSERVICESCIRCULAR SERVICES
CENTERS
DELIVERYCENTERSCIRCULAR SERVICES
CENTERSOur extensive partner network covers field services and onsite
support globally and services Computacenter’s European and US
headquartered customers.

For Computacenter, human rights fall into two areas: protecting
the rights of our employees and ensuring we are not complicit inhuman rights abuses in our supply chain.

Our supply chain is made up of products and services that we use in
our business; our employees; contractors; partner organisations whowe work with; and IT equipment which we supply to our customers.

To ensure that we continue to operate in alignment with ourcompany values and sustainability goals; we believe it isnecessary to ensure that our supply chain is similarly aligned andis operating in a lawful and responsible manner.

MODERN SLAVERYSTATEMENTOUR POLICIES IN RELATION TO SLAVERYAND HUMAN TRAFFICKING
Our commitment to human rights means we have adopted theprinciples of the leading international standards and conventions
across our business dealings, in particular the UN Global Compact(signatories since 2007), the Universal Declaration of Human Rights,
the UN Guiding Principles on Business and Human Rights, the UN
Conventions on Rights of the Child, and fundamental conventionsof the International Labour Organization (ILO) and understand ourresponsibility to respect and support human rights.
The human rights of our employees are covered by our people
policies and compliance with local labour laws and fair labour
practices wherever we do business. This includes our Health andSafety, Equality and Respect at work policies, our disciplinary andgrievance processes and terms and conditions of employment.
Our Group Ethics policy sets out our commitment to observing thehighest ethical standards in our business conduct, including theprotection of human rights.
Our Group Speak Up (whistleblowing) policy explains how our people
and anyone in our supply chain can report any concerns they may
have through the external, independent reporting service, providedby Safecall.
An overview and the details of Safecall are publicised internallyon our compliance portal, in our Group Ethics policy, through anannual multi-channel communications campaign and are included
in all our compliance training. Those within our supply chain are
informed of Safecall and the requirement to report any concerns
they may have via our Supplier Code of Conduct. Our Group Speak Up(whistleblowing) policy is also published on our company website toensure that it is easily accessible to anyone within our supply chain.
Any concerns raised are fully investigated, with oversight from theGroup Legal and Compliance Director and Chief People Officer. As
part of our wider processes around managing reports at a highlevel, an anonymous summary of each report is reviewed by ourAudit Committee, and if necessary, by the Computacenter Board ofDirectors.

In 2023, there were no issues raised within the company that related
to modern slavery or human trafficking amongst our people or in
our supply chain.
We also have a comprehensive Anti-Bribery and Corruption policy,and Supplier Code of Conduct.
As part of our supplier onboarding, all potential suppliers in our core
countries are provided with our Supplier Code of Conduct whichclearly lays out our requirements within both the modern slavery
and wider compliance environment and sets out related standardsof how they are expected to conduct themselves within theirbusiness operations. As part of the Code of Conduct, suppliers arerequired to notify Computacenter of any breach of these standards
and to take appropriate steps to remedy them.
Any breaches of the requirements of our Code of Conduct areconsidered by us to be very serious and could lead to us terminating
relationships with a supplier, where we feel this is appropriate inorder to protect ourselves and our customers.
We also have a policy statement published on our company websitethat outlines our approach to our responsibilities under the German
Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz(LkSG)).

MODERN SLAVERYSTATEMENTOUR DUE DILIGENCE PROCESSES
We have continued to evolve our third-party due diligence system since its implementation in 2022.
The system enables us to collate comprehensive vendor information prior to their inclusion within oursupply chain, alongside a requirement to adhere to our Supplier Code of Conduct. Issues arising arereferred to Group Compliance.
A key focus in 2023 was adapting these processes to incorporate the requirements of the LkSG. We
also continued to strengthen our due diligence through in-life checks and re-attestation of ourSupplier Code of Conduct with current suppliers, and the planned implementation of the tool to ourremaining countries in 2024.
The system enables us to carry out appropriate due diligence on vendors in our supply chain throughour Group Technology Supplier Advisory and Monitoring Team and our Services Partnering team incore countries. One of the areas covered in the due diligence conducted focuses on human rights
and modern slavery-related risk. This information is reviewed annually to ensure that it remains
acceptable. The outcome of the due diligence directly correlates to the risk profile associated witha supplier and the resulting actions that we put into place to safeguard against modern slavery
occurring within our supply chain.

OUR RISK ASSESSMENT AND MANAGEMENT
Due to the nature of our business, operations, and practices, we consider ourselves to be a low-riskenterprise as regards the potential for modern slavery or trafficking.
Our risk assessment is based on the purchasing category of goods and services that the supplier iscategorised in and an overall country risk analysis, based on a comprehensive Human Rights Country
Risk Database.
Having undertaken a thorough internal review and audit of our global HR practices and policies we aresatisfied that we are operating in compliance with all labour law and fair labour practices across ourglobal employing entities. We therefore believe that there is an extremely low risk of modern slavery
amongst our own employees.
Most of our suppliers are categorised as low risk in terms of exposure to modern slavery. Certain
suppliers due to the country and industry they operate in are deemed higher risk, based oninternationally understood risks and reliable sources.
Although the electronics and manufacturing industry are high risk sectors for modern slavery, we
do not manufacture hardware, and therefore believe this to be a moderate area of risk for us. When
we purchase hardware from original equipment manufacturers (OEM’s), we work with companies
that have a comprehensive approach to the prevention of modern slavery and other human rights
violations. Through our Partner Management relationships, we are satisfied that there is appropriate
governance and oversight of these suppliers to reduce the risk within our supply chain.
Where we believe we interact with higher risk suppliers or operate in countries that are at a higher riskof modern slavery occurring, we have proportionate actions and governance in place to mitigate therisk of this occurring within our supply chain. This includes our corporate standard terms of contractand supply, including the right to audit and attestation to our Supplier Code of Conduct as previously
mentioned.

MODERN SLAVERYSTATEMENTKEY PERFORMANCE INDICATORS
We continue to review our policies, practices and how we identify any risks of modern slavery and other human rights on a rolling basis as partof our continued commitment to ethical and responsible business practices. Group Internal Audit regularly tests compliance with our policies.
We will continue with our commitment to ethical and responsible business practices, ensuring that if modern slavery is identified anywhere
within our supply chain, we will not tolerate it.
Group Ethics Policy, Supplier Code of Conduct and Speak Up (whistleblowing) policy review completed a minimum ofonce every two years

100%% of employees that have completed ‘Combatting Modern Slavery’ e-learning in 2023

91%

% of employees that have completed ‘Ethical Workplace Conduct’ e-learning in 2023

89%

% of employees that have completed ‘Anti-Bribery and Corruption’ e-learning in 2023

86%Number of reports or investigations into allegations of Modern Slavery or Human Rights concerns in 2023

0%

Number of Suppliers terminated due to Modern Slavery or Human Rights concerns in 2023

0INCREASING AWARENESS AND TRAININGON MODERN SLAVERY
We continue to provide our people with e-learning on ‘Combatting Modern Slavery,’ ‘Ethical Business Conduct’ and ‘Anti-bribery and Corruption’.
These programmes support our people in developing their understanding of these critical areas and provides guidance to them on ethicalbehaviours and subject specific red flags to look for. All our compliance e-learnings contain a dedicated module on whistleblowing, ensuringthat our people know where and when to report any concerns that they may have as well as the details of the independent external hotline
being publicised internally through an annual multi-channel communications campaign.
As in previous years, key members of our Compliance, Group Legal, Group HR, Group Technology Sourcing and In Country Sales teams havedeveloped further awareness and understanding of modern slavery.
Making an eﬀective contribution in this area is entirely the right thing to do for wider society and for our business and we will continue withour commitment to ethical and responsible business practices, ensuring that we do not tolerate modern slavery anywhere within our supplychain.

This statement was approved by the Board of Directors of Computacenter PLC on 18 March 2024 and has been published on our company
website in accordance with the requirements of the Modern Slavery Act 2015.

Mike Norris
Chief Executive Officer

Computacenter (UK) Ltd
Hatfield Avenue, Hatfield, Hertfordshire AL10 9TW, United Kingdom
computacenter.com+44 (0)1707 631000