Tech Data’s Shared Values of Integrity, Excellence, Accountability, Collaboration and Inclusion along with our Global Code of Conduct reflect our commitment to acting ethically and with integrity in all our business relationships. Tech Data requires all employees to demonstrate honesty, respect for others and trustworthiness in all we do, and to demonstrate ethical behaviour in all of our interactions with customers, suppliers and colleagues.

On March 26 2015, the Modern Slavery Act 2015 was passed into law in the United Kingdom. This law requires all business entities that complete business, or part of a business, in any part of the United Kingdom and operate above a specific turnover threshold, to prepare and publish a slavery and human trafficking statement for each financial year of the organization. Tech Data fully supports the aims of the legislation and is committed to complying with applicable anti-slavery and human trafficking laws.

Our Supply Chains
Tech Data’s standard supplier contracts contain Compliance with Laws provisions that require the parties to comply with all applicable laws, which includes laws about anti-slavery and human trafficking. In addition, Tech Data’s Supplier Integrity Principles establishes and communicates Tech Data’s expectations regarding our suppliers’ compliance with international ethical standards, including regulations on anti-slavery and human trafficking.

Many of our major suppliers are members of the Electronic Industry Citizenship Coalition (“EICC”) and/or have adopted the EICC Code of Conduct, which prohibits forced, bonded or indentured labour, involuntary prison labour, slavery or trafficking of persons, and requires minimum standards in terms of working conditions. Tech Data supports our suppliers’ compliance with the EICC Code of Conduct.

Our Policies and Procedure on Slavery and Human Trafficking
Tech Data has made efforts to address the risks of slavery and human trafficking violations in its own business. During pre-employment screening of potential employees, Tech Data verifies that individuals are eligible to work in the Company and meet all applicable age requirements. Tech Data provides Ethics and Compliance training to its employees upon joining the company and employees are also required to complete Tech Data’s Global Code of Conduct Training at regular intervals.

Tech Data’s Supplier Integrity Principles outline principles on human rights, minimum wage, maximum hour and overtime rules, forced, bonded or involuntary labour, human trafficking, child labour and other important legal and compliance areas. The document provides methods for suppliers to speak up if they have a question or to make a report if they suspect any unlawful conduct, including anti-slavery and human trafficking violations.

Employees are expected to report any violations of Tech Data’s Global Code of Conduct to their manager, anyone in the management reporting chain, a Human Resources representative, or any member of Tech Data’s Ethics and Compliance department or to Tech Data’s Ethics Line, which is managed by an external, independent third party. Suppliers, customers, partners, shareholders, and any stakeholders may report concerns anonymously, toll free or online on the Ethics Line’s website.

Reports are reviewed and appropriate action including investigations and corrective actions are taken within a reasonable period. Employees and suppliers are protected from retaliation for making a report in good faith, and anyone found to have acted against this protection is subject to disciplinary action up to and including termination.

Our Effectiveness in Combating Slavery and Human Trafficking
Tech Data is continuing to review its processes and supplier relationships to comply with the Modern Slavery Act 2015.

Over the last year Tech Data has introduced a more comprehensive section on modern slavery to its Global Code of Conduct. In addition, there has been awareness training and communication provided across Tech Data’s business relating to the Global Code of Conduct.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31st January 2018.

The UK Modern Slavery Act Transparency Statement has been duly approved and adopted by the Board of Directors of Tech Data Limited and Azlan Logistics Limited who have delegated authority to Andy Gass to sign this statement on their behalf.

Signed by, Andy Gass DIRECTOR, TECH DATA LIMITED Date:19th September 2018