Modern Slavery
Statement

Winner Recruitment’s own policy, as published on winnerrecruitment.co.uk.

Modern Slavery and Human Trafficking Statement

Financial Year Ending: 31 March 2025

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Winner Recruitment has taken to prevent modern slavery and human trafficking in our business operations and supply chains.

1. Our Business and Structure

Winner Recruitment is a UK-based recruitment agency providing temporary and permanent staffing solutions across multiple sectors including logistics, warehousing, manufacturing, and commercial services. With a wide geographical footprint and an extensive network of clients and candidates, we operate as both a direct employer and a strategic workforce supplier.

We recognise the critical responsibility we have to combat modern slavery and uphold human rights within our operations and throughout our labour supply chains.

2. Our Commitment

Winner Recruitment is committed to acting ethically and with integrity in all business dealings. We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, and exploitation of any kind. We work diligently to ensure transparency, accountability, and due diligence in all areas of our business and among our supply chain partners.

3. Our Supply Chains and Labour Providers

As a labour provider ourselves, we maintain a clear understanding of the risks associated with the recruitment and deployment of temporary workers. We also work with outsourced payroll providers, umbrella companies, and third-party vendors. These relationships are carefully managed to ensure compliance with the Modern Slavery Act and aligned ethical standards.

4. Policies in Relation to Modern Slavery

Winner Recruitment has implemented and maintains the following policies relevant to identifying and preventing modern slavery:

Anti-Slavery and Human Trafficking Policy
Ethical Trading
Anti-Bribery policy
Equal Opportunity Policy

These policies are reviewed annually and embedded across the business to raise awareness, set expectations, and ensure accountability.

5. Due Diligence and Risk Management

We conduct robust due diligence during onboarding of clients, candidates, and supply chain partners. This includes:

Right to Work checks for all workers in accordance with UK Home Office guidelines
Verification of all umbrella and payroll partners
Regular audits of worker documentation, addresses, and bank details to identify red flags (e.g., multiple workers registered at a single address or sharing the same bank account)
Site audits and worker interviews to assess workplace practices
Compliance with the Stronger Together initiative and other industry best practices

6. Training and Awareness

All internal staff, particularly those involved in recruitment, compliance, and operations, receive annual training on:

Indicators of modern slavery and trafficking
How to handle suspicions or disclosures
Legal obligations under the Modern Slavery Act
Reporting mechanisms and internal escalation routes

7. Monitoring and Performance Indicators

To assess the effectiveness of our actions, we monitor:

Number of internal and external modern slavery alerts raised and investigated
Audit compliance scores for our sites and supply chain
Completion rates of training modules
Feedback from workers via confidential surveys

8. Future Steps and Continuous Improvement

In the coming year, we plan to:

Strengthen our partnership with Stronger Together and attend their latest workshops
Further enhance our due diligence and audit programme
Extend our risk mapping across new client sectors
Explore implementation of tech-based tools for worker welfare monitoring

Approval

This statement was approved by the Board of Directors of Winner Recruitment on 02 June 2025 and will be reviewed and published annually.

Company Reg : 07134314
Vat No : 110 1628 73
Head Office : 6 Burnett Road, Sutton Coldfield, B74 3EJ

Anti-slavery and human trafficking policy

ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

Winner Recruitment strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

MODERN SLAVERY AND HUMAN TRAFFICKING

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
Consistent with our risk based approach we may require:
Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships

Company Reg : 07134314
Vat No : 110 1628 73
Head Office : 6 Burnett Road, Sutton Coldfield, B74 3EJ