EFT Winston Ltd
Last Updated: 01/01/26
1. Our Commitment
EFT Winston Ltd has a zero-tolerance approach to modern slavery and human trafficking in any form.
We are committed to conducting our business ethically, transparently and in compliance with the UK Modern Slavery Act 2015. We recognise our responsibility to prevent slavery, servitude, forced labour and human trafficking within both our own operations and our supply chain.
As a specialist recruitment firm operating within Private Equity and Corporate Finance, we understand the importance of upholding the highest standards of professional integrity and human rights.
2. Our Business
EFT Winston Ltd is a UK-based recruitment consultancy providing executive search and talent advisory services to private equity firms, portfolio companies and corporate finance businesses.
Our operations are primarily office-based professional services. Our supply chain is limited and typically includes:
- IT and technology providers
- Professional advisers
- Marketing and website providers
- Office and administrative service providers
While the risk of modern slavery within our core operations is considered low due to the professional nature of our services, we remain vigilant and proactive.
3. Our Approach to Preventing Modern Slavery
We are committed to:
- Operating fair and transparent recruitment practices
- Ensuring all employees and contractors work voluntarily and are free to leave employment with reasonable notice
- Verifying the right to work documentation of employees and contractors
- Paying at least the National Minimum Wage / National Living Wage where applicable
- Maintaining lawful working hours and employment conditions
We do not charge recruitment fees to candidates, and we do not engage in practices that could result in bonded or forced labour.
4. Supply Chain Standards
We expect all suppliers and business partners to:
- Comply with the Modern Slavery Act 2015
- Operate ethical employment practices
- Prohibit forced labour, trafficking and child labour
- Provide transparency upon reasonable request
Where appropriate, we may:
- Conduct due diligence on new suppliers
- Include anti-slavery clauses in contracts
- Terminate relationships where ethical standards are breached
5. Risk Assessment
Given the nature of our professional services business, the risk of modern slavery within our direct operations is assessed as low.
However, we remain aware that risks can arise indirectly through third-party suppliers or overseas service providers. We therefore take a proportionate and risk-based approach to supplier engagement.
6. Reporting Concerns
Employees, contractors, clients and suppliers are encouraged to report any concerns relating to modern slavery or unethical conduct.
Concerns can be raised confidentially by contacting:
Email: contact@eftwinston.co.uk
All concerns will be treated seriously and investigated appropriately. We will not tolerate retaliation against individuals who raise concerns in good faith.
7. Training and Awareness
We ensure that senior leadership and relevant personnel understand:
- What constitutes modern slavery
- Indicators of forced labour and trafficking
- Appropriate reporting procedures
As the business grows, we will continue to review whether additional formal training is required.
8. Ongoing Review
This policy is reviewed annually and updated as required to reflect:
- Changes in legislation
- Changes in business operations
- Best practice guidance
Annual Modern Slavery Statement
(For the purposes of Section 54 of the Modern Slavery Act 2015)
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and outlines the steps EFT Winston Ltd has taken during the financial year ending [Insert Year End Date] to prevent modern slavery and human trafficking in our business and supply chains.
During the reporting period, we have:
- Maintained a zero-tolerance policy towards modern slavery
- Reviewed supplier relationships and assessed risk exposure
- Ensured compliant right-to-work checks for all employees
- Continued to operate transparent and ethical recruitment practices
EFT Winston Ltd is committed to continuous improvement in identifying and mitigating modern slavery risks.
This statement has been approved by the Director of EFT Winston Ltd.
Signed:
Director
EFT Winston Ltd
Date: 01/01/26