This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act

2015 and relates to actions and activities for the financial year ending 05 April 2021.

Winners Media Limited (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking

violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our

supply chain to comply with our values.

Organisational structure

Winners Media Limited has business operations in the United Kingdom.

We operate in the Gambling sector. The nature of our supply chains is as follows: We work with a number of suppliers such

as outsourced content writers and web hosting providers.

For more information about the Company, please visit our website:


We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

Supplier code of conduct – We operate this policy to ensure our suppliers operate in full compliance with the laws,

rules and regulations of the countries in which they operate, and to seek similar commitments across their own supply


Staff code of conduct – We are committed to the fair treatment of all staff. Our staff code of conduct reflects our

core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to

modern slavery.

Safeguarding policy – This policy highlights the potential risks of modern slavery and human trafficking, including

how to identify signs of exploitation and how to report concerns.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we

have adopted the following due diligence procedures:

Internal supplier audits.

Our due diligence procedures aim to:

Identify and action potential risks in our business and supply chains.

Monitor potential risks in our business and supply chains

Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in

its UK supply chain through:

Evaluating the slavery and human trafficking risks of each new supplier.

Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We do not consider that we operate in a high-risk environment because The business operates in this risk level environment

because the majority of our supply chain is based in the UK and in low-risk industries, such as web hosting and services.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our

policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.


The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human

trafficking is not taking place in its business and supply chains. These KPIs are as follows:

We will contact suppliers to enquire about their modern slavery practices every 12 months.

The statement was approved by the board of directors.

Matthew Kennedy, Director

Winners Media Limited

Date 19th January 2022