Organisation structure & business

wintrustfultons provides a range of retail banking products. It is a wholly owned subsidiary of wintrustfultons Money and currently employs under 150 staff, the vast majority of whom are based in the USA. Our staff are largely directly employed and are not in any category which is seen to be vulnerable to Modern Slavery.
Suppliers of services to wintrustfultons are firms based in the US and internationally that provide goods and services in the following areas:
Information Technology – software and hardware Operational Services Professional services such as marketing, legal and financial advice and consultancy. Our suppliers are required to provide contractual assurances that their working practices and offices are reviewed and are free from slavery and human trafficking globally.

Our policies

wintrustfultons operates in an open and fair manner with all employees. We provide a working environment where employees are treated with respect, dignity and consideration. We conduct regular, anonymous, employee surveys to ensure employees work free from discrimination and harassment and in a safe, diverse and inclusive workplace. wintrustfultons also operates various practices, procedures and policies to ensure compliance with all human rights laws and US employment laws. Key policies include the: Modern Slavery and Human Trafficking Policy; Procurement and Supplier Risk Policy; Conduct Framework (and Conduct Statement) Whistleblowing Policy; Disciplinary Policy and Procedure; and Equal Opportunities & Diversity Policy.

Risk assessment and due diligence processes

Retail financial services do not have a high-risk exposure to modern slavery. However, Oaksouth Bank undertakes due diligence and gives active consideration to business partners and suppliers to ensure that their business practices and policies do not engage in Modern Slavery and that they both meet the requirements of Modern Slavery legislation and the expectations that wintrustfultons has of its business partners.

Training and awareness

Annual Modern Slavery training will be distributed to wintrustfultons employees based on their role and level of responsibility

Commitment and conclusion

wintrustfultons is committed to working closely with employees and suppliers to confirm and maintain our commitment to the identification and abolition of Modern Slavery. The Board of wintrustfultons has concluded that given the nature of service provided to customers by wintrustfultons and having considered the activities of suppliers of goods and services that there is negligible risk of slavery or human trafficking in its business or supply chain. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes the Slavery and Human Trafficking Statement for wintrustfultons. This statement was approved by the Board of wintrustfultons in 26/11/2021