Modern Slavery Statement covering 2023/24 financial year.

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that
Rondanini UK Ltd has taken and is continuing to take to ensure that modern slavery or human
trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking, and forced labour. Rondanini UK
Ltd has a zero-tolerance approach to any form of modern slavery. We are committed to acting
ethically and with integrity and transparency in all business dealings and to putting effective systems
and controls in place to safeguard against any form of modern slavery taking place within the
business or our supply chain.

Our business

Rondanini UK is part of the Vita Food Group and takes pride in manufacturing and importing high-
quality fine foods, supplying leading retailers in the UK and Europe.

We recognise that our business has collective responsibilities in the way that we operate and,
specifically, in which organisations we choose to do business with. As an organisation, we must
ensure that al businesses we deal with honour the following principles.

Code of business conduct

  • Employment should be freely chosen
  • Workers should have freedom of association
  • Workers rights to collective bargaining are respected
  • Working conditions should be safe and hygienic, and a Health and Safety policy should be in place
  • Child labour must not be used
  • Minimum wage requirements are met
  • Discrimination should not be tolerated
  • Workers are not subjected to harsh or inhumane treatment
  • Workers are trained and developed as appropriate
  • Quality Policies are in place and are adhered to
  • Equal Opportunities Policies are in place and are adhered to

Our high-risk areas

In areas deemed high-risk, suppliers who source from such countries are requested to become part
of SEDEX, a non-profit organisation dedicated to promoting responsible and ethical practices in
global supply chains. For suppliers not registered with SEDEX, we administer a questionnaire to
ensure their commitment to our code of business conduct.

During our internal audits, our technical teams actively engage with and monitor seasonal workers,
ensuring transparency and compliance at their sites. Moreover, these sites are required to conduct
their own audits on the agencies they work with.

When evaluating our haulier and third-party storage suppliers, we assess their adherence to the
code of business conduct and assign a risk rating. Based on this rating, further investigations may be
undertaken before granting supplier approval.

For recruitment agencies supplying workers directly associated with food production, we only work
with those holding a GLAA License. The GLAA, or The Gangmasters and Labour Abuse Authority, is
the UK s primary intelligence and investigative agency combating labour exploitation. This ensures
that the workers we employ are protected and treated fairly.

Our policies

To uphold ethical and transparent business practices, we have implemented several internal policies,
each serving a specific purpose:

  • Recruitment Policy: Our robust recruitment policy includes comprehensive checks on
    eligibility to work in the UK for all employees. This measure helps safeguard against human
    trafficking or any form of coerced labour.
  • Whistleblowing Policy: Our organisation maintains a whistleblowing policy, encouraging all
    employees to voice concerns regarding colleague treatment or practices within our business
    or supply chain. We assure them of protection from any reprisals for speaking up.
  • Code of Business Conduct: Our code sets out the standards of behaviour expected from our
    organisation, employees, and suppliers. It covers aspects such as adhering to minimum wage
    requirements and adopting a zero-tolerance approach towards child labour.
  • Equal Opportunities Policy: Rondanini is committed to promoting equal opportunities and
    non-discriminatory practices, as outlined in our equal opportunities policy.
  • Health and Safety Policy: Our commitment to health and safety management is laid out in
    our policy, ensuring the well-being of all individuals associated with Rondanini.
  • Data Protection Policy: We prioritise data protection and adhere to data protection
    principles, ensuring responsible use of personal information within our organisation.

Through these policies, we strive to create an ethical and transparent work environment, fostering
trust and accountability at all levels.

Our suppliers

Rondanini UK Ltd conducts due diligence on all suppliers before allowing them to become a supplier,
and where required conducts on-site audits which include a review of working conditions and

Rondanini’s expectations of our suppliers, as it relates to modern slavery compliance, form part of
the agreement with our suppliers.

The agreement states:

The supplier undertakes, warrants and represents that neither the supplier nor any of its officers,
employees, agents or subcontractors has:

(a)       committed an offence under Anti-Slavery Laws (a Slavery Offence); or

(b)       been notified that it is
subject to an investigation relating to an alleged Slavery Offence or prosecution under Anti-Slavery
Laws; or

(c)       is aware of any circumstances within its supply chain that could give rise to an
investigation relating to an alleged Slavery Offence or prosecution under the Anti-Slavery Laws;

Any breach of this clause of the supplier agreement shall be deemed a material breach and
Rondanini will terminate the agreement with immediate effect.


As part of employee training, we ensure they stay well-informed about modern slavery issues. We
have prominently displayed posters of the modern slavery helpline and whistleblowing policy in staff areas, making it easily accessible. These resources are available in both English and Polish, catering
to the two primary languages used in our business.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human
trafficking is not taking place within our business or supply chain if:

  • No reports are received from employees, the public, or law enforcement agencies to
    indicate that modern slavery practices have been identified.

Our 2023/24 performance

  • In the 2023/24 financial year there have been no reports received from employees, the
    public, or law enforcement agencies to indicate that modern slavery practices have been

This statement was approved by the Board of Directors