Modern Slavery Statement covering 2021/22 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 take 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 all 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 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

Suppliers that source from high-risk countries are asked to join SEDEX. SEDEX is a non-profit organisation dedicated to driving improvements in responsible and ethnical practices in global supply chains. For those suppliers who are not SEDEX registered, a questionnaire is conducted to ensure they commit the above code of business conduct.  In addition, during own our audits our technical teams are required to engage and have visibility over seasonal workers. We also ensure that these sites audit their own agencies.

Our haulier and third-party storage suppliers are assessed against the above code of business conduct and given a risk rating to determine if further investigation is required prior to supplier approval.

Our recruitment agencies that supply workers directly associated with food production are GLAA Licenced. GLAA, or The Gangmasters and Labour Abuse Authority, is the foremost intelligence and investigative agency for labour exploitation in the UK.

Our policies

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

Whistleblowing Policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act, including minimum wage requirements and zero tolerance towards child labour.

Equal Opportunities Policy. This policy makes clear Rondanini’s commitment to equal opportunities, non-discriminatory procedures, and practices.

Health and Safety Policy. This policy outlines Rondanini’s commitment to the management of health and safety.

Data protection Policy. This policy states our commitment to the data protection principles and ensures we control how personal information is used responsibly within our organisation.

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 practices.

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

Training

Employees are expected to keep up to date with modern slavery information. In this financial year, the HR Director responsible company policies attended a two-day modern slavery programme to guide internal employees on how to spot the signs of modern slavery both in the supply chain and in the workforce. All managers are trained in how to conduct right to work checks internally.

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.

This statement was approved by the Board of Directors