Modern Slavery Statement covering 2022/23 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.
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
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.
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.
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.
As part of employee training, we ensure they stay well-informed about modern slavery issues. Throughout this financial year, we’ve made significant strides in raising awareness of modern slavery at all our locations by directing employees to relevant resources. Moreover, 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.
To further strengthen our approach, the HR department proactively contacted the modern slavery helpline, which provided essential information and guidance on how to handle situations where employees might be at risk of modern slavery. This ensures that we are better equipped to address such concerns effectively.
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