Gender Pay Report 2024

Modern Slavery Statement

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Updated July 2024

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Policy Statement

This statement applies to On A Roll Sandwich Company Ltd and sets out the steps we will take to understand all potential modern slavery risks related to its business and which are aimed at ensuring that there is no slavery or human trafficking in its own business or throughout its supply chains.  The information in this statement refers to the financial year 2023-2024.

 

Whilst we have not been required to publish a modern slavery statement by legislation in previous financial years, our own moral standards of trading means that we have published statements which are available to view on our website.  We will continue to adhere to the necessary demands of the Modern Slavery Act 2015 and we have taken steps to ensure that such slavery/human trafficking does not take place in our business nor the business of any organisation that supplies goods and/or services to On A Roll Sandwich Company Ltd (OAR).  Within the manufacturing sector, we recognise that we have a responsibility to take a robust approach to prevent slavery and human trafficking. 

 

Organisational Structure

OAR manufactures fresh and frozen food-to-go products for a diverse range of markets, including the retail, education and healthcare sectors.  The sale of the aforementioned goods takes place on the telephone, by email and online. Demand for our products is consistently high throughout the year and therefore we would not describe it as seasonal in nature.  All manufacturing is carried out in the United Kingdom, from our production facilities in Middlesbrough.

 

OAR considers itself to be at low risk from modern slavery.  We operate from two locations in the UK, where protection against breaches of human rights can be limited.  We have one additional distribution site in the UK, which remains under the control of our manufacturing location.  OAR has two shareholders (a Director and Company Secretary) with a senior management team in place.

 

Commitment

As part of our ongoing commitment to maintaining ethically and socially responsible behaviour throughout our operations, we adhere to high standards of labour rights.  We continue to operate responsibly and demonstrate continual improvement in:  providing working conditions which are safe and hygienic; not employing child labour; ensuring that living wages are paid and that we provide regular employment to our workers which is safe from discrimination.

 

In acknowledging our responsibilities in relation to tackling modern slavery, we commit to complying with the provisions in the Modern Slavery Act 2015 and understand that this requires an ongoing review of both internal practices in relation to our workforce and additionally our supply chains. 

 

OAR does not enter trading relationships with any organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

 

People

We actively encourage our people to report any ethical concerns they have, particularly with regard to Modern Slavery.  We have an open management culture in which everyone is able to speak up where they have concerns but we also operate a whistleblowing system, which is available to all at each of our sites.  We have also recently started to promote the Stronger Together initiative at each of our sites, in order to ensure greater awareness of Modern Slavery issues.

 

We have achieved positive changes to our labour employment model and over 89% of our team are now employed on permanent contracts of employment.  To respond to peaks of production in a fast-paced working environment, employment agencies providing temporary labour perform a key role in ensuring our success but these agencies are carefully sourced and approved only where they are able to demonstrate that they have a GLAA licence in place.  We recognise that there is a particular vulnerability associated with the nature of agency work but our labour providers have worked with us for a number of years and we ensure that we carry out regular reviews with them to continually assess our partnerships.

 

Our induction processes for both permanent and agency workers include information on how to identify modern slavery and we provide information on how to report any suspected cases or raise concerns.

 

OAR strictly adheres to the minimum standards required under relevant employment legislation in the United Kingdom and we have further embedded our employment principles by completing a self-assessment questionnaire for our facilities as part of our SEDEX membership, which is available to our customers to review, where required.

 

Supply chains

In order to fulfil our activities, the main supply chains of OAR include those related to the purchase of fresh foods and raw material packaging and other goods and services from third party suppliers in the UK and elsewhere.  We strive to conduct business with third party suppliers who share our commitment to high ethical standards and who operate in a responsible and ethical manner towards their workers and suppliers.

 

We choose our suppliers with care, acknowledging the importance of the Modern Slavery Act in the context of our supply chain.  Indeed, we ask our suppliers to complete self-assessment questionnaires and we conduct audits defined by risk assessment according to questionnaire scores.  We also ask that our suppliers use GLAA approved agencies in the employment of their own labour.  We acknowledge the elevated risk of modern slavery in certain countries of the world, including some of those we trade with directly or indirectly and will develop our due diligence and evaluation processes to address those elevated risks appropriately.  We also ask that all our suppliers provide a copy of their own Modern Slavery Policy so that we can manage risk appropriately.

 

OAR may carry out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of our suppliers.

 

OAR has not, to its knowledge, conducted business with another organisation which has been found to have been involved with modern slavery and/or human trafficking.

 

 

In accordance with the Modern Slavery Act, OAR is committed to taking the following steps to ensure that modern slavery is not taking place:

 

• reviewing our supplier contracts to include termination powers in the event that the supplier is, or is suspected to be, involved in modern slavery

• putting measures in place to identify and assess the potential risks in its supply chains

• creating action plans to address the risk of modern slavery, including trend analysis of supplier status

• taking a zero-tolerance approach towards modern slavery

• providing training to staff, where required, regarding modern slavery

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Policies

During this financial year, On A Roll has developed a new recruitment policy which furthers our aims of tackling modern slavery.  We are currently in the process of enhancing our approach to Whistleblowing by developing a new policy (incorporating measures already in place) and by the end of this financial year, we aim to have our new social responsibility policy in place.

 

Compliance

We recognise that the risks from modern slavery and human trafficking change and that efficient methods to identify and address modern slavery and human trafficking will be developed and enhanced.  We will monitor and evaluate such developments and our approach to preventing modern slavery will be reviewed annually so that we can adapt and improve our approach.

 

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, which will be reviewed annually, has been reviewed by the senior management team and has been approved by our Managing Director.