Company Statements | On a roll sandwich company

Updated April 2026

Purpose and Commitment

On A Roll Sandwich Company (the Company) is committed to promoting gender equity and ensuring fair progression, equal treatment, and equal access to opportunities for all workers. We recognise that fairness in the workplace requires more than equal pay for the same role and includes identifying and addressing structural or systemic barriers that may affect progression and access to higher paid roles.

Gender equity does not require equal representation across all roles; rather, it requires that individuals of all genders have fair and reasonable access to opportunities appropriate to their role, skills, experience, and circumstances. This commitment aligns with UK equality legislation and the principles of the ETI Base Code.

Gender Pay Gap Reporting – Key Evidence

As a large UK employer, the Company undertakes statutory Gender Pay Gap (GPG) reporting annually. The most recent report (snapshot date: 5 April 2025) shows the following outcomes:

Gender Pay Gap

Mean gender pay gap: 7%

Median gender pay gap: 0%

Gender Representation by Pay Quartile

Lower quartile: 33% women / 67% men

Lower middle quartile: 46% women / 54% men

Upper middle quartile: 37% women / 63% men

Upper quartile: 37% women / 63% men

Bonus Pay

Proportion of women and men receiving a bonus: 100%

Mean gender bonus gap: -30.7% (in favour of women)

Median gender bonus gap: 0%

Senior management and the leadership team review these figures annually to identify trends, underlying causes, and potential risks relating to gender equity, progression, and access to higher paid roles. Findings are used to inform workforce planning and development activities.

Identified Equity Risks and Barriers

Analysis of the Gender Pay Gap data indicates that women are under‑represented in higher paid roles and upper pay quartiles, suggesting potential structural barriers to progression rather than unequal pay for the same work.

To better understand these outcomes, the Company has assessed potential barriers across the workforce, including:

Recruitment, selection, and promotion pathways

Access to training, upskilling, and development opportunities

Representation by gender across job levels, functions, and departments

The impact of working patterns, caring responsibilities, and flexible working arrangements

Access to progression opportunities for different contract types, including zero‑hours arrangements

This assessment recognises that equal treatment alone may not always result in equitable outcomes and that differing needs or circumstances may influence access to progression opportunities.

Targeted Actions to Promote Fair Progression

Informed by Gender Pay Gap analysis and wider workforce assessment, the Company has identified targeted and proportionate actions to support fair progression and reduce potential barriers, including:

Open and transparent advertising of internal vacancies and progression opportunities

Clear, objective, and documented criteria for promotion and role advancement

Equal access to training and development opportunities for all workers, regardless of gender or contract type

Management awareness of bias and fair decisionmaking in recruitment, performance assessment, and promotion

Ongoing review of gender representation in senior and higher paid roles

These actions are designed to promote fairness without the use of quotas and remain appropriate to the Company’s operational structure and business needs.

Monitoring and Review

Progress is monitored through ongoing workforce review, annual Gender Pay Gap reporting, and senior management oversight. This statement and the associated actions are reviewed periodically to ensure continued alignment with the Company’s values, operational needs, and UK equality obligations.

The Company’s commitment to gender equity and fair progression is communicated to workers through internal communications and management briefings. Workers are able to raise concerns relating to fairness, progression, or equal treatment through established grievance procedures without fear of retaliation.

Conclusion

Through the use of Gender Pay Gap analysis and broader workforce assessment, On A Roll Sandwich Company seeks to promote gender equity, remove barriers to progression, and support fair access to opportunities for all workers. The Company remains committed to continuous improvement and to maintaining a workplace where progression is based on merit, capability, and opportunity.
Policy Statement April 2026

This Modern Slavery Statement applies to On A Roll Sandwich Company Ltd (the Company) and sets out the steps we have taken, and continue to take, to understand and mitigate the risk of modern slavery and human trafficking within our business and our supply chains. The information in this statement relates to the financial year 2025–2026.

Whilst the Company is not legally required to publish a Modern Slavery Statement under the Modern Slavery Act 2015, we do so voluntarily as part of our commitment to ethical, responsible and transparent business practices. We recognise our responsibility within the manufacturing sector to take a robust and proactive approach to preventing slavery, servitude, forced or compulsory labour and human trafficking.

This statement is informed by the principles of the Modern Slavery Act 2015, relevant UK employment legislation, the UN Guiding Principles on Business and Human Rights, and the Ethical Trading Initiative (ETI) Base Code.

Organisational Structure

The Company manufactures fresh and frozen food to go products for a diverse range of customers across the retail, education and healthcare sectors. All manufacturing operations are carried out in the United Kingdom from our production facilities in Middlesbrough, supported by one additional UK distribution site that remains under the control of our manufacturing operation.

Sales of our products are conducted via telephone, email and online channels. Demand for our products remains consistent throughout the year and is not considered seasonal in nature.

The Company operates solely within the UK and is overseen by two shareholders (Director and Company Secretary), supported by an established Senior Management Team.

Risk Assessment

The Company considers the risk of modern slavery within its direct operations to be lower due to the following factors:

UKbased manufacturing and distribution

A predominantly directly employed workforce

Use of GLAAlicensed employment agencies only

Established HR, compliance and management systems

However, we recognise that modern slavery risks can still exist within UKbased operations, particularly in relation to:

Temporary and agency labour

Migrant workers

Upstream supply chains such as raw ingredients, packaging and outsourced services

We therefore take a cautious and proportionate, riskbased approach to managing potential modern slavery risks.

Commitment

Th Company is committed to maintaining ethical and socially responsible business practices and to upholding the rights and dignity of all workers.

We are committed to:

Prohibiting forced labour, bonded labour, and human trafficking

Not employing child labour

Providing safe, hygienic and respectful working conditions

Ensuring fair pay, at or above statutory requirements

Preventing discrimination and promoting equality

Respecting freedom of association

We do not knowingly enter into trading relationships with organisations, in the UK or elsewhere, that support or are found to be involved in slavery, servitude or forced or compulsory labour.

Governance and Accountability

Overall responsibility for preventing modern slavery and human trafficking rests with the Senior Management Team, with daytoday oversight delegated to responsible managers within HR and site management.

Performance and risk are reviewed annually, and whenever there are significant changes to our operations, labour model or supply chain.

People

The Company actively encourages all workers to raise concerns related to ethical issues, including modern slavery. We promote an open management culture where individuals feel confident to speak up. A formal Whistleblowing Policy is in place across all sites and applies to permanent and agency workers alike.

Modern slavery awareness forms part of our induction process for both permanent and agency workers. Employees are provided with information on how to identify potential indicators of exploitation and how to report concerns confidentially.

We use publicly available guidance and awareness materials from initiatives such as Stronger Together to support worker awareness of modern slavery risks and reporting routes.

Over 85% of our workforce is now employed on permanent contracts. Where temporary labour is required to meet production demands, employment agencies play an important role; however, these agencies are carefully selected, approved and regularly reviewed. We only work with agencies that hold a valid GLAA licence.

The Company strictly adheres to the minimum standards required under relevant employment legislation in the UK 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

The Company’s supply chains include the purchase of food ingredients, packaging materials, and a range of goods and services from suppliers based in the UK and abroad.

We seek to work with suppliers who share our commitment to ethical trading and responsible labour practices. Our approach to supply chain due diligence includes:

Supplier self-assessment questionnaires

Risk based supplier reviews and audits

Ongoing engagement with suppliers where elevated risks are identified

Requesting suppliers to adopt their own Modern Slavery or Ethical Trading policies

Encouraging suppliers to use GLAA licensed labour providers

We recognise that certain countries and commodity sectors may present a higher inherent risk and continue to develop our due diligence processes to address these risks proportionately.

To date, The Company is not aware of having conducted business with any organisation that has been found to be involved in modern slavery or human trafficking.

Actions Taken to Prevent Modern Slavery

During the 2025–2026 financial year, The Company has continued to strengthen its approach by:

Reviewing supplier contracts to include termination rights where modern slavery risks are identified

Assessing and monitoring labour providers and recruitment practices

Maintaining a zerotolerance approach to modern slavery and providing modern slavery awareness training where appropriate

Enhancing our management systems through SEDEX membership and selfassessment

Implementing a Human Rights & Ethical Trading Policy to reinforce expectations internally and across our supply chain

Measuring Effectiveness

The effectiveness of our approach is monitored through a combination of qualitative and quantitative indicators, including:

Regular review of labour providers

Supplier risk assessments and engagement activity

Use of whistleblowing and grievance mechanisms

Outcomes of internal and external audits

Any concerns raised are investigated promptly and appropriate action taken.

Review and Approval

This statement is reviewed annually and updated to reflect changes in our business, supply chains and risk landscape. It has been reviewed by the Senior Management Team and approved by the Managing Director, demonstrating The Company’s ongoing commitment to responsible business conduct and continuous improvement.
Updated April 2026

Policy Statement

On A Roll Sandwich Company Ltd. (the Company) is committed to respecting and upholding human rights across all its operations and throughout its supply chain. This commitment is informed by UK legislation, including the Human Rights Act 1998, the Equality Act 2010, and the Modern Slavery Act 2015, and aligns with internationally recognised standards such as the UN Guiding Principles on Business and Human Rights and the Ethical Trading Initiative (ETI) Base Code.

Scope

This policy applies to all individuals working for or on behalf of the Company, including employees, agency workers, contractors, suppliers, service providers, and business partners. The Company expects its suppliers and partners to operate in a manner consistent with the principles set out in this policy and to take appropriate steps to uphold human rights within their own operations and supply chains.

Our Commitments

The Company is committed to:

Prohibiting all forms of forced, bonded, or involuntary labour, including human trafficking and modern slavery

Preventing the use of child labour in line with UK law and applicable international standards

Providing a workplace free from discrimination, harassment, bullying, intimidation, and abuse

Respecting the rights to freedom of association and collective bargaining, in accordance with applicable law

Paying wages that meet or exceed the National Minimum Wage or National Living Wage, as applicable

Providing safe, healthy, and hygienic working conditions for all workers

Responsibilities

Senior management has overall responsibility for the implementation and oversight of this policy. All employees are expected to comply with its principles in their daytoday activities. Suppliers and business partners are encouraged to adopt comparable standards where appropriate and to ensure compliance within their own operations.

Grievance and Reporting

All workers have the right to raise concerns or report potential or actual human rights issues confidentially and without fear of retaliation. Concerns may be raised in accordance with the Company’s grievance procedures or through appropriate management channels. The Company is committed to investigating all concerns promptly, fairly, and appropriately, and to taking corrective action where required.

Approval, Review, and Continuous Improvement

This Human Rights Policy Statement has been approved by the Managing Director and demonstrates the Company’s commitment to ethical trading, responsible employment practices, and respect for human rights. The policy is reviewed annually and updated as necessary to ensure it remains effective, reflects changes in legislation and business operations, and responds to the Company’s evolving risk profile.

This policy operates alongside the Company’s Modern Slavery Statement, which sets out the specific steps taken to identify, assess and mitigate risks of modern slavery and human trafficking.