Human Rights Statement 2026 is available to download by clicking the PDF icon to the left.
Human Rights Policy Statement
April 2026
This policy is non-contractual
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.
Modern Slavery Statement 2026 is available to download by clicking the PDF icon to the left.
Modern Slavery Statement
April 2026
Policy Statement
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.
