Rocket Rose

Modern slavery statement

The steps Rocket Rose and its businesses, Culinera, Thomas & Tate and Nimbyx, take to ensure that modern slavery and human trafficking have no place in our operations or our supply chains.

Our business

Rocket Rose Holdings Limited ("Rocket Rose") is the independent group behind Culinera, Thomas & Tate and Nimbyx. Culinera creates restaurants in schools, providing freshly prepared, nutritious food for primary, secondary and independent schools and multi-academy trusts. Thomas & Tate provides high performance hospitality for business and industry: workplace restaurants, cafes and delis, client dining and reception management. Nimbyx builds the technology that runs both. Rocket Rose is owned and run by the people who work in it, with Base Camp in Little Chalfont, Buckinghamshire.

Across the group we work with many partners, stakeholders and suppliers, from the farms, butchers, bakers and wholesalers who supply our restaurants, to the agencies, equipment, uniform, cleaning and software providers that support them. We are committed to a zero-tolerance approach to slavery and human trafficking in every part of our operations and our supply chain.

Introduction

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps Rocket Rose and its businesses have taken, and continue to take, to ensure that modern slavery and human trafficking are not taking place within our business or our supply chains. Hospitality relies on people, and some of the roles and supply chains in our industry carry a higher risk of exploitation than others. We are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.

This statement covers Rocket Rose Holdings Limited and each of the businesses in the group, including Culinera Limited and Thomas & Tate. Each business applies the policies and processes described here.

Relevant policies

We operate the following policies that describe our approach to identifying modern slavery risks and the steps to be taken to prevent slavery and human trafficking in our operations.

• Whistleblowing policy. We encourage all team members, customers and business partners to report any concerns related to the direct activities, or the supply chains, of any Rocket Rose business. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy to raise a concern, and to do so without fear of retaliation, including through a confidential disclosure form.
• Code of conduct. Our code of conduct makes clear to every team member the actions and behaviour expected of them when representing a Rocket Rose business. We strive to maintain the highest standards of conduct and ethical behaviour in the way we operate and in the way we manage our supply chain.
• Supplier code of conduct. We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat the people who work for them with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their working practices. Serious violations of the supplier code of conduct lead to the termination of the business relationship.
• Recruitment policy. We use only specified, reputable employment agencies to source labour, and we verify the practices of any new agency before accepting people from that agency. Every person who joins a Rocket Rose business has their identity and right to work in the UK checked, is paid directly into a bank account in their own name and receives a written statement of their terms.

Due diligence

We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include:

• mapping the supply chain of each business to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier before we trade with them;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• using our group supplier agreements and Supplier Rules of Engagement to set out the standards we expect, with appropriate sanctions, including termination, for suppliers that fail to improve their performance in line with an agreed action plan or who seriously violate our supplier code of conduct.

Training

We require every manager in a Rocket Rose business to complete training on modern slavery as part of our wider human rights and ethical trade programme. The training covers:

• our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to the various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant people within the business;
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and Stronger Together initiative;
• what messages, business incentives or guidance can be given to suppliers and other business partners to implement anti-slavery policies;
• what steps should be taken if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.

Awareness-raising programme

As well as training managers, we raise awareness of modern slavery issues with every team member through induction, team communications and our internal platforms. These explain the basic principles of the Modern Slavery Act 2015, how team members can identify and prevent slavery and human trafficking, what to do if they suspect slavery or human trafficking within any part of our business or our supply chains, and what external help is available, for example through the Modern Slavery Helpline.

Review

This statement is reviewed by the board of Rocket Rose Holdings Limited every year, and updated whenever a change in the business or its supply chains requires it. We monitor the effectiveness of the steps described above and take corrective action where it is needed to ensure that we remain compliant with the Modern Slavery Act 2015 and that our approach continues to reflect the standards we hold ourselves to.