QUALITY SYSTEM REV

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1 REV

2 Quality at Modecor products service A feature A value REV

3 Our businesses Develpoment and production of cake decorations in sugar, sugar paste, wafer and chocolate. Trading under own brand of products for pastry made of chocolate, sugar, wafer, products based on starchy raw materials and of non edible cake decorations. Internal Organization, Working group Sales Manager Quality Assurance Manager Purchasing Manager Product Research & Development Manager Modecor provides all information product with relevant declarations of compliance with the European rules. Sensitive information about the composition / recipe of the product will not be available. REV

4 QUALITY POLICY Modecor Italiana Srl Chief Executive pursues following goals: Guarantee and improve food safety of our products due to the certifications obtained Keep the full implementation of the Organizational Model 231 Guarantee a constant intrinsic quality of our products Maintain and increase the hygiene, storage, order and cleanliness Maintain the leading position in the field of decoration Develop new products and services Improve technical performances of the company Improve working methods and internal communication Develop the skills of our employees Optimize relationship with our suppliers Ensure sustainable development Define and reach the required level of training REV

5 Biological Contamination Animal pests Microorganisms present in the environment Microorganisms carried by operators Microorganisms present in raw materials Chemical Contamination Hazard Identification Risk Assestment Chemicals substance used for maintenance / cleaning of the plants and processing machines Transfer of chemicals from primary packaging material The presence of additives (the maximum quantity of use) Contaminants such as pesticide residues, heavy metals, Ochratoxin A in raw materials Allergenic substances present in the RM, ingredients and / or cross-contamination Chemical components migration contained in the pack Physical Contamination Foreign bodies in the raw materials Foreign bodies in the primary packaging material From the working area/ processing plants (eg. metals: ferrous, non-ferrous metals, steel from operators REV

6 CCP CCP1 LABELLING- ALLERGENS CCP2-METAL DETECTOR Ferrous /Non Ferrous 1,5mm stainless steel 2,0 mm Ferrous /Non Ferrous 2,0mm stainless steel 2,5 mm QUALITY SYSTEM CCP Critical Control Point Area Labelling Department Labelling Department Ferrous /Non Ferrous 1,2 mm stainless steel 1,8 mm Ferrous /Non Ferrous 1,0 mm stainless steel 1,5 mm Preparto intubettatrice Sugar Paste Department CCP 3 -BRIX DEGREES CCP4- ph Gelatine Department Gelatine Department The monitoring of the CCP carried out using methods and frequency established based on risk assessment. Any other monitoring on request will be charged to the applicant Metrological control (e) from January 2016 Law 690/1978 and subsequent amendments Approved scale checkweigher Division 0.2 g Department of positioning Gelatine and sugar paste REV

7 MICROBIOLOGICAL ANALYSIS Units of measurement UFC/g QUALITY SYSTEM ANALYTIC PLAN Chemical and Microbiological Analysis Frequency Laboratory Method Total Bacterial Count Enterobacteriaceae E.Coli Staphylococcus coagulase + Yeast and mold Listeria monocytogenes Salmonella TWO-MONTHLY FOR EACH CATEGORY OF PRODUCT (Own production, Purchased, Raw Materials) External (Accredia) ISO :2013 ISO :2004 ISO :2001 UNI EN ISO :2004 ISO :2008 ISO :1996/Amd. 1:2004 ISO 6579:2002/Cor. 1:2004 Ecl. p.to The values and limits of reference are contained in the Technical Data Sheets Any more restrictive limits must be agreed in advance between the parties The costs and timing may vary according to the choice of Analysis Laboratory Any specific analytical requests not included in this document will be handled at customer s charges. REV

8 CHEMICAL ANALYSIS Samples Frequency Laboratory Method Degrees Brix Gelatine CoA =Measured on each batch and reported on the Internal MP/C/751 REV ph Gelatine certificate of analysis / accordance with delivery if required MP/C/818 REV Aw Gelatine CoC = Given in compliance standards. Measured regularly, but not every batch Internal and/or External MP/C/7502 REV Viscosity apparent Gelatine Internal or external Absorbance Gelatine Internal Environmental and Hanheld Swabs From production departments Measured regularly every three-months External Microbiology Surface Hygiene Swabs and clothes From production departments Weekly Yearly (validation of internal method) Production operators External Internal Gluten Research (ELISA) From Gluten Free production department Monthly Yearly (validation of internal method) External Elisa MO 0340 REV Method RI DA Check From Gluten Free production department For mix production ( from «gluten» to «gluten-free») Production operators Method RI DA Check 8

9 Others analysis Sample Frequency Laboratory Method Colours (the maximum quantity of use) Products in self production - purchase 3 times / year 2 times / year External (Accredia) External (Accredia)+ Certified suppliers MP 0491 REV Ocratoxina Chocolate Products 1 times / year/supplier External (Accredia)+ Certified suppliers MP 0028 REV Pesticide residues Products in self production - purchase 2 times / year External (Accredia)+ Certified suppliers Different for each detecting Allergenic substances Products in self production - purchase Raw materials Washing water 1 times / year For validation allergens according to the production line / department External(Accredia) Different for every allergen GMO Products in self production - purchase 2 times / year External (Accredia)+ Certified suppliers MP 0348 REV Peroxides Raw materials 1 times / year/supplier External (Accredia)+ Certificato fornitori REG CEE 2568/1991 Heavy Metal Products in self production - purchase 2 times / year External (Accredia)+ Certified suppliers MP 1289 REV Water from the mains Departments 1 times/year Montly External (Accredia)+ Validation municipal analysis publications APAT CNR IRSA 2020 A Man APAT CNR IRSA 2050 Man

10 PREVENTION OF FOREIGN BODIES Supplier Qualification (raw materials and packaging materials) Metal Detector (CCP2) Rules of behaviour (training) Pest Control (rodent and pest prevention and control, internal inspection by an expert in pest control) Glass and hard plastics (prevention and monitoring in accordance with the procedures) Food Defence (training and intrusion simulation, specific procedure) Internal audits and hygiene inspections (monthly) REV

11 PEST CONTROL PEST PREVENTIVE ACTION FREQUENCY MONITORING RODENTS Cleaning and hygiene control, non toxic bait placement internally and externally, maps updates Internal daily Every two months by specialist FLYING INSECTS Insect LightsTraps : UV rays (outdoor areas) and sticky traps (departments). Door locks, brushes close gaps, mosquito nets Internal monthly Every two months by specialist CRAWLING INSECTS Sticky traps Internal daily Every two months by specialist REV

12 Supplier Qualification Guarantee that materials, products and services supplied are appropriate for the level of quality required Careful examination of the incoming goods (Quality Control) Arrangement for a control plan/ supplier qualification that starts from product delevopment process Sending a preliminary knowledge questionnaire and consequent checks on food safety Control of finished products and raw materials (Ingredients, physical and organoleptic characteristics microbiological limits, presence of allergens,conservation conditions, nutrition tables, information GMOs, shelf life, colourings compliance of packaging, etc., according to the current mandatory regulations). Sampling Plan scheduled for analysis. Packaging (Compliance with mandatory regulations for food contact (MOCA), see "Regulations." Release of the "Declaration of Conformity" in Annex IV of Regulation 10/2011. Migration tests available (if sent by the supplier to Modecor).Otherwise charged to the applicant with reference to the table below REV

13 DETERMINATION OF OVERALL MIGRATION Reg.10/2011 Simulant Specific Conact in Cost Timing Simulant A Ethanol to 10%. Aqueous foods with ph >4,5 105,00 Outcomes whitin 21 calendar days considering 10 days in contact Simulant B Acetic acid 3% Aqueous foods with ph > 4,5 105,00 Outcomes whitin 21 calendar days considering 10 days in contact Simulant C Ethanol to 20%. Foods Containing Alcohol and food with many organic ingredients 105,00 Outcomes whitin 21 calendar days considering 10 days in contact Simulant D1 Ethanol to 50% Foods Containing Alcohol > 20% and emulsions of oil and water 105,00 Outcomes whitin 21 calendar days considering 10 days in contact Simulant D2 Vegetable oil Food with dry fat on the surface 220,00 Outcomes whitin calendar days considering 10 days in contact Simulant E MPPO Dry Food, only for specific migration testing To be evaluated according the type of material Outcomes whitin 21 calendar days considering 10 days in contact Bisphenol A Acetonitrile Food 95,00 Outcomes withing 10 working days considering 24 hours in contact. REV

14 HACCP Statement This product is manufactured in accordance with the requirements of Regulation (EC) 852/2004 on food hygiene. To ensure conformance to legislative requirements, all production processes undergo a periodic HACCP study. GMO Statement We confirm that the products we deliver are NOT derived from genetically modified raw materials. Neither additives nor processing aids which may result from GMOare used. Therefore: Our product is non GMO and we are not subject to mandatory labelling according to EU directives 1829/2003/EC and 1830/2003/EC. If the actual situation should be changed, we will inform you in accordance with the legal requirements Statement on CONTAMINANTS We confirm that our products compel with the REGULATION (EC) No 315/93 of 8 February 1993 laying down Community procedures for contaminants in food and the REGULATION (EC) No 1881/2006 of 19 December 2006 setting maximum levels for certain contaminants in foodstuffs and consequent amendments. IONIZING RADIATION statement We confirm that our products are not treated with ionizing radiation energy. If the actual situation should be changed, we will inform you in accordance with the legal requirements. Statement concerning PESTICIDES We confirm that our products are manufactured according to the current European Regulations concerning pesticides. If the actual situation should be changed, we will inform you in accordance with the legal requirements. REV

15 ALLERGEN statement Statement of the allergen present as an ingredient and Cross Contamination declaration on all finished products made on the same production line. The Allergens Policy is supported by a specific procedure that ensures the management of each stage in the production process, including hygiene, standards of staff behavior and check of the effectiveness of cleaning. The allergens list in this data sheet is in accordance with the Annex llla of the European Directive 2000/13 / EC on the labeling of foodstuffs, amended by Directives 2003/89 / EC and 2007/68 / EC. GLUTEN FREE statement Modecor presents a wide range of gluten free products according to the Regulation (CE) N. 41/2009 of 20/01/2009 concerning the composition and labelling of foodstuffs suitable for people intolerant to gluten. The raw material is by nature free of prolamins responsible for hypersensivity against gluten. / Any cross contamination with cereals containing gluten (wheat, rye, barley, oats, spelt, kamut or their hybridised strains) and products thereof is prohibited in the production process. Statement on PACKAGING MATERIAL All the package used are suitable to contain foodstuffs, because they are made with materials meeting the requirements of the DM , subsequent amendments and additions. If the actual situation should be changed, we will inform you in accordance with the legal requirements. TRACEABILITY Compliance with Regulation EC 178/2002 on traceability of food products. Ensuring immediate action in case of food alerts (Crisis Unit and speedy computer system) DECLARATION OF NET QUANTITY/WEIGHT OF THE PRE-PACKAGED PRODUCT E.E.C Declaration of net quantity of the pre-packaged product will be provided only for products where required by law 690/1978 and subsequent amendments. REV

16 Regulations (and subsequent amendments and additions) Non edible Regulations (and subsequent amendments and additions) Non edible Regulation No 1935/2004/ EC materials and items meant to come in contact with food Regulation 1895/2005/ EC Epossodici Use (Dangerous Chemical Substances) Regulation 1907/2006/ EC Chemical Substances REACH Regulation 10/2011/ EC Migration test for plastic material ( statement of complaince in accordance Annex IV) Regulation 2023/2006/ EC Good manufacturing practice of items meant to come in contact with food Directive 2009/48 CE Toys Compliance with standards EN 71/1-2-3 (Chemical Requirements) D.M.21/03/1073 and subsequent updates and changes (rubber, cellulose, paper and cardboard, glass, steel, silicone) Decreto Lgs.76 /2007 (steel) DPR 777/1982 and subsequent updates and changes Directive 2009/48/EC Directive 2011/65/EC (rohs) and standars EN (electrical components) Reg.2005/84 EC Absence of Ftalati DPR 777/82 materials and items which are not yet in contact with food 178/2002 Traceability Regulations (and subsequent amendments and additions) Edible Reg.1169/2011 EC information of food to costumers (labelling) Reg.2003/89 EC Allergens Reg.1829/2003 EC Reg /2008 EC Flavourings 2001/111/EC Sugar and fructose 690/1978 Metrological control 178/2002 Traceability Standard Reference Sources, The Codex Alimentarius Guidelines, Technical Standards (certifications) Trade Magazine, EFSA, UNI, EUR-LEX portal, AIFLE (Food Labelling Expert Association), RASFF, Food Global Incident Map, Global portal on product recalls, Food safety/official controls food fraud REV

17 Our price includes Products having high Quality standards Meeting the expectations of customers relying on Modecor Quality Periodic study of new products joined the exclusive for each channel / sector Intention and capability to change to keep up with markets in progress Capability to do it quickly Ethics Motivation Return of the costs occurred «Quality» means doing it right when no one is looking at you REV