SQFI Ethical Sourcing

Transcription

1 SQFI Ethical Sourcing EDITION Crystal Drive, Suite 800 Arlington, VA USA Food Marketing Institute. All rights reserved.

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3 Description Page Introduction Scope References Definitions System Requirements 4.1 Commitment Suppliers and Subcontractors Social Management Programs Environmental and Occupational Health & Safety Management Programs Monitoring and Management Review Business Management Principles for Senior Management.. Certification to the Ethical Sourcing Standard. Conflict of Interest Provisions.. Appendix 1: Certification Assessment Requirements 1.0 Scope Ethical Sourcing (ES) Policy ES Objectives, Targets and Management Programs (OTMPs) Development of the Organization s ES Team Suppliers and Subcontractors Social Management Programs Environmental Aspects and Impacts Occupational Health & Safety Hazard Identification & Risk Assessment Recognition of and Compliance with ES-Related Legal & Other 29 Requirements 10.0 Equipment Maintenance Emergency Preparedness and Response Checking to Support Continual ES Performance Improvement Business Management Principles for Senior Management 35 Appendix 2: Implementation and Auditing Guide 1.0 Why We Need a Guide on Ethical Sourcing Responsible Social Practice Responsible Environmental Practice Structure of the Ethical Sourcing Standard Ethical Sourcing Management System Requirements 4.1 Commitment Suppliers and Contractors Social Management Programs Environmental and Occupational Health and Safety Management Programs Monitoring and Management Review Business Management Principles for Senior Management Annexes 1. Social Issues in the Agrifood Industry Social Risk Assessment Toolkit Environmental Issues in the Agrifood Industry Environmental Risk Assessment Toolkit Page 2

4 Appendix 3: Audit Methodology Part A: Implementing and Maintaining the SQFI Ethical Sourcing (ES) Standard Ethical Sourcing (ES) Certification Learn about the SQFI Ethical Sourcing (ES) Standard and Appendices Register in the SQFI Ethical Sourcing Assessment Database Use of Ethical Sourcing Consultants Designate an Ethical Sourcing Management Representative Ethical Sourcing Implementation Training Select the Certification Level Document and Implement the Ethical Sourcing Standard Ethical Sourcing Implementation and Auditing Guidance Document Select a Certification Body Conduct a Pre-assessment Audit The Initial Certification Process Selection of the SQFI-Certified Ethical Sourcing Auditor(s) Identifying the Scope of Certification The Certification Audit ES System Elements Identifying the Scope of the Audit Nonconformities Opportunities for Improvement The Audit Report Audit Duration Guide The Initial Certification Decision Responsibility for the Certification Decision Audit Corrective Actions Audit Score and Rating Granting Certification Failure to Achieve Certification Surveillance and Recertification Suspension and Withdrawal of Certification Maintaining SQFI Ethical Sourcing (ES) Certification Surveillance Audit Recertification Audit Variations to the Recertification Process Suspension of Certification Withdrawal of Certification Obligations of Organizations Seeking Certification and and Certification Bodies Changing the Scope of Certification Changing the Certification Body Change of Ownership Relocation of Premises Language Conflict of Interest Complaints, Appeals and Disputes Page 3

5 Part B: SQFI Ethical Sourcing (ES) Logo - Use and Reproduction Requirements Introduction Conditions for Use Reproduction Obligations of an ES Certified Organization Grounds for Suspending or Ceasing Use of the ES Logo Disclaimer Logo Reproduction Requirements Logo Dimensions Special Cases Part C: Glossary of Definitions and Terms Appendix 4: Auditor Competency 1.0 Fundamentals Registration Category Definitions Overview of Requirements for SQFI Ethical Sourcing Auditor Registration Requirements For Registration Education Training Work Experience Auditing Experience Key Competencies For SQFI ES Auditors General Competencies Ethical Sourcing Competencies Application For Registration Audit Log Sponsors Personal Declaration Application Processing Certificate of Registration and Identification (ID) Card Publication of Registration Appeals Complaints Against Registered SQFI ES Auditors Re-registration of SQFI Auditors Auditing Experience Professional Development SQFI ES Professional Update SQFI ES Auditor Code of Conduct Fundamental Principles Relations with the Public Relations with Their Employer s Colleagues/Clients Relations with Peers Page 4

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7 Introduction The food supply in the 21 st century is characterized by fundamental changes, particularly at the consumer retailer interface. These changes are having a major impact on suppliers. There has been a shift from a food supply that is driven by the producer/manufacturer to a situation in which the consumer has considerable influence. Consumers have higher demands on food products. They want quality, safety, freshness, variety, convenience and a good quality/price relationship. The circumstances under which products are produced and manufactured are of increasing importance to consumers, especially those that impact on the care of labor, the environment and animal-friendly production methods. In response to a growing consumer awareness of employee welfare and environmental conditions in the food sector, consumers are placing greater pressure on suppliers and retailers to raise their standards and performance. In this respect, the consumer is determining who is successful and who is not. The Safe Quality Food Institute s Ethical Sourcing Standard (SQFI ES Standard) is provided for sourcing and supplier organizations whose customers require an independent assessment of their commitment to the implementation of responsible practices related to trading activities, environmental management programs, and social management programs, including those related to occupational health & safety. The SQFI ES Standard provides a core set of requirements that lead a sourcing organization or supplier to document those management systems and procedures/practices that it applies in order to demonstrate that it has implemented Ethical Sourcing in its operations, particularly in the areas noted in the preceding paragraph. While implementation is voluntary, it is necessary to advise sourcing organizations and suppliers that, if they elect to pursue certification to the ES Standard, all elements of the Standard must be addressed. The SQFI ES Standard provides the flexibility for organizations to certify to three levels of implementation. The three levels are discussed in Appendix 1, along with the specific requirements associated with each level of implementation/certification. Level 3 SQFI requirements have been benchmarked with the criterion of the GSCP Reference Code. Mandatory provisions are indicated by the use of the words shall, will and must throughout the ES Standard and Appendix 1. Appendix 2 is provided to help organizations/individuals who are implementing and auditing the ES Standard to better understand the requirements of the Standard. The SQFI ES Standard is not designed to replace other, more extensive codes/standards that apply to the assurance of good social, environmental and occupational health and safety practices. However, ES Standard implementation can be considered as sound footing toward achieving those codes/standards. Please note that the scope of ethical sourcing, as used in the SQFI ES Standard, is limited to management of social/labor and environmental considerations, along with regulatory compliance activities related to these issues. There may be other factors that one may consider ethical (e.g., humane handling of animals); however, those are not addressed in this ES Standard. The standard has embraced references from multiple international codes/standards and from retailers who have developed similar requirements. The provisions of this Ethical Sourcing Standard constitute minimum and not maximum standards. In all instances, the national/state/provincial/local or the SQFI ES Standard requirements, whichever are more protective of employees and the environment, shall apply to those organizations that elect to implement the ES Standard. This reference standard shall not be interpreted as preventing national, state/provincial and/or local legislation or international labor and environmental standards from being Page 8 SQFI Ethical Sourcing Standard April 2017

8 exceeded. Suggestions for improvements to this document and its appendices are encouraged from all users. Please submit suggestions in writing to: SQFI 2345 Crystal Drive, Suite 800 Arlington, VA U.S.A. 1. Scope This standard specifies the requirements for the management of employment, environmental, and safety and health to enable an SQF Certified Supplier to: i. Develop, implement and maintain policies and procedures applicable to ethical sourcing issues that it can control or influence; and ii. Demonstrate to interested parties that it has implemented policies, procedures and practices that conform to the requirements of this standard. 2. References The standard makes reference to the following documents: i. Business Social Compliance Initiative (BSCI), Code of Conduct, Version 3, November 2009 ii. Global Social Compliance Program (GSCP), Reference Code, Version 2, April 2010 iii. Global Social Compliance Program (GSCP), Reference Environmental Requirements, October 2010 iv. Safe Quality Food Institute (SQFI), Code of Conduct for Socially Responsible Sourcing (2nd Edition, 2001) v. Social Accountability International (SAI), Social Accountability 8000 Standard (SA8000), Definitions See Appendix 3, Part C for the terms and definitions applicable to this standard. 4. System Requirements 4.1 Commitment Ethical Sourcing Policy Senior management shall document its Ethical Sourcing Policy outlining the company s commitment to provide and continually improve employment, environmental, and health and safety management practices such that they are in line with national, state/provincial and local laws and agreements and the requirements of this standard The Policy shall be signed by the senior company executive, documented in a Policy Manual and communicated to all staff Senior management shall make the required financial, physical and human resources available so that this policy may be fully implemented Policy and Operational Manual A Policy Manual outlining the policies that the company will implement to meet the requirements of this standard shall be documented. It shall reference an Operational Manual detailing the means by which the company will implement the policies and the procedures established Company Representative(s) A senior company representative shall be appointed to plan and oversee the implementation of the company s ES policy and the requirements of this standard. A job description outlining the responsibility and authority of this position shall be documented The company representative shall appoint individuals or a cross-functional team to Page 9 SQFI Ethical Sourcing Standard April 2017

9 monitor overall performance related to social, environmental, health and safety, and business management practices A job description outlining the responsibility and authority of these individuals/ team members shall be documented Training Appropriate training shall be provided for new/existing personnel carrying out the tasks that are identified in the social management programs, the environmental management plan and the occupational health and safety plan as necessary to maintain the company s commitment to ethical sourcing. Training shall cover: General occupational health, safety and environmental (HSE) induction training; Ongoing training as required by applicable HSE regulations; Instructions outlining how tasks identified in the environmental management plan (EMP) and occupational health and safety plan (OHSP) are to be performed; Topics and tasks required to ensure compliance with the applicable regulations related to employment practices. A training register shall be maintained describing: who has been trained in the relevant areas, who has delivered the training, the content of the training, methods employed to demonstrate competence, and other information as required by applicable national, state/provincial or local regulations. 4.2 Suppliers and Subcontractors Selection of Suppliers and Subcontractors A senior company representative shall be responsible for maintaining procedures for the selection of suppliers and subcontractors and determining their ability to meet the company s ethical sourcing policies and the requirements of this standard Periodic Evaluation of Suppliers and Subcontractors The company shall document its procedure for periodically evaluating the performance of suppliers and subcontractors against the specified requirements. A senior company representative shall be responsible for evaluating, or monitoring the evaluation of, suppliers and subcontractors. Evaluations shall occur: Prior to the awarding of contracts to determine if the supplier or subcontractor can meet the specified requirements; and At appropriate intervals following the award of a contract to verify compliance with the conditions of the contract and the specified requirements Evaluation and Assessment Reports The company shall maintain appropriate records of all evaluations and assessments of suppliers and subcontractors. 4.3 Social Management Programs Discrimination and Harassment Equal Opportunity in Hiring The company shall not discriminate in its hiring of potential employees on the basis of age, gender, religion, marital status, race, caste, social background, disease, disability, pregnancy, ethnic or national origin, nationality, membership in worker organizations including unions, political affiliation, sexual orientation or any other personal characteristic. Page 10 SQFI Ethical Sourcing Standard April 2017

10 Equal Opportunity in Employment With regard to compensation, training, promotion, termination or retirement, the company shall not discriminate against any employee on the basis of age, gender, religion, marital status, race, caste, social background, disease, disability, pregnancy, ethnic or national origin, nationality, membership in worker organizations including unions, political affiliation, sexual orientation or any other personal characteristic Harassment The company shall ensure that employees are not subjected to any sort of bullying, harassment or abuse (sexual, verbal, physical, cyber, etc.) for any reason Wage Compliance The company has a wage compliance program in place which ensures that employee wages, payment cycles, and overtime policies all adhere to applicable national, state/provincial and local regulations, contractual agreements, or International Labor Organization (ILO) Conventions Pay rates (regular and overtime), dates and means of payment, and usual working hours Excessive working hours (>72 hours per week) are not utilized Benefits The company will have a provision in place for employee benefits, as required by national, state/provincial or local regulation Provisions are identified, if applicable, for vacation, holidays and leave (regular, maternity/ paternity, sick, etc.) Fair Labor Practices and Terms of Employment The company shall provide employees documented terms of employment. The document shall address at a minimum: Forced labor is not utilized. Bonded labor is prohibited. Identity documentation must be verified if required by local regulation. Identity papers shall not be bonded to the company by employees Child labor is not utilized except as permitted by national, state/provincial or local regulations, or consistent with ILO Conventions 138 and 182. Minimum age of employment complies with applicable regulations or is in line with ILO Conventions 138 and Employees have the right, as permitted by national, state/ provincial and/or local legislation, to join or form trade unions of their own choosing without prior authorization from management and have the right to bargain collectively. The company shall not interfere with, obstruct, or prevent such legitimate and lawful activities Rights and obligations of both parties as appropriate Conditions for disciplinary action, including suspension and termination. 4.4 Environmental and Occupational Health & Safety Management Programs Environmental Management Plan The company shall evaluate and prioritize its environmental impacts and develop an Environmental Management Plan (EMP) for priority impacts identified through this process. The EMP must specify management objectives, targets and program activities intended to eliminate, control and/or reduce priority impacts, and to identify and comply with applicable regulatory and other requirements (e.g., trade association or community commitments). The tasks, time frames, resources and responsibilities required to meet the nominated objectives and targets shall be identified. At a minimum, the EMP shall include specific details on the following topics, if Page 11 SQFI Ethical Sourcing Standard April 2017

11 applicable to the scope of the organization s ES Program: (1) Energy use and air emissions, including greenhouse gases (GHG) and ozone-depleting substances (ODS) Water consumption Wastewater effluent management; stormwater management Waste management Proper identification, handling, segregation/storage and disposal of waste and waste containers Compliance with regulations/ordinances governing on-site burning/landfilling Implementation of reuse, recycle and reduction actions Pollution prevention Hazardous chemicals inventory Prevention of groundwater Noise and nuisance prevention contamination (community impact) Land/ soil pollution prevention Land use and biodiversity: Impacts of the company on the environment and communities Occupational Health and Safety Management Plan The company shall provide a healthy and safe working environment for employees. The company shall evaluate its occupational health and safety hazards, assess and prioritize their associated risks, and develop an Occupational Health and Safety Plan (OHSP) for priority tasks identified through this process. The OHSP must specify management objectives, targets and program activities intended to eliminate, control and/or reduce priority hazards and risks, and to identify and comply with applicable regulatory/other requirements (e.g., trade association commitments). The tasks, time frames, resources and responsibilities required to meet the nominated objectives and targets shall be identified. At a minimum, the OHSP shall include specific details on the following topics, if applicable to the scope of the organization s ES Program: (1) Results of the risk assessment that identifies/ evaluates all hazards to employee health and safety in the work environment, including hazards related to the usage, storage and transportation of hazardous and potentially hazardous substances; Control measures (e.g., equipment, policies, procedures, etc.) that are appropriate to the industry sector and that, as far as reasonably practicable, eliminate, isolate and/or minimize the priority hazards/risks; Methods to periodically evaluate the effectiveness of these control measures; Procedures to manage risks associated with contractors and visitors; and Safe and clean drinking water, conditions for work, sanitary facilities and, where provided, residential facilities Regulatory Compliance Both the Environmental Management Plan and the Occupational Health and Safety Plan shall ensure: the identification of, and compliance with, all applicable regulations; that all applicable monitoring and recordkeeping requirements are completed; and that all business licenses/ permits are maintained and current Equipment Maintenance All equipment used in the treatment, handling, monitoring and storage of air, waste, Page 12 SQFI Ethical Sourcing Standard April 2017

12 waste water, water, or other elements, as identified within the Environmental Management Plan, shall be included on an inspection, testing and preventive maintenance (ITPM) schedule and have records maintained to verify these activities All equipment utilized to provide healthy and safe working conditions for employees, as identified within the Occupational Health and Safety Plan, shall be included on an inspection, testing and preventive (ITPM) schedule. Records shall be maintained to verify ITPM activities Incident Management An emergency response program shall be in place to respond to an environmental or health and safety incident, including an emergency management team with current contacts, a communications plan for incidents, a current contact list of customers and stakeholders, procedures to manage an emergency response, and at least annual testing of the emergency response program. (1) Further details of the graduated requirements (i.e., Levels 1, 2 and 3) for each referenced EMP aspect are presented in Appendix 1, Certification Assessment Requirements. 4.5 Monitoring and Management Review Internal Audits The company shall schedule, carry out and document regular internal audits to confirm the effectiveness of its implementation of this module. Results of audits shall be brought to the attention of senior management and those responsible for the area being audited, who shall be responsible to ensure that actions are taken in a timely manner to correct all nonconformities identified Monitoring The company must establish and maintain programs to monitor and measure impacts and risks identified as a priority for management. All equipment used for monitoring must be routinely calibrated to accuracy appropriate to its use. Equipment and calibration records must be maintained Investigation of Employee Concerns The concerns of company employees and other directly-involved, interested parties with regard to their working environment and conditions shall be investigated by a senior company representative in a timely manner Corrective and Preventive Action The company shall document a procedure for identifying and documenting the cause and resolution of issues that arise as a result of accidents and incidents, internal audits/reviews and concerns by employees or other parties. Appropriate effective action shall be taken to resolve issues that are raised Recordkeeping The company shall maintain legible records to demonstrate conformity to the requirements of this standard Management Review Senior management shall document the company s procedure for ensuring the continued effectiveness of its policy in relation to the ethical sourcing requirements of this standard. Reviews shall be completed at least annually and shall be the responsibility of senior Page 13 SQFI Ethical Sourcing Standard April 2017

13 management. The outputs of management review meetings (performance results, improvement actions, etc.) shall be communicated to appropriate internal and external stakeholders. 4.6 Business Management Principles for Senior Management Systematic Approach A systematic approach is in place for realizing financial and economic benefits associated with implementation of Ethical Sourcing. Example approaches include, but are not limited to: customer focus, continual improvement, process approach, mutually-beneficial supplier relationships, etc Senior Management Actions This systematic approach is supported by actions on the part of Senior Management such as: Value-added customer focus; Implementing methods to realize financial benefits; Establishing a baseline for financial performance measurement; Establishing a trend analysis to review program performance and continual improvement; Communicating program performance to the organization; and Periodically reviewing the Ethical Sourcing program to ensure its continuing suitability, adequacy and effectiveness. Certification to the Ethical Sourcing Standard Certification to the Safe Quality Food Institute (SQFI) Ethical Sourcing Standard is conducted by certification bodies (registrars) that are licensed by the SQFI. Certification bodies are required to meet specific criteria. The SQFI has prepared a document, titled General Requirements for Certification Bodies Offering Certification of SQF Systems, to outline the requirements for SQF auditors and certification bodies. In addition, SQF auditors must meet specified individual criteria, which include: Completion of ESP systems training; Registration of industry sector under audit; Auditing experience; and Registration as an SQF auditor with SQFI. Following a comprehensive certification audit, recertification audits are conducted annually. The Ethical Sourcing Standard Audit Methodology is presented in Appendix 3. Auditor Competency and Registration requirements are presented in Appendix 4. Conflict of Interest Provisions Conflict of interest provisions form part of internationally accepted procedures and codes/standards to ensure the impartiality of auditors and to maintain the integrity of the third-party audit system. Auditors must disclose to the certification body any existing, former or proposed link between themselves or their organization(s) and the client. The SQFI program outlines requirements for SQF auditors and certification bodies to ensure that there is no conflict of interest with regard to the way in which SQF auditors undertake audits of Ethical Sourcing. Page 14 SQFI Ethical Sourcing Standard April 2017

14 Ethical Sourcing Standard Appendix 1: Certification Assessment Requirements April 2017 Safe Quality Food Institute 2345 Crystal Drive, Suite 800 Arlington, VA USA SQF Institute is a division of the Food Marketing Institute (FMI) Page 15 Appendix 1 SQFI Ethical Sourcing Standard April 2017

15 Page 16 Appendix 1 SQFI Ethical Sourcing Standard April 2017

16 1.0 Scope [Reference: Ethical Sourcing Standard 1.0] Requirements Level 1 Level 2 Level Has the organization's top management defined and documented the scope of their SQF Ethical Sourcing Program? Top management has determined and documented the boundaries of the organization to which the Ethical Sourcing (ES) Program applies. The scope of the program covers all operations and activities that are under the control of the organization, spanning from selection of raw materials to sale or shipment of finished products (depending on the nature of the business). Once this scope has been determined, all activities and operations of the organization that are within the defined scope are included in the ES Program. The program scope is kept current. Management has also determined and documented the program level for which the organization is pursuing certification. 2.0 Ethical Sourcing (ES) Policy [Reference: ES Standard and 4.1.2] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 2.1 Has the organization's top management developed and documented an ES Policy? An ES Policy has been developed, documented and signed by the top management of the organization. The current management of the organization is familiar with and supports the commitments included in the ES Policy. 2.2 Does the policy include commitments: to provide and continually improve practices related to employment, environmental and employee health and safety? to identify and comply with legal requirements, and other requirements to which the organization subscribes, that apply to its employment, health & safety and environmental activities? to effective employee participation? 2.3 Is the policy communicated to all persons working for or on behalf of the organization? 2.4 Does the policy provide a framework for setting and reviewing ES objectives and management programs? 2.5 Is the policy periodically reviewed for adequacy with regard to the current scope of the organization s ES Program? 2.6 Is the policy available to the public? 2.7 Is the policy available to other interested parties? The organization s ES policy includes a commitment to provide and continually improve practices related to employment, environmental and employee health and safety management practices. The ES policy includes commitments to: - identify and comply with applicable legal requirements and other requirements to which the organization subscribes (e.g., those of trade associations, customers, etc.); and - effectively involve employees in the ES Program. The policy provides a framework for setting and reviewing ESrelated objectives and targets, as well as programs intended to achieve established objectives and targets. The policy is communicated to all persons working for and on behalf of the organization, including employees (permanent and temporary), visitors, contractors, suppliers, etc. The ES Policy is periodically reviewed to ensure that it is adequate for the current scope of the ES Program. A manual has been documented and maintained, in either electronic or hard copy form, which outlines the methods that the organization will use to meet the requirements of this standard. The ES manual will include, at a minimum: - the scope of the organization s ES program; - a summary of ES policies and procedures; - the ES policy; and - an organization chart showing how responsibilities have been assigned (per element 3.0). The ES Policy is made available to the public. The ES policy and manual are made available, in either electronic or hard copy form, in a language that is understood by all employees. The ES policy is made available to other interested parties (e.g., non-governmental organizations). The Supplier has a process for regular engagement, interaction and dialogue with potentially affected stakeholders and members of communities in which it operates. This process facilitates discussion on ESrelated performance, where stakeholders have concerns or would like to see additional improvement, etc. (Also see requirements in 7.0, Level 3.) Page 17 Appendix 1 SQFI Ethical Sourcing Standard April 2017

17 3.0 ES Objectives, Targets and Management Programs (OTMPs) [Reference: ES Standard 4.1 through 4.6] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 3.1 Has the organization established, documented, and implemented processes and programs to achieve established objectives and targets? [Note: The term ES-related includes environmental and health & safety (EHS), and social considerations.] The organization has established and documented ES-related objectives, targets and management programs at each relevant function and level within the organization. 1 Focus is on operations, activities and potential EHS and social impacts at the site level. The focus has been expanded to consider how the site influences and interacts with the local environment and community beyond the physical boundaries of the facility. The focus has been further expanded to evaluate potential impacts on, and influence over, activities beyond the immediate consideration of the site and the local environment/ community. Evaluate using industrial and leading practice mechanisms when developing programs to achieve objectives for improving environmental performance (e.g., using energy sources with lower GHG intensity, using recycled water, etc.). 3.2 Has the organization established, documented, and implemented management processes and programs that are designed to achieve established objectives and targets for priority (significant) aspects/ impacts and hazards/ risks? Note: Objectives, targets and management programs will be linked with, but not limited to, the following requirements of the ES Standard: significant environmental aspects and impacts; significant occupational health and safety risks; and significant risks associated with social/ employment programs. The organization has documented/implemented operational controls to give guidance to associates on: - appropriate objectives, targets and programs; - monitoring and measurement criteria for objectives and targets; - defined roles and responsibilities of individuals who manage, perform and verify implementation; - identifying and documenting required implementation resources; - required timing; and - actions to respond to out-ofrange events. OTMPs have been approved and adequately resourced by management. The status of OTMPs is periodically reviewed by top management. The organization takes appropriate action when the status of objectives, targets and management program is not within the established range. The organization has broadened its program to include impact on the local environment beyond the physical boundaries of the facility. Data are being collected on programs and are being reported to top management. Objectives, targets and programs are: increasingly more proactive in nature (e.g., topics such as pollution prevention, source control, use of alternative/renewable energy, etc.); normalized (e.g., to annual production or sales volume) to support performance trending; and are reviewed at least annually. The organization has initiated communications with the local community about the organization s efforts to be an environmentally and socially responsible organization. Programs have grown to maturity. Some programs have been closed and new ones implemented. Some programs are still in place with new targets. If there were excursions from established targets, there was evidence of activity within the organization to respond to these excursions. The organization has initiated communications with stakeholders, customers, distributors, wholesalers, etc. about the organization s efforts to be a socially and environmentally responsible organization. Performance objectives and targets are designed to improve or sustain the organization s ESrelated programs and processes. Evaluate proactive programs (e.g., the reduction of greenhouse gas intensity, alternative fuels, etc.). 3.3 Are operational control procedures in place that: stipulate safe operating criteria, and identify consequences of deviation from these safe operating criteria? Operational control procedures are in place that: - document safe/ normal operating conditions; and - identify consequences of deviation (i.e., potential harm or compliance violation). Priority environmental impacts and health and safety risks do not necessarily require a formal program, but are there: - Operational controls to monitor the impact/risk? - Responsibility for monitoring? - Go, no-go parameters? - Guidance on actions to take in the event of excursions to acceptable parameters? Formal procedures have been developed to address the broader range of identified Ethical Sourcing aspects and not solely the priority aspects, and include those associated with: monitoring and measuring the key characteristics of its operations that can have ESrelated impacts; and on-site contractor activities. If an unacceptable excursion to risk parameters has occurred, there is evidence that immediate actions were taken to return to safe /normal operating conditions. The organization proactively seeks to identify and commit to voluntary codes/ standards for improving ES-related performance that are appropriate for its site/ activities. Operational control procedures have been developed and implemented to ensure the organization s practices conform to these voluntary codes/ standards. Evaluate using targets that are sustainable and exceed recognized international standard practices. Consider a target of zero impact. Page 18 Appendix 1 SQFI Ethical Sourcing Standard April 2017

18 3.0 ES Objectives, Targets and Management Programs (OTMPs) (continued) [Reference: ES Standard 4.1 through 4.6] Requirements Level Does the organization have to periodically calibrate instrumentation or monitoring equipment? If yes: are calibration procedures and the method to determine calibration accuracy documented? does the organization s recordkeeping procedure ensure traceability of calibration records? 3.5 Are procedures in place to ensure that employees/ contractors are aware of: The importance of conformity with the ES policy and procedures? The ES-related consequences, actual or potential, of their work activities and responsibilities? The ES-related benefits of improved personal performance? Their responsibilities in achieving conformity to the ES policy and procedures? Potential consequences of departure from specified operating procedures? 3.6 Are operational control procedures in place that address: risks associated with goods, equipment and services that are purchased and/or used by the organization? the design of the workplace, processes, machinery, operating procedures and work organization in order to eliminate or reduce EHS risks at their source? Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: There is evidence that any calibration that has been performed has been in accordance with applicable manufacturers specifications, regulatory requirements, Best Engineering Practice (BEP), and/or Acceptable Environmental Practice (AEP). Each calibration procedure is repeatable. (e.g., calibrated to a primary standard or conducted by an approved 3 rd party). Calibration records are documented/organized and are retained in accordance with regulatory requirements and/or organizational record retention requirements. There is evidence that the importance of conformance to the ES policy and procedures has been communicated to those working for or on behalf of the organization. It has also been explained to everyone working for or on behalf of the organization that deviating from these established procedures may: - negatively impact the organization s ES policy; - have negative impact on the organization s goals and objectives; - negatively impact the personal achievement goals of responsible employees; and - place the organization into noncompliance status. Operational controls are in place to address: - the risk/impact of working with certain products or materials; - controlling unwanted materials from impacting the organization; and - new materials or practices being used that have not been properly assessed for impact, risk and/or regulatory implications. A mechanism has been developed to ensure that the ES policy and procedures are communicated to all new employees, contractors, vendors, visitors, etc. A robust management of change process has been implemented which supports the proactive identification of environmental aspects and impacts (and their required control) ahead of changes being made. The management of change process also considers potential impacts on social/labor aspects, as well as health & safety and quality. If an unacceptable excursion to risk parameters has occurred, there is evidence that immediate actions were taken to return to normal operating conditions. Contractors, visitors, vendors, etc. are periodically audited to ensure that they are aware of the ES policy and procedures, how these documents related to them, and potential consequences to the organization, its employees and the environment if the policy and procedures are not followed. The organization proactively seeks to identify and commit to voluntary codes/standards for improving ESrelated performance that are appropriate for its site/activities. 2 Operational control procedures have been developed and implemented to ensure the organization s practices conform to these voluntary codes/ standards. Activities that have an unacceptable risk ranking are immediately stopped until the risk has been reduced to an acceptable level. 1 Consider using targets that are sustainable and exceed recognized international standard practices. Consider a target of zero impact. Page 19 Appendix 1 SQFI Ethical Sourcing Standard April 2017

19 4.0 Development of the Organization s ES Team [Reference: ES Standard and 4.1.4] Requirements Level Who retains overall responsibility within the organization for performance related to the Ethical Sourcing Program (ESP)? 4.2 Has an individual(s) been appointed by top management to drive improvement of ES-related performance, at the department or facility level, in the areas of: Suppliers and subcontractors? Social management/ employment? Environmental management? Occupational health and safety (OH&S) management? 4.3 Has a cross-functional team been developed to drive continual improvement and communications? Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: There is evidence that top management retains overall responsibility for the Ethical Sourcing Program. Consistent with the Ethical Sourcing Standard requirements found at 4.5.6, Management Review, top management periodically reviews the performance of individuals/teams appointed below to support continual improvement of the Ethical Sourcing Program. Appropriate personnel have been appointed by top management to pertinent positions to assist in the management of the ES Program, especially in the areas of: - Suppliers and Subcontractors, - Human Resources, - Environmental Programs, and - OH&S Programs. Where possible, appointed individuals are members of the site management team. Roles and responsibilities have been documented and communicated. There is evidence that assigned personnel have the appropriate training and experience to achieve their goals in supporting the ES Program. A cross-functional team (CFT) has been established with membership from all departments within the organization. The CFT meets periodically to drive communications and continual Improvement. Written meeting minutes are developed and are shared with management and associates. There is an organizational chart or other document that identifies supervision and roles/ responsibilities of all employees and contractors within the ESP. The responsibility of champions includes performance monitoring, reporting and internal auditing for their area(s) of responsibility. Ongoing education or training programs are provided to allow for continued growth of personnel in their roles in supporting the ESP. Performance goals and objectives have been established for personnel having ES-related responsibilities. CFT membership is documented and communicated within the organization. A system has been established to periodically rotate new members onto the CFT (in order to increase the base of participation within the organization). There is evidence that management of change is considered by an appropriate individual(s) as to how changes may impacts the ES program. There is evidence that an individual(s) has the authority to stop any activity that could have adverse environmental or occupational health and safety impacts. The CFT includes members who are non-management personnel and, if appropriate, members from supplier and/or community organizations. Page 20 Appendix 1 SQFI Ethical Sourcing Standard April 2017

20 5.0 Suppliers and Subcontractors [Reference: ES Standard 4.2] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 5.1 Has the organization developed, documented and implemented a procedure to initially evaluate/select its suppliers and subcontractors based on their ability to meet defined requirements related to the ES Standard (i.e., social/ employment programs, environmental programs and occupational health and safety programs)? A procedure for initial evaluation and selection of suppliers/ subcontractors based on their ability to meet the requirements related to the ES Standard has been developed, documented and implemented. Selection criteria have been clearly communicated to suppliers/subcontractors, including required corrective and preventive actions for identified issues (e.g., in service agreements). Evidence is available to confirm that: the organization applied its selection criteria to all supplier/ subcontractor decisions that have occurred since these criteria were developed; and the organization s suppliers/ subcontractors have agreed to these requirements. The written procedure specifies the required qualifications for those who perform these initial selections. As contracts come up for extension and/or renewal, the organization employs the same selection criteria to existing suppliers and subcontractors as it would for new suppliers and subcontractors. All of the requirements for Level 1 then apply for Level 2 certification. All Suppliers and Sub-contractors will be compliant with the buyers requirements The organization maintains records of suppliers and subcontractors social and EHS commitments including contractual agreements and other written commitments. These commitments are periodically audited (see Requirement 12.1). The organization has taken reasonable steps to extend its knowledge of the origin of all raw materials, ingredients, and/or products provided by suppliers and subcontractors. This knowledge is factored into initial selection criteria, as well as decisions on contract extensions and/or renewals. 5.2 Has the organization developed, documented and implemented a procedure to periodically evaluate the performance of its suppliers and subcontractors in meeting the agreed-upon requirements related to the ES Standard? The organization has developed, documented and implemented a procedure for periodic evaluation of its supplier/subcontractor base. Documentation is available to confirm that evaluations were performed according to the method, level of detail and required frequency as stipulated in the evaluation procedure. The written procedure specifies the required qualifications for those who perform these periodic evaluations. Meetings are periodically held with a representative(s) of each supplier and subcontractor to: review supplier/ subcontractor performance in conforming to the organization s ES-related requirements; and develop objectives that are intended to drive continual performance improvement. The results of these periodic evaluations are factored into decisions related to contract extension and/or renewal. Page 21 Appendix 1 SQFI Ethical Sourcing Standard April 2017

21 5.3 Does the organization maintain records of its evaluations of suppliers and subcontractors (both initial selection and periodic evaluations)? The retention period for records related to the evaluation of suppliers/ subcontractors has been identified to ensure compliance with applicable regulatory/company record retention requirements and/or good management practices. Retained records contain sufficient objective information to support decisions regarding supplier/ subcontractor performance. Records are retained for periodic performance review meetings with each supplier/ subcontractor. The records include documentation of agreed objectives and performance to those objectives. Available documentation confirms that issues resulting from periodic evaluations have been addressed in a timely manner. Records related to initial selection decisions, periodic evaluations, and contract extension/ renewal decisions are made available to other facilities and/or subsidiaries of the organization s parent company. Page 22 Appendix 1 SQFI Ethical Sourcing Standard April 2017

22 6.0 Social Management Programs [Reference: ES Standard 4.3] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 6.1 Does the organization have written policies and procedures that prohibit discrimination and harassment? Note: This requirement is intended to ensure that all employees are treated with respect and dignity. 6.2 Does the organization have written policies and procedures that describe the organization's wage compliance program? 6.3 Does the organization have written policies and procedures that describe the organization's benefits program? 6.4 Does the organization have written policies and procedures that describe fair labor practices and terms of employment? The organization has written policies and procedures that require equal opportunity to be afforded during recruitment/hiring and during employment (i.e., compensation, training, promotion, termination, retirement, etc.) and expressly prohibit discrimination on the basis of gender, age, religion, marital status, race, caste, social background, diseases, disability, pregnancy, ethnic and national origin, nationality, membership in worker organizations including unions, political affiliation, sexual orientation, or any other personal characteristics. Written policies/procedures have also been developed that prohibit subjecting employees to any form of bullying, harassment or abuse (sexual, verbal, physical, etc.) for any reason, including membership in or affiliation with a trade union, or their legitimate trade union activity. Policies and procedures related to wage compliance address the following topics: pay rates (minimum, regular/overtime), dates and means of payment, withholding of wages 1 and usual working hours. Workers shall not be required to make deposits/financial guarantees. Policies and procedures related to the organization s benefits program address, at a minimum, the following topics, if applicable: vacation, holidays and leave (regular, sick, maternity/ paternity, etc.). These policies and procedures address requirements related to the following topics: - forced 2, bonded 3, indentured 3 and child labor 4 ; - employee rights regarding trade unions 5 ; - rights and obligations of the employer and employees; and - conditions for disciplinary action, including suspension and termination 6. All terms and conditions of employment shall be based on an individual's ability to do the job, not on the basis of personal beliefs or characteristics. All work must be conducted on a voluntary basis, and not under threat of any penalty or sanctions. Employers shall not retain employee identity documents (such as passports, identity cards, etc.). Policies and procedures regarding the following subject areas are consistently implemented at all levels of the organization: discrimination in hiring and employment; harassment and abuse of employees; wage compliance; compensation and benefits; fair labor practices and labor relations; and terms of employment. The organization has a means in place to be aware of changes to any applicable laws and/or regulations in the subject areas listed above. There are periodic updates and training on particular issues to reinforce understanding and to communicate changes, when they occur, to policies, procedures and/or regulations. Communication is conducted in appropriate language(s) and is adapted to workers education level. There is a confirmation procedure to ensure understanding by workers. Risk assessment activities include considerations related to social management programs. There is a verification process in place to ensure that fair labor practices are working (Ex: anonymous survey.) A Code of Ethics and Business Management Practices, or similar mechanism, in place that embodies the organization's policies and commitments to compliance with national and/or international labor codes/ standards and ethical trading. A variety of methods are used for communicating and consulting with workers and their representatives on issues raised by any of the parties to this dialogue. Risk assessments are expanded to include the organization s suppliers and contractors. The organization complies with the Core Labor Standards of the International Labor Organization (ILO) if they are more protective than national, state/provincial and/or local regulations. 7 The organization complies with the requirements of other applicable ILO Labor Standards if they are more protective than national, state/provincial and/or local regulations. 7 The use of forced or compulsory labor in all its forms is prohibited, including prison labor when not in accordance with CO29. Suppliers shall comply with: i) the national minimum age for employment, ii) or the age of completion of compulsory education, iii) or any otherwise specified exceptions, and shall not employ any person under the age of 15, whichever of these is higher. However, if local minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO CO 138, this lower age may apply. If a child is found to be directly or indirectly working for a supplier contrary to the requirements above, the supplier will seek a satisfactory solution that gives priority to the best interests of the child. Terms of employment and working hours: 8 Page 23 Appendix 1 SQFI Ethical Sourcing Standard April 2017

23 6.0 Social Management Programs (continued) [Reference: ES Standard 4.3] Requirements Level Are these policies/ procedures communicated to affected employees? Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: A process is in place to ensure that workers understand their rights, responsibilities and benefits and how the policies and procedures work. Mandatory Footnotes to 6.0 Social Management Programs: Includes withholding of wages that is not permitted by national, state/provincial and/or local law or as a provision of a legal contractual agreement. Forced labor includes any work or service exacted from a person as a consequence of a conviction in a court of law unless the work or service is carried out under the supervision and control of a public authority and the person is not hired to or placed at the disposal of private individuals, companies or associations. Bonded labor includes encouraging workers to incur debt through recruitment fees, fines or other means. Suppliers shall respect the right of workers to terminate their employment after reasonable notice. Suppliers shall respect the right of workers to leave the workplace after their shift. Suppliers shall comply with: i) the national, state/provincial or local minimum age for employment, or ii) or the age of completion of compulsory education, or iii) any otherwise specified exceptions and shall not employ any person under the age of 15, whichever of these is higher. However, if local minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO Convention 138, this lower age may apply. Suppliers shall not employ young workers under 18 years in conditions which compromise their health, their safety or their moral integrity, and/or which harm their physical, mental, spiritual, moral or social development. If the employment involves work at night, compulsory curfew requirements must be observed. Employees have the right, as permitted by national, state/ provincial and/or local legislation, to join or form trade unions of their own choosing without prior authorization from management and have the right to bargain collectively. The company shall not interfere with, obstruct, or prevent such legitimate and lawful activities. Duly-elected worker representatives shall have access to the workplace to carry out their representative functions (i.e., persons who have been duly elected by workers at a location to represent them). All disciplinary actions shall be documented. Organizations that are pursuing Ethical Sourcing certification at Level 3 will comply with the requirements of the following International Labor Organization (ILO) conventions if they are more protective than national, state/provincial and/or local laws and regulations. ILO Core Labor Standards: C29 Forced Labour Convention, 1930 C87 Freedom of Association and Protection of the Right to Organise Convention, 1948 C98 Right to Organise and Collective Bargaining Convention, 1949 Other ILO Labor Standards, as applicable: The ILO call for Decent Work C1 Hours of Work (Industry) Convention, 1919 C14 Weekly Rest (Industry) Convention, 1921 C95 Protection of Wages Convention, 1949 C131 Minimum Wage Fixing Convention, 1970 C135 Workers' Representatives Convention, 1971 C155 Occupational Safety and Health Convention, 1981 C100 Equal Remuneration Convention, 1951 C105 Abolition of Forced Labour Convention, 1957 C111 Discrimination (Employment & Occupation) Convention, 1958 C138 Minimum Age Convention, 1973 C182 Worst Forms of Child Labour Convention, 1999 C161 Occupational Health Services Convention, 1985 R85 Protection of Wages Recommendation, 1949 R116 Reduction of Hours of Work Recommendation, 1962 R135 Minimum Wage Fixing Recommendation, 1970 R164 Occupational Safety and Health Recommendation, 1981 R184 Home Work Recommendation, 1996 R190 Worst Forms of Child Labour Convention Recommendation, Organizations pursuing Ethical Sourcing certification at Level 3 will comply with the following requirements related to terms of employment and working hours: 1. Provide all workers with written, understandable information about their employment terms, including wages, before they enter employment; and about details of their wages for the pay period concerned each time that they are paid. 2. Set working hours that comply with national laws or benchmark industry standards or relevant international standards, whichever affords greater protection to ensure the health, safety and welfare of workers. 3. Limit the standard allowable working hours in a week to 48, excluding overtime and not require workers to work more than 48 hours per week on a regular basis. 4. Overtime shall be voluntary, limited to a maximum of twelve hours per week and not be requested on a regular basis. 5. Respect workers right to breaks during work shifts and to at least one free day following six consecutive days worked as well as public and annual holidays Page 24 Appendix 1 SQFI Ethical Sourcing Standard April 2017

24 7.0 Environmental Aspects and Impacts [Reference: ES Standard 4.4.1, and 4.4.4] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 7.1 Has the organization developed, documented and implemented a process to identify its environmental aspects and their associated impacts? 7.2 Has the organization developed, documented and implemented a process for prioritizing its environmental aspects to identify those which have the highest priority (i.e., most significant) impact on the environment? 7.3 Has the organization developed, documented and implemented an Environmental Management Plan (EMP) to address identified priority (significant) impacts? NOTE: Additional details on the graduated requirements for this section (i.e., Levels 1, 2 and 3) are presented on page 11.) The organization has developed and documented a procedure to identify all environmental aspects and their associated impacts. There is additional evidence that the procedure considered: negative (adverse) and positive (beneficial) impacts; and routine, non-routine and emergency operations. All identified environmental aspects, and their associated impacts, have been documented for further evaluation/action. The organization has developed, documented and implemented a procedure to prioritize those impacts having the most significant actual or potential impact on the environment (i.e., priority or significant impacts). All identified priority impacts have been documented for inclusion in the organization s Environmental Management Plan (EMP). [See 7.3.] The organization has developed an EMP to measure and address (eliminate, control or reduce) the effect of identified priority impacts on the environment. Control measures have been implemented per the objectives, targets and management programs identified in 3.0. At a minimum, the EMP shall include specific control measures related to the following aspects, if applicable: energy usage; water consumption; air emissions, including greenhouse gases (GHG) and ozone-depleting substances (ODS); wastewater treatment and effluent management or connection to offsite wastewater treatment system; storm water management; waste management, including activities related to pollution prevention, waste minimization and re-use/ recycle; prevention of groundwater and soil contamination; and land use and biodiversity. A robust management of change (MOC) procedure has been implemented which supports the proactive identification of environmental aspects and impacts prior to changes being made. The MOC procedure considers changes to materials, processes, equipment, packaging, regulations, etc. The organization s aspects and impacts are reviewed at least annually to ensure that the listing is complete and current. The reviews are documented and records are retained. To ensure that the organization s listing of priority impacts is complete and current, aspects and impacts are reevaluated for priority: 1. as part of the management of change review; and 2. at least annually. The reviews are documented and records are retained. The Environmental Management Program addresses impacts that go beyond direct air/waste/ water discharges, to include other topics including, but not limited to: design and development, raw material use, packaging use, transportation, distribution and end of life. The EMP incorporates leadingpractice programs/technologies, where relevant and appropriate for the site/ activities, regarding: 1. Air Emissions Reduce greenhouse gas intensity Abatement and/or source reduction Sustainable within local ecosystem limits 2. Water Consumption Efficient use, reuse, recovery, recycle Sustainable within local ecosystem limits and drainage / catchment areas 3. Wastewater Effluent (quality/volume) On-site treatment of waste water or connection to off-site treatment system; reuse of grey water, etc. Volume/quality are sustainable within local receptor and ecosystem limits 4. Waste (volume/disposal method) Minimize natural resource and virgin raw material consumption Reduce, reuse, recycle waste; energy from waste; etc. Sustainable disposal method/volume within availability of treatment and disposal facilities and the local environment 5. Land Use and Biodiversity Prevent further/future contamination to soil and/or groundwater and in relation to remediation Promote biodiversity and land management Sustainable within local ecosystem Zero Contamination target and policy 6. Nuisances Reduce impacts related to process changes, traffic, noise, etc. Zero Complaint target and policy Engage appropriate stakeholders throughout the value chain in mutual discussions regarding: environmental impacts, incidents, performance indicators/data, and controls; opportunities to reduce impacts and improve environmental performance; and exert influence, as appropriate, on the environmental performance of suppliers and off site contractors who provide goods and services to the organization. Note: Topics for stakeholder engagement include, as appropriate, those listed in on this page and in 7.3 Continued on the following page. Page 25 Appendix 1 SQFI Ethical Sourcing Standard April 2017

25 7.3 Continued: Graduated Requirements for Environmental Management Plan [Reference: ES Standard 4.4.1] Level 1 Air emissions General: Inventory and permit if required by regulation; report greenhouse gas (GHG) emissions if required by regulations Air emissions ODS: Inventory; stop use of CFCs, trichloroethylene (TCE) and carbon tetrachloride; comply with regulations on HCFC refrigerants, if applicable Biodiversity and land use: Know and comply with applicable regulations (e.g., endangered species); manage any known existing environmental condition (e.g., soil or groundwater contamination) Chemicals: Hazardous chemicals inventory; current versions of safety data sheets (SDS); handle, use, store, transport and dispose as required by regulation, SDS and/or facility operational control procedures 2 Energy and fuel consumption: Inventory sources and quantities Major incident prevention: Identify potential scenarios; site emergency response plan in place Oil/ oil products: Inventory; recycle versus disposal; spill prevention, control and countermeasure plan if required by regulation Stormwater: Identify and permit if required by regulation Waste management: Proper identification, handling, segregation/storage and disposal of waste and waste containers; proper labeling and recordkeeping; waste minimization through recycling and reuse Wastewater effluent: Inventory and permit if required by regulation Water consumption: Inventory sources and volumes Level 2 Level 1 Requirements, plus: Air emissions GHG: Reduce emissions from on-site vehicles and stationary sources Air emissions ODS: Identify alternative substances/products for HCFCs and halons; prepare for phase out of HCFCs and halons Biodiversity and land use: Evaluate impact of operations on neighbors, local community and sensitive environmental receptors; plan to reduce impact; for nonindustrial land, proactive management to maintain soil fertility, avoid soil erosion and promote soil/biodiversity recovery; implement appropriate recovery actions Chemicals: Substitute with less hazardous alternative; reduce, reuse, recycle; manage inventory levels and usage; optimization of agricultural chemical input Energy and fuel consumption: Identify and implement source reduction actions Major incident prevention: Identify and implement actions to prevent identified emergency scenarios; coordinate actions with local emergency agencies Oil/ oil products: Reuse; develop and implement spill prevention, control and countermeasure plan Stormwater: Develop and implement stormwater pollution prevention plan 1 Waste management: Increased use of waste recycling and reuse; initial source reduction actions Wastewater effluent: Reduction/ reuse (treatment, etc.) 1 Water consumption: Identify and implement opportunities to reuse Level 3 Level Requirements, plus: Air emissions GHG: Incorporate carbon accounting into business system Air emissions ODS: Discontinue use of HCFCs and halons Biodiversity and land use: Actively involve neighbors and community in evaluation of the impact of operations; assume leadership role in biodiversity; promote biodiversity; no negative impact on designated protection areas or species; demonstrable improvement, where appropriate, in land use/biodiversity performance including deforestation, rehabilitation and conservation activities Chemicals: Investigate non-chemical alternatives; Identify and comply with prohibited chemicals lists (e.g., for agrichemicals from the World Health Organization) Energy and fuel consumption: Specify the most environmentally efficient combinations of vehicle types, fuels and technologies for the distribution fleet and for facility/ process operations, including on-site transport Major incident prevention: Proactive engagement with local community to ensure awareness of risks of major incidents and emergency response procedures; proactive prevention program supporting an objective of zero major incidents; EHS included in management of change reviews Oil/ oil products: Source reduction Stormwater: Active management plan that includes objectives for improving the quantity and quality of the stormwater as appropriate Waste management: Increased use of source reduction; evaluate zero waste to landfill, waste to energy, and other environmentally beneficial disposal options Wastewater effluent: Active management plan that includes objectives for improving the quantity and quality of the wastewater as appropriate Water consumption: Identify and implement source reduction actions 1 Develop a wastewater/storm water management plan that includes: a) a drainage plan that provides a general understanding of wastewater/storm water flow paths/direction and discharge points; b) identification of any contaminants, their flow direction and potential impact; and c) wastewater/ storm water quantity and quality, receiving body(ies) and impact on the environment. 2 Detailed audits and inspections are required to be performed with sufficient frequency to ensure conformity with stated pollution prevention requirements. Page 26 Appendix 1 SQFI Ethical Sourcing Standard April 2017

26 8.0 Occupational Health & Safety Hazard Identification & Risk Assessment [Reference: ES Standard 4.4.2, & 4.4.4] Requirements Level Has the organization established, documented and implemented a procedure to identify occupational health and safety hazards and their associated risks? 8.2 Has the organization conducted and documented an assessment of the risks associated with identified hazards per the established procedure, including evaluation of the effectiveness of existing controls and the need for additional controls? 8.3 Has the organization developed, documented and implemented an Occupational Health and Safety Management Plan (OHSP) to address identified priority (significant) risks? The organization has developed, documented and implemented a procedure to identify all occupational health and safety hazards and to assess their associated risks. The procedure considered actual and potential hazards associated with: routine, non-routine and emergency operations; contractors, delivery personnel, and visitors; and adequate safeguards against fire, and adequate strength, stability and safety of buildings and equipment. All identified hazards have been documented for further evaluation/ action. The organization has conducted/ documented a comprehensive risk assessment and has prioritized those hazards posing the highest actual or potential safety and health risks. Risk assessment/prioritization has included an evaluation of the effectiveness of existing control measures, as well as the need for additional controls to bring risk to an acceptable level. The most significant identified risks have been documented for inclusion in the organization s Occupational Health and Safety Management Plan (OHSP). [See 8.3.] The organization has developed an OHSP to address (eliminate, control or reduce) the risks associated with identified health and safety hazards. Control measures have been implemented per objectives, targets and programs in 3.0. The OHSP shall include specific control measures related, but not limited to, the following areas, if applicable: hazardous materials and environments (flammable, toxic, confined spaces, compressed gases, etc.); machinery and equipment (stationary and mobile); electrical hazards; control of hazardous energy; personal protective clothing and equipment Level 2 Level 1 Requirements, plus: A robust management of change (MOC) procedure has been implemented which supports the proactive identification of occupational health and safety hazards/risks prior to changes being made. The MOC procedure considers changes to materials, processes, equipment, packaging, regulations, etc. The organization s hazard identification, risk assessment and evaluation of controls are reviewed at least annually to ensure that the listing is complete and current. The reviews are documented and records are retained. To ensure that the organization s listing of prioritized risks is complete and current, hazards and control measures are re-assessed for priority (significance): 1. as part of the management of change review; 2. following a health or safety incident; and 3. at least annually. The reviews are documented and records are retained. The Occupational Health and Safety Management Plan addresses potential hazards/risks that go beyond traditional employee health and safety to include other topics such as: product stewardship; restricted/ banned substances; control of major accident hazards; etc. Level 3 Level Requirements, plus: Communications activities are initiated with external stakeholders in order to: encourage two way dialogue on occupational health and safety performance, especially in areas that may impact the local environment and/or community (e.g., fires and explosions); familiarize them with the organization s priority hazards/risks; familiarize stakeholders with the activities in the OHSP that are intended to address priority health and safety risks; and discuss where stakeholders may have concerns or would like to see additional improvement. Where possible, control is exerted over the occupational health and safety performance of contract/toll manufacturers and over off site contractor activities that are undertaken on behalf of the organization. (PPC&E) 1 ; walking and working surfaces; emergency and fire prevention plans; fall prevention and protection; and safe and clean drinking water, sanitary facilities and residential facilities, and, if applicable, sanitary facilities for food preparation and storage. 1 Where personal protective clothing and equipment (PPC&E) are necessary to control worker exposure to hazards (physical, chemical, etc.), ensure that PPC&E are provided, along with training on the limitations and proper use/maintenance of such equipment. Page 27 Appendix 1 SQFI Ethical Sourcing Standard April 2017

27 8.0 OHS Hazard Identification & Risk Assessment (continued) [Reference: ES Standard 4.4.2, & 4.4.4] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 8.4 Is appropriate training provided for new and existing personnel carrying out the tasks that are identified in the occupational health and safety plan as necessary to maintain the company s commitment to ethical sourcing? Training for new/ existing personnel shall include: General occupational health and safety (OHS) induction training; Ongoing training as required by applicable OHS laws and regulations; Instructions outlining how tasks identified in the OHS Plan are to be safely performed, including effective use of controls intended to eliminate, control and/or reduce hazards and risks. Waste management/ handling and disposal of chemicals and other dangerous materials. A training register shall be maintained describing: who has been trained in the relevant areas, who delivered the training, the content of the training, methods employed to demonstrate competence, and other information as may be required by applicable national, state/provincial or local regulations. Page 28 Appendix 1 SQFI Ethical Sourcing Standard April 2017

28 9.0 Recognition of and Compliance with ES-Related Legal and Other Requirements [Reference: ES Standard 4.4.3] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 9.1 Has the organization established a procedure to identify, access, and keep up to date the ESrelated legal requirements that are applicable to its operations, as well as other ES-related requirements to which the organization subscribes? (Note: The term ESrelated includes applicable legal and other requirements in the areas of environmental protection, occupational health and safety, labor, wage and hour, equal employment opportunity, etc.) 9.2 Has the organization established the relationship between its legal and other requirements and its aspects/impacts/hazards/ and risks? 9.3 Have applicable legal and other requirements been considered in establishing the organization s objectives, targets and programs? All legal and other ES-related requirements that are applicable to the organization s operations have been identified and documented, including, EHS training required by regulation/ law; training topics required by the facility s Environmental Management Plan and OH&S Management Plan (reference sections and 11.0), including pollution prevention and response training being delivered to all relevant employees; monitoring and recordkeeping requirements; required licenses, permits and certifications have been obtained and are current. Sufficient resources have been allocated to ensure that the identification of applicable legal/ regulatory requirements is accurate, complete and current. (This could be accomplished by knowledgeable in-house resources or through the use of appropriate 2 nd or 3 rd party resources.) The relationship between the organization s aspects/impacts, and hazards/risks and its legal and other requirements has been documented. A mechanism is in place to ensure that the organization is aware of new or revised ESrelated requirements that apply to the organization s operations. All associates understand the legal and other obligations that are applicable to the organization, their role in compliance, and the potential consequences to the organization of failure to comply with these requirements. Mechanisms are utilized to remind employees that certain processes and activities have critical ES/EHS or other concerns (e.g., training, posters, etc.). The organization identifies and commits to implement voluntary standards/codes of practice, that are felt to be appropriate for the organization s site/activities, that are promoted by applicable governmental bodies, nongovernmental organizations, trade associations, client networks, community groups, etc. The organization may sponsor local initiatives or donate to voluntary or charitable bodies that promote improvement on environmental performance, social issues, etc. 9.4 Does the organization periodically review its ES legal and other obligations and respond to changes and updates? Applicable legal and other requirements are considered by the organization when setting its ES objectives, targets and management programs. A mechanism is in place to ensure that the organization is in compliance with ES-related legal and regulatory requirements that have been identified. Page 29 Appendix 1 SQFI Ethical Sourcing Standard April 2017

29 10.0 Equipment Maintenance [Reference: ES Standard 4.4.4] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 10.1 Is all equipment used in the treatment, handling, monitoring and/or storage of air, waste, water, waste water, or other elements, as noted within the Environmental Management Plan, included on an inspection, testing and preventive maintenance (ITPM) schedule and have records maintained to verify these activities? (Note: ITPM activities include calibration.) 10.2 Is all equipment used to provide healthy and safe working conditions for employees, as identified within the Occupational Health and Safety Management Plan, included on an inspection, testing and preventive maintenance (ITPM) schedule and have records maintained to verify ITPM activities. (Note: ITPM activities include calibration.) 10.3 Are records of ITPM activities, including calibration, maintained for all equipment referenced in 10.1 and 10.2 above? All equipment is included on an inspection, testing and preventive maintenance (ITPM) schedule that is: 1. used in the treatment, handling, monitoring and/or storage of air, waste, water, waste water, or other elements, as noted within the Environmental Management Plan (EMP); and 2. used to provide healthy and safe working conditions for employees, as identified within the Occupational Health and Safety Management Plan. Records of ITPM activities, including visual inspections, are maintained in accordance with regulatory requirements and/or company record retention requirements. Records include documentation that any findings have been addressed. Appropriate employees (e.g., maintenance, engineering, operations) understand the role of the ITPM program in ensuring compliance with regulatory requirements and the potential consequences to the organization if these activities are not performed accurately and on schedule (e.g., exceedances of permitted emission levels, overexposure of employees to toxic substances, agency fines/ penalties, etc.). Issues related to the lack of or improper maintenance and calibration have been included in the organization s environmental aspects/impacts analysis and the occupational health and safety hazard identification, risk assessment and evaluation of controls. The status of the ITPM program is included as an agenda item in periodic management reviews of the ES Program (e.g., whether required inspections are being performed on schedule, whether sufficient resources are being allocated to the program, any identified trends, etc.). Results of inspections performed by external agencies or organizations (e.g., federal, state or provincial environmental or health and safety agency; insurance carrier; 3 rd party contractors; etc.) are communicated to management, along with an action plan for addressing any findings. The organization has a written policy governing how it will manage deficiencies that are noted during ITPM program activities (e.g., shut down until repaired/replaced, continue to use following implementation of precautionary measures, etc.). Confirmatory testing (e.g. noise levels along the site boundary, local air quality testing) or site inspections (e.g. for litter, settled dust etc.) can be used to demonstrate reduction in the potential for nuisance and/or to confirm the effectiveness of remedial measures implemented following complaints. Pollution prevention inspections may be performed by internal resources or contracted external resources. For sites holding legal environmental permits, such inspections could include further process optimization and/or optimization of control or abatement technologies. The site engages with parties in the supply chain to look for opportunities to reduce the potential for pollution. [Examples of equipment that may be referenced in the EMP and/or the OHSP include, but are not limited to: RTOs, bag houses, water treatment equipment, scrubbers, electrostatic precipitators, equipment containing ozone-depleting substances, local exhaust ventilation, laboratory hoods, oxygen meters, sound level meters, carbon monoxide meters, scales, fire protection systems and equipment, employee alarm systems, machine controls and guards, gas meters/detectors (portable and stationary), fall prevention/ protection equipment, etc.] Page 30 Appendix 1 SQFI Ethical Sourcing Standard April 2017

30 11.0 Emergency Preparedness and Response [Reference: ES Standard 4.4.5] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 11.1 Have plans and procedures been developed and implemented to identify the potential for incidents and emergency situations, as well as for preventing and mitigating potential illnesses/ injuries that may be associated with them? 11.2 Does the organization have documented procedures in place to respond to such issues? The organization has identified and documented potential emergency scenarios that could impact its operations. Documentation includes prevention and mitigation actions for all identified potential EHS emergency situations. Evaluation of potential EHS emergency scenarios has been expanded to assess potential impact on the local community. The organization is actively working with local community emergency agencies/groups to coordinate incident prevention and response actions and general emergency communications. Evaluation of potential EHS emergency scenarios has been expanded to assess potential impact on customers and other stakeholders. Suppliers and subcontractors are required to submit a contingency plan, in case of emergencies, to prevent supply chain disruptions and to respond to in-transit emergencies involving materials being shipped to the organization Does the organization have a group of associates that responds to such incidents (e.g., an emergency response team ERT)? 11.4 Has the organization trained all associates as to their role in such activities (i.e., respond or evacuate)? The organization has elected not to respond to potential emergency situations with internal resources. In this case: a procedure is in place to safely evacuate employees; and arrangements are in place with external incident response resources (e.g., local spill response and medical resources/facilities). Employees and wardens have received training on emergency evacuation and shelter-in-place procedures. Procedures for contacting/ activating external incident response personnel have been developed and communicated to appropriate personnel (e.g., receptionists, security, supervision, etc.). The organization has established an internal team to respond to identified potential emergency situations (e.g., spills, releases, and medical emergencies). Internal incident response personnel have received appropriate training of sufficient depth and frequency to enable effective incident response. Emergency response team training meets applicable regulatory and/or certification requirements. There is a documented inventory of response equipment and materials which is inspected/ audited on a periodic basis to ensure that they are maintained in a state of readiness. The organization has requested suppliers to identify their incident response capabilities and evaluates evidence of: evacuation and/or incident response training that suppliers provide to their personnel; and suppliers arrangements for contacting and activating external incident response personnel Does the organization, where applicable, periodically review and test its incident response procedures? There is evidence of periodic evacuation/ response drills and testing of emergency equipment. External response resources that are utilized by the organization are included in drills where applicable. The organization communicates their facility emergency contact information to the appropriate local entity (e.g., LEPC). Documented evidence exists to verify that emergency preparedness and response procedures, including evacuation and shelter-in-place, are reviewed on a regular basis for adequacy. This includes postdrill / post-incident evaluations of preparedness and response effectiveness. Community organizations are included in emergency drills (e.g., local fire department, local medical incident response personnel, etc.). The organization invites the local fire department to drill with them for emergencies. The organization involves local emergency agencies (e.g., fire department and LEPC or equivalent) in post-incident reviews of emergency preparedness and response procedures/ capabilities, as well as in post-incident critiques. The organization requests and evaluates evidence of evacuation and/or incident response drills that are conducted by their suppliers. A mechanism is in place for personnel of the organization to participate in post-incident reviews of emergency preparedness and response procedures/capabilities, as well as in post-incident critiques, for suppliers and contractors. Page 31 Appendix 1 SQFI Ethical Sourcing Standard April 2017

31 11.0 Emergency Preparedness and Response (continued) [Reference: ES Standard 4.4.5] Requirements Level Have proactive steps been taken to reduce potential/actual malfunctions and releases? 11.7 Does the organization have a legal obligation to report their presence or activities to outside agencies with regard to emergency preparedness (e.g., local fire department, local emergency planning committee (LEPC), Department of Homeland Security, etc.)? Controls are in place to minimize the potential negative environmental impact of malfunctions and releases. Procedures are in place to determine the applicability of such requirements to the organization s operations and to comply with any identified requirements (e.g., training, reporting, etc. Level 2 Level 1 Requirements, plus: The community is aware of the facility s potential negative impact and what steps are taken to minimize this impact. Procedures are in place to ensure that any new or revised requirements are identified and appropriate compliance action is taken. Level 3 Level Requirements, plus: The organization has requested suppliers to submit contingency plans to prevent supply chain interruption in case of emergencies. Procedures are in place to ensure that suppliers and subcontractors have identified whether they have a legal obligation to report their presence to outside agencies and to confirm that this reporting has taken place, if applicable Checking to Support Continual ES Performance Improvement [Reference: ES Standard 4.5] Requirements Level Does the organization have an internal audit process in place to confirm effective implementation of their ES program and conformity to the requirements of this module? (Note: Internal audits can be performed utilizing appropriately trained and qualified internal or external resources.) The organization has a written procedure for scheduling, performing and documenting internal audits of their ES program, including conformity to the requirements of this standard, compliance with identified legal and other requirements, and working conditions. Audit results are communicated to senior management and to those responsible for the area being audited. Corrective/preventive actions are taken in a timely manner, for all identified nonconformities, by the responsible management. In addition, there is evidence of checking for the effectiveness of corrective actions. Level 2 Level 1 Requirements, plus: The internal audit program includes special-focus topics such as, but not limited to: energy and water management, pollution prevention, electrical safety, hazardous materials management, wage and benefit management, etc. The organization performs audits of external firms that provide services to them (e.g., waste hauling and disposal). Level 3 Level Requirements, plus: The organization periodically performs audits of suppliers/ subcontractors to ensure that they are meeting contractual commitments (see Requirement 5.1). The results of internal audits are included in communications with external bodies (e.g., agencies, the community, customers, etc.). Page 32 Appendix 1 SQFI Ethical Sourcing Standard April 2017

32 12.0 Checking to Support Continual ES Performance Improvement (continued) [Reference: ES Standard 4.5] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 12.2 Have procedures been established and maintained to monitor and measure the organization s ES performance on a regular basis? There are documented procedures that drive the organization to periodically review: - the effectiveness of controls intended to manage priority environmental impacts and priority health and safety risks; - the implementation status of objectives and targets; - compliance with legal and other obligations; - the adequacy of the ES policy; - review of accidents/incidents, - review of ES deficiencies, - review of near misses, and - internal audits and corrective actions. The organization ensures that all equipment and devices that are used to demonstrate compliance with/conformity to monitoring and measurement requirements have been used, maintained and calibrated in accordance with manufacturers specifications, Best Engineering Practice (BEP), and/or Acceptable Environmental Practice (AEP). Do monitoring procedures include: Proactive performance measures that monitor compliance with ES management program(s), operational criteria and applicable legislation and regulatory requirements? Reactive measures of performance to monitor policy deviations, accidents, ill health, incidents, etc. (including near-misses) and other historical evidence of deficient ES performance? Data and measurements sufficient to facilitate appropriate corrective and preventive action analysis and resolution? The results of monitoring the performance of ES program activities are shared with external stakeholders (e.g., through faceto-face meetings, through an annual ES progress report, etc.). Records of use, maintenance and calibration of such devices and equipment are documented, organized and readily available Does the organization have procedures to investigate and address employee concerns? Procedures have been developed and implemented to ensure that concerns which are raised by company employees and other directly involved parties, with regard to their working environment/ conditions, are investigated by a senior company representative in a timely manner. Resolution of concerns has been documented. Mechanisms are in place to actively solicit employee concerns regarding any facet of the Ethical Sourcing Program including, but not limited to, concerns related to: the environment, employee health and safety, compensation and benefits, terms of employment, etc. Examples of mechanisms could include grievance procedures, suggestion programs, employee meetings, etc. The organization takes steps to promote proactive engagement with stakeholders to: encourage two way dialogue on Ethical Sourcing program performance; and discuss where stakeholders have concerns or would like to see improvement. Examples of mechanisms could include town hall sessions with the public, holding roundtable discussions with shareholders, inviting site visits by interested parties, etc. Page 33 Appendix 1 SQFI Ethical Sourcing Standard April 2017

33 12.0 Checking to Support Continual ES Performance Improvement (continued) [Reference: ES Standard 4.5] Requirements Level 1 Level 2 Level 1 Requirements, plus: Level 3 Level Requirements, plus: 12.4 Does the organization have a procedure for identifying and documenting corrective and preventive actions? 12.5 Does the organization maintain records sufficient to demonstrate conformity to the requirements of this Ethical Sourcing Standard? 12.6 Is the performance and effectiveness of the Ethical Sourcing Program reviewed by management on a periodic basis? The organization has developed and implemented a procedure(s) to guide root-cause identification and the development of corrective and preventive actions with regard to deviations from policies/procedures, accidents, incidents, employee concerns, internal audits findings, etc. The procedure(s) indicates which appropriate personnel have been assigned responsibility by top management to assist in the investigation and resolution of deviations and consequences, especially in the areas of: - supplier/subcontractor issues, - human resource/social issues, - employee concerns, - environmental incidents, and - occupational health and safety incidents. The procedure(s) addresses how complaints are to be recorded, tracked and closed out, and provides guidance on evaluating the effectiveness of corrective and preventive actions. All proposed corrective and preventive actions are reviewed through the risk assessment process prior to implementation. Post-incident investigations also include a review of whether the aspects/impacts/hazards/risks and controls were properly evaluated (i.e., why they did not prevent the incident from occurring/ recurring). Communication and training focusing on gaps identified are delivered at all site levels. Scheduling of internal audits includes evaluation of whether ES-related incidents are recurring. (See 12.1.) An incentive system is in place for management based on performance in relation to proactive and preventative remediation actions. The types of incidents occurring at the facility, as well as corrective and preventive actions to prevent recurrence, are shared with relevant stakeholders during periodic communications meetings. A process is in place to ensure that results of supplier/ contractor audits and associated corrective action plans are factored into decisions for selection and contract extension/ renewal. (See 5.0.) Procedures have been developed and maintained for the identification, maintenance and disposition of ES records, including the results of aspect and impact analyses, risk assessments, evaluation of control measures, audits, reviews, etc. Procedures include provisions for record identification, storage, protection, retrieval, retention and disposal. Senior management has documented the organization s procedure for ensuring the continued effectiveness of its ES Policy in relation to the requirements of this standard. Reviews are conducted at least annually. Minutes of the management review meetings are documented and are shared with the organization s personnel, including decisions taken to improve program performance. Inputs to management reviews include: results of internal audits and evaluations of compliance with applicable legal and other requirements; communication(s) from external interested parties, including complaints; the overall performance of the organization related to the Ethical Sourcing program; the extent to which objectives have been met; status of employee concerns, incident investigations, corrective actions, and preventive actions; follow-up actions from previous management reviews; changing circumstances, including developments in legal and other requirements related to ES; and recommendations for performance improvement. The organization has a process in place to benchmark Ethical Sourcing policies/procedures against evolving leading practice in the industry both locally and internationally. Page 34 Appendix 1 SQFI Ethical Sourcing Standard April 2017

34 13.0 Business Management Principles for Senior Management [Reference: ES Standard and 4.6] Requirements Level Does the organization utilize a systematic approach for realizing the financial and economic benefits associated with the implementation of Ethical Sourcing? 13.2 Is this systematic approach supported by actions on the part of senior management? An approach such as the following is utilized to help the organization realize the financial/ economic benefits associated with implementation of their Ethical Sourcing Program: customer focus, continual improvement, process optimization, mutually-beneficial supplier relationships, etc. The approach utilized in 13.1 is supported by senior management actions such as: value-added customer focus; implementing methods to realize financial benefits; establishing a baseline for financial performance measurement; establishing a trend analysis to review program performance and continual improvement; communicating program performance to the organization; and periodically reviewing the ES Program to ensure its continuing suitability, adequacy and effectiveness. Key performance indicators (KPIs) have been established to link Ethical Sourcing Program performance with financial/ economic benefits. Level 2 Level 1 Requirements, plus: Organizational indicators and goals are incorporated into the performance targets of managers and supervisors. A process is in place to record and analyze financial results and for considering the reasons in relationship to the Ethical Sourcing Program. Analysis is based on pre-defined metrics and KPIs. Financial considerations are incorporated into management review activities. (See 12.6.) Key findings (performance to KPIs and opportunities for improvement) are communicated within the organization. Level 3 Level Requirements, plus: Where possible, results are benchmarked against appropriate organizations. Key findings (performance to KPIs and opportunities for improvement) are communicated to appropriate external organizations. Page 35 Appendix 1 SQFI Ethical Sourcing Standard April 2017

35 Page 36 Appendix 2 SQFI Ethical Sourcing Standard April 2017

36 Ethical Sourcing Standard Appendix 2: Implementation and Auditing Guide April 2017 Safe Quality Food Institute 2345 Crystal Drive, Suite 800 Arlington, VA USA SQF Institute is a division of the Food Marketing Institute (FMI). Page 37 Appendix 2 SQFI Ethical Sourcing Standard April 2017

37 Page 38 Appendix 2 SQFI Ethical Sourcing Standard April 2017

38 1.0 Why We Need a Guide on Ethical Sourcing This guideline explains how to develop, document and implement Ethical Sourcing (ES), dealing with social, environmental and occupational health and safety, and business management practices at various stages along the agrifood chain. The ES Standard is provided for both sourcing and supplier organizations. It allows you to demonstrate to your customers that you have implemented practices and procedures that result in enhanced social responsibility and environmental and business management. In addition, you are able to show that you meet health and safety requirements and that you are complying with employment law and applicable legislation. 2.0 Responsible Social Practice Fisheries Crop Production Livestock/ Fish Production Typical Social Issues Community Viability (e.g., fishing or farming) Health Care Education Community Infrastructure Local Trade and Businesses Landscape and Amenity Consumer Interest in Ethical Trade Processing Potential Employment Issues Labor Laws Equal Opportunities Discrimination Health and Safety Gender and Child Labor Labor Organizations and Associations Packaging Distribution Consumption Figure 1: The Agrifood supply chain highlighting the main social and employment issues that can impact on the food chain. (Adapted from the UNEP Sustainable Agrifood Production and Consumption Forum) The most important social impacts of businesses are generally related to conditions of employment of employees and casual labor. As a minimum, these conditions are defined by various national, state/provincial and local legislative instruments that may be based on international labor standards promoted by the International Labour Organisation (ILO). Corporate social responsibility can go further to include social impacts of businesses on the local community, suppliers and consumers. Several standards and guides have been developed in this area such as the International Standards Organization Social Accountability Standard (SA 8000), the international Fair Trade Alliance or the ground breaking Johnson & Johnson Credo introduced in the mid-20th Century. Ethical Sourcing (ES) has been developed to embrace the wide range of corporate social responsibility challenges facing the agrifood chain. Through adopting a management systems approach, you can address those areas of social responsibility that are specific to your business and stage in the supply chain. This is the same approach to the way you develop your food Page 39 Appendix 2 SQFI Ethical Sourcing Standard April 2017

39 safety and quality plans. In developing the ES guidance, the main focus has been on those aspects that are under the direct control of the business. However, the guidance also takes into account those areas of social responsibility that can be influenced by others outside the business. Those who can influence a business social responsibility include public officers, customers such as retailers, special interest groups, labor associations and the local community (Figure 1). Including these interest groups in your management system is sometimes referred to as internalizing business externalities. Equally, businesses that have developed and implemented corporate social responsibility programs can use this to differentiate themselves in the marketplace. Government Pressures Sustainability, Ballot Box Strategies Regulations, Policy, Incentives, Subsidies External Stakeholder Pressures E.g. Shareholders, Insurers, Lenders, Standards Bodies, Industry Associations Your Business Inputs Processes Outputs Corporate Responsibilities E.g. Safety and Quality, Liability, Market Share, Employee Welfare, Customer Confidence, Business Ethics, Local Community Supply Chain Pressures E.g. Suppliers, Customers, Consumers Community Pressures E.g. Local Community, Consumers (local to Global), NGOs Figure 2: The internal and external pressures on businesses to address corporate social responsibility issues. Consumers are becoming increasingly aware of the social consequences of agrifood production and processing activities (Figure 2). At the same time governments and pressure groups are creating pressure on major food industry employers (and retailers in particular) to raise their own social standards and to influence the standards of their suppliers. Some retailers have gone further and actively promote their social responsibility (and that of their suppliers) as one element of their market differentiation from competitors. Several food assurance standards include reference to worker conditions, including health and safety. However, major food buyers recognize that labor rules and health and safety vary in different parts of the world and that some consumers want more than legal compliance. It is for these reasons that this implementation and auditing guide has been developed. Page 40 Appendix 2 SQFI Ethical Sourcing Standard April 2017

40 2.1 Responsible Environmental Practice Generally, the most significant environmental impacts of business operations are addressed through various legislative instruments in different countries, and some are the focus of international conventions such as the Climate Change Convention or the Convention on Biodiversity. So why do we need this guide? Greater consumer awareness of the environmental consequences of agrifood production and processing activities (Figure 3) is creating pressure (on retailers in particular) to raise the environmental standards of their suppliers. This has led to the inclusion of legal compliance with environmental legislation in many food assurance standards including the SQF Code, 7 th Edition. However, major food buyers recognize that the standards of environmental protection and enforcement vary in different parts of the world and that some consumers want more than just legal compliance. It is for this reason that this implementation and auditing guide has been developed. Figure 3: The agrifood supply chain highlighting the main inputs and potential losses that can impact the environment. (Adapted from UNEP Sustainable Agrifood Production and Consumption Forum.) Many governments, in association with agricultural and food industry sectors, have developed guidance on environmental issues. However, in considering your environmental responsibilities it is not sufficient to rely on such generalizations or sector guides. Each business should evaluate their specific and unique impacts and ensure that the most significant ones are addressed along with meeting any relevant regulatory obligations. This is why ES has been developed for those who wish to achieve higher levels of environmental responsibility and to be able to demonstrate this to their customers and their consumers. ES provides the logical framework to demonstrate Page 41 Appendix 2 SQFI Ethical Sourcing Standard April 2017

41 environmental responsibility and thus supports the integrity of food businesses already operating to the SQF Code, 7 th Edition. Responsible environmental management has been developed to embrace the wide range of environmental challenges facing the agrifood chain. Through the adoption of a management systems approach, you can address those areas of environmental responsibility that are specific to your business and stage in the supply chain. This is the same approach to the way you developed your food safety and quality plans. In developing the environmental management programs, the focus of environmental responsibility has been defined as those aspects that are primarily under the direct control of your business. This is sometimes referred to as the business environmental footprint (Figure 4). It is recognized, however, that businesses can influence their suppliers through specifying conditions of supply as some retailers currently do. Equally, an environmentally-responsible business can, through promoting the care taken in delivering appropriate goods and services, influence its customers activities (Figure 5). Figure 4: The input -process-output model used to define the direct environmental aspects of a business, sometimes called the environmental footprint. REP REP Influence REP Food Producer Supplier Food Business REP Food Business Customer Food Business Consumers Figure 5: The influence of environmentally responsible businesses on suppliers, customers and consumers. Page 42 Appendix 2 SQFI Ethical Sourcing Standard April 2017

42 The ES Standard allows sourcing and supplier organizations to demonstrate to your customers that you have implemented practices and procedures that deliver enhanced environmental responsibility. Furthermore, you are able to show that you meet environmental requirements that have been established by regulations or your customer. Page 43 Appendix 2 SQFI Ethical Sourcing Standard April 2017

43 3.0 Structure of the Ethical Sourcing (ES) Standard The ES Standard consists of four sections: 1.0 Scope Specifies the policies and procedures that SQF Certified Suppliers can develop, maintain and demonstrate to interested parties in relation to ethical sourcing practices that can be controlled by the business. 2.0 References The relevant documents that the standard references, including the SQF Code, 7 th Edition. 3.0 Definitions Contained in Part C of Appendix 3 of this standard. 4.0 ES System Requirements The SQF ES System requirements contain six elements that are further divided into 24 sub-elements (Figure 6). Element Number 4.1 Commitment Element Title Suppliers and Subcontractors Social Management Programs Environmental and Occupational Health & Safety Management Programs Monitoring and Management Review Business Management Principles for Senior Management Sub-element Number Policy Sub-element Title Policy and Operational Manuals Company Representative(s) Training Selection of Suppliers and Subcontractors Evaluation of Suppliers and Subcontractors Evaluation and Assessment Reports Discrimination and Harassment Wage Compliance Benefits Terms of Employment Environmental Management Plan Occupational Health and Safety Plan Regulatory Compliance Equipment Maintenance Incident Management Internal Audits Monitoring Investigation of Employee Concerns Corrective Action Recordkeeping Management Review Systematic Approach Senior Management Actions Figure 6: Elements and Sub-elements of the Ethical Sourcing Module The 24 sub-elements of the standard indicate what you need to do. This may include such things as documented procedures, employee understanding and implementation of these procedures, recordkeeping or evidence that actions are being taken. It is your responsibility to Page 44 Appendix 2 SQFI Ethical Sourcing Standard April 2017

44 provide the necessary evidence to achieve certification. In order to help you develop your Ethical Sourcing (ES) management system, this guidance is set out using the following format: SQFI ES Standard Element Name and Number Implementation Guidance for the Element (as shown below) Auditing Guidance for the Element (as shown below) Implementation Guidance What does it mean? Some interpretation of what the element requires or definition of words used in each element is given in this section. What do I have to do? Suggestions of what is required to be done are made in this section. The suggestions are not exhaustive and they may not apply in every situation. This could include examples of documents and records that may be needed for the ES management system. Auditing Guidance In this section, general suggestions of what an auditor will be looking for are made. This also provides some guidance to those auditing the standard, including documents and types of records to verify the ES management system. Specific criteria from Appendix 1, ES Certification Assessment Requirements, are referenced following this symbol. Page 45 Appendix 2 SQFI Ethical Sourcing Standard April 2017

45 4.0 System Requirements 4.1 Commitment Ethical Sourcing (ES) Policy Senior management shall document its Ethical Sourcing policy outlining the company s commitment to provide and continually improve employment, environmental, and health and safety management practices such that they are in line with national, state/provincial and local laws and agreements and the requirements of this standard The policy shall be signed by the senior company executive, documented in a Policy Manual and communicated to all staff Senior management shall make the required financial, physical and human resources available so that this policy may be fully implemented. Implementation Guidance What does it mean? Commitment to a policy by the senior management team is a clear sign of leadership. The policy statement provides a focus on what the organization is wishing to achieve in relation to employment conditions. Tangible actions must follow commitment. Management must ensure that the resources required to implement the policy are available. Resources are scarce in most organizations. Management must be able to demonstrate that employees get "their fair share" of the resources that are available. Senior means a person who controls or directs an organization at the highest level. In smaller organizations this will usually be the Chief Executive (or owner/manager). In medium to large organizations, the Chief Executive and Directors may have the policy drafted by others, but the senior managers must be the ones to commit the company to achieving the policy. Senior management should sign the document as a sign of their commitment to implement the policy. The management team s follow-up actions, such as providing resources to implement the policy, must be put into place. Walking the walk is more important than talking the talk. A policy statement usually sets out the objectives of the management system or provides a framework for the setting of objectives at an operational level. (Objectives should be SMART specific, measurable, achievable, realistic and time-bound.) Objectives relate to the outcomes of the management system and not the inputs to the management system. An example objective could be: During the coming year to have no lost time due to work accidents. Objectives should be written in a way that everybody in the organization can contribute toward achieving them. Legal compliance is a bottom-line requirement for certification this means compliance with legal requirements in the country in which staff are employed. Agreements may include staff employment contracts (individual or collective) as well as customer requirements set out in purchase specifications. The policy statement is usually the first document in a manual containing all relevant procedures and information. This manual, or relevant extracts from it, should be made available to all staff, and particularly to those staff whose decisions influence the application of employment and EHS policies in the workplace including supervisory staff. There may have to be a range of means of communicating the message to suit local conditions and customs for example if the workforce has poor literacy standards. Continual improvement of employment conditions and EHS performance should be a clear objective and this module utilizes the Plan, Do, Check, Act management cycle as used in other standards such as SQF 7 th Edition and ISO (environmental management systems). The manual should be available for examination by interested parties particularly clients. If done well, the policy (and its implementation) may provide excellent opportunities for informing all stakeholders of the work being performed. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Ensure that all national and local laws and other agreements related to employment are known and understood by those setting employment conditions and EHS standards. 2. Start writing the policy based on an analysis of where the organization is today and knowledge of where the organization wants to be in the future. 3. Set objectives and targets for the organization - these may be short, medium and/or long term. 4. Has senior management committed to achieving these objectives? Page 46 Appendix 2 SQFI Ethical Sourcing Standard April 2017

46 Implementation Guidance Publish the policy within the organization and ensure that staff is aware of the policy and in particular what it means to them in the work place. 6. Ensure that supervisors and managers are aware of the responsibilities they have to implement the policy. 7. Implement the policies. Auditing Guidance The auditor may look for evidence of: 1. A documented policy statement in which the senior managers in the company commit the company to providing and improving employment conditions for employees and continual improvement in environmental, health and safety (EHS) performance. 2. The policy statement providing a framework for setting and reviewing objectives, targets and management programs. 3. Employees being able to demonstrate that, when the policy is implemented, activities and outcomes will comply with national, state/provincial and local laws and agreements relating to employment and EHS. 4. Examples of situations where the policy s implementation led to improvements in employment conditions and EHS performance. 5. The policy having been clearly communicated to all staff in a form that they understood, and the being able to tell, in their own words, what the employment condition policy is. 6. Objectives, targets and management programs (OTPs) intended to drive continual improvement in ES-related performance. 7. The policy and OTPs being reviewed on a periodic basis to verify that they are appropriate for the current scope of the organization s ES program. See Appendix 1, 2.0 for specific requirements related to ES Policy. See Appendix 1, 3.0 for specific requirements related to ES Objectives, Targets and Management Programs Policy and Operational Manual A Policy Manual outlining the policies the company will implement to meet the requirements of this standard shall be documented. It shall reference an Operational Manual detailing the means by which the company will implement the policies and the procedures established. Implementation Guidance What does it mean? Documents, both internal and external, that provide consistent information are collectively referred to as a manual. The Policy Manual outlines the policies the company has determined to apply social, responsible practices. It also will refer a reader to the Operational Manual where the detailed work instructions, specifications and guidelines can be found - filling the role of a master reference document. The Operational Manual is intended to describe how you will meet the requirements of the standard. Working instructions should be provided where their absence may create a problem. As an example, where staff undertake an activity on a daily basis, are fully aware of the risks involved, and use appropriate protective equipment, detailed instructions are unlikely to be useful. But where an activity is irregular, a check sheet of safety precautions to be followed could be of value. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. The methods that the organization uses to achieve objectives set out in the policy (4.1.1) need to be designed and agreed upon. 2. Methods need to be documented when required. Where necessary, reference documents are defined and made available. 3. The manual and/or reference documents shall be made available to employees who will need to access their contents. 4. Training may be required to ensure that employees understand the contents of the manual, so that they may comply with it and therefore contribute to achieving the organization's objectives. Page 47 Appendix 2 SQFI Ethical Sourcing Standard April 2017

47 Auditing Guidance The auditor may look for evidence of: 1. A documented operational manual which sets out how the policy would be implemented, or provides guidance to find documents that set out how the policy will be implemented. 2. The manual or documents referenced with it are available at places where they are needed to be consulted. 3. Documents being able to be understood by the people required to follow them. 4. Documents providing enough detail so that staff following them can clearly understand the requirements. See Appendix 1, 3.0 for specific requirements related to ES Objectives, Targets and Management Programs Company Representative(s) A senior company representative shall be appointed to plan and oversee the implementation of the company s ES policy and the requirements of this standard. A job description outlining the responsibility and authority of this position shall be documented The company representative shall appoint individuals or a cross-functional team to monitor overall performance related to social, environmental, health and safety, and business management practices A job description outlining the responsibility and authority of these individuals/team members shall be documented. What does it mean? Implementation Guidance The means of achieving the company policy (and of compliance with this standard) must be planned, implemented and maintained. The position requires the person to have a level of authority sufficient to mobilize the organization s resources (such as people, equipment and money) in such a way that the company policy can be fully implemented. A key part of a successful implementation process is the communication of the policy and the means of achieving it throughout the organization. If this can be done by senior management, it will reinforce their commitment to the objectives within the policy. The company representative is typically responsible for monitoring the effectiveness of the policy s implementation, to support continual improvement. Performance monitoring also is usually an input into management review (see 4.1.4). The representative is responsible for implementing the policy which implies that some part of their performance measurement should be related to the achievement of goals and objectives stated in the policy. In many organizations, a cross-functional team will be needed to supplement the responsibilities of the appointed company representative, especially in areas that require knowledge of laws/regulations and the technical skills required to ensure compliance with employment and EHS laws/regulations. The person appointed to the position of company ES representative, as well as the ES team members, should have the necessary knowledge, training and skills. Ideally, they will have clear authority to take action on employment related matters. Organizations should carefully consider whether further training in specialist areas is required. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Appoint a senior person to be responsible for planning and overseeing implementation of policies. 2. Appoint individuals/ team members as needed to oversee technical aspects related to regulatory compliance. 3. Ensure that job descriptions set out their responsibilities and authorities. 4. Provide them with the resources they require to develop and implement the program, including training as required. Page 48 Appendix 2 SQFI Ethical Sourcing Standard April 2017

48 The auditor may look for evidence of: Auditing Guidance A senior manager being appointed with responsibility to plan and oversee implementation of the company policy. 2. Additional individuals/ team members appointed as needed to implement technical aspects related to employment and EHS. 3. A job description(s) having been prepared. 4. The job description(s) setting out the responsibility and authority of the position(s). 5. The person(s) appointed to the position demonstrating a clear understanding of their role and being able to demonstrate examples of their work. See Appendix 1, 4.0 for specific requirements related to Development of the Organization s ES Team Training Appropriate training shall be provided for new and existing personnel carrying out the tasks that are identified in the social management programs, the environmental management plan and the occupational health and safety plan as necessary to maintain the company s commitment to ethical sourcing. Training shall cover: General occupational health, safety and environmental (HSE) induction training; Ongoing training as required by applicable HSE regulations; Instructions outlining how tasks identified in the health and safety plan and the environmental management plan are to be performed; Topics and tasks required to ensure compliance with the applicable regulations related to employment practices. A training register shall be maintained describing: who has been trained in the relevant areas, who delivered the training, the content of the training, methods employed to demonstrate competence, and other information as required by national, state/provincial or local regulations Page 49 Appendix 2 SQFI Ethical Sourcing Standard April 2017

49 What does it mean? Implementation Guidance Several sections of the standard require employees to be properly trained, including: Requires training for employees who have been assigned ES responsibilities, including the requirements of this standard Requires training to a) meet legal requirements related to EHS and employment topics, b) to properly perform environmental aspects and impacts analysis, c) to properly perform health and safety hazards identification and risk assessment, etc. Induction training should set the tone for all new employees and should include discussion about management commitment to achieving the objectives set out in the policy. Key hazards identified in the health and safety management plan should be discussed, along with significant environmental aspects and impacts, and the employees roles in managing these hazards and impacts must be covered. In addition, senior managers and internal auditors for this standard require appropriate training. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Ensure that all new staff (new to the organization and new to a different site or role within the organization) receives general induction on the ES policy as well as health and safety matters. 2. Ensure that staff involved in implementing, managing and auditing the policy are appropriately trained to carry out their roles. 3. Maintain records of induction and training activities including dates, what was covered and who attended. The auditor may look for evidence of: Auditing Guidance Training that is appropriate for employees who have been assigned ES-related responsibilities, including those related to environmental aspects and impacts analysis, health and safety hazard identification and risk assessment, internal auditing, supplier selection and auditing, etc. 2. Employees identified above are competent as a result of the training activities. 3. Accurate training and induction records are up to date and are linked to the operational manual. See Appendix 1 for specific requirements related to training (e.g., 4.2, 6.1, 9.1, 11.4 and 11.5). 4.2 Suppliers and Subcontractors Selection of Suppliers and Subcontractors A senior company representative shall be responsible for maintaining procedures for the selection of suppliers and subcontractors and determining their ability to meet the company s social policies and the requirements of this standard. Page 50 Appendix 2 SQFI Ethical Sourcing Standard April 2017

50 What does it mean? Implementation Guidance The obligation to provide a suitable working environment for employees also covers subcontractors and suppliers. As an example, if a contract harvest crew is used, crew members should, at a minimum, comply with legal requirements and other agreements (including customer specifications) which the employing organization complies with itself. This implies that those requirements are adequately documented and included as part of the contract service specifications. Suppliers and subcontractors who are successful in obtaining work should agree (possibly in a contract) to comply with the organization's requirements regarding employee conditions and the requirements of this standard. What do I have to do? Some of the main steps to be followed to comply with this clause are: 1. Appoint a person with responsibility for evaluating suppliers and subcontractors. 2. Ensure they fully understand the ES policy and operational procedures. 3. Ensure that the specifications relating to supplier and subcontractor employment conditions have been developed and are adequately set out in the company's requirements for supplier or subcontractor services. 4. Maintain records of all supplier and subcontractor service agreements. The auditor may look for evidence of: Auditing Guidance Specifications for supplier and subcontractor performance having been completed. 2. The company's requirements being clearly communicated to suppliers and subcontractors (and agreed to by them). 3. These specifications having been adequately documented and maintained. See Appendix 1, 5.0 for specific requirements related to Suppliers and Subcontractors Evaluation of Suppliers and Subcontractors The company shall document its procedure for evaluating the performance of suppliers and subcontractors against the specifications set. A senior company representative shall be responsible for evaluating or monitoring the evaluation of suppliers and subcontractors. Evaluations shall occur: prior to the awarding of contracts to determine if the supplier or subcontractor can meet the specification required; and at appropriate intervals following the award of a contract to verify compliance with the conditions of the contract and the specified requirements. Page 51 Appendix 2 SQFI Ethical Sourcing Standard April 2017

51 What does it mean? Implementation Guidance This requirement relates to evaluation and assessment both prior to the awarding of a contract and after a contract has been awarded. Before a contract is awarded, suppliers and subcontractors should be asked to provide evidence that demonstrates their ability to comply with specified requirements. The organization must have a documented procedure to determine whether the supplier or subcontractor will be able to comply with the specifications set (see 4.2.1). This process should be objective and may include checking of references, interviewing past and current staff, labor associations, past users of the supplier or subcontractor and performing evaluation of performance at their present contract. Once a supplier or subcontractor has been appointed, the organization must have a means of monitoring their compliance with specifications. This may be by means of scheduled or unscheduled inspections, review of documentary evidence, monitoring of nonconformance, complaints or similar methods. The frequency and scale of monitoring should be appropriate to the risks and probability that noncompliance could occur. For examples, monitoring of subcontractors using dangerous equipment should be more frequent than of those not using equipment at all. Where past performance indicates that there is a risk of supplier noncompliance, frequency of monitoring should be higher than where evidence suggests a long history of compliance on the part of the supplier. One person in the organization must be clearly responsible for carrying out the evaluations or for ensuring that the evaluations are performed by other staff. Records of evaluations or assessments should be kept to demonstrate compliance (see for details). The procedure should address staff qualifications for carrying out the evaluations or inspections. It also should state what happens when evidence of noncompliance is discovered. What do I have to do? Some of the main steps to be followed to comply with this element are: Develop a documented procedure for evaluating and assessing suppliers and subcontractors. The procedure should cover the means and frequency of evaluation and assessment. It should ensure that actions are appropriate to the risks and consequences of noncompliance and to knowledge about the past performance of the supplier or subcontractor. Appoint a senior company representative who is responsible for evaluation or monitoring of suppliers and subcontractors, or ensuring that this is performed by other staff. Ensure that staff involved in evaluation are suitably qualified and are aware of the specifications suppliers and subcontractors are to be evaluated against. The auditor may look for evidence of: General Auditing Guidance There being a documented procedure for evaluating and assessing the performance of suppliers and subcontractors. 2. The evaluations and assessments having been performed according to that procedure. 3. Evidence being actively looked for by the supplier to show that suppliers and subcontractors are able to comply with conditions that have been set. 4. Evaluations taking place at a frequency and detail appropriate to the risks, status and importance of the activity being undertaken. 5. Those undertaking the evaluation being qualified to do so and understanding the specification they are assessing against. 6. Adequate records of evaluation and assessment must be maintained. 7. A senior company representative who is responsible for carrying out evaluation and monitoring of suppliers and subcontractors having discharged his or her responsibility. See Appendix 1, 5.0 for specific requirements related to Suppliers and Subcontractors. Page 52 Appendix 2 SQFI Ethical Sourcing Standard April 2017

52 4.2.3 Evaluation and Assessment Reports The company shall maintain appropriate records of all evaluations and assessments of suppliers and subcontractors. What does it mean? Implementation Guidance When supplier or subcontractor performance is evaluated, a written record of the results of that assessment shall be created. The record should identify, among other relevant information: the date and location of the evaluation; the person(s) conducting the evaluation; who was evaluated, and at what location; the means of evaluation; the outcomes of the evaluation, including objective evidence of compliance and noncompliance; a summary of corrective actions that will be taken on all non-compliances. The record could be in the form of a formal report, completed checklists or inspection notes. The type of record should be specified in the assessment procedure referenced in Ideally, the record should be agreed to by the supplier or subcontractor as being an accurate record of the evaluation. The record should show that corrective actions (see 4.5.4) have been carried out and any nonconformity has been rectified. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Specify what records are required, the means of recording data and how long records should be retained. 2. Specify where records will be kept and how they will be indexed and retrieved; 3. Ensure that for each assessment of a supplier or subcontractor who is assessed a record is created and kept. The auditor may look for evidence of: Auditing Guidance Maintain complete, legible and accessible records of supplier/subcontractor assessment activities. 2. Records containing enough objective information to allow an assessment of supplier or subcontractor compliance with specified requirements. 3. Non-compliances being clearly identified in the records. 4. Appropriate corrective action being taken on non-compliances. See Appendix 1, 5.0 for specific requirements related to Suppliers and Subcontractors. 4.3 Social Management Programs Discrimination and Harassment Equal Opportunity in Hiring The company shall not discriminate in its hiring of potential employees on the basis of age, gender, religion, marital status, race, caste, social background, disease, disability, pregnancy, ethnic or national origin, nationality, membership in worker organizations including unions, political affiliation, sexual orientation or any other personal characteristic Equal Opportunity in Employment With regard to compensation, training, promotion, termination or retirement, the company shall not discriminate against any employee on the basis of age, gender, religion, marital status, race, caste, social background, disease, disability, pregnancy, Page 53 Appendix 2 SQFI Ethical Sourcing Standard April 2017

53 ethnic or national origin, nationality, membership in worker organizations including unions, political affiliation, sexual orientation or any other personal characteristic Harassment The company shall ensure that employees are not subjected to any sort of bullying, harassment or abuse (sexual, verbal, physical, cyber, etc.) for any reason. What does it mean? Implementation Guidance The intent of this section is to ensure that all employees are treated with respect and dignity. These statements are legal requirements in the U.S. and many other countries. To comply with these requirements and to communicate the need to comply with these requirements within the organization, documented policies and procedures prohibiting discrimination in hiring/employment and prohibiting harassment or abuse are needed. People with the same skills shall be treated equally and evaluated equally. They shall have the same opportunities and be subjected to the same sorts of constraints. They must also have the same opportunities regarding compensation, promotion and training, and be subjected to the same sorts of constraints. A recruitment policy must be developed that includes evaluation of candidates based solely on skills and qualifications. Discrimination, bullying, harassment and abuse of any type shall not be tolerated, and this behavior shall be specifically prohibited by company policy. The actions of the organization should show that the policy is being carried out. These policies cannot be fully implemented just by addressing activities of the personnel department. All employees must be actively involved. Where there is evidence of bullying, discrimination, harassment or abuse by any employee, management must act quickly and decisively to send out a clear message that this behavior will not be tolerated. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Ensure that company policy prohibits discrimination in hiring and employment, as well as harassment/abuse. 2. Implement the policies and ensure that all employees are aware of the policies. 3. Treat all allegations of discrimination, harassment or abuse seriously to reinforce the message that these are not acceptable behaviors. 4. Maintain records of incidents and complaints plus any action taken. See Annexes 1 and 2 for guidance on performing a risk assessment related to social management programs. Auditing Guidance The auditor may look for evidence of: 1. Recruitment and hiring policies and procedures that address discrimination. 2. Policies and procedures that address discrimination following hiring, as well as harassment or abuse. 3. All employees are aware of these policies. 4. The company's policy being implemented at all levels of the organization. 5. Examples of management acting decisively with respect to allegations of discrimination. 6. Any indications that harassment or abuse may be being practiced within the organization. See Appendix 1, 6.1 for specific requirements related to Discrimination and Harassment Wage Compliance 1 The company has a wage compliance program in place which ensures that employee wages, payment cycles, overtime policies all adhere to national, state/provincial and local regulation or International Labor Organization (ILO) Conventions Pay rates (regular and overtime), dates and means of payment, and usual working hours comply with applicable regulatory requirements or international conventions Excessive working hours (>72 hours per week) are not utilized. Page 54 Appendix 2 SQFI Ethical Sourcing Standard April 2017

54 What does it mean? Implementation Guidance Employees should be at or above the level of salaries and wages set out in legislative minimums and in all labor agreements. All deductions legally required (for example income tax or social security payments) shall be made, and the employer shall correctly account authorities for these deductions and shall communicate the nature and amount of these deductions to the employee. Employers shall not withhold wages except as permitted by national, state/ provincial, and/or local law or by a legal contractual agreement. Workers shall not be required to make deposits/financial guarantees. Wages should be paid in cash, by check or directly into a bank account. Expenses should not be offset against those wages unless this is freely and explicitly agreed by the employee. Appropriate records of hours worked, the wages paid and the date of payment shall be kept. Ideally, employees should acknowledge payment by way of signature or similar, and this should be included in the record. Employees shall be compensated for all hours worked (including overtime) according to local regulatory requirements. Excessive working hours (>72 hours/week) should be avoided Organizations that are pursuing Ethical Sourcing certification at Level 3 will comply with the following requirements related to working hours: 1. Set working hours that comply with national laws or benchmark industry standards or relevant international standards, whichever affords greater protection to ensure the health, safety and welfare of workers. 2. Limit the standard allowable working hours in a week to 48, excluding overtime and not require workers to work in excess of 48 hours per week on a regular basis. 3. Overtime must be voluntary, limited to a maximum of 12 hours per week and not be requested on a regular basis. 4. Respect workers right to breaks during work shifts and to at least one free day following six consecutive days worked as well as public and annual holidays. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Determine the minimum level of wages and salary to be paid in legislation or in labor agreements. 2. Pay employees at or above this level. 3. Keep records of hours worked, deductions and payments, with employee acknowledgement. 4. Ensure any deductions are paid to the appropriate government bodies. See Annexes 1 and 2 for guidance on performing a risk assessment related to social management programs. The auditor may look for evidence of: Auditing Guidance A documented policy for the description of wage compliance, focusing on ensuring compliance with regulations. 2. A documented policy stating that no forced or bonded labor will be utilized within the facility. 3. A documented procedure on the minimum age for workers to be used within the facility. 4. A documented procedure to ensure that all working hours will be compensated for within local regulatory requirements or ILO requirements. [ If in high risk countries lacking a firm regulatory foundation in wage compliance, an auditor may review worker files (wage records, payment slips) at a rate of 2 per 50 employees (max 10) to ensure compliance.] 5. Interviews with employees show that employees are aware of wage policy and it is consistently applied. See Appendix 1, 6.2 for specific requirements related to Wage Compliance Benefits 1 The company will have a provision in place for employee benefits, as required by national, state/ provincial or local regulation Provisions, if applicable, are identified for vacation, holidays and leave (regular, sick, maternity/paternity, etc.). Page 55 Appendix 2 SQFI Ethical Sourcing Standard April 2017

55 Implementation Guidance What does it mean? The supplier must have a documented provision regarding vacation, paid holidays and leave (regular, maternity/ paternity, sick, etc.) as required by local regulation. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Identify any applicable legal requirements related to the provision of vacation, holidays and employee leave. 2. Document these provisions and communicate them to employees. See Annexes 1 and 2 for guidance on performing a risk assessment related to social management programs. The auditor may look for evidence of: Auditing Guidance A documented provision for vacation, holidays and leave. 2. Interviews with employees verify that employees are aware of benefits and able to freely join unions. Note: Evidence that some employees are members of associations is a sound indicator that there are no restrictions but is not, in and of itself, evidence that restrictions do not exist. See Appendix 1, 6.3 for specific requirements related to Benefits Terms of Employment 1 The company shall provide employees documented terms of employment. The document shall address at a minimum: Forced labor is not utilized. Bonded labor is prohibited. Identity documentation must be verified if required by local regulation. Identity papers shall not be bonded to the company by employees Child labor is not utilized except as permitted by national, state/provincial or local regulations, or consistent with ILO Conventions 138 and 182. Minimum age of employment complies with applicable regulations or is in line with ILO Conventions 138 and Employees have the right, as permitted by national, state/provincial, and/or local legislation, to join or form trade unions of their own choosing without prior authorization from management and have the right to bargain collectively. The company shall not interfere with, obstruct, or prevent such legitimate and lawful activities Rights and obligations of both parties as appropriate Conditions for disciplinary action, including suspension and termination. Page 56 Appendix 2 SQFI Ethical Sourcing Standard April 2017

56 What does it mean? Implementation Guidance The terms of employment must exist in a written document. All terms and conditions of employment shall be based on an individual s ability to do the job, not on the basis of personal beliefs or characteristics. Where employees may not be able to read a written document, employers should ensure that as well as the written document, there are means to communicate with employees so that they have a full understanding of the contents. Employees, when asked to sign a formal contract, should be given reasonable time to consider the contract s content and seek advice from third parties if required. It is unlikely that reasonable time will be under a full day. The employer shall keep a copy of any contract and shall provide a copy to the employee. All work must be conducted on a voluntary basis, and not under threat of any penalty or sanctions. No forced, bonded or indentured labor is utilized. Forced labor includes any work or service exacted from a person as a consequence of a conviction in a court of law unless the work or service is carried out under the supervision and control of a public authority and the person is not hired to or placed at the disposal of private individuals, companies or associations. Bonded labor is a form of debt slavery that is created when an individual begins to work for another person who holds a debt from that worker. Bonded labor includes encouraging workers to incur debt by recruitment fees, fines or other means. Employers shall not retain employee identity documents (such as passports, identity cards, etc.). Workers have the right to terminate their employment after reasonable notice and the right to leave the workplace after their shift. For companies pursuing Level 3 certification, the use of forced or compulsory labor in all its forms is prohibited, including prison labor when not in accordance with ILO Convention 29. The employer shall identify local regulations governing the use of child labor and minimum age requirements, if applicable, and either comply with these regulations or follow ILO recommendations (if the latter are more protective of children). Young workers under 18 years shall not be employed in conditions which compromise their health, safety or moral integrity, or which harm their physical, mental, spiritual, moral or social development. If a child is found to be directly or indirectly working for a supplier contrary to the requirements above, the supplier will seek a satisfactory solution that gives priority to the best interests of the child. Employees have the right to join lawful associations such as labor unions. Employers (including subcontractors) shall not impede those employees who choose to join associations. The right of employees to be represented by those associations shall be respected, and representatives of those associations shall be given reasonable access to their members and be permitted to represent them in negotiations. There shall be no hidden discrimination toward members of associations. If employees wish to represent themselves in negotiations, and where this is legally allowable, this right shall be respected. A written procedure is in place to address disciplinary action, including suspension and termination. All such actions must be documented. What do I have to do? 1. Develop documented terms of employment or contract. 2. Ensure employees have time to consider the contents before binding themselves to the terms or the contract. 3. Where employment contracts are signed by employees, provided copies to employees for their records. 4. Ensure that at all levels throughout the organization, employees are not prevented from joining lawful associations. 5. Recognize the right of those organizations to bargain on behalf of their members. 6. A documented statement is available which describes rights and obligations for employee and employer. See Annexes 1 and 2 for guidance on performing a risk assessment related to social management programs. Auditing Guidance The auditor may look for evidence of: 1. Documented terms of employment, which layout pay rates, overtime and usual work hours. 2. Employees knowing of documented terms of employment or a contract and being aware of the main terms. 3. Employees who may be illiterate being able to explain how the content of the documented terms/contract has been communicated to them. 4. Employees having identified regulations governing the use of child labor/ minimum age requirements and ILO recommendations. 5. Employers having identified whether local regulation or ILO recommendations are more protective of children. 6. Employees being able to join lawful associations. 7. The supplier must have a documented termination program, which describes specifically the protocols to follow for termination. Page 57 Appendix 2 SQFI Ethical Sourcing Standard April 2017

57 See Appendix 1, 6.4 for specific requirements related to Social Compliance Programs. 1 Supplemental Implementation Guidance (Level 3) Organizations that are pursuing Ethical Sourcing certification at Level 3 will comply with the requirements of the following International Labor Organization (ILO) conventions if they are more protective than national, state/provincial and/or local laws and regulations. Implementation and auditing guidance is consistent with actions described in sections for Social Management Programs, as well as in sections for Occupational Health and Safety Management Programs. ILO Core Labor Standards: - C29 Forced Labour Convention, C87 Freedom of Association and Protection of the Right to Organise Convention, C98 Right to Organise and Collective Bargaining Convention, 1949 Other ILO Labor Standards, as applicable: - The ILO call for Decent Work - C1 Hours of Work (Industry) Convention, C14 Weekly Rest (Industry) Convention, C95 Protection of Wages Convention, C131 Minimum Wage Fixing Convention, C135 Workers' Representatives Convention, C155 Occupational Safety & Health Convention, C100 Equal Remuneration Convention, C105 Abolition of Forced Labour Convention, C111 Discrimination (Employment & Occupation) Convention, C138 Minimum Age Convention, C182 Worst Forms of Child Labour Convention, C161 Occupational Health Services Convention, R85 Protection of Wages Recommendation, R116 Reduction of Hours of Work Recommendation, R135 Minimum Wage Fixing Recommendation, R164 Occupational Safety and Health Recommendation, R184 Home Work Recommendation, R190 Worst Forms of Child Labour Convention Recommendation, 1999 Organizations pursuing Ethical Sourcing certification at Level 3 will comply with the following requirements related to terms of employment and working hours: 1. Provide all workers with written, understandable information about their employment terms, including wages, before they enter into employment; and about details of their wages for the pay period concerned each time that they are paid. 2. Set working hours that comply with national laws or benchmark industry standards or relevant international standards, whichever affords greater protection to ensure the health, safety and welfare of workers. 3. Limit the standard allowable working hours in a week to 48, excluding overtime and not require workers to work in excess of 48 hours per week on a regular basis. 4. Overtime shall be voluntary, limited to a maximum of twelve hours per week and not be requested on a regular basis. 5. Respect workers right to breaks during work shifts and to at least one free day following six consecutive days worked as well as public and annual holidays. See Appendix 1, 6.0 for specific requirements related to Social Management Programs. 4.4 Environmental and Occupational Health and Safety (EHS) Management Programs Environmental Management Plan The company shall evaluate and prioritize its environmental impacts and develop an Environmental Management Plan (EMP) for priority impacts identified through this process. The EMP must specify: management objectives, targets and program activities intended to eliminate, control and/or reduce priority impacts and to identify/comply with applicable regulatory and other requirements (e.g., trade association or community commitments). The tasks, time frames, resources and responsibilities required to meet the nominated objectives and targets shall be identified. At a minimum, the EMP shall include specific details on the following topics, if applicable to the scope of the organization s ES Program: Energy use and air emissions; Inventory energy usage and air emissions, including greenhouse gases (GHG) and ozone-depleting substances (ODS) Water consumption Page 58 Appendix 2 SQFI Ethical Sourcing Standard April 2017

58 Waste water treatment and effluent management Waste management Proper identification, handling segregation/storage and disposal of waste and waste containers Compliance with regulations/ ordinances governing on-site burning/landfilling Implementation of recycling/ waste reduction programs Pollution prevention Hazardous chemical inventory Groundwater Noise and nuisance prevention Land and soil pollution (community impact) prevention Land use and biodiversity - Impacts on the local environment and communities What does it mean? Implementation Guidance Environmental Management Plans (EMPs) relate to the significant or priority environmental impacts you have identified through the initial Environmental Review and/or subsequent Management Reviews. Generally, they include specific objectives and targets to be met within stated timeframes for the priority areas backed up by procedures to eliminate, reduce and control the risks identified along with procedures for internal auditing and review. They also will define records and documentation needed to demonstrate the EMP is operating effectively. What do I have to do? Your Environmental Management Plan is the core of the systems management approach. It is the strategic plan for key areas of environmental impacts caused by your business. Some EMPs are applicable to all businesses in the agrifood chain, while others are specific to key stages, types of business or even geographical location. An effective EMP requires detailed knowledge of your operations, including historical exposures and the potential contamination from off-site sources. In developing your EMP, you should focus on the following: Understand and record data on appropriate environmental impacts. Consider normalizing the data if by so doing the data are more meaningful and will help to improve environmental performance. Consider objectives and targets that reflect industry/international standards, exceed these standards, and/or are sustainable. Where appropriate, consider targets beyond standards. Operating practices include a review of opportunities to optimize the input of agrichemicals. Where local regulations describe objective or targets, the supplier must ensure that these are utilized and met. If no regulatory requirement exists for the area of concentration, the supplier should utilize best industry practice. The organization must manage its waste properly. Storage must be managed to prevent releases, cross- contamination or an incident. Waste must be disposed of as appropriate for the waste stream and within regulations. This excludes on-site burning and uncontrolled landfilling of hazardous waste. Waste minimization and source reduction must be actively pursued. Proper records must be kept to show that the waste was managed properly. Audits and inspections must be performed to verify conformity to requirements. Engage stakeholders (customers, distributors, the community, etc.) about the organization s efforts to be socially- and environmentally-responsible and to identify opportunities to improve environmental performance. Many countries provide guidance on good agricultural practices. These can be used to help develop your EMP. Food sectors in some countries also have developed environmental guidance. See Annexes 3 and 4 for guidance on performing an environmental aspects and impacts analysis. Page 59 Appendix 2 SQFI Ethical Sourcing Standard April 2017

59 Supplemental Implementation Guidance (Level 3) The organization proactively seeks to identify and commit to voluntary codes/ standards for improving ES-related performance that are appropriate for its site/ activities. The EMP incorporates leading- practice programs/technologies, where relevant and appropriate for the site/ activities, regarding: 1. Air Emissions Reduce greenhouse gas intensity Abatement and/or source reduction Sustainable within local ecosystem limits 2. Water Consumption Efficient use, reuse, recovery, recycle Sustainable within local ecosystem limits and drainage / catchment areas 3. Wastewater Effluent (quality/volume) Treatment of waste water (on-site or connection to off-site system; reuse of grey water, etc. Volume/quality are sustainable within local receptor and ecosystem limits 4. Waste (volume/disposal method) Minimize natural resource and virgin raw material consumption Reduce, reuse, recycle waste; energy from waste; etc. Sustainable disposal method/volume within availability of treatment and disposal facilities and the local environment Supplemental Implementation Guidance (Level 3) (continued) 5. Land Use and Biodiversity Prevent further/future contamination to soil and/or groundwater and in relation to remediation Promote biodiversity and land management Sustainable within local ecosystem Zero Contamination target and policy No negative impact on designated protection areas or species; Demonstrable improvement, where appropriate, in land use/biodiversity performance including deforestation, rehabilitation and conservation activities 6. Nuisances Reduce impacts related to process changes, traffic, noise, etc. Zero Complaint target and policy 7. Chemicals Investigate non-chemical alternatives Identify and comply with prohibited chemicals lists (e.g., for agrichemicals from the World Health Organization) Engage appropriate stakeholders throughout the value chain in mutual discussions regarding: environmental impacts, incidents, performance indicators/data, and controls; opportunities to reduce impacts and improve environmental performance; and exert influence, as appropriate, on the environmental performance of suppliers and off site contractors who provide goods and services to the organization. Note: Topics for stakeholder engagement include, as appropriate, those listed in Appendix 1, and 7.3 Continued. Auditing Guidance The auditor may look for evidence of: 1. A documented environmental management plan that includes objectives and targets for achieving each area of concentration. 2. Objectives and targets which are relevant to the priority areas and capable of being realized through the application of the documented procedures and management. 3. Procedures which are capable of eliminating or reducing the identified environmental impacts to an acceptable level. 4. Operators following these procedures including those for normal, abnormal, accident and emergency situations. This may mean that auditors will interview operators to evaluate their understanding of procedures. 5. The documented plan must include energy use and air emissions, water consumption, waste water treatment, waste management, pollution prevention, land use and other actions required by Appendix 1, 7.3 graduated requirements (for each applicable environmental aspect for the appropriate certification level). See Appendix 1, 7.0 for specific requirements related to Environmental Aspects/ Impacts and EMPs. See Appendix 1, 7.3 for details on graduated requirements (i.e., Levels 1, 2 and 3) for each EMP aspect Occupational Health and Safety Plan The company shall provide a healthy and safe working environment for employees. The company shall evaluate its occupational health and safety hazards, assess and prioritize their associated risks, and develop an Occupational Health and Safety Plan (OHSP) for priority risks identified through this process. The OHSP must specify management objectives, targets and program activities intended to eliminate, control and/or reduce priority hazards and risks, and to identify and comply with applicable legal and other requirements (e.g., trade association Page 60 Appendix 2 SQFI Ethical Sourcing Standard April 2017

60 commitments). The tasks, time frames, resources and responsibilities required to meet the nominated objectives and targets shall be identified. At a minimum, the OHSP shall include details on the following topics, if applicable to the scope of the organization s ES Program: Results of the risk assessment that identifies all hazards to employee health and safety in the work environment, including hazards related to the usage, storage and transportation of hazardous and potentially hazardous substances; Control measures (e.g., equipment, policies, procedures, etc.) that are appropriate to the industry sector and that, as far as reasonably practicable, eliminate, isolate and/or minimize the priority hazards/risks; Methods to periodically evaluate the effectiveness of these control measures; Procedures to manage risks associated with contractors and visitors; and Safe and clean drinking water, conditions for work, sanitary facilities and, where provided, for residential facilities, including sanitary facilities for food preparation and storage. What does it mean? Implementation Guidance The Occupational Health and Safety Plan is analogous to the Food Safety Plan and Food Quality Plan required by the SQF Code, 7 th edition. A similar framework may be used to develop these plans. One individual shall be made responsible for occupational health and safety. This person does not have to do all the work, but must ensure that the work is performed. It is desirable to involve employees in the determination of hazards to health and safety to be managed and in the daily appropriate means of management. Occupational health and safety programs usually involve an identification of occupational health and safety hazards, followed by an analysis of the risks posed by these hazards, taking into account the measures currently in place to eliminate or control identified hazards. Risk assessment also involves the design of any additional measures needed to manage identified risks and a process to verify that the risks are appropriately managed (i.e., to evaluate the effectiveness of implemented controls). The most common methods of managing identified risks are by: 1) elimination (for example, by changing a process to remove a toxic or flammable component), 2) engineering controls (for example, by isolating the risk posed by moving machine parts through the use of guarding), 3) administrative controls (for example, training and procedures), and 4) by protecting individual employees against the hazards (for example, by providing employees with protective clothing). The preferred order to manage hazards is elimination, then engineering controls, then administrative controls and, lastly, by impact minimization through the use of personal protective equipment. Risk assessment activity must include an evaluation of safeguards against fire, and adequate strength, stability and safety of buildings and equipment. Where personal protective clothing and equipment (PPC&E) are necessary to control worker exposure to hazards (physical, chemical, etc.), ensure that PPC&E are provided, along with training on the limitations and proper use/maintenance of such equipment. Supervisors must ensure that employees follow procedures and use the PPC&E provided. Failure to use safety equipment should be treated as a serious matter, and, if necessary, disciplinary action should be taken. All new employees should undergo some form of induction training, pointing out occupational health and safety policies and procedures and ensuring the employees understand their responsibilities in successfully carrying out the occupational health and safety program. Additional required training topics include the handling, management and disposal of waste, chemicals and other hazardous materials. There may be significant benefits in carrying out a pre- employment (and later a post-employment) health check, to identify any pre-existing conditions, and to verify that the employee s health has not deteriorated during the period of employment. For example, a hearing test or lung capacity test could be appropriate for those working in a noisy or dusty environment. Arrangements should be in place with resources/facilities to support medical incident response and, if appropriate, medical surveillance. Existing employees should receive training for all new situations that they may encounter (including the use of new machinery). Refresher training (particularly for seasonal operations) may be required. In some cases, regular health monitoring may be required to see if the long-term deterioration may be occurring. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Appoint a senior manager with responsibility for occupational health and safety. 2. Identify the hazards present and the risks to be managed. Page 61 Appendix 2 SQFI Ethical Sourcing Standard April 2017

61 3. Document the procedures by which hazards will be controlled (elimination, engineering controls, etc.). 4. Implement the control measures/procedures, including appropriate training for new and existing employees. 5. Carry out follow-up audits to ensure that control measures are effective in managing these hazards. 6. Arrange for induction and refresher training. See Annexes 1 and 2 for guidance on performing a hazard identification and risk assessment. See Annexes 3 and 4 for guidance on performing an environmental aspects and impacts analysis. The auditor may look for evidence of: Auditing Guidance A senior management person being appointed to be responsible for employee occupational health and safety. 2. Hazards being correctly identified. 3. Policies and procedures appropriate to the industry sector have been developed and implemented. 4. Control points for each hazard being identified and then eliminated, controlled and/or minimized. 5. Procedures being implemented in the workplace. 6. All new staff receiving occupational health and safety training. 7. Existing staff receiving additional occupational health and safety training as required. 8. Safety equipment being used and kept in good condition. 9. Regular updating of risk analysis. See Appendix 1, 8.0 for specific requirements related to Occupational Health and Safety Hazard Identification and Risk Assessment and development of OHSPs Regulatory Compliance The Environmental Management and Occupational Health and Safety Plans shall ensure the identification of, and compliance with, all applicable regulations, including that all monitoring and recordkeeping is completed per regulatory requirements and business licenses/permits are maintained and current. What does it mean? Implementation Guidance The company must be aware of all applicable regulations dealing with environmental impact, discharge or waste, as well as those governing occupational health and safety. In addition, the supplier must be aware of all social, labor, and employment regulations under which they operate. Where no regulation exists, the supplier should be aware of industry best practice or the International Labor Organization (ILO) ( for social and labor compliance best practices. For environmental, the Global Social Compliance Program guideline on implementation of environmental programs is an excellent resource and can be found at: ( The company must be aware of any and all business licenses and permits which are required for environmental management and occupational health and safety compliance and ensure that all licenses and permits are current. What do I have to do? 1. Be aware of all applicable regulations for the implementation of this ES Standard. 2. Ensure that plans developed for Social Program Management, Environmental Management, and Occupational Health and Safety Management ensure compliance with applicable regulations. 3. Ensure that all required business licenses and permits are current. See Annexes 1 and 2 for guidance on performing a risk assessment related to social management programs. See Annexes 3 and 4 for guidance on performing an environmental aspects and impacts analysis. Page 62 Appendix 2 SQFI Ethical Sourcing Standard April 2017

62 The auditor may look for evidence of: Auditing Guidance The supplier being aware of all local and national regulations which include all applicable areas which are covered under this ES Standard. 2. The supplier ensuring that all business licenses and permits are current as required by local regulation. See Appendix 1, 9.0 for specific requirements related to Recognition of, and Compliance with, Legal and Other Requirements for ES Equipment Maintenance All equipment used in the treatment, handling, monitoring and storage of air, waste, waste water, water, or other elements, as identified within the Environmental Management Plan, shall be included on an inspection, testing preventive maintenance (ITPM) schedule. Records shall be maintained to verify ITPM activities All equipment used to provide healthy and safe working conditions for employees, as identified within the Occupational Health and Safety Plan, shall be included on an inspection, testing and preventive maintenance (ITPM) schedule. Records shall be maintained to verify ITPM activities. What does it mean? Implementation Guidance The company must be aware of all monitoring that is required in their environmental management plan and their health and safety plan. Any equipment that is utilized to monitor compliance with these management plans must be identified. The identified equipment must be properly maintained per manufacturers recommendations. This includes a preventative maintenance schedule for proactively assuring that the equipment remains in proper working order. Records must be maintained for all maintenance activities, including preventative maintenance, to ensure that it was completed and documented. What do I have to do? 1. Identify all equipment used to monitor environmental and health and safety management plan targets. 2. Develop a maintenance program, including preventative maintenance schedule, for all identified equipment. 3. Maintain records of all maintenance activities. See Annexes 1 and 2 for guidance on performing a risk assessment related to social management programs. See Annexes 3 and 4 for guidance on performing an environmental aspects and impacts analysis. Auditing Guidance The auditor may look for evidence of: 1. The company must have a documented maintenance program for all equipment which is used in the monitoring of EHS targets and to demonstrate compliance with regulatory requirements. 2. The supplier must ensure that the maintenance program has a preventative schedule of activities and records to ensure that activities have occurred and are documented See Appendix 1, 10.0 for specific requirements related to Equipment Maintenance. Page 63 Appendix 2 SQFI Ethical Sourcing Standard April 2017

63 4.4.5 Incident Management An emergency response program shall be in place to respond to an environmental or health and safety incident, including an emergency management team with current contacts, a communications plan for incidents, a current contact list of customers and stakeholders, procedures for managing an emergency response, and at least annual testing of the emergency response program. What does it mean? Implementation Guidance This can be an extension of a crisis management program or business continuity plan. A supplier must ensure that their incident management plan includes the event of an incident in the area of environmental management. Although various definitions exist, an incident would usually be considered major if it causes (among others): persistent and extensive effect on the quality of the air, land or water environment; significant harm to the environment; closure (temporary or permanent) of a drinking (potable) water abstraction point; significant impact on property; significant damage to agriculture and/or commerce; or serious impact on humans. Significant harm to the environment or humans can include (but not necessarily be limited to): death of or serious injury/illness to humans; the death of, or adverse effects on, local species; widespread damage to habitats or specific ecosystems; significant contamination of water supplies, soil or groundwater; damage to historic buildings, landscape, heritage sites, recreations areas; and the loss of utility/resource, e.g. fishing grounds in a river, an area for recreation or leisure. The impact of a major incident will not only relate to the cause and the substances involved, but also to the environment in which it occurs, proximity of other land uses, people, sensitive habitats etc. An uncontrolled situation (incident) may arise due to on-site or off-site events or factors. If operations at your facility could not lead to a major environmental incident, this element may not be applicable. As with all incident management plans, a current contact list of all stakeholders is critical to success. The incident management plan must be tested at least annually What do I have to do? 1. Identify the types of emergency scenarios that could occur at your operations. 2. Ensure that your current business continuity plan includes the possibility of an environmental incident. 3. Ensure that all stakeholder contact lists are current and up to date. 4. Test the incident management program at least annually. See Annexes 1 and 2 for guidance on performing a risk assessment related to social management programs. See Annexes 3 and 4 for guidance on performing an environmental aspects and impacts analysis. Auditing Guidance The auditor may look for evidence of: 1. The supplier must have a documented emergency response program which included environmental incident management. 2. The supplier must have a current contact list of stakeholders, internal resources and customers. 3. The supplier must test the system at least annually. See Appendix 1, 11.0, Emergency Preparedness for specific requirements related to Incident Management. Page 64 Appendix 2 SQFI Ethical Sourcing Standard April 2017

64 4.5 Monitoring and Management Review Internal Audits The company shall schedule, carry out and document regular internal audits to confirm the effectiveness of its implementation of this standard. Results of audits shall be brought to the attention of senior management and those responsible for the area being audited, who shall be responsible to ensure that actions are taken in a timely manner to correct any nonconformities identified. What does it mean? Implementation Guidance The scope of the SQF Code, 7 th edition, clause can be expanded to cover the requirements of this standard. Internal reviews should be carried out by suitably qualified employees to ensure that the organization's activities comply with planned arrangements. These employees should be qualified in the process of auditing (ISO and ISO provide useful guidance in this area), as well as having detailed knowledge about the company's policy and procedures with respect to employment and EHS conditions. Reviews must be scheduled at a frequency that is appropriate to the probability and magnitude of any risks being faced, and to information regarding previous levels of nonconformity. The minimum frequency for reviews is once a year. The results of audits must be documented. Evidence of nonconformity must be clearly documented and follow-up action taken (see 4.5.4). What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Create an audit schedule. 2. Schedule audits according to the risk, status and importance of the activity. 3. Define qualification criteria for people performing audits. 4. Carry out audits using suitably trained/competent employees. 5. Ensure that audit results are documented. 6. Ensure that audit results are brought to the attention of those managers responsible for the area being audited. 7. Ensure that a system exists to verify that appropriate and effective corrective action is taken on non-conformities. See Annexes 1 and 2 for guidance on performing a risk assessment related to social management programs. See Annexes 3 and 4 for guidance on performing an environmental aspects and impacts analysis. Auditing Guidance The auditor may look for evidence of: 1. Internal audits being scheduled. 2. Audits being carried out according to the schedule. 3. The schedule reflecting the risk, status and importance of the activity. 4. Employees involved in auditing complying with the staff competency criteria. 5. Results of audits being documented. 6. Results of audits being brought to the attention of those people who are responsible for the area being audited. 7. Effective corrective and preventive action taking place. See Appendix 1, 12.0 for specific requirements related to Internal Audits. Page 65 Appendix 2 SQFI Ethical Sourcing Standard April 2017

65 4.5.2 Monitoring The company must establish and maintain programs to monitor and measure impacts identified as a priority for management. All equipment used for monitoring must be routinely calibrated to ensure accuracy appropriate to its use. Equipment and calibration records must be maintained. What does it mean? Implementation Guidance It is important to monitor whether your procedures are actually addressing the environmental threat(s) you have identified. This means that you must develop a program to monitor the threats. It also means that any equipment you use to monitor or carry out a process must be maintained and regularly calibrated. In order to demonstrate that this has been done, you need to keep records of monitoring and calibrations. What do I have to do? Based on the methods you used to identify the threat(s) to the environment in the Environmental Review (4.4.1) and Risk Assessment (4.4.2), the key steps in developing a monitoring program are as follows: 1. Where you have identified steps in your process that can have an impact on environmental/human receptors, establish monitoring procedures for operational and critical limits and keep records of this monitoring. 2. Identify how you can objectively assess the environmental/human impact of the threats you have identified and establish a program to eliminate or control the threats and periodically reassess the effectiveness of these control measures. The frequency of this will partly depend on the length of the production process (e.g. annual production of some crops to daily batch processes). 3. If any equipment is used in a procedure that may affect the presence or absence of the threat, this equipment must be calibrated according to manufacturer s instructions and records maintained of the calibrations. 4. Similarly, any equipment used to specifically measure EHS parameters/performance or to demonstrate compliance with applicable regulations, also must be calibrated according to manufacturers instructions and records kept of these calibrations. 5. All equipment used in procedures or for monitoring should be appropriate for the intended use. The outcomes of the monitoring program should be used as part of the Management Review (4.5.6). The auditor may look for evidence of: Auditing Guidance The methods and equipment used to measure environmental threats to ensure they are appropriate for the intended use. 2. Calibration of equipment used in procedures and/or to measure EHS impacts/ hazards is carried out in accordance with manufacturers instructions. 3. Records that show monitoring procedures and calibration are being carried out regularly and according to the EMP. 4. Appropriate training of staff responsible for monitoring to ensure that they understand their roles and responsibilities. 5. That monitoring records are used to inform internal audit procedures and the management review. See Appendix 1, 12.0 for specific requirements related to Monitoring. Page 66 Appendix 2 SQFI Ethical Sourcing Standard April 2017

66 4.5.3 Investigation of Employee Concerns The concerns of company employees and other directly involved interested parties in respect to their working environment and conditions shall be investigated by a senior company representative in a timely manner. What does it mean? Implementation Guidance There should be a process by which the employees can freely raise their concerns, without fear of negative consequences of discrimination (4.3.1). This may be formal by way of scheduled meetings with employees, suggestion boxes, using an independent third party to elicit employee views, or informal by managers asking employees about their concerns, or by observation. Concerns raised by employees must be followed up by way of the corrective action system (see 4.5.4). Other interested parties could include stakeholders such as the local community, shareholders, employee collective bargaining agents, regulatory authorities or the organization's suppliers or customers. Recognizing that some concerns will be related to occupational health and safety, responses need to be timely in relation to the level and immediacy of the hazard and its associated risk. It may be appropriate for significant concerns to be investigated by an independent party who does not have an interest in the outcome of the investigation. This ensures that the investigation will be seen as unbiased and objective. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Ensure that all concerns are investigated by a senior company representative or by an impartial person who reports to that representative. 2. Ensure that the issues arising from investigations are reviewed and, where required, effective actions are taken. 3. Document the outcome of such investigations. The auditor may look for evidence of: Auditing Guidance Concerns of employees and third parties being investigated in a timely manner. 2. Findings of such investigations being followed up on in an appropriate fashion. 3. Findings of actions taken as a result of reviews of these concerns. 4. Documentary evidence of investigations and outcomes. See Appendix 1, 12.0 for specific requirements related to Investigation of Employee Concerns Corrective and Preventive Action The company shall document a procedure for identifying and documenting the cause and resolution of issues that arise as a result of accidents and incidents, internal audits/reviews and concerns by employees or other parties. Appropriate and effective action shall be taken to resolve issues that are raised. What does it mean? Implementation Guidance When a noncompliance (or potential noncompliance) is raised, the matter should be investigated. The noncompliance may be with the company's own procedures, or may be that the procedures themselves are not in compliance with legal or other requirements, or that they do not result in the stated policy objective being met. The investigation should consider the root cause of the problem and how this root cause can be addressed so that the problem does not recur. Other instances where the root cause may have created problems should be investigated and corrected. Page 67 Appendix 2 SQFI Ethical Sourcing Standard April 2017

67 Implementation Guidance The effectiveness of the corrective action taken needs to be verified to ensure that the root cause of the noncompliance was correctly identified and that the solution has correctly and effectively addressed the problem. The process for achieving this shall be documented. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Develop a procedure for identifying and documenting the cause and resolution of actual or potential noncompliances. 2. Ensure that all actual or potential non-compliances are fully investigated to identify the root cause. 3. Propose appropriate effective corrective action to address the issues. 4. Verify that the action has been taken. 5. Verify that the action has been successful in addressing the matter raised. 6. Document procedures. The auditor may look for evidence of: Auditing Guidance There being a documented procedure for identifying and documenting non-compliances or potential noncompliances. 2. The procedure requiring that the investigation of the cause of the noncompliance or potential noncompliance and its resolution are documented. 3. The procedure being effectively implemented. 4. Examples of effective corrective action addressing problems. 5. Records indicating that action taken to address actual or potential non-compliances are appropriate and effective. See Appendix 1, 12.0 for specific requirements related to Corrective and Preventive Action Record Keeping The company shall maintain legible records to demonstrate compliance with this standard. What does it mean? Implementation Guidance Records are documents that provide objective evidence of activities performed or results achieved. They must be complete, legible, and stored in a way that they can be retrieved, and be created and stored in a way to prevent them from deterioration during the required period of maintenance. Electronic records should be backed up, with backup copies kept off-site. The minimum period of record retention should be specified, based on regulatory requirements, customer requirements and/or company record retention policy requirements. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Develop a procedure for the creation, maintenance, control, and retrieval of records. 2. Ensure that records required by regulations or by customer requirements are retained for the required period, and that all other records are retained according to company record retention requirements. 3. It also may be useful to specify disposal methods for records, especially those containing confidential employee information. 4. Ensure that records are appropriately created, maintained, controlled and stored. Page 68 Appendix 2 SQFI Ethical Sourcing Standard April 2017

68 Auditing Guidance The auditor may look for evidence of: 1. Records being able to be easily retrieved on request, showing that they are well filed and indexed. 2. All records being legible. 3. Records being complete. 4. Retention times for records being set. 5. Retention times for records being followed. 6. Records adequately demonstrating compliance with this module. See Appendix 1, 12.0 for specific requirements related to Record Keeping Management Review Senior management shall document the company s procedure for ensuring the continued effectiveness of its policy in relation to responsible social practice. Reviews shall be completed at least annually and shall be the responsibility of senior management. The outputs of management review meetings (e.g., performance results, improvement actions, etc.) shall be communicated to appropriate internal and external stakeholders. What does it mean? Implementation Guidance Senior management has set a policy (4.1.1) with supporting operational manuals(s) (4.1.2) and has delegated a manager to ensure that the policy is effectively implemented (4.1.3). To complete the management cycle, a performance review needs to be carried out and, where needed, changes made to the policy and/or plans for creating desired staff employment conditions, and those changes implemented. A management review usually includes an assessment of opportunities for improvement, review of the continuing appropriateness of the policy, and of the current means of implementing it. A good management review meeting considers a range of data that indicates how well objectives are being met. Data to be reviewed could include: Page 69 Appendix 2 SQFI Ethical Sourcing Standard April 2017

69 results of audits or inspections; Implementation Guidance (continued) status of objectives, targets and management programs intended to address significant impacts; implementation status of the facility s EMP, OHSP, etc.; records of accidents and incidents; feedback from staff and/or staff representatives, including complaints; results of corrective actions; changes in laws or other agreements that may have come into force since the last review, or are about to come into force; and recommendations for improvement. The management review shall be a relatively formal process and written minutes should be kept. It should occur at least annually, but a higher frequency may be appropriate if the system is newly introduced, is undergoing significant change, or if data indicate that objectives are not being achieved. A range of people may be involved in management review. Along with senior managers and supervisors, front-line staff could provide valuable contributions to setting and achieving objectives. The outcomes of the management review should concentrate on what changes may be required to enhance the company s social, environmental and occupational health and safety practices, and on how these changes need to be implemented. Implementation may require change or creation of documented procedures, records and training programs. Outputs from management reviews must be communicated to internal and external stakeholders, as appropriate, to raise awareness. What do I have to do? Some of the main steps to be followed to comply with this element are: 1. Schedule a management review meeting at least annually and more frequently if required. 2. Provide data for the meeting to consider. 3. Set an agenda and hold the meeting. 4. Complete the minutes and proceed to implement action points. 5. Communicate outputs to internal and external stakeholders, as appropriate. The auditor may look for evidence of: Auditing Guidance A management review having been performed within the past 12 months. 2. The management review considering reports/data/information on the effectiveness of the management system in meeting objectives for staff employment 3. Management review decisions having been fully implemented in the organization. 4. The management review procedure being documented. 5. The results of the management review having been documented. 6. The results of the management review having been communicated to employees. 7. The management review resulting in documented actions for improvement. See Appendix 1, 12.0 for specific requirements related to Management Review. 4.6 Business Management Principles for Senior Management Systematic Approach A systematic approach is in place for realizing financial and economic benefits associated with implementation of Ethical Sourcing. Example approaches include, but are not limited to: customer focus, continual improvement, process approach, mutually-beneficial supplier relationships, etc. Page 70 Appendix 2 SQFI Ethical Sourcing Standard April 2017

70 What does it mean? Implementation Guidance Effective implementation of elements of this standard can help an organization to realize economic and financial benefits. The management of resources and organizational improvement processes provide financial benefit and contribute to the overall economic health of the organization through the implementation of costeffective management practices. What do I have to do? The selection and implementation of improvement processes is a senior management decision. Thus, this level of management must decide and document which methods will be utilized to realize and sustain the financial and economic benefits related to Ethical Sourcing. The auditor may look for evidence of: Auditing Guidance The existence of a documented approach for realizing the financial and economic benefits related to Ethical Sourcing. See Appendix 1, 13.0 for specific requirements related to Business Management Principles for Senior Management Senior Management Actions This systematic approach is supported by actions on the part of Senior Management such as: Value-added customer focus; Implementing methods to realize financial benefits; Establishing a baseline for financial performance measurement; Establishing a trend analysis to review program performance and continual improvement; Communicating program performance to the organization; and Periodically reviewing the Ethical Sourcing program to ensure its continuing suitability, adequacy and effectiveness. What does it mean? Implementation Guidance Various methods and tools are available to help an organization achieve the financial/ economic benefits associated with implementation of the ES Standard. These methods/tools include, but are not limited to: valueadded customer focus, establishing a baseline for financial performance improvement, trend analysis, material requirement planning (MRP), advanced product quality planning (APQP), human resources succession planning, de-bottlenecking, balanced scorecard, etc. The auditor may look for evidence of: Auditing Guidance Existence of documented methods/tools utilized to achieve these objectives. A process is in place to track, record and analyze these benefits. Key performance indicators (KPIs) are used by the organization to link Ethical Sourcing performance with associated financial and economic benefits. 2. Derived benefits are communicated to appropriate internal and external stakeholders. See Appendix 1, 13.0 for specific requirements related to Business Management Principles for Senior Management. Page 71 Appendix 2 SQFI Ethical Sourcing Standard April 2017

71 Annex 1: Social Issues in Agrifood Supply (1) All businesses have a responsibility to their employees irrespective of their position along agrifood supply chains. However, some stages have particular problems to address such as seasonal and gang work in primary agriculture or the unsocial hours associated with the 24-hour operations of some retail and food service businesses. Corporate Social Issues Fisheries and Fish Farming Primary Production Stages in the Food Supply Chain Food Processing Food Manufacture Food Distribution Food Service and Retail Employment Full-time/part-time Seasonal * Legal compliance * * Subcontractors Services Projects + Gang workers * Conditions of Employment Contracts and pay Freedom of association / employment * * * * * * Time off and holidays Health and Safety General Higher risk operations * Legal compliance * * * * + Equal Opportunities Gender and age Child labor * Disability * * * * * Suppliers and Customers Terms of trading Customer health * Special interest groups * * Local community Health and safety Prosperity * * * Figure A1: Potential social issues at different stages of the food supply chain in relation to key stakeholders. Note: + = Potential minor issue and = Potential major issue. * Many organizations and special interest groups have sought to define corporate social responsibility in both general terms and in relation to specific sectors of industry. Some approaches consider whole sectors, all stakeholders linked and the communities affected by proximity to the sector. Other approaches, including the SQF Responsible Social Practice Module, focus more on individual businesses and those factors under the direct control of management. The following section details key social issues linked to the agrifood supply chains and indicate how adopting ES can help you address such issues. (1) While the primary focus of Annexes 1 and 2 is on social issues and risks within the agrifood industry, the principles discussed are more broadly applicable to multiple industries. Page 72 Appendix 2 SQFI Ethical Sourcing Standard April 2017

72 Equal Opportunities Refers to a general principle that each person should have the same opportunities for employment without discrimination on grounds of race, religion, gender or any other arbitrary division. In stating this, however, it is important to recognize the global nature of many food supply chains and the sensitivity needed to embrace trading relationships where cultural differences may impact the equality of opportunity. Adopting ES provides the framework to enable you to consider the issues raised under equal opportunities and laws linked to preventing any form of discrimination in the workplace. Employment Food and farming businesses depend on people to deliver safe quality products and services. Investing in the training and development of employees and the provision of career development opportunities are indicative of socially responsible businesses that value their staff. As a minimum, employers must ensure that employees are aware of their rights and obligations as well as those of the employer. Potential employees should be aware of their pay rate and method of payment, usual working hours and any overtime arrangements, holiday and sick leave arrangements, and should be given adequate time and access to independent advice before signing any contract of employment. The ES Standard allows you to link your employment policy and procedures to the promotion of your products and services in the marketplace Conditions of Employment It is important that food and farming businesses are aware of and comply with local laws and any industry standards or agreements. In addition, employees should not be required to deposit any identity papers or other documents of value as a condition of employment. Equally, employees should not be denied their employment rights (above) by employers treating them as subcontractors or outworkers. In addition, employees should have the right to join and be represented by lawful associations or unions and be free to terminate their employment after an agreed term of notice. Adopting ES enables you to ensure that your conditions of employment meet the requirements of local employment law and the principles of employment established by the ILO. Child Labor An important issue in agrifood supply is the use of child labor. Children can contribute significantly to family and small business incomes, but they can be exploited in terms of their conditions of employment and the detrimental impact of work on physical and emotional development as well as affecting their access to education. As a minimum, International Labour Organisation conventions on protecting child labor should be adopted to prevent child labor exploitation, unless local laws set alternative standards and rules. The ES Standard enables you to address the difficult issues of child labor (within your own business or in relation to those you trade with) according to ILO conventions and local laws. Subcontractors and Suppliers Where subcontractors, including gang work masters, are used to provide services to a food business, it is the responsibility of the food business to ensure that these subcontractors meet the same requirements as the business in relation to employment laws, employee conditions of service, and health and safety requirements. A socially-responsible business also may choose to stipulate conditions of employment, health Page 73 Appendix 2 SQFI Ethical Sourcing Standard April 2017

73 and safety on their suppliers as part of the contract to supply raw materials or finished product and in return should be prepared to provide suppliers with fair terms of trading such as clear product specifications and payment terms. By following the requirements and guidance of the ES module, the terms and conditions you develop with subcontractors will reflect the quality of management that you have set for your own business. Health and Safety Employers are obligated to provide a safe working environment for employees, contractors and visitors, as well as for the local community, and this is codified by legislation in many countries. In the absence of any legal requirements, your policies and procedures should reflect a clear awareness of obvious hazards and a general regard for the well-being of employees and other visitors to your business. At the most basic level, employees should have access to drinking water and clean toilet areas, and there should be procedures to deal with minor and serious injuries that may occur. Fundamental to your health and safety strategy, however, is the assessment of risks to people and the strategies to avoid, minimize and reduce such risks to an acceptable level. Adopting ES provides you with an opportunity to ensure that you are complying with local laws and that your occupational health and safety plan (OHSP) is implicitly linked to your food production management plan. Customers and the Local Community As a food or farming business, it is important to be aware of, and sensitive to, local community and customer (and consumer) issues. At the local community level, it is important to demonstrate how your business links with the community in relation to employment and career opportunities to how you may support local public groups or projects. At the same time, you should gauge what social and ethical issues are important to your customers and consumers in general. This may include issues of animal welfare, how food is produced or whether farmers in emerging countries are getting a fair price for their goods, or there may be a focus on resource use and environmental responsibility. If your food or farm business is able to deliver these extra attributes, then it is important to promote this to your customers. By embracing the views and opinions of customers and the local community through the adoption of the ES module, you have the opportunity to demonstrate and communicate your corporate social responsibility. Given this overview of the social issues (including health and safety) linked to agrifood supply chains and consumption, it is important to now consider the impacts of your business in these areas. Annex 2 provides you with a social risk assessment tool kit to help you decide which parts of your business may adversely or beneficially affect social topics. Page 74 Appendix 2 SQFI Ethical Sourcing Standard April 2017

74 Annex 2: Social Risk Assessment Toolkit Carrying out a social risk assessment is partly about meeting your legal obligations in relation to employment, health and safety conditions, and contractual relationships and partly about how others perceive your company or your company reputation. For example: Corporate Social Risk Corporate Reputation = Severity of Threat to Person(s) X Likelihood of Occurrence = Severity of Loss to Reputation X Likelihood of Occurrence The following risk assessment toolkit combines health and safety with corporate ethics and takes you through the key steps in determining the social impacts of your business. Step 1: Using your existing food process flow diagram, developed as part of your SQF 7 th edition system, map each stage of your food or farm process against potential social issues. (See Figure A2.1, Social Threat Identification Matrix.) The receptors listed in Figure A2.1 can be used as the basis of your social issues list. Highlight cells where there might be threats to persons or the company s reputation. This is called Threat Identification. You also should highlight any areas that link to legal compliance related to employment, health and safety, and contractual relationships. Corporate Social Issues Employment Full time/ Part time Seasonal Legal Compliance Subcontractors Services Projects Gang workers Conditions of Employment Contracts and pay Freedom of association/ employment Time off and holidays Health and Safety General Higher risk operations Legal compliance Equal Opportunities Gender and age Child labor Disability Suppliers and Customers Terms of trading Customer health Special interest groups Local Community Health and safety Prosperity Key Stages in Your Food Business e.g. Farming Step 1 Step 2 e.g. Crop Spraying T 1 * T 2 * T 3 Step 3 Step 4 e.g. Crop Harvest Figure A2.1: Social Threat Identification Matrix linking food or farming processes to social issues. T 4 T 5 Step 5 Comments on Examples T1 Are employees qualified operators for pesticide application? T2 Pesticide application can harm operators. Is protective clothing being used? T3 Pesticide drift can affect the public. Are warning signs posted, and re weather conditions being monitored? T4 If gang work is used, does gang master comply with employment legislation and conditions of employment? T5 Does your customer specify any requirements linked to gang work or the use of child labor? * Legal Compliance Now that you have identified the potential threats to the environment, you should determine the points in your process where you can control these threats (see Step 2). Page 75 Appendix 2 SQFI Ethical Sourcing Standard April 2017

75 Step 2: For each of the threats identified along your food process flow diagram, you now have to determine which threats are Critical Social Points (CSPs) and which are Social Points (SPs). These may affect the legal status or reputation of your company (or the social credentials of your product or service). In deciding whether a Social Control Point is critical or not, a decision tree can be used (Figure A2.2). Q1 Is there a significant social threat at this stage in the process? Yes No Modify step, process or product Yes Is control necessary? No Not a CSP Q2 Do preventative measures exist for the identified threat(s)? Yes No No Q4 Could injuries (or damage to company reputation) occur or increase to unacceptable levels? Yes Yes No Q3 Is the step specifically designed to eliminate or reduce (to an acceptable level) the likely occurrence of the threat? Q5 Will subsequent steps or actions eliminate or reduce threat(s) to an acceptable level? Yes No Critical Social Point (CSP) Figure A2.2: Social Control Point Decision Tree Those points in your process that are not Critical Social Points may warrant some form of monitoring or control over them. This may be because your customer has specified some additional social conditions in your supply contract (e.g., employee working and housing conditions) or because you are promoting your products or services with associated social or ethical benefits (e.g., fair trade products). These control points are Social Points (SPs) points in your process where a lack of control could compromise your business reputation or product quality attributes. At this stage, your judgments of these Social Points will be generally subjective. The next step is to verify your initial findings through a more quantitative risk assessment method, which evaluates the probability of the threat occurring and the consequences to your business see Step 3. Page 76 Appendix 2 SQFI Ethical Sourcing Standard April 2017

76 Step 3: For each CSP and SP identified, you now should assess the significance of the threats identified in terms of their impact. You can do this by using the Social Risk Criteria Assessment (Figure A2.3a) and the Social Threat Significance Matrix (Figure A2.3b). Severity of Threat to Person(s) and Company Likelihood of Occurrence 1 Death or permanent injury to person(s) A Common occurrence 2 Major but temporary injury to person(s) B Known to occur 3 Minor but temporary injury to person(s) Perceived major impact to company reputation C Could occur (published) 4 Perceived minor impact to company reputation D Not expected to occur 5 No perceived impact to company reputation E Practically impossible Figure A2.3a: Social Risk Criteria Assessment (severity and occurrence) used in the Social Threat Significance Matrix. Note 1: A major impact can be considered as an impact that results in the loss of major customer contracts or similar. Note 2: A temporary impact can be considered as one where concerns are raised by stakeholders, but where the company is able to recover to its original state within a reasonable time period. Likelihood of Occurrence Severity A B C D E What the values indicate to your business: Critical Social Point (CSP) values 1-3 indicate serious threats that should be addressed immediately; values 4-10 require that control measures be put in place Social Point (SP) values 11-25, you should decide whether control measures need to be put in place or whether any loss of control could compromise your business. Figure A2.3b: Social Threat Significance Matrix. Although this social risk assessment focuses on the potential of agrifood businesses to cause harm to the persons (from employees to customers and the local community) or the reputation of your company, you also should consider the economic benefits of additional corporate social responsibility activities. In other words, you can set the social limits of your processes to a level above legal compliance (the green zone) in the same way as you have addressed quality under the SQF system. This is particularly important if your customers are looking for ethical suppliers to help them meet their stated CSR program. This can be addressed along with legal employment, health and safety, or contractual requirements at the next stage (see Step 4). Page 77 Appendix 2 SQFI Ethical Sourcing Standard April 2017

77 Step 4: Determine and document the critical limits for the identified CSPs (and SPs) and document them. Critical limits set the boundaries for controls. In deciding on your critical limits, you also may choose to set more stringent operational limits, which will trigger actions before limits are reached and product integrity is compromised. Social Points can be divided into two groups, those linked to legal compliance and those that demonstrate positive business ethical policies. Legal Compliance Information on employment and health and safety legislation is held by various government departments and also may include guidance on meeting legal requirements. Issues linked to contractual obligations can be discussed with legal experts within trade associations or opinions sought from the legal profession. In the absence of any specific in country guidance, you should refer to the standards and guidance provided by the International Labour Organisation ( to see if the country has ratified any conventions in relation to: Freedom of association, Abolition of forced labor, Equality, and Elimination of child labor. Corporate Social Policy This is a more subjective area and will require more effort to determine your critical and operational control limits. Some governments and industrial sectors have developed guidance documents. In addition, several non-governmental organizations also have evaluated the social impacts of agrifood chains and have subsequently developed guidance. Examples of social enhancement limits include: Providing markets for small-scale suppliers or suppliers in developing countries, Donating some profits to charitable funds or projects, Supporting social and educational developments in communities, Promoting well-being and supporting health initiatives, and Linking social responsibility with environmental responsibility and enhancement. You have now completed your social risk assessment and have identified the critical and operational limits for those stages in your process that have either positive or negative impacts on your business. You should now build this into your ES system. The remaining steps you should take are as follows: Step 5: Develop and document the monitoring procedures and their frequency. You should set up a scheduled program for the measurement of your CSPs and SPs so that any loss of control can be detected. Step 6: Develop and document corrective action procedures. These procedures will inform you of what should be done if a loss of control is detected through monitoring. Step 7: Develop and document verification procedures. The development of these procedures will enable you to ensure that your entire social responsibility plan is working effectively. Step 8: Develop and document recordkeeping procedures. It is essential to maintain records to show that your social responsibility plan is working and to help you identify problem areas that need further development. Step 9: Train those employees who have operational, audit or management responsibilities at the Social Points in the procedures developed. Page 78 Appendix 2 SQFI Ethical Sourcing Standard April 2017

78 Annex 3: Environmental Issues in the Agrifood Supply (2) Some aspects of environmental responsibility are common to all businesses such as energy use and waste management, while others are more relevant to particular stages such as atmospheric emissions linked to distribution or the impacts on soil, water and biodiversity as a result of primary production (Figure A3). Stages in the Food Supply Chain Environmental Receptor Fisheries and Fish Farming Primary Production Food Processing Food Manufacture Food Distribution Food Service and Retail Earth Soils Landscape + * Water Surface Ground Seas * * * * + + Air Quality Climate + + * * * + Biodiversity Species Habitats * * Landscape Natural Built + * Local Community Health Safety Energy Use Fossil Renewable + + * * * + Waste Generated Effluent Solid Packaging Chemicals + + * * + * Figure A3: Potential impacts of different stages of the food supply chain in relation to key receptors. (2) + * Note: = Potential Minor Impacts and = Potential Major Impacts While the primary focus of Annexes 3 and 4 is on environmental issues and risks within the agrifood industry, the principles discussed are more broadly applicable to multiple industries. Page 79 Appendix 2 SQFI Ethical Sourcing Standard April 2017

79 The following further details key areas of environmental concern linked to the agrifood supply chains and indicates how the adoption of ES can help you address these concerns: Soil Damage and Land Losses Concerns over soil damage can arise under both dry and wet conditions and can result in the loss of biological or economic productivity in croplands, pastures and woodlands. The most commonly cited forms of unsustainable land use are over-cultivation and periods without crop cover, overgrazing, deforestation and poor irrigation practices. In addition to the challenges facing primary production, the increasing volume of global agricultural production and trade also has impacts on land use, including increased demand for roadways, distribution centers, port facilities and other related infrastructure. ES provides you with the framework to adopt practices that avoid or minimize soil damage and losses, especially in relation to primary production. Water Agriculture accounts for 70 percent of all water use; however, water resources are being depleted at a rapid rate, with water tables falling worldwide. Both primary food production and food processing are critically dependent upon reliable water supply and adequate water quality. Improper use of pesticides and fertilizers, poor management of animal manure, as well as inefficient practices in the food processing industry can all contribute to serious pollution of ground and surface waters. ES encourages organizations to focus on practices that minimize the use and pollution of water resources. Energy While energy input for food production is relatively low compared to other industrial sectors, substantial amounts of energy are consumed throughout food production and preparation. Also, the way food is prepared and consumed at home has significant impacts on the environment with up to 20 percent of the total energy being used in home preparation. The food sector now consumes about 10 to 15 percent of total energy in industrialized countries, though only 20 to 30 percent of this occurs on farms. In contrast, transport activities related to agrifood production have widespread and serious environmental impacts mainly due to air pollution from fossil fuels. ES encourages an assessment of energy use which can lead to greater energy efficiencies and cost savings. Climate Change Greenhouse gas emissions are generated throughout the agrifood production and consumption chain. For example, up-stream agricultural activities such as livestock production and land preparation, release greenhouse gases. Fertilizer manufacture contributes to climate change through the generation of carbon dioxide (CO2) and nitrous oxide (N2O). Energy consumed in the transport of agricultural products and food processing is another source of greenhouse gas emission. Refrigeration facilities used for food processing, storage and retail can release greenhouse gas emission if chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) contained in the equipment are not placed and disposed of responsibly. Climate change, in turn, can become a major threat to agrifood production as supply and the impact on crop yields and productivity may vary considerably. Added heat stress, shifting monsoons and drier soils may reduce yields in the tropics and subtropics, whereas longer growing seasons may boost yields in northern Canada and Europe for example. Addressing climate change is a strategic challenge to society and to the agrifood industry. The adoption of ES can help to address this challenge. Page 80 Appendix 2 SQFI Ethical Sourcing Standard April 2017

80 Use of Chemicals Many of the negative environmental effects of agrifood production are associated with chemical use, especially that of mineral fertilizers and pesticides used in agriculture. The use of mineral fertilizers, which has expanded tremendously since 1960, is one of the factors contributing to the "Green Revolution" and has vastly increased global agricultural yields. However, to be effective, fertilizers need to be applied at the right times and in the correct quantities and balances. If this is not done, some or most of the fertilizer will be wasted, and this can have an impact on the wider environment. Similarly, the introduction of synthetic pesticides (insecticides, fungicides and herbicides) has changed the concept of pest control and permitted agricultural intensification and safer storage of food along supply chains. This rapid growth in the use of pesticides in agrifood chains has, however, increased the level of risks for the users of these chemicals, the consumers of treated foodstuffs, domestic animals and the wider environment. In addition, the use of chemicals throughout the food chain in cleaning routines, food processing and packaging also has increased. Chemical use is largely inevitable in the current practice of food production and consumption. ES encourages you to focus on how to maximize the benefits of chemical use in the food chain and to minimize the associated negative environmental impacts. Biodiversity Biodiversity includes all components of biological diversity relevant to food, fisheries and agriculture. It also includes all components of biological diversity that constitute the wider environment: the variety and variability of animals, plants and micro-organisms, at the genetic, species and ecosystem levels that are necessary to sustain key functions of ecosystems. Impacts of agrifood production activities on biological diversity can be negative and irreversible; however, this trend is not inevitable. Different approaches to agrifood production are being developed to minimize negative impacts and enhance biodiversity. ES provides you with an opportunity to consider both the positive and negative impacts of your business on biodiversity. Biotechnology Modern biotechnology has great potential to contribute to human well- being (for example the development of many medicines used today). Various food crops have been genetically modified for greater productivity or nutritional value, or for resistance to pests or diseases. However, there is growing public concern about the potential risks of biotechnology to human health and the wider environment, and these potential risks may affect future developments in agrifood production. As a result, there is growing pressure for the international community to take action to create credible and effective safeguards for humans and the environment. Currently however, the marketplace largely determines the choice of adopting or not adopting biotechnology. You can integrate specific biotechnology requirements/ restrictions into ES where necessary. Waste All businesses produce waste, which has to be disposed of in a legal and safe way. From both environmental and economic perspectives, it is a challenge to minimize expensive and damaging wastes. Assessing your current business processes to look for opportunities to reduce, reuse or recycle waste can address these challenges. In agriculture, for example, the wastes from cropping can be valuable inputs for livestock or crops, and livestock wastes can improve soil fertility and reduce fertilizer purchases. All along the supply chain there are opportunities to reduce waste streams, such as reducing secondary packaging or the adoption of reusable containers for raw materials and finished product. Page 81 Appendix 2 SQFI Ethical Sourcing Standard April 2017

81 Waste may damage the environment and cost you money. ES provides the framework for you to evaluate and reduce waste streams. International Trade The trade of agrifood inputs and products plays an important role in world food supply and economic development; however, the threat of increased environmental degradation is a factor associated with trade. Trade in agrifood products creates significant transport and energy-related environmental impacts. The environmental consequences of current agrifood trade practices need to be better understood are so that productivity can continue to increase while environmental degradation is minimized. The adoption of ES provides you with an opportunity to reduce the negative impacts and enhance the positive impacts of your trading activities. Consumption What we choose to eat affects not only our health and well-being, but also the environment and natural resources. The production of different types of food requires the input of different natural resources that in turn have different environmental impacts. Consumer concerns over the environment reflect this, which is why more retailers are responding by demanding higher environmental responsibility from their suppliers. ES provides the means of demonstrating to customers and consumers your environmental integrity. Given this overview of the environmental issues linked to agrifood supply chains and consumption, it is important to now consider the impacts of your business on the environment. Annex 4 provides you with an environmental risk assessment tool kit to help you decide which parts of your business may cause environmental damage or may result in environmental improvements and benefits. Page 82 Appendix 2 SQFI Ethical Sourcing Standard April 2017

82 Annex 4: Environmental Risk Assessment Toolkit Carrying out an environmental risk assessment is very similar to the food assessments you have already carried out. For example: safety risk Food Safety Risk = Severity of Food Safety Hazard X Likelihood of Occurrence Risk to Environment = Severity of Threat to the Environment X Likelihood of Occurrence The risk assessment toolkit discussed in this section takes you through the key steps in determining the environmental impacts of your business. Step 1: Using your existing food process flow diagram developed as part of your SQF system, map each stage of your food or farm process against potential environmental receptors (Figure A4.1). The receptors listed in Figure A3 can be used as the basis of your environmental receptor list. Highlight cells where you consider there might be threats to environmental receptors or where energy use and waste generation may be significant. This is called Threat Identification (Figure A4.2). You also should highlight any areas that link to legal/ regulatory compliance. Environmental Receptors Earth Soils Landscape Water Surface Ground River Ocean Air Quality Climate Biodiversity Species Habitats Step 1 Key Stages in Your Food Process Step 2 e.g., Crop Spraying T1 * T2 * Step 3 Step 4 e.g., Road Transport T3 Comments on Examples T1 Pesticide spray could drift over water courses or drinking water supplies and affect water quality. T2 Pesticide application could harm non-target pests and indirectly harm their predators. T3 Road transport results in air pollution in the form of gases and particulate matter. Landscape Natural Man-made T4 Transport of food represents a significant consumption of fossil fuel. However, green fuels are available. * Legal Compliance Local Community Health Safety Energy Use Fossil Renewable Waste Generated Effluent Solid Packaging Chemicals T4 Now that the potential threats (impacts) to the environment have been identified, determine the points in your process where you can control these threats (impacts) see Step 2. Figure A4.1: Environmental Threat Identification Matrix linking food or farming processes to environmental receptors. Page 83 Appendix 2 SQFI Ethical Sourcing Standard April 2017

83 Step 2: For each of the environmental threats identified along your food process flow diagram, you now have to determine which of these are Significant Environmental Points (SEPs) and which are Environmental Points (EPs) that may affect the environment (or the environmental credentials of your product or service). In deciding whether an environmental control point is critical or not, it is useful to consider whether there is an environmental threat if control is lost at this particular point or whether later controls can overcome the threat. To assist in determining where the correct SEPs are, a decision tree can be used (Figure A4.2). Q1 Is there a significant environmental threat at this stage in the process? No Modify step, process or product Yes Not an SEP Yes Is control necessary? No Q2 Do preventative measures exist for the identified threat(s)? No Q4 Could environmental damage occur or increase to unacceptable levels? No Yes No Yes Yes No Q3 Is the step specifically designed to eliminate or reduce (to an acceptable level) the likely occurrence of the threat? Q5 Will subsequent steps or actions eliminate or reduce threat(s) to an acceptable level? Yes Significant Environmental Point (SEP) Figure A4.2: Critical Environmental Control Point Decision Tree Those points in your process that are not Critical Environmental Points may warrant some form of environmental monitoring or control over them. This may be because your customer has specified some environmental conditions in your supply contract (e.g., active conservation on the farm) or because you are promoting your products or services with associated environmental benefits (e.g., only using recycled packaging). These control points are Environmental Points (EPs) points in your process where a lack of control could compromise your business reputation or product quality attributes. At this stage, your judgments of these Environmental Points will be generally subjective. The next step is to verify your initial findings through a more quantitative risk assessment method that evaluates the probability of the threat occurring and the consequences to the environment and your business see Step 3. Page 84 Appendix 2 SQFI Ethical Sourcing Standard April 2017

84 Step 3: For each SEP and EP identified, you should now assess the significance of the threats identified in terms of their impacts on the environment. You can do this by using the Environmental Risk Criteria Assessment (Figure A4.3a) and the Environmental Threat Significance Matrix (Figure A4.3b). Severity of Threat to Environment Likelihood of Occurrence 1 Major and permanent impact on the environment A Common occurrence 2 Major but temporary impact on the environment B Known to occur 3 Minor but temporary impact on the environment C Could occur (published) 4 Perceived minor and temporary impact D Not expected to occur 5 No impact on the environment E Practically impossible Figure A4.3a: Environmental Risk Criteria Assessment used in the Environmental Threat Significance Matrix. Note 1: A major impact can be considered an impact that occurs beyond the physical limits of the food business. In the case of primary production, impacts within the business boundary may be included. Note 2: A temporary impact can be considered one where the environment is able to recover to its original state within a reasonable time period once the threat is removed. Likelihood of Occurrence Severity A B C D E What the values indicate to your business: Significant Environmental Point (SEP) - values 1-3: indicate serious environmental threats that warrant immediate attention. - values 4-10: require control measures to be put in place. Environmental Point (EP) - values 11-25: decide whether control measures need to be put in place or whether any loss of control could compromise your business. Figure A4.3b: Environmental Threat Significance Matrix Although environmental risk assessment focuses on the potential of agrifood businesses to cause harm to the environment, you also should consider the economic benefits of environmental enhancement. In other words, you can set the environmental limits of your processes to a level above legal compliance (green zone) in the same way as you have addressed quality under the SQF system. This is particularly important if your customers are looking for environmentally-friendly products. This can be addressed along with legal environmental requirements at the next stage see Step 4. Step 4: Determine and document the critical limits for the identified SEPs (and EPs) and document them. Critical limits set the boundaries for environmental controls. In deciding on your Page 85 Appendix 2 SQFI Ethical Sourcing Standard April 2017

85 critical limits, you also may choose to set more stringent operational limits, which will trigger actions before limits are reached and product integrity is compromised. Environmental Points can be divided into two groups, those linked to legal compliance and those that demonstrate positive business environmental improvements. Legal Compliance Information on environmental legislation is held by various government departments and also may include guidance on meeting legal requirements. The following are examples of critical environmental compliance limits: Compliance with environmental legislation (e.g. effluent discharge that may require sampling of effluent concentration and volumes); Legislation linked to the storage, use and disposal of pesticides; Fertilizer limits in environmentally sensitive water catchment areas; Waste disposal legislation/ regulations; and Legal protection of vulnerable wildlife sites or species. Environmental Enhancement This is a more subjective area and will require more effort to determine your critical and operational control limits. Some governments and industrial sectors have developed guidance documents. In addition, several environmental organizations have evaluated the environmental impacts of agrifood chains and subsequently have developed guidance. The following are examples of environmental enhancement limits. Enhancement of biodiversity on farmland (see good agricultural practice guidance); Contribution of part of product value to environmental organizations and their activities; Reduced pollution from transport (e.g., through route planning and vehicle servicing); Waste management strategies (reduce, recycle and reuse); and Energy use reduction (building design, insulation, heat recovery, etc.). You now have completed your environmental risk assessment and have identified the critical and operational limits for those stages in your process that have either positive or negative impacts on the environment. You should now build this into your SQF system in the same way you did for safety and quality by completing the remaining steps. Step 5: Develop and document the monitoring procedures and their frequencies. You should set up a scheduled program for the measurement of your SEPs and EPs so that any loss of control can be detected. Step 6: Develop and document corrective action procedures. These procedures will inform you of what should be done if a loss of control is detected through monitoring. Step 7: Develop and document verification procedures. These procedures will enable you to ensure that your entire environmental management plan is working effectively. Step 8: Develop and document recordkeeping procedures. It is essential to maintain records to show that your environmental management plan is working and to help you identify problem areas that need further development. Step 9: Train those employees who have operational, audit or management responsibilities at the Environmental Care point in the procedures developed. Page 86 Appendix 2 SQFI Ethical Sourcing Standard April 2017

86 Ethical Sourcing Standard Appendix 3: Audit Methodology April 2017 Safe Quality Food Institute 2345 Crystal Drive, Suite 800 Arlington, VA USA SQF Institute is a division of the Food Marketing Institute (FMI). Page 87 Appendix 3 SQFI Ethical Sourcing Standard April 2017

87 Page 88 Appendix 3 SQFI Ethical Sourcing Standard April 2017

88 Part A: Implementing and Maintaining the SQFI Ethical Sourcing (ES) Standard 1. Ethical Sourcing (ES) Certification Figure 1: Steps in Preparing for SQFI ES Certification 1.5 ES Implementation Training (optional) (to be developed) 1.1 Learn about the ES Standard and Appendices 1.2 Register in the SQFI ES Assessment Database 1.5 ES Implementation Training (recommended) (to be developed) 1.4 Designate an ES Management Representative 1.6 Select the Certification Level 1.3. Use of ES Consultants (optional) 1.7 Document and Implement the ES Standard and Appendices 1.8 ES Guidance Documents (recommended) 1.9 Select a Certification Body 1.10 Conduct a Pre-assessment (recommended) Page 89 Appendix 3 SQFI Ethical Sourcing Standard April 2017

89 1.1 Learn about the SQFI Ethical Sourcing (ES) Standard and Appendices Train yourself by downloading the SQFI Ethical Sourcing Standard and Appendices from the SQFI ES database free of charge, and read how to apply the requirements within your organization. Additional training options will be available at a later date. (See paragraph 1.5.) 1.2 Register in the SQFI Ethical Sourcing Assessment Database To be considered for certification, organizations are required to register in the SQFI ES assessment database. The database can be accessed from the SQFI website (sqfi.com). Registration is annual, and there is a fee per company site payable at registration and renewal. The fee scale is dependent on the size of the site as determined by gross annual sales revenue. The fee scale is available on the SQFI ES website. Organizations must register with SQFI prior to achieving ES certification and must remain registered at all times to retain their certification. If the organization fails to maintain registration, the organization s certificate will be invalid until the facility is properly registered in the assessment database. 1.3 Use of Ethical Sourcing Consultants The ES Consultant criteria will be developed at a later date. 1.4 Designate an Ethical Sourcing Management Representative Whether or not an SQF consultant is used, the SQFI ES Standard requires that every site has a suitably qualified Management Representative to validate and verify the fundamental ES requirements at Level 1, 2 or 3. The requirements for an ES Management Representative are described in of the SQFI ES Standard and in section 4.0 of Appendix 1. Some sites may choose to have more than one ES Management Representative to meet shift and operational requirements. 1.5 Ethical Sourcing Implementation Training An Implementing SQFI Ethical Sourcing Systems training course will be developed at a later date and made available through the ES training centers. 1.6 Select the Certification Level The organization must choose one of three levels of ES certification, based on the needs of their customers and the developmental stage the organization s ethical sourcing management system. The three levels of certification are: Level 1 Awareness, Compliance and Fundamental Control: Level 1 is an entry level for organizations initially developing an Ethical Sourcing management system. The focus at this level is on awareness of, and conformity with, required practices in the areas of social management, environmental management, and occupational health and safety management, including the identification of and compliance with applicable regulatory requirements. Level 2 Proactive Management and Performance Improvement: Incorporates all Level 1 system requirements and, additionally, requires that organizations have progressed to implementing a more advanced Ethical Sourcing system with demonstrable management of all significant ethical sourcing risks and achievement of performance improvement standards. Level 3 Leading Practice: Incorporates all Level 1 and Level 2 system requirements and requires: Page 90 Appendix 3 SQFI Ethical Sourcing Standard April 2017

90 leading practice ethical sourcing management and performance (beyond recognized industry/sector standards); engagement with key stakeholders through the value chain to achieve significant performance improvement; and demonstrable leadership in ethical sourcing management and achievement of stretch performance improvement targets. An organization may elect to pursue Level 1, 2 or 3 at the initial certification; however, the organization must declare the desired level to the certification body to ensure that sufficient staffing is scheduled to support auditing to that level. See Part A, 5.1, Changing the Scope or Level of Certification, for information related to moving to a higher level of certification. 1.7 Document and Implement the Ethical Sourcing Standard To achieve certification, the organization must document and implement the relevant requirements of the ES Standard, at the level selected (refer to Part A, section 1.6 above). This requires a two stage process: Document the ES System Prepare policies, procedures, work instructions and specifications that meet the relevant requirements of the ES Standard and Appendix 1. In other words, Say what you do. Implement the ES System Implement the prepared policies, procedures, work instructions and specifications, and keep records to demonstrate compliance to the relevant requirements of the ES Standard. In other words, Do what you say. 1.8 Ethical Sourcing Implementation and Auditing Guidance Document An Implementation and Auditing Guide (Appendix 2) is available from the SQFI ES website. This document is available to help the implementing organization interpret the requirements of the ES Standard and assist with documenting and implementing an ES System. The document also provides insights for implementing organizations on the types of questions that they may encounter during an Ethical Sourcing certification audit. The guidance document is available to assist organizations, but is not an auditable document. Where there is a divergence between the guidance document and the SQF Standard, the Standard and its certification assessment requirements (Appendix 1) prevail. 1.9 Select a Certification Body Certification bodies are licensed by SQFI to conduct SQF Ethical Sourcing audits and to issue the SQF certificate of registration. SQFI-licensed certification bodies are required to be accredited to the international standard ISO/IEC and be subject to annual assessments of their certification activities by SQFI-licensed accreditation bodies. The organization seeking certification is required to have an agreement with a certification body in place at all times which outlines the SQFI Ethical Sourcing audit and certification services provided. These include as a minimum: i. the scope of the audit and expected time to conduct and finalize the audit and the reporting requirements; ii. the certification body s fee structure; iii. the conditions under which the SQFI ES certificate will be issued, withdrawn or suspended; and iv. the certification body s appeals, complaints and disputes procedure. Page 91 Appendix 3 SQFI Ethical Sourcing Standard April 2017

91 A current list of licensed certification bodies is available on the SQFI ES website and includes their countries of operation. Certification bodies are also listed in the ES assessment database and organizations seeking ES certification can request a quote or select a certification body online once they have registered Conduct a Pre-assessment Audit A pre-assessment audit is not mandatory, but is recommended to provide a health check of the organization s implemented Ethical Sourcing System. A pre-assessment audit can assist in identifying gaps in the organization s ES System so that corrective action can occur before engaging the selected certification body for a full certification audit. It can be conducted using internal resources, an SQFI-certified ES auditor, or another external resource having appropriate familiarity with management systems and the specific requirements of the SQFI Ethical Sourcing Standard. Page 92 Appendix 3 SQFI Ethical Sourcing Standard April 2017

92 2. The Initial Certification Process 2.1 Selection of the SQFI-Certified Ethical Sourcing Auditor(s) ES auditors must be employed by or contracted to an SQFI-licensed certification body, and must be registered with the SQFI. The certification body selects the most appropriate qualified ES auditor to perform the certification audit. The certification body shall ensure that no ES auditor, after the initial certification audit, conducts audits of the same facility for more than one full recertification cycle. The certification body must advise the organization of the name of the ES auditor at the time that the ES audit is scheduled. 2.2 Identifying the Scope of Certification The Ethical Sourcing certification is site-specific. When activities are carried out in different premises but are overseen by the same senior, operational and technical management, and are covered by one ES System, the site can be expanded to include those premises. The scope of certification forms part of the certificate of registration. It describes the industry sector of that site. The certificate of registration outlines the location and operations of the site, along with the nature and extent of the organization s ES certification. If the organization seeking certification elects to exclude processes or other parts of a facility from the scope of certification, the rationale for exclusion must be approved by the certification body and be specified in the certification audit report. The exclusions shall not be listed on the certificate of registration, and must not be promoted as being covered by the certification. Instances where promotion of exclusions are identified and substantiated, either by regular audit or by other means, shall result in immediate withdrawal of the SQFI Ethical Sourcing certification. 2.3 The Certification Audit Certification audits are performed by a registered ES auditor/team of auditors appointed by the certification body. The initial SQFI Ethical Sourcing certification audit shall consist of two stages: 1. The Stage 1 audit is undertaken 1 to evaluate preparedness for the Stage 2 audit through: a. verification that the ES management system is appropriately documented and approved (ES Manual review); b. confirmation that an appropriately-qualified ES management representative has been identified, an ES policy has been established, and the scope of the ES system has been appropriately established; c. evaluation of the client's location and site-specific conditions; d. discussions to gauge understanding of the requirements of the standard, especially those related to key risks/impacts, key performance measurements, and compliance with applicable regulations; and e. determination of whether internal audits and management review are being planned and performed. 1 The initial review of the ES Manual and other requested documents is performed remotely. All other Stage 1 activities are performed onsite. The certification body shall notify the audited organization of needed corrections or corrective action, or any aspects of the ES System that require improvement or adjustment. The certification body will also verify that all corrections or corrective action for major and minor nonconformities have been addressed before proceeding with a Stage 2 audit. 2. The Stage 2 audit is on site at a time when the main processes of the facility are operating. The audit must encompass a review of the entire facility, including the inside Page 93 Appendix 3 SQFI Ethical Sourcing Standard April 2017

93 and outside of the buildings included in the scope of certification. The Stage 2 facility audit determines if the ES System is effectively implemented as documented. It establishes and verifies: a. conformity to all requirements of the standard and the organization s internal requirements; b. that the social, environmental, and health and safety risks are effectively identified and controlled; c. monitoring and control of processes, key risks/impacts, performance objectives and targets to promote continual improvement and compliance with applicable regulations; d. internal auditing, management review and management responsibility for the client's policies; and e. effective interaction between the elements of the standard and the role of internal audits and management review in driving management system performance improvement. Where an organization operates under seasonal conditions (a period in which the major activity is conducted over five (5) consecutive months or less) the certification audit shall be completed within thirty (30) days from the start of such seasonal conditions. The criteria for determining audit resources are provided in Part A, section 2.9, Audit Duration Guide. 2.4 ES System Elements All applicable requirements of the Ethical Sourcing Standard and Appendix 1 shall be checked as part of the certification audit. Where an element is not applicable and appropriately justified, it shall be stated so by the auditor in the audit report. 2.5 Identifying the Scope of the Audit The organization seeking certification and the certification body shall agree on the audit scope before the Stage 1 audit begins. The scope of the audit shall cover the required level of certification and the operations listed under the scope of certification for a site. The audit scope shall cover all processes under the control of the organization seeking certification, including from raw material receipt to shipment of finished product. The proposed audit scope shall be confirmed during the Stage 1 audit. Once the audit scope is agreed between the organization and the certification body, it cannot be changed after the Stage 2 audit has commenced. 2.6 Nonconformities Where the Ethical Sourcing auditor finds deviation(s) from the requirements of relevant requirements of the ES Standard and Appendix 1, the auditor shall advise the audited organization of the number, description and extent of the nonconformity(ies). (Nonconformities may also be referred to as non-conformances.) Nonconformity against the SQFI ES Standard requirements or the organization s own requirements shall be graded as follows: A minor nonconformity is an omission or deficiency in the ES System that produces unsatisfactory conditions that, if not addressed, may lead to a risk to an environmental, health and safety or social program risk but is not likely to cause an ES System element breakdown. Page 94 Appendix 3 SQFI Ethical Sourcing Standard April 2017

94 A major nonconformity is an omission or deficiency in the ES System producing unsatisfactory conditions that carry an environmental, health and safety or social program risk and is likely to result in an ES System element breakdown. A critical nonconformity is the absence or breakdown of a requirement or control that is judged likely to cause a significant risk to employees or the environment. A critical nonconformity is also raised if the audited organization fails to take effective corrective action within the timeframe agreed with the certification body, or if the certification body deems that there is systemic falsification of records relating to elements of the ES System (e.g., regulatory compliance, supplier management, etc.). Timelines for the resolution of corrective actions are discussed in Part A, section 3.2, Audit Corrective Actions. 2.7 Opportunities for Improvement Opportunities for improvement are observations made by the auditor during a facility audit that identify issues that are not nonconformities but recognize that the practices conducted by the organization are not industry best practice. They do not require a corrective action response by the organization, but provide the organization with an opportunity to improve their Ethical Sourcing System. 2.8 The Audit Report The SQFI provides the certification body with the electronic audit checklist to be used by ES auditors when conducting Ethical Sourcing audits. The audit checklist is available from the ES assessment database. The checklist is designed to ensure the uniform application of ES audit requirements. It is used by ES auditors to record their findings and determine the extent to which the organization s operations comply with stated requirements. All required elements must be reported or noted as not applicable for the audit report to be submitted. Nonconformities identified during the ES audit shall be accurately described in the audit report and shall fully describe the requirement of the ES Standard/Appendix 1 and the reason for the nonconformity. The electronic audit report must be completed by the ES auditor and uploaded to the certification body for technical review. The certification body shall make the audit report available to the audited organization within ten (10) calendar days from the last day of the audit. The certification body shall retain a copy of the audit report and shall provide a copy of the report to SQFI. The audit report shall not be distributed to other parties without the permission of the client. 2.9 Audit Duration Guide Once the certification body and organization have agreed on the scope of certification, and the number of different processes/operations on the site, the certification body shall provide the organization with an estimate of the time it will take to complete the certification audit. The audit times will vary according to the size and complexity of the site operations. Factors that can impact on the audit duration include: a. scope of the audit; b. size of the site and the design of product and people flows; Page 95 Appendix 3 SQFI Ethical Sourcing Standard April 2017

95 c. number and complexity of product lines and the overall process; d. whether the processes/operations are high or low risk; e. complexity of the ES System design and documentation; f. level of mechanization and labor intensiveness; g. ease of communication with company personnel (consider different languages spoken); and h. cooperation of the organization s personnel. Tables 1 and 2 provide a guide to the duration of an SQF Ethical Sourcing certification audit. Justification is required if the certification body deviates from this guide by greater than thirty (30) percent. Table 1: Stage 1 and Surveillance Audit Duration Table Certification Level Stage 1 Audit Duration (days) Surveillance Audit Duration (days) SQFI ES Level SQFI ES Level SQFI ES Level Table 2: Stage 2 Audit Duration Table Step 1 Step 2 Step 3 Step 4 Certification Level Basic duration (days) Additional days based on number of employees Additional days based on size of facility SQFI ES Level 1 SQFI ES Level 2 SQFI ES Level to 200 = to 400 = to 600 = to 1000 = to 2500 = to 4000= > 4,000 = ,000 ft2 = 0 (0 19,000 m2 = 0) 200, ,000 ft2 = 0.50 (19,000 27,000 m2 = 0.50) 300, ,000 ft2 = 1.00 (27,000 46,000 m2 = 1.00) (> 500,000 ft2 - > 46,000 m2 = 2.00) In addition to audit time, the certification body shall provide the organization pursuing certification with the time and expected costs, if applicable, for planning, travel, report writing and close out of nonconformities. 3. The Initial Certification Decision 3.1 Responsibility for the Certification Decision It is the responsibility of the certification body to ensure that audits undertaken by their ES auditors are thorough, that all requirements are fulfilled, and that the audit report is complete. The certification decision shall be taken by the certification body based on the evidence of Page 96 Appendix 3 SQFI Ethical Sourcing Standard April 2017

96 conformity or nonconformity collected by the ES auditor during the ES audit. Although SQFI provides guidance on certification, the certification body is responsible for deciding whether or not certification is justified and granted. Any certification decisions that are made outside of the scope of this Section 3: The Initial Certification Decision, require the certification body to provide written justification to SQFI. 3.2 Audit Corrective Actions All nonconformities and their resolution shall be documented by the ES auditor. Nonconformities shall be corrected, verified and closed out 1 according to the following schedule: Major nonconformities within twenty (20) calendar days of completion of the certification audit; and Minor nonconformities within forty (40) calendar days of completion of the certification audit. Complete closure of the audit must occur within sixty (60) calendar of completion of the certification audit. In circumstances where corrective action involves structural change or cannot be corrected due to seasonal conditions or installation lead times, this period can be extended provided that temporary action is taken by the audited organization to mitigate the risk to employees and/or the environment and the temporary action and corrective action timeframe are approved by the certification body. The audited organization shall be advised of the extended timeframe. Under these circumstances extended timeframes for close out of minor nonconformities shall not impede and delay certificate issuance. In such cases, the nonconformity shall be closed out on the ES database and the auditor shall document all details of justification of the extension, how the risk is being controlled, and the agreed completion date. If the ES auditor considers that a critical nonconformity exists during an audit, the auditor shall immediately advise the audited organization and notify the certification body. A critical nonconformity that is raised at a Stage 2 audit results in an automatic failure of the audit and the organization must re-apply for certification. (Refer to Part A, section 3.5, Failure to Achieve Certification.) 1 Closed Out. The following actions must be completed and approved by the ES auditor in order for nonconformities to be considered as closed out. A Root Cause Analysis is performed that identifies the root cause(s) of the nonconformity. Containment Action is taken to address the identified nonconformity(ies). A Corrective Action Plan is developed to eliminate the cause(s) of the identified nonconformity(ies). Objective Evidence is provided to indicate that the approved Corrective Action Plan has been implemented. 3.3 Audit Score and Rating Based on the evidence collected by the ES auditor, each applicable aspect of the ES Stage 2 audit is automatically scored when the audit report is uploaded to the ES assessment database. Stage 1 audits are not scored. Page 97 Appendix 3 SQFI Ethical Sourcing Standard April 2017

97 The calculation uses the following factors based on the definitions noted in paragraph 2.9: 0 element meets the criteria 1 element does not meet the criteria due to minor variations (minor nonconformity) 10 element does not meet the criteria (major nonconformity) 50 element does not meet the criteria (critical nonconformity) A single rating is calculated for the facility audit as (100 N), where N is the sum of the individual rating criteria allocated. The rating provides an indication of the overall condition of the audited site against the SQFI ES Standard and provides the basis for a certification decision as follows: Score Rating Certification 2 > 70 Pass Certificate issued < 70 Fails to comply No certificate issued 2 Certification also requires that all major nonconformities are closed out within twenty (20) calendar days and minor nonconformities within forty (40) calendar days, or an agreed extended timeline (refer to 3.2 above). 3.4 Granting Certification Certification of the SQFI ES System shall be awarded to organizations that achieve a Stage 2 audit rating of seventy or greater (>70) with no outstanding nonconformities. The certification decision shall be made within sixty (60) calendar days of the last day of the Stage 2 audit. Once SQFI ES certification is granted, the SQFI issues a unique certification number which is specific to that organization s site. Within ten (10) calendar days of granting certification, the certification body shall provide an electronic and/or hard copy of the organization s certificate of registration to the organization. The certificate of registration is valid for three (3) years from the date the certification decision was taken, pending successful completion of surveillance audits as discussed in paragraphs , and shall be in a form approved by the SQFI. The certificate of registration shall include: i. The name, address and logo of the certification body; ii. The logo of the accreditation body and the certification body s accreditation number; iii. The heading Certificate of Registration; iv. The phrase (Organization name) is registered as meeting the requirements of the SQFI Ethical Sourcing Standard, (revision number); v. The level of certification and the description; vi. The scope of registration (facility/operations); vii. Dates of audit (last day), date of next recertification audit, date of certificate issue, and date of certificate expiry; and viii. Signatures of the authorized officer and issuing officer; 3.5 Failure to Achieve Certification Where an organization achieves a rating of less than seventy (<70) at a certification audit, the organization is considered to have failed the SQFI ES audit. If this occurs, the organization must re-apply for another certification audit. Page 98 Appendix 3 SQFI Ethical Sourcing Standard April 2017

98 When the organization s re-application occurs within six (6) months of the last audit date, and with the same certification body and ES auditor, a Stage 2 audit shall be scheduled but a Stage 1 audit is not required. If the re-application occurs after six (6) months from the last audit date, or with a new certification body or ES auditor, then both a Stage 1 and Stage 2 audit are required. If the organization has previously attained certification at a given level and is pursuing certification to a higher level, a rating of seventy or higher (>70) must be attained for certification to be conferred at the higher level. If the required rating for the higher level is not attained, the organization may continue to be certified at a lower level only if they continue to achieve the minimum required rating for that level and all nonconformities have been closed out. Example: An organization that is certified to Level 1 has requested an audit for certification to Level 2. During the audit, the organization fails to achieve a minimum rating of >70 for Level 2. The organization may continue to be certified to Level 1 only if they achieve a minimum rating of >70 against the Level 1 requirements during the audit. 4. Surveillance and Recertification Suspension and Withdrawal of Certification 4.1 Maintaining SQFI Ethical Sourcing (ES) Certification To maintain SQFI ES certification at a given level, an organization is required to attain an audit rating of seventy or greater (>70) for that level at triennial recertification audits and intervening surveillance audits. Organizations must further ensure that recertification and surveillance audits occur within the required time frames, that no critical nonconformities are raised at recertification or surveillance audits, and that all major and minor nonconformities are corrected within the time frame specified. 4.2 Surveillance Audits Two (2) surveillance audits are conducted in the intervening years between the initial certification audit and the first recertification audit and, thereafter, between recertification audits. The surveillance audits shall be conducted within thirty (30) calendar days either side of the annual anniversary of the last day of the previous audit (initial certification, surveillance or recertification). The purpose of the surveillance audit is to: a. Verify the continued efficacy of corrections and corrective actions closed out at previous audits; b. Verify that the SQFI ES System continues to be implemented as documented; c. Consider and take appropriate action where changes to the organization s operations are made and the impact of those changes on the organization s SQFI ES System; d. Confirm continued compliance with the requirements of the SQFI ES Standard; and e. Contribute to continued improvement of the organization s SQFI ES System and business operation. Major or minor nonconformities raised at the surveillance audit shall be closed out as indicated in Part A, 3.2, Audit Corrective Actions. The organization s certificate of registration shall be suspended by the certification body if: Page 99 Appendix 3 SQFI Ethical Sourcing Standard April 2017

99 a. The organization fails to permit the surveillance audit within the required timeframe. b. A critical nonconformity is raised at the surveillance audit. or c. The organization fails to close out major or minor nonconformities within the agreed timeframe. A surveillance audit is also conducted when an organization s certificate is suspended for reasons outlined in section 4.5. In this case, the surveillance audit shall be conducted within thirty (30) calendar days either side of the six (6) month anniversary of the last day of the previous certification or recertification audit. 4.3 Recertification Audit The recertification audit of the ES System is undertaken every three years to verify the continued effectiveness of the organization s SQFI ES System in its entirety. The recertification audit shall be conducted within thirty (30) calendar days either side of the 3- year anniversary of the last day of the initial certification audit. The recertification audit score is calculated in the same way as the initial certification audit, and the same rating applied (refer to 3.3 above). In exceptional circumstances, such as operational or seasonal requirements, the recertification date may be moved earlier than the 3-year anniversary by mutual agreement between the certified organization and the certification body, and the new recertification date fixed as the new initial certification audit date. The purpose of the recertification audit is to: a. Verify the continued efficacy of corrections and corrective actions closed out at previous audits; b. Verify that the ES System continues to be implemented as documented; c. Verify that the organization continues to demonstrate a commitment to maintaining the effectiveness of the ES System and to meeting regulatory and customer requirements; d. Verify that the impact of changes to the organization s operations have been considered and appropriate action has been taken regarding these changes; and e. Contribute to continued improvement of the organization s ES System and business operation. 4.4 Variations to the Recertification Process The requirements for the recertification audit are the same as those described in sections for the certification audit, with the following exceptions: a. A Stage 1 audit is not required as part of a recertification audit, except as specified in 3.5. However, the organization s documentation shall be reviewed as necessary as part of the recertification audit. b. If a certified organization fails to permit the recertification audit within the agreed timeframe, the certification body shall immediately suspend the certificate of registration. Page 100 Appendix 3 SQFI Ethical Sourcing Standard April 2017

100 c. If the certified organization receives less than a seventy (<70) rating for Level 1 requirements at the recertification audit, the certification body shall immediately suspend the certificate of registration. If the certified organization fails to close out nonconformities within the agreed timeframe, the certification body shall immediately suspend the certificate of registration. 4.5 Suspension of Certification The certification body shall suspend the ES certificate of registration where the certified organization receives a fails to comply rating, or where the organization fails to take corrective action within the timeframe specified. Where an organization s certificate of registration is suspended, the certification body shall immediately amend the organization s details on the SQFI ES database to a suspended status indicating the reason for the suspension and the date of effect; and in writing: a. inform the organization of the reasons for the action taken and the date of effect; b. copy the Senior Technical Director of SQFI on the notice of suspension sent to the organization; and c. request that the suspended organization provides to the certification body, within forty-eight (48) hours of receiving notice of the suspension, a detailed corrective action plan outlining the corrective action to be taken. When an organization s certificate of registration is suspended, the certification body shall, upon receipt of the detailed corrective action plan: a. Verify that immediate correction has been taken by means of an on-site audit within thirty (30) calendar days of receiving the corrective action plan. b. When corrective action has been successfully implemented, re-instate the organization s status on the SQFI database and give written notice to the organization that their certificate of registration is no longer suspended. c. Not more than six (6) months after suspension, the certification body shall conduct a surveillance audit to verify the effective implementation of the corrective action plan and that the organization s ES System is achieving stated objectives. (Seasonal clients may delay their surveillance audit until the commencement of the new season.) and d. Copy SQFI on the notice indicating lifting of the suspension sent to the organization. When a certification body has suspended an organization s ES certificate of registration, the suspended organization shall not represent itself as holding an ES certificate of registration for the duration of the suspension. 4.6 Withdrawal of Certification The certification body shall withdraw the certificate of registration when a certified organization: a. has been placed under suspension and fails to submit approved corrective action plans as defined by the certification body, or take approved corrective action as determined by the certification body within the time frames specified; b. has falsified its records; Page 101 Appendix 3 SQFI Ethical Sourcing Standard April 2017

101 c. fails to comply with the certificate of registration; or d. has an administrator, receiver, receiver and manager, official manager or provisional liquidator appointed over its assets or where an order is made or a resolution passed for the closure of the certified organization (except for the purposes of amalgamation or reconstruction) or the certified organization ceases to carry on business or becomes bankrupt, applies to take the benefit of any law for the relief of bankrupt or insolvent debtors or makes any arrangement or composition with its creditors. When an organization s certificate of registration is withdrawn, the certification body shall immediately amend the organization s details on the SQFI ES assessment database to a withdrawn status indicating the reason for the withdrawal and the date of effect; and in writing: a. inform the organization that the ES certificate of registration has been withdrawn, the reason for such action and the date of effect; b. copy SQFI on the notice of withdrawal sent to the organization; and c. instruct the organization to return the certificate of registration. An organization that has their certificate of registration withdrawn must re-apply for certification. 5. Obligations of Organizations Seeking Certification and Certification Bodies 5.1 Changing the Scope or Level of Certification The scope of certification forms part of the certificate of registration. If the certified organization wishes to modify, terminate or change the scope of its registration or ethical sourcing quality system, it must notify their certification body (CB). The CB will make the appropriate decision as to the actions to take based on the nature and extent of the requested change to the scope of certification. Certified organizations who desire to move to a higher level of certification do not have to wait until their next recertification or surveillance audit date; however, the following rules are applicable: Corrective actions related to nonconformities from the most recent certification surveillance or recertification audit must have been closed out. The certified organization must contact their CB to coordinate a new certification audit schedule. If successful in attaining certification to the higher level, the certified organization must update their company profile in the SQFI ethical sourcing database and inform their SQFI contact of the change in certification level. If not successful in attaining certification to the higher level, the organization must achieve the required audit results: - to maintain Level 2 if attempting to move from Level 2 to Level 3, or - to maintain Level 1 if attempting to move from Level 1 to a higher level, and - close out any applicable nonconformities as described in Part A, 3.2, Audit Corrective Actions. 5.2 Changing the Certification Body A certified organization may change its certification body at any time as long as the following conditions have been satisfied: Page 102 Appendix 3 SQFI Ethical Sourcing Standard April 2017

102 Corrective actions related to nonconformities from the most recent certification surveillance or recertification audit must have been closed out. The organization s certification is not suspended or under threat of suspension or withdrawal. Organizations that require a suspension surveillance audit may change certification bodies only after the surveillance audit is conducted or through written approval by the SQFI Senior Technical Director. When a certified organization that meets the criteria noted above changes certification bodies, the certificate of registration issued by the old certification body remains valid until the expected expiration date. The certification number and recertification date are transferred with the certified organization to the new certification body. The new certification body shall undertake a pre-transfer review of the organization s certification to: a. confirm the certificate of registration is current, valid and relates to the SQFI ES System so certified; b. confirm that actions are taken on any complaints received; c. review the certified organization s audit history (where the organization can demonstrate such history to the satisfaction of the new certification body by way of copies of audit reports completed by any former certifier) and the impact of any outstanding nonconformities; and d. confirm the stage of the current certification cycle. Following a change of certification body, the responsibility for updating the company s profile in the SQFI database lies with the company, not with the former certification body or the new certification body. 5.3 Change of Ownership When a certified organization s business has been sold and the business name is retained, the new owner shall, within thirty (30) calendar days of the change of ownership, notify the certification body and apply to retain the ES certification and the existing certification number. In cases where the ownership of a certified organization changes but the staff with major responsibility for the management and oversight of the ES System has been retained, the certification body may retain the existing audit frequency status. In making this application, the certification body shall determine that staff with major responsibility for the management and oversight of the ES System has been retained. It is the responsibility of the certified organization to make any required changes to the company profile in the SQFI database. If there are significant changes in site management and personnel, the certification body shall complete a certification audit and issue a new certificate of registration and a new certification number. The audit frequency applicable to a new certification shall apply. 5.4 Relocation of Premises When a certified organization relocates the business premises, the organization s certificate of registration is no longer valid until a successful recertification of the new premises is conducted. Page 103 Appendix 3 SQFI Ethical Sourcing Standard April 2017

103 5.5 Language The certification body shall ensure that the auditor conducting the audit can competently communicate in the oral and written language of the organization being audited. In circumstances where a translator is required, the translator shall be provided by the certification body and shall have knowledge of the technical terms used during the audit, be independent of the organization being audited and have no conflict of interest. The organization shall be notified of any increase in audit duration and cost associated with the use of a translator. For the purpose of resolving a conflict, the English version of the SQFI ES Standard shall be the deciding reference. 5.6 Conflict of Interest The certification body shall ensure that all certification activities are separately controlled and managed (including the development of policy and practices) from any consulting activity. It shall preclude any prospective ES auditor from undertaking any audit in relation to the certification of an SQFI ES System that constitute a conflict of interest as outlined below or any other condition that could lead to a conflict of interest. ES auditors shall not audit any organization where they have participated in a consulting role involving the organization in question, or anybody related to that organization, within the last two (2) years (considered to be participating in an active and creative manner in the development of the SQFI ES System to be audited). Consulting includes, but is not limited to, activities such as: a. producing or preparing environmental or social plans, manuals, handbooks or procedures; b. participating in the decision-making process regarding the ES System; c. giving advice as a consultant or otherwise toward the design, documentation, development, validation, verification, implementation or maintenance of the ES System; and d. delivering or participating in the delivery of an in-house training service at which advice and instruction on the development and implementation of environmental or social plans and an ES System for eventual certification is provided. The certification body shall ensure that an ES auditor discloses any existing, former or proposed link between themselves or their organization and the organization pursuing ES certification. The certification body shall ensure through organizational structure that no potential conflict of interest, consulting, or training occurs from auditors contracted or employed by the certification body to an existing or potential organization within the ES program. An organization that is pursuing certification can refuse the service of an ES auditor when they consider the auditor has a conflict of interest, or for other reasons. In such circumstances, the organization pursuing certification shall outline the reasons in writing to the certification body. 5.7 Complaints, Appeals and Disputes The certification body shall document its procedure for handling and resolving appeals, complaints and disputes made by an organization, or made by another party about an organization. Page 104 Appendix 3 SQFI Ethical Sourcing Standard April 2017

104 When an organization has cause to register a complaint about a certification body s activities, or appeals or disputes a decision made by a certification body, including the activities and decisions of its auditors, the certification body shall investigate and resolve these matters without delay and keep a record of all complaints, appeals and disputes and their resolution. When a certification body receives a complaint about an organization from other parties, the certification body is required to investigate and resolve the matter without delay and keep a record of all complaints, appeals and disputes and their resolution. Appeals regarding decisions on the suspension and/or withdrawal of the certification by a certification body shall not delay the decision to suspend or withdraw the certification. When upon investigation of a complaint it is determined that there has been a substantiated breakdown of an organization s SQF ES System or any other condition not in accordance with the ES Standard and/or other supporting documents, the certification body shall suspend certification as outlined in section 4.4 above. Where a complaint is registered about the conduct or behavior of an auditor or certification body personnel, the certification body shall investigate and resolve the complaint without delay and keep a record of all complaints and their resolution. Records of complaints and investigations shall be available to the SQFI upon request. Where a complaint, appeal or dispute cannot be satisfactorily resolved between the organization and the certification body, the matter shall be referred to the SQFI complaints and appeals procedure. Page 105 Appendix 3 SQFI Ethical Sourcing Standard April 2017

105 Part B: SQFI Ethical Sourcing (ES) Logo - Use and Reproduction Requirements 1. Introduction 1.1 The SQFI Ethical Sourcing (ES) logo is owned by the Safe Quality Food Institute (SQFI). 1.2 Organizations at all levels of certification will have the right to use the SQFI ES logo upon and for the duration of certification. There will be no fee payable by certified organizations for the right to use the SQFI ES logo, other than fees payable to obtain and maintain certification. 1.3 Certified organizations obtain no property in the SQFI ES logo. 1.4 Certified organizations may only use the SQFI ES logo in accordance with these rules of use, which are designed to protect the integrity and enhance the value of the SQFI ES logo. 1.5 SQFI delegates any or all of its functions described herein to a licensed Certification Body (CB). 1.6 These rules of use regulate the use of the SQFI ES logo by certified organizations only. These rules of use do not regulate the use of the SQFI ES logo by SQFI, CBs or other entities licensed by SQFI to use them, unless otherwise provided for in this or another instrument. 2. Conditions for Use 2.1 A certified organization shall, for the duration of its certification, prove to the satisfaction of SQFI and the CB that its ethical sourcing system satisfies the requirements set forth in the current edition of the SQFI Ethical Sourcing Standard and appendices, at level 1, 2 or 3; and 2.2 A certified organization must only use the SQFI ES logo in accordance with its certificate of registration and these rules of use. 3. Reproduction 3.1 If a certified organization wishes to reproduce the SQFI ES logo, it must do so strictly in accordance with the requirements and specifications set out in clauses 7-9 below. 4. Obligations of an ES Certified Organization 4.1 A certified organization must: a) comply fully with these rules of use; b) direct any queries regarding their intended use of the SQFI ES logo to the certifying CB who issued the certificate of registration; c) discontinue any use of the SQFI ES logo to which SQFI or the certifying CB reasonably objects; Page 106 Appendix 3 SQFI Ethical Sourcing Standard April 2017

106 d) operate entirely within the scope of its certificate of registration, including the certification schedule. (Subsidiary companies and site addresses not included on the certificate of registration are not certified to use the SQFI ES logo.); e) give SQFI, a CB and/or their agents access to examine publicity material and all other such items bearing or indicating the SQFI ES logo for the purpose of confirming compliance with these rules of use and the certificate of registration; and f) pay any fees set by SQFI within the specified time period. 5. Grounds for Suspending or Ceasing Use of the ES Logo 5.1 The permission for a certified organization to use the SQFI ES logo will be suspended if the organization s certification is suspended. In this event, all efforts must be made by the organization to suspend the use of the logo in their operations, marketing, etc. 5.2 If an organization s ES certification is withdrawn, relinquished or not renewed, the organization will immediately cease the use of the SQFI ES logo. 5.3 Conditions for suspending or ceasing a certified organization s permission to use the SQFI ES logo, to be notified by the certifying CB, include (but are not necessarily limited to): 6. Disclaimer a) suspending - if a certified organization breaches or fails to comply with these rules of use; b) suspending - if a certified organization fails to use the SQFI ES logo in accordance with its certificate of registration, including the certification schedule; c) ceasing - if a certified organization uses the SQFI ES logo in a way that, in the opinion of SQFI or the CB, is detrimental to the SQFI ES logo or the SQFI ES program as a whole, is misleading to the public or otherwise contrary to law; or d) ceasing - if a certified organization has an administrator, receiver, receiver and manager, official manager or provisional liquidator appointed over its assets or where an order is made or resolution passed for the winding up of the certified organization (except for purposes of amalgamation or reconstruction) or the certified organization ceases to carry on business or becomes bankrupt, applies to take the benefit of any law for the relief of bankrupt or insolvent debtors, or makes any arrangement or composition with its creditors 6.1 SQFI may, from time to time, alter these rules of use or make new rules but no such alteration or new rule shall affect the use of the SQFI ES logo by a certified organization until six (6) months have expired from the date the alteration or new rules of use are first published by SQFI on its website (sqfi.com) unless specified by SQFI. 7. Logo Reproduction Requirements Organizations who achieve and maintain level 1, 2 or 3 certification are granted permission by their certifying CB to use the SQFI ES logo, subject to the rules of use and the conditions set out in Part B and hereunder per level 1, 2 or level 3 certified site. Page 107 Appendix 3 SQFI Ethical Sourcing Standard April 2017

107 Electronic SQFI ES logo files are to be obtained from the certifying CB. Color Format Full Color Reproduction of the SQF logo is to be clear, precise and of the highest standard. The following guidelines govern full color reproduction: PMS 3005C CMYK: C=100, M=34, Y=0, K=2 Single Color Reproduction: black and white. For Use On brochures, flyers, advertisements, press releases, company website internal documents and training materials brochures, flyers, advertisements, press releases, company website internal documents and training materials 8. Logo Dimensions To ensure readability, do not reproduce the SQF logo smaller than indicated below. Larger variation to these dimensions is permitted provided that any such variation is proportional to the dimensions given below. 8 MM 18 MM 9. Special Cases Where it is demonstrated that alternative reproduction of the SQFI ES logo enhances the status of the logo and/or of SQFI, the alternative is permitted provided it is approved by the certifying CB prior to use by the certified organization. All requests must be provided in writing per certified site to both the CB and SQFI. Page 108 Appendix 3 SQFI Ethical Sourcing Standard April 2017