AUDITING FOR THE CERTIFICATION OF SUSTAINABILITY OF BIOFUELS AND BIOLIQUIDS, FOOD AND FEED, TECHNICAL/CHEMICAL AND BIOENERGY APPLICATIONS

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1 Page 1 of 28 CONTENTS 1. SCOPE/OBJECTIVE FIELD OF APPLICATION DEFINITIONS AND/OR ABBREVIATIONS REFERENCES AUDIT ACTIVITIES DESCRIPTION TABLE A. CERTIFICATION PROCESS TABLE B. SURVEILLANCE (OR UNANNOUNCED OR EXTRA) AUDIT PROCESS TABLE C. RECERTIFICATION AUDIT PROCESS TABLE D EXTENSION AUDIT PROCESS DATA TO BE INSERTED IN ASCESI UPLOADING DOCUMENTATION IN ASCESI ANNEX GROUP CERTIFICATION SAMPLING CLASSIFICATION OF FINDINGS AND TIMES FOR RESOLUTION SNC: FORMULATION OF SCOPE... 28

2 Page 2 of SCOPE/OBJECTIVE This instruction describes for biofuel and bioliquid sustainability systems: activities necessary to enable the audit team to carry out the audits - including audit planning and drawing up the audit reports - and to manage communications with the personnel who perform audit programming activities. 2. FIELD OF APPLICATION This instruction applies to all the auditors, including non-exclusive personnel, involved in verification activities aimed at certification, and related maintenance, of biofuel and bioliquid sustainability systems, working in head office and in the operational network (OPN), in Italy and abroad on behalf of Rina Services SpA. This instruction is also considered applicable to personnel involved in verification activities aimed at the certification of food products and animal feed, as well as for technical/chemical applications (for example, bioplastics) and applications in the bioenergy sector (for example, solid biomass). The reference schemes for the certification of biofuel and bioliquid sustainability systems are: NATIONAL SCHEME DM 23/01/2012 (in the following SNC) National Certification System of the sustainability of biofuels and bioliquids, defined by Italian decree dated 23 January 2012 Sistema nazionale di certificazione per biocarburanti e bioliquidi, issued by the Ministry of the Environment and for Protection of the Land, in conjunction with the Ministry for Economic Development and the Ministry for Agricultural, Food and Forestry Policies; VOLUNTARY SCHEME: ISCC EU (in the following ISCC EU) "International Sustainability & Carbon Certification", managed by ISCC System GmbH. VOLUNTARI SCHEME: 2BSvs Biomass Biofuels Sustainability (in the following 2BSvs) Managed by 2BS Consortium, the scheme has been designed to cover all the requirements of the Directive 2009/28/EC and related EC Communication. The reference scheme for the certification of food products and animal feed, as well as for technical/chemical applications and applications in the bioenergy sector is:

3 Page 3 of 28 VOLUNTARY SCHEME: ISCC PLUS (in the following ISCC Plus) "International Sustainability & Carbon Certification", managed by ISCC System GmbH. 3. DEFINITIONS AND/OR ABBREVIATIONS AD: Chief Executive Officer of RINA Services S.p.A. ANACLI: Software used to codify clients AR (Application Reviewer): Person responsible for application review (personnel who have the competency requirements established in instruction IS-QPT-BIOC-01) ASCESI: Software used for the technical management of certification activities related to management systems/products and biofuel and bioliquid sustainability AUD: Auditor (personnel who have the competency requirements established in instruction IS-QPT-BIOC-01) person who, on the basis of his/her competency and knowledge, is able to collaborate in performing audits on biofuel and bioliquid sustainability systems, operating autonomously under the guidance of a Lead Auditor) AUDIT (assessment): systematic, independent and documented process to obtain evidence of the audit and objectively evaluate, in order to establish to what extent the audit criteria (set of policies, procedures or requirements) have been met BATCH: quantity of product with homogeneous chemical-physical properties CA: Corrective action CAI-C: Software used for the economic management of certification activities of management systems/products and of biofuel and bioliquid sustainability CERTIFICATE OF CONFORMITY: document which states that biofuel and bioliquid sustainability system implemented by an economic operator complies with the reference scheme CERTIFICATE OF SUSTAINABILITY (SNC): written statement, with the value of self-certification pursuant to the decree of the President of the Republic of 28 December 2000, n o 445, as amended, issued by last economic operator of chain of custody, including information to prove sustainability of batch of biofuel, bioliquid. CHAIN OF DELIVERY (CHAIN OF CUSTODY): methodology which makes it possible to create a link between the information or assertions related to the raw materials or intermediate products and the assertions relevant to the final products. This methodology includes all the phases from raw material production to supply of biofuel or bioliquid intended for consumption COMPETENT NATIONAL AUTHORITIES: Ministry of the Environment and for Protection of the Land and Sea, Ministry for Economic Development and the Ministry for Agricultural, Food and Forestry Policies CM: Certification Manager (in charge of the operational office) CO (CERTIFICATION OFFICES): RINA offices responsible for managing certification files COLLECTING POINT: first economic operator to receive waste or residues for the production of biofuel and bioliquid from companies which grow and produce waste or residues CA: Corrective Action

4 Page 4 of 28 CONVERSION UNIT: economic operator which process biomass (i.e. mills, refineries, ethanol and biodiesel plants, processing plants of bioliquids and biofuels) DECLARATION OF CONFORMITY: (for SNC): written statement, with the value of self-certification pursuant to the decree of the President of the Republic of 28 December 2000, n o 445, as amended, by any trader transferring the biofuel and bioliquid product, including transportation, which is issued as accompaniment to the batch, to the following economic operator DELIVERY NOTE (ISCC): documentation issued by every certified economic operator of the delivery chain as evidence of the sustainability and traceability characteristics attributed to the sustainable product DM (Decision Maker): responsible for the certification decision (person or group of people who has/have the competency requirements established in instruction IS-QPT-BIOC-01, and who is/are independent of the audit team) EXP: technical or legal expert: person who has specific technical know-how or skills relevant to the processes, products, services (and related laws, if necessary) provided in connection with management systems and who may be used in order to complement the technical competency of the audit team. This person may be enabled in relation to the technical area and/or geographic area (local laws, cultural or linguistic/dialectal knowledge, etc., ), to particular methodologies used in some organisations or to specific requirements of the reference standard FIRST GATHERING POINT: operational units which buy from farms/plantations sustainable biomass for the first time in order to trade or further distribute this biomass GROUP CERTIFICATION (SNC): - (AGRICULTURAL PRODUCTION): certificate issued to a group of economic operators consisting of agricultural enterprises and producer organisations, agricultural consortia or cooperatives as defined by the legislation in force - (BIOMETHANE PRODUCTION): certificate issued to a group of economic operators producers of biogas to be delivered to an upgrading plant for biomethane production and of economic operator which deliver raw material to anaerobic digestion plant. Coordinator is the manager of biogas plant. GROUP CERTIFICATION (ISCC EU/Plus): certificate issued to producers of raw materials, in particular small, agricultural enterprises, consortia and cooperatives. The Group must set up a central office to manage the group and internal audits FIRST GATHERING POINT: first economic operator to receive biomass for the production of biofuel and bioliquid from companies which grow and produce biomass SOCIAL AND ENVIRONMENTAL INFORMATION (for SNC): information as per paragraph 5, art. 7-quater of legislative decree n o 66 dated 21 March 2005, as introduced by paragraph 6 of art.1 of legislative decree n o 55 dated 31 March 2011 LA: Lead auditor (personnel who have the competency requirements established in instruction IS-QPT-BIOC-01) person who, on the basis of his/her competency and knowledge, is able to: prepare, organise and perform management system audits; coordinate the work of the audit team members; instruct the auditors on the method of execution and guide and control their work; prepare and check audit reports;

5 Page 5 of 28 maintain interface relations with the organisation during the audit Aud/ LA in training: person who follows the work of auditors in order to acquire the necessary operational experience as foreseen for auditor /Lead Auditor m/d: man/days NEWAGE: Software used to manage the competencies of the personnel involved in the certification process of sustainability systems NC: Non Conformity NUTS 2: NUTS (from the French 'Nomenclature des Unités territoriales statistiques') is a geographical nomenclature subdividing the territory of the European Union (EU) into regions at three different levels (NUTS 1, 2 and 3, respectively, moving from larger to smaller territorial units). Each EU member state has identified NUTS 2 regions for which default values can be used (please note that land use change shall not have occurred to use the relevant default value). OdC: Certification body OPN: Operational network OU: Operational Unit PR (Program Reviewer): Responsible for the audit programme and technical/managerial responsibility relevant to the certification files assigned to him/her and responsible for the implementation of the three-year audit programme for the file assigned (personnel who have the competency requirements established in instruction IS-QPT-BIOC-01) PRODUCTION CHAIN: all the activities of the economic operator which contribute to the production, transport, processing and supply of biofuel or bioliquid PVI: Audit plan PVP: Programme of periodical surveillance audits (general planning document of the audits to be performed during the period of validity of the certificate) QI: Informative questionnaire, filled in by the client and containing all the data needed to draw up an offer QPT: Sustainability, Environment & Climate Change Sector RVI: Audit report SEG: Secretariat of the OPN offices SL (Scheme Leader): Responsible for managing the specific sustainability scheme SM (Sector Manager): Responsible of Sustainability, Environment & Climate Change Sector TL (Team leader): Responsible for the audit team, personnel who have all the competency requirements foreseen by the role of Lead Auditor (IS-QPT-BIOC-01), who has been assigned responsibility for the audit TRACEABILITY SYSTEM: system consisting of all the data and operations (procedures) which enable the information desired to be kept on a product throughout or along part of its delivery chain and during subsequent use CONTROL AIM: reason for the control CONTROL AND RESPONSIBILITY: activity necessary to obtain, with reasonable certainty, the achievement of an objective

6 Page 6 of REFERENCES UNI CEI EN ISO/IEC Conformity assessment Requirements for bodies certifying products, processes and services DIRECTIVE 2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of the use of energy from renewable sources and amending and subsequently repealing Directives 2001/77/EC and 2003/30/EC, transposed by Italian legislative decree n o 28 dated 3/03/2011 DIRECTIVE 2009/30/EC of the European Parliament and of the Council of 23 April 2009 which amends Directive 98/70/EC as regards the specification of petrol, diesel and gas-oil and introduces a mechanism to monitor and reduce emissions of greenhouse gases, amends Directive 1999/32/EC of the Council as regards the specification of fuel used by inland waterway vessels and repeals Directive 93/12/EEC (the Directive has been transposed by Italian legislative decree n o 55 dated 31/03/2011) IAF (International Accreditation Forum) documents G series: IAF GD 5:2006 IAF Guidance on the Application of ISO/IEC Guide 65:1996 General Requirements for Bodies operating Product Certification System Issue 2 UNI EN ISO Guidelines for auditing management systems Rina Code of Conduct (edition 9 June 2014) Specific for SNC MINISTERIAL DECREE dated 23 January 2012 "National certification system for biofuel and bioliquid sustainability UNI TS Qualification of economic operators involved in the production chain of biofuels and bioliquids UNI TS Management of mass balance in the production chain of biofuels and bioliquids FAQ published on the website of the Ministry of the Environment ACCREDIA RULES FOR THE ACCREDITATION OF CERTIFICATION BODIES - RG 01 ACCREDIA REQUIREMENTS FOR THE ACCREDITATION OF BODIES THAT ISSUE CERTIFICATES OF CONFORMITY IN RELATION TO THE NATIONAL CERTIFICATION SYSTEM OF THE SUSTAINABILITY OF BIOFUELS AND BIOLIQUIDS - RT 31 rev. 1 UNI EN : Sustainability criteria for the production of biofuels and bioliquids for energy applications - Principles, criteria, indicators and verifiers - Part 1: Terminology UNI EN :2012 Sustainability criteria for the production of biofuels and bioliquids for energy applications - Principles, criteria, indicators and verifiers - Part 3: Biodiversity and environmental aspects related to nature protection purposes UNI EN :2013 Sustainability criteria for the production of biofuels and bioliquids for energy applications - Principles, criteria, indicators and verifiers - Part 4: Calculation methods of the greenhouse gas emission balance using a life cycle analysis approach. UNI/TS 11567:2014 Guidelines for qualification of economic operators (organisations) of supply chain of biomethane for traceability and mass balance. MINISTERIAL DECREE dated 5 Dicember 2013 Terms for subsidy of biomethane injected into the natural gas grid Specific for ISCC EU ISCC System Basics

7 Page 7 of 28 ISCC EU Waste and residues supplement ISCC Requirements for traceability ISCC Methodology for the calculation of the Mass Balance ISCC 207 Risk management ISCC Requirements for the use of the logo ISCC Requirements for Certification Bodies ISCC Rules for the conduct of audits ISCC 256 Group certification ISAE 3000 International Standard on Assurance Engagements 3000 Other documents available from the ISCC site ISCC Sustainability requirements - Requirements for the production of biomass ISCC Methodology for the calculation of GHG emissions and GHG audit Specific for 2BSvs 2BSvs-DES-01 [Scheme Description] 2BSvs-PRO-01 Governance and Management 2BSvs-PRO-02 Procedure for the Verification Process 2BSvs-PRO-04 Production of biofuels, biogas and bioliquids from wastes and residues 2BSvs-STD-01 First gathering entity and biomass producers 2BSvs-STD-02 Requirements for Mass Balance System Altri documenti disponibili sul sito 2BSvs For ISCC EU/2BSvs Communication from the Commission on the practical implementation of the EU biofuels and bioliquids sustainability scheme and on counting rules for biofuels (2010/C 160/02) Communication from the Commission on voluntary schemes and default values in the EU biofuels and bioliquids sustainability scheme (2010/C 160/01) Specific for ISCC Plus

8 Page 8 of 28 Documents available on the site in the ISCC PLUS System Documents section. 5. AUDIT ACTIVITIES 5.1 DESCRIPTION The audit is one of the main stages of the certification process, as evident from the following outline: The following tables apply to the audit activities planned for all types of audit for the certification of biofuel and bioliquid sustainability. Normally, the activity includes for all schemes an initial audit and a re-certification audit (five years for SNC and 2BSvs, annual for ISCC) to be made before the expiry of the certificate, for the SNC and 2BSvs scheme also surveillance audit (if applicable, also unannounced) to be carried out during the period of validity of the certificate for maintenance purposes. The general planning document of the audits to be carried out during the period of validity of the certificate, or PVP, is: for SNC and 2BSvs over five years for ISCC over a number of years equal to the number of renewals requested by the customer

9 Page 9 of 28 As it is product certification, all aspects are to be checked. Sampling is only applicable in the case of group certification and with reference to the subjects to be checked, not the technical aspects. Any pre-audit activities (readiness for assessment) do not fall within the scope of this instruction and the results of these audits cannot be considered for the purposes of the Certification audit. The competences required for this phase are described in instruction IS-QPT-BIOC-01. In particular, the personnel responsible for the execution of audits is available in NEWAGE and identified as AUDITOR, LEAD AUDITOR, TECHNICAL EXPERT. The Team Leader (TL), defined as the person who has the skills of LEAD AUDITOR and who is designated as the person in charge of the audit team, is responsible for preparing the audit plans, organising and carrying out the audits on the sustainability system; coordinating the work of the audit team members; instructing the auditors regarding the manner of execution and guiding and monitoring the work; preparing and monitoring the audit reports; maintaining relations with the customer during the execution of the audit. The AUDITOR is responsible for performing audits on the sustainability system, working independently under the guidance of the Team Leader. The TECHNICAL EXPERT integrates the expertise of the audit team related to the technical area and/or geographic area (local legislation, cultural or language/dialect knowledge, etc....), particular methodologies used in some organisations or specific requirements of the reference standard. The Audit Team may also be accompanied by an Aud / LA in training whose participation is purely intended for qualification purposes and therefore takes no active part in the audit TABLE A. CERTIFICATION PROCESS N o PHASE DESCRIPTION OF ACTIVITY Audit team defined and customer documentation 1 PLANNING CERTIFICATION AUDIT The TL verifies the audit time and team members defined by PR, prepares and sends the documents "Dispatch audit plan" and "Audit Plan" to the customer and a copy to the members of the Team. The audit must necessarily include a part at the site/sites of the customer and must cover, in relation to the technical aspects, at least the following: Traceability system Meet all the sustainability criteria Management of the mass balance Calculation of GHG emissions Risk Management Social and environmental information (only for SNC if the subject is responsible for the production of raw materials)

10 Page 10 of 28 N o PHASE DESCRIPTION OF ACTIVITY If applicable, Group Certification: effectiveness of the internal control system In the case of group certification, see the attachments "group certification" and "Sampling" for details on sampling, to be agreed with PR. For group certification, it is not possible to proceed with the evaluation procedure in the event of unavailability of one or more organisations belonging to the group/chain unless it is possible to carry out the verification on other sites that cover the same segment or perform the same activity. The rules for the application of the sampling plan to the permanent sites and/or organisations belonging to the supply chain are to be part of the documentation provided to the organisation by sending the verification program for initial certification, as the organisation must be aware of the criteria used by RINA Services for evaluation and monitoring. The names and respective roles of the AUDIT TEAM must be communicated to the customer in sufficient time to enable him to contest the assignment of individual members and to allow the redefinition of the Team if the objection is deemed valid by PR. To preserve the independence of the audit, each component of the Team, LEAD AUDITOR/AUDITOR/EXPERT before taking on the assignment, is required to disclose to PR any relation with, or which has existed in the past three years, with the customer to be verified. Any subsequent changes to the audit plan already sent (variation AUDIT TEAM, audit dates, etc.) are to be promptly communicated to the customer and to the other members of the Team. OUTPUT Plan sent to the customer Audit team defined and plan sent to the customer The AUDIT TEAM, in accordance with the Audit Plan, verifies that the customer s sustainability system complies with the requirements of the reference scheme, applicable RINA Rules and documents of the customer s sustainability system. The AUDIT TEAM must analyse all information and audit evidence in order to establish a review of the findings and conclusions. The AUDIT TEAM must analyse all information and audit evidence in order to establish a review of the findings and conclusions. 2 CERTIFICATION AUDIT For SNC audits, in the audit report it is necessary to give evidence of: accuracy of the method for calculating GHG emissions adopted by the customer having carried out at least one mass balance and a traceability test as required by UNI/TS assessments performed for the qualification of economic operators on the basis of the requirements of UNI/TS if applicable, information relating to the provisions of Annex I "Information of a social and environmental nature", Ministerial Decree 23/01/2012 and subsequent amendments (completion of the BIOC_RVI_A file) all the information necessary to determine the associated risk (completion of the file BIOC_SNC_RISK_TL to be signed by the customer and attached to the report) The audit report is prepared by TL using ASCESI and is identified by the file number. If ASCESI cannot be used, the forms of the BIOC_RVI series,

11 Page 11 of 28 N o PHASE DESCRIPTION OF ACTIVITY available in the Forms database in Lotus, are to be filled in; then enter in the notes field provided in ASCESI that "the report has been completed and filed on paper", adding to the note the date and author and attaching it in the "Attachment" section. The integrative records and for internal use are to be carried out at each audit, using the forms BIOC_CHK and/or BIOC_FINDINGS. and/or, if any, check list dedicated on the basis to activity carried out by economic operator. For ISCC EU/Plus audits, the report is represented by the ISCC procedure(s) indicated in the registration that ISCC sends RINA and which PR forwards to the Team Leader who, in sufficient time before the audit, is to report any non-receipt. The registration also contains the registration number assigned to the organisation by ISCC and that TL is to put on the procedure(s) (ISCC registration No.). The code assigned to RINA by ISCC, or "Registration No. certification body", to be placed on each procedure is IT-206. For ISCC EU audits, the BIOC_ISCC EU certificate info form is to be attached to the filled in ISCC procedure(s). In the Notes field provided in ASCESI, the TL is to record that "the report has been completed and filed on paper", adding the date and author to the note and attaching the audit documentation, with the customer s signature, in the section "Attachment". For 2BSvs, the audit report is drawn up by the audit team filling in the form: 2BSvs_ST01_REPORT + BIOC_RVI_NC for audit performed at 1 st gathering point 2BSvs_ST02_REPORT + BIOC_RVI_NC for audit performed at legal entities in the biofuel industry (transformation units, traders ) up to the storage under customs duty The audit report belongs to RINA. A copy is to be provided to the customer. The audit documentation, together with the program of surveillance audits (PVP), is to be made available to PR within 3 working days. OUTPUT Audit documentation made available to PR (for audits without NC go to step 4) Audit documentation made available to PR: sustainability system non-compliant For the classification of NC, see the attachment "Classification of findings" 3 FOLLOW-UP AND ANY SUPPLEMENTARY AUDIT ISCC: Presence of major NC (type A): the NC are to be resolved with pertinent evidence - within 40 days from the end of the audit; otherwise, certification is not possible. Presence of minor NC (type B): only allowed in the case of agricultural activities/plantation or central office: within 40 days, at least 60% of the minor non-conformities are to have been resolved; otherwise, certification is not possible.

12 Page 12 of 28 N o PHASE DESCRIPTION OF ACTIVITY SNC: Presence of major NC (type A): the NC are to be resolved with pertinent evidence within a maximum of 90 days from the end of the audit. Presence of minor NC (type B): the NC are to be resolved with pertinent evidence within a maximum of 60 days from the end of the audit. If the NC are not resolved within the said period, with the pertinent evidence, the certificate will be suspended. Certification may be reinstated following the positive outcome of a supplementary audit, to be carried out within 30 days of suspension. If the causes which led to suspension are not resolved, the certificate will be withdrawn. 2BSvs Presence of Critical non-conformity (i.e. nonconformity identified against one of the Principle level requirements specified in the relevant 2BSvs documents) a new verification audit is required before a certificate can be issued. Presence of major NC (type A) the NC are to be resolved with pertinent evidence within a maximum of 90 days from the end of the audit. Presence of minor NC (type B) the NC are to be resolved with pertinent evidence within a maximum of 30 days from the end of the audit. If the NC are not resolved within the said period, with the pertinent evidence, the certificate will be suspended. Certification may be reinstated following the positive outcome of a supplementary audit, to be carried out within 30 days of suspension. If the causes which led to suspension are not resolved, the certificate will be withdrawn. For both types of NC, the customer is to propose, by the deadline established by the team and, in any case, not later than 5 working days from the end of the audit, the analysis of causes, corrections and corrective action and the time frame to resolve the NC, by filling in: for ISCC, the template "Non conformity list" of the procedure completed by TL during the audit; for SNC, the relevant sections of the audit report filled in by the TL, or through the MEMBER AREA for 2BSvs, the relevant form The TL checks the analysis of causes, corrections, corrective action and the time frame proposed by the customer. If the TL is not available, PR may request another competent Lead Auditor. If the proposals are not acceptable, the customer is to be informed by sending the ASCESI document (or through the MEMBER AREA) "Corrective action not accepted," providing suitable reasons and indicating the timing for the submission of new proposals. If the NC are acceptable, then acceptance is confirmed in writing to the customer by sending the ASCESI document (or through the MEMBER AREA) "Corrective action accepted."

13 Page 13 of 28 N o PHASE DESCRIPTION OF ACTIVITY In order to verify that the CA have been implemented, a supplementary audit may be carried out whose duration and method are defined by PR in conjunction with the TL on the basis of the number and type of NC which have emerged: a) supplementary audit on a documental basis, if corrective action/corrections can be checked by simply analysing documents b) supplementary audit on-site to verify only implementation of the corrective action c) supplementary audit on-site of all requirements of the scheme to verify not only implementation of the corrective action but also to verify the system as a whole as the audit team considers it deficient (number of NC even if only type B). The AUDIT TEAM must include at least one member who performed the previous audit, chosen in relation to the type of findings which has made the supplementary audit necessary. For SNC, the supplementary audit report is drawn up using ASCESI. For ISCC, the supplementary audit report is drawn up using the procedure(s) indicated by ISCC. The audit report belongs to RINA. A copy is to be provided to the customer. If it is not possible to resolve the type A NC or additional type A NC are found in the sustainability system during the supplementary audit, a complete onsite audit is to be performed, using the recertification time. 4 POST-AUDIT ACTIVITIES AND CERTIFICATION DECISION OUTPUT Supplementary audit documentation made available to PR Request for clarification/integration The AUDIT TEAM, in particular the TL, collaborates with PR if clarification of and/or integrations to audit documents are needed or for the management of comments made by the DM. OUTPUT Clarification/integrations exhaustive TABLE B. SURVEILLANCE (OR UNANNOUNCED OR EXTRA) AUDIT PROCESS In the case of the ISCC EU/Plus scheme, as recertification is annual, the following table is only to be taken into account if an extra audit is performed. N o PHASE DESCRIPTION OF ACTIVITY Audit team defined and PVP 1 Audit planning The TL checks the audit time and the members of the AUDIT TEAM, as determined by PR and recorded in ASCESI in the audit step of interest; prepares and sends the document "Dispatch of audit plan" and "Audit Plan" (or Communication unannounced audit) to the customer, with a copy to the members of the Team.

14 Page 14 of 28 N o PHASE DESCRIPTION OF ACTIVITY Follow step 1 in TABLE A. OUTPUT Communication and Plan sent to the customer Audit team defined and plan sent to the customer 2 AUDIT The AUDIT TEAM verifies that the customer s sustainability system complies with the requirements of the reference scheme, applicable RINA Rules and documents of the customer s sustainability system and that it is effectively applied. Follow step 2 of TABLE A, with the following additional requirements: The team is also take note of the following: effectiveness of the implemented system and the progress of improvement activities; review of every change, including any amendments to the documents of the system; any preventive actions implemented following the recommendations made during the last audit; retrospective check of a representative sample of declarations of conformity/sustainability certificates use of the RINA certification logo and any other reference to certification, including publicizing of the system and products/services provided by the customer, including by checking the web site. Among the documentation to be submitted to PR, the PVP is not required. OUTPUT Audit documentation made available to PR (for audits without NC go to step 4) Audit documentation made available to PR: sustainability system non-compliant 3 4 FOLLOW-UP AND ANY SUPPLEMENTA RY AUDIT POST-AUDIT ACTIVITIES AND MAINTENANC E OF CERTIFICATIO N OUTPUT Follow phase 3 in TABLE A, the only difference being that in the case of SNC and type A NC, the certificate is withdrawn. RINA will inform the Competent National Authorities of the withdrawal. Supplementary audit documentation made available to PR Request for clarification/integration THE AUDIT TEAM, in particular the TL, collaborates with PR if clarification of and/or integrations to audit documents are needed. An independent review by the DM of every surveillance made is not required. OUTPUT Clarification/integrations exhaustive TABLE C. RECERTIFICATION AUDIT PROCESS N o PHASE DESCRIPTION OF ACTIVITY 1 RE- CERTIFICATION Audit team defined, PVP and previous audit reports

15 Page 15 of 28 N o PHASE DESCRIPTION OF ACTIVITY AUDIT PLANNING The TL checks the audit time and AUDIT TEAM members, established by PR and recorded in ASCESI in the audit step in question; prepares and sends the document Dispatch audit plan and Recertification audit plan to the customer and a copy to the team members. Follow phase 1 in TABLE A OUTPUT Plan sent to the customer Audit team defined and plan sent to the customer The AUDIT TEAM checks that the sustainability system of the customer is compliant with the requirements of the reference standard, with the applicable RINA Rules and with the customer s system documents and that it is efficiently implemented. The aim of certification renewal is to confirm continuous compliance and efficiency of the sustainability system overall, as well as continuous suitability of the certification scope. 2 RE- CERTIFICATION AUDIT Follow phase 2 in TABLE A with the following additional requirements: The team is also take note of the following: the review of earlier audit reports verify commitment shown to maintain the efficiency and improvement of the system efficacy of the implemented system and progress of the activities aimed at improvement review of every modification, including any changes to system documents any preventive action taken as a consequence of the recommendations made during the last audit retrospective check of a representative sample of declarations of conformity/sustainability certificates, use of the RINA certification logo and any other reference to certification, including publicizing of the system and products/services provided by the customer, including by checking the web site. In the case of ISCC EU /ISCC Plus audits, the TL: is to request the customer for the ISCC Terms of use document in force at the time of the audit and available at the following link The document, signed by the customer, is to be attached to the filled in procedure(s); is to verify and report in the procedure if the quantity of product/year harvested (in the case of FGP and/or Collecting Point) and/or the turnover (in other cases) have changed compared with what the customer communicated to ISCC during registration on the ISCC-Registration form. In the case of modifications during the audit, the TL is to request the customer to send an update to ISCC (and a copy to SL). The TL is to provide PR with all the audit records in sufficient time to allow the recertification proposal to be submitted to the DM in charge of the review, which is to be performed before the expiry date of the certificate. OUTPUT Audit documentation made available to PR (for audits without NC go to step 4)

16 Page 16 of 28 N o PHASE DESCRIPTION OF ACTIVITY Audit documentation made available to PR: sustainability system non-compliant 3 4 FOLLOW-UP AND ANY SUPPLEMENTA RY AUDIT POST-AUDIT ACTIVITIES AND RE- CERTIFICATION DECISION Follow phase 3 in TABLE A The whole recertification process, including any supplementary audit, is to be completed prior to the expiry date on the certificate; otherwise, see indications in phase 1 of Table A. OUTPUT Supplementary audit documentation made available to PR Request for clarification/integration THE AUDIT TEAM, in particular the TL, collaborates with PR if clarification of and/or integrations to audit documents are needed or for the management of comments made by the DM. OUTPUT Clarification/integrations exhaustive TABLE D EXTENSION AUDIT PROCESS N o PHASE DESCRIPTION OF ACTIVITY Extension request examined and audit team defined 1 AUDIT PLANNING TO EXTEND THE SCOPE Based on the information received from the customer, PR verifies what kind of process is needed to extend certification to new activities or sites. The various processes managed by ASCESI, during which extension can be carried out, are shown below: extension process in the case of an extension involving a modification in man/days for the audit; surveillance process in the case of an extension which does not involve a modification in man/days for the audit and the extension is assessed in conjunction with an audit already planned by PVP; audit extra process in the case of an extension which does not involve a modification in man/days for the audit if it's decided to plan an audit specifically to verify the extension; recertification process if the extension is assessed in conjunction with a recertification audit. TL is responsible for drawing up the audit plan, based on what is established by PR. Independently of the type of process (extension, surveillance, extra or recertification) and in addition to activities/sites already planned in the PVP, activities/sites requiring extension subject to verification, are to be clearly identified in the audit plan. The audit plan is to be sent to the customer together with the Dispatch audit plan document. Any subsequent amendments to the audit plan already sent (change in AUDIT TEAM, audit dates, etc.) are to be promptly communicated to the customer.

17 Page 17 of 28 N o PHASE DESCRIPTION OF ACTIVITY In any case, to keep track of the modifications made to the scope, PR adds a note in the Notes field in ASCESI. OUTPUT Communications sent to the customer Audit planned 2 AUDIT TO EXTEND THE SCOPE Extension of the scope can be checked, in accordance with what is stated in the previous phase, at the time of a surveillance, extra or extension audit. The TL performs the audit according to the audit plan. Follow phase 2 in TABLE A, bearing in mind to include in the report detailed records related to activities and/or sites subject to extension. 4 5 FOLLOW-UP AND ANY SUPPLEMENTA RY AUDIT POST-AUDIT ACTIVITIES AND RE- CERTIFICATIO N DECISION OUTPUT Audit documentation made available to PR (for audits without NC go to phase 5) Audit documentation made available to PR: sustainability system non-compliant For extension, surveillance and extra audits, see table B phase 3. For recertification, see table C phase 3. OUTPUT Supplementary audit documentation made available to PR Request for clarification/integration THE AUDIT TEAM, in particular the TL, collaborates with PR if clarification of and/or integrations to audit documents are needed or for the management of comments made by the DM. OUTPUT Clarification/integrations exhaustive DATA TO BE INSERTED IN ASCESI Before every audit, the TL verifies the info available in ASCESI. Particularly, the following information in Process List : In Details : Client Data, Head Office and Site Information (i.e. company name and addresses, number of personnel not relevant, etc.). In Notes : any amendments made, for example to the company s name, list of operational sites, certificate scope and related EA sector, addresses of the main office and/or operational sites, etc. The company name and addresses are to be the same as those on the Chamber of Commerce registration or equivalent document. In Operative Units : list of all operational sites subject to assessment and which will have to appear in the audit report and on the certificate. In Contacts : contact details of the customer s representative to whom the communications generated by ASCESI are to be sent. In Requests : Details (i.e. n of personnel, indicate if multisite);

18 Page 18 of 28 Scope (field of application which will appear on the certificate). The scope is to be confirmed and/or modified during certification assessment on the basis of the information collected by the team and consistency with the activity indicated in the Chamber of Commerce registration (or equivalent document). In the case of ISCC, the scope coincides with the type of activity for which the customer has registered with ISCC; Operative units (the previously inserted operational sites are to be associated with the reference scheme so that they appear in the audit reports and on the certificate); EA code(s) (the EA codes related to the activities included in the scope of the sustainability system are to be inserted); Accreditation (it s necessary to insert the accreditation used, whose logo will appear on the certificate; if RINA is accredited for the reference scheme and technical area, it cannot issue certificates outside accreditation) In Step : In Team : the members of the audit team assigned to the process and relative role (i.e. Team Leader, auditor, technician, observer, etc.) and the time dedicated to the audit. Once the date is set, for every type of audit, insert: the start and end dates of the planned audit; once the audit has been made, insert the start and end dates of the audit and the relative task of every auditor making up the Audit Team in terms of man/days. The TL is responsible for filling in the following documents in ASCESI, depending on the case: Initial audit Audit plan Dispatch audit plan First certification audit report Acceptance/non acceptance of any CA Surveillance audit program (PVP) Surveillance audit Confirmation verification of data communicated by the customer Surveillance audit plan Dispatch of surveillance audit plan Surveillance audit report Acceptance/non acceptance of any CA Recertification audit Confirmation verification of data communicated by the customer Recertification audit plan

19 Page 19 of 28 Dispatch recertification audit plan Recertification audit report Acceptance/non acceptance of any CA Three-year program for surveillance audits (PVP) Supplementary audit (if applicable) Notification necessity supplementary audit Supplementary audit report Acceptance/non acceptance of CA Three-year program for surveillance audits (PVP) For all processes: the planned starting and ending dates for the pertinent audit and relative time spent by each auditor of the audit team in terms of man/days in Team : the audit team members assigned to the process and relative role (i.e. Team Leader, auditor, technician, observer, etc...) and the time dedicated to the audit UPLOADING DOCUMENTATION IN ASCESI The aim is to simplify document filing and the exchange of documentation among the internal and external auditors and the various RINA Operational Units. Furthermore, in this way, ASCESI makes the technical documentation available electronically instead of on paper, useful for consultation by PR and the Team assigned to subsequent audits. If the TL supplies the audit documentation to the PR through filing in ASCESI, the methods to be used are: a) CERTIFICATION/RECERTIFICATION/SURVEILLANCE (UNANNOUNCED OR EXTRA) EXTENSION PROCESSES For every process of this type, it s necessary to upload the documents using BROWSE in Process List, by selecting the window attachment. The documents can be filed separately or through two separate files named as follows: CB DOC: file which contains all the documents generated by the certification body. In particular, the ISCC EU/Plus procedure(s) must be filed in full, meaning from the first to the last page which also has the customer s signature. Partial scanning only of the pages with the signatures is not allowed. ORG DOC: file which contains all the documents of the audited customer. The documents uploaded in the process will automatically appear in the relative process identified by the paper clip symbol; through this icon the PR can consult the audit documents. In the case of single filing of documents, it is important to name the files such that their content can be understood (i.e. observation sheets, audit plan, customer documents, manual, etc.).

20 Page 20 of 28 It is possible to file documents using the following extensions:.pdf,.doc,.xls,.zip,.rar,.jpg,.bmp. It is necessary to ensure that the quality of the scanned documents is good, such that they are clearly legible and the content cannot be misunderstood.

21 AUDITING FOR THE CERTIFICATION OF BIOFUEL AND BIOLIQUID SUSTAINABILITY SYSTEMS Page 21 of ANNEX 6.1. GROUP CERTIFICATION Group certification is based on the concept that a large part of the audits is performed by internal auditors. The external certification body verifies and evaluates the efficacy of the internal control system, carries out an audit on a sample and certifies the whole group. It can be applied: in the SNC case: o to economic operators, such as farms, manufacturers, consortia, agricultural cooperatives (meaning subjects belonging to the agrarian category), as long as they have set up a central office responsible for the management of the group and for internal audits. For the conditions to be applied, reference is to be made to the ACCREDIA RT-31 document o to group of economic operators producers of biogas to be delivered to an upgrading plant for biomethane production and of economic operator which deliver raw material to anaerobic digestion plant. Coordinator is the manager of biogas plant. For the conditions to be applied, reference is to be made to the ACCREDIA RT-31 document in the ISCC EU case: only to producers of raw materials (homogeneous groups of agricultural producers; agricultural operators who provide a First Gathering Point). For the other economic operators in the supply chain, group certification is not allowed. Thus, group certification can be applied in particular in the case of small farmers, producer organisations and cooperatives. For the conditions to be applied, reference is to be made to the ISCC 256 Group Certification document. In the 2BSvs case: only to producers of biomass and to waste producers, collecting sites of a collection point Applicability for the purpose of sampling is based on the following prerequisites. If these prerequisites are not satisfied, the single site, meaning operator in the chain, will have to be evaluated applying the usual RINA procedures and issuing individual certificates. Before the evaluation visit, the coordinator is to verify that the entire traceability system functions, meaning he has to verify the complete implementation, efficacy and efficiency of the Control Plan throughout the defined Chain of Custody. Slight variations in the applicable system (procedures and/or instructions) are allowed between one site and another as a consequence of the differences in activities among the various organizations which make up the chain. VERIFICATION METHOD The purpose of verification is to assess the efficacy of the internal control system, the aim being to determine whether every operator complies with the requirements. The verification is made on a sample of companies defined for the year based on what is stated in the attachment SAMPLING. The operators subject to audit by the certification body are to be, in the main, different from those audited the year before. SAMPLING PLAN (GROUP CERTIFICATION Agricultural Operators)

22 AUDITING FOR THE CERTIFICATION OF BIOFUEL AND BIOLIQUID SUSTAINABILITY SYSTEMS Page 22 of 28 See annex SAMPLING RESOLUTION OF NON-CONFORMITIES If a non-conformity is found at the central office /co-ordinating body, or in an operational site/organization of the supply chain, the corrective action is to be applied (if and as applicable) at all sites covered by the certificate. Confirmation of the successful completion of the corrective action may be made by the Audit Team, where relevant, also at a site other than the one in which the non-conformity was found, after verifying the documents submitted by the organization. In the case of recurring, marginal non-conformities, the Audit Team should consider imposing an appropriate increase in audit frequency on the organization. CERTIFICATES A single group certificate is issued with the address of the coordinator and of the other subjects in the supply chain. It is possible, on request, to issue a certificate to an individual subject of the supply chain as long as reference is made, on the certificate, to the group certificate.

23 AUDITING FOR THE CERTIFICATION OF BIOFUEL AND BIOLIQUID SUSTAINABILITY SYSTEMS Page 23 of SAMPLING The table below gives the information for sampling in cases where the customer to be certified is one of the following: Agricultural operators part of a group certification Warehouses/collection centers associated with a First gathering point Collectors of waste/by-products dependent on a collector of waste/by-products, i.e. those who collect, but not-for-sale, waste/residues on behalf of a certified collector Storage facilities not certified individually acting on behalf of a certified subject Biogas plant for production of biomethane/biomethane production plant The certificate holder is to be audited at each audit. If part of the sample presents non--conformities, then the sample is always doubled. If more non conformities are found among the new members of the sample group, then the sample is to be doubled again, and so on. Members of the Group successfully audited during the previous year s audit are not to be part of the consecutive audit sample. OPERATOR OF THE SUPPLY CHAIN ISCC REGISTRATION AS ISSUE OF CERTIFICATE SAMPLE SIZE FOR SNC SAMPLE SIZE FOR ISCC SAMPLE SIZE FOR 2BSvs Agricultural operators Warehouses / collection centers associated with a First gathering point (in agriculture) Group N.a. (the entity which registers is the First Gathering Point) Yes, to Central Office No (included in the certificate issued to the First Gathering Point) Not less than 5% of agricultural enterprises participating in the group and which produce overall at least 5% of the total production. If the audit concerns compliance with the criteria relating to land, the areas in question must be close to each other and have similar characteristics. If the audit concerns the calculation of greenhouse gas emissions, the units must have production systems and products which are similar to each other (see Note 1) n r x n r is a risk factor: 1, 1.5, 2 n is the group member number r x n r = risk factor: 1, 1.5, 2 n. is the number of warehouses/ collection centers n n is the group member number The members to be audited shall be selected in a way that represents the whole group as follow: 75% of group members audited are selected following a risk analysis and 25% of group members audited are selected at random. n