IFS CERTIFICATION PROCESS International Featured Standard Food

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1 ID-IFS-06 July 2017 Page 1 sur 12 IFS CERTIFICATION PROCESS International Featured Standard Food PREAMBLE Certification is a voluntary process and you are responsible for meeting the certification requirements of scheme. Each company engaging in the certification is therefore responsible for this compliance upgrade. This document aims to describe the key steps of the certification process and is an integral part of your contract with ECOCERT France SAS. PROGRAMME APPLICABLE The IFS Food is a reference document designed for audit of the quality, safety processes and products of the agro-food industry. It concerns the food processing companies or the packaging companies of loose products. This program is private and managed by IFS Management GmbH. ECOCERT France SAS, that signed a contract with IFS Management GmbH, is accredited by COFRAC for Product Certification and Services under the accreditation number No (available on to achieve IFS Food audits and to provide services in France and through its subsidiaries. The documents composing this program are: - The IFS Food standard and other associated documents (doctrine notes, potential erratum) whose current versions are available free of charge on the IFS website: - Ecocert France own documents: terms and conditions, the present document and the rules of ECOCERT s references (document Ecocert TS17 available on request). A team at your service! Nicolas BESCOND, Thibaut ROGER, Florence CAPOT, Laure SCHORNSTEIN et Leslie CAZENAVE ECOCERT France sas BP 47, L'Isle Jourdain Phone : nicolas.bescond@ecocert.com, thibaut.roger@ecocert.com, florence.capot@ecocert.com; laure.schornstein@ecocert.com, leslie.cazenave@ecocert.com

2 ID-IFS-06 July 2017 Page 2 sur 12 STEPS OF THE CERTIFICATION PROCESS The service is based on an annual cycle. It leads, when the certification requirements are fulfilled, to the issuance or to the conservation of the certification. The key steps are: A. Application/ application review See steps 1 to 3 in the flowchart in annexe I. Your application is registered by our service upon receipt of the filled form "Information for certification Food Safety". The information gathered in the questionnaire is important for the study of feasibility and the definition of your project (audit scope, duration, audit type...). The feasibility of the project will depend on your ability to implement certification. For example: your company is not ready (no quality management in place) or the audit scope does not apply to the IFS Food standard. In some cases, it is possible that ECOCERT would be unable to implement the certification process. Example: - Lack of qualified auditor on the product / technology scope (eg. scope 3. Eggs and derivatives) or in the appropriate language. - Unavailability of qualified auditor during the desired audit period. - Conflict of interest that may affect the impartiality of our decisions. - Geographical location leading to technical obstacle, or presenting a risk for the auditors (armed conflict in the country, danger...). Furthermore, ECOCERT may refuse to accept a certification request or to sign a certification contract with a company for fundamental reasons. For example: illegal activities or nonconformities antecedent of absence of compliance following certification requirement, inappropriate behaviour, unpaid services, etc. Unannounced audit: you have the possibility to be audited unexpectedly for your initial audit or your renewal audit. In the case of a renewal audit, this choice must be notified to ECOCERT no later than 16 weeks prior to the audit due date. Beyond this period, the audit must be announced. The unannounced audit must take place within the following period: between 16 weeks prior to the audit due date and 2 weeks after the audit due date. The audit shall be conducted during consecutive days. You can notify maximum 10 operational days, when the site is not available for the audit (over maximum 3 periods), in addition to the days of closure of the site (holidays, halting production for maintenance). Blackout period should be communicated to ECOCERT no later than 16 weeks before the audit due date. Seasonal products: in case of seasonal production, you must notify the planned dates of production and audit should be held on these dates (even if the 16 weeks before - 2 weeks after window is not respected).

3 ID-IFS-06 July 2017 Page 3 sur 12 Multi-site audits: the audit of the common activities may be announced but shall not be performed during consecutives days with the site audit (may not take place the same week or the following week). As for announced audits, the audit of headquarters must always occur before the audits on site. B. Formalization of your contract and commitment See steps 4 to 5 in the flowchart in annexe I. After analysis of the application, ECOCERT establishes a customized cost-estimate, called "certification offer" which is based on the estimation of the working time needed. The audit duration is estimated through the use of the calculation tool provided by IFS and available on its website. Caution!! The exclusion of products from the certification scope must be exceptional and can only be linked to product(s) exclusion. The acceptance of exclusions rules are defined in annexe 2. The certification offer is sent along with the terms and conditions and the present document. All these documents are an integral part of your contract. C. Initial Evaluation See steps 6 to 13 in the flowchart in annexe I. 1) Submission of audit conditions When signing the contract, we decide together an audit date (excepted if it s an unannounced audit) as well as the auditor's name. In case of disagreement you may decline the chosen auditor. After the approval of the audit condition, you will receive a letter summarizing the terms of the audit as well as the documents necessary for the audit preparation to be sent to the auditor before the audit (usually 15 days before the audit or when receiving the in case of unannounced audit). Upon receipt of the audit conditions, you can specify to the auditor your time constraints (eg.: production rate or specific services requirements, imperative schedule...). Reminder: On the day of the audit you will have to schedule manufacturing for each family product*: it is imperative for the auditor to observe all products scopes/ technology scopes within the scope during the time of the audit. Otherwise an extension audit will have to be organised or the products will have to be excluded from the scope if the conditions of exclusion are met. * Product family= Different HACCP and / or different CCP and / or a different product scope and / or a different technology scope 2) Submission of documents DOCUMENTS NECESSARY FOR THE AUDIT: a form relative to "mandatory fields" will have to be completed, Manual quality or equivalent, organizational chart, list of procedures and instructions, report of the last management reviews, list of products, HACCP studies, control plans, factory plan, welcoming booklet for staff, list of regulatory and technical texts applicable, list of NA points (to confirm with the auditor).

4 ID-IFS-06 July 2017 Page 4 sur 12 Caution! The submission of these documents is mandatory. In the absence of submission, the time allocated to the preparation of the audit will be increased to the audit plan (2 hours according to the IFS standard). For an initial audit, it may be cancelled. 3) Documentation review and audit plan proposal The auditor will perform the review of your documents and suggest you an audit plan. Audit plan will be defined in accordance with the IFS procedures and be dependent upon your activity (eg. presence of a laboratory, realization of product development, subcontracting...). 4) Return of completed audit plan You should provide the audit plan with the name and function of the participants and send it back to the auditor. Depending on time constraints and participants availability, you have the option to request an adjustment of the audit plan that will have to be approved by the auditor. 5) Certification Initial audit The aim of audit on site is to check the conformity of products/systems with the standard criteria and will be performed at all operational sites dealing with the concerned products: processing, packaging... The audit is carried out according to the following steps: - The opening meeting: the auditor presents the objectives and steps that will have to be checked and confirms the audit scope and audit plan - Evaluation of documentation - Visit of the facilities and interviews of the involved employees - Closing meeting: the auditor summarizes the on-site evaluation Unannounced audit: In the case of unannounced audits, the audit should immediately start on the production area. Entering the production area shall take place no more than 30 minutes after the arrival on site of the auditor. The opening meeting will begin after the site visit. If the company denies access to the auditor (except in cases of force majeure ), the current IFS certificate will be suspended within a maximum of 2 working days. The company shall pay the total cost of the audit. The next audit will be necessarily announced 6) Submission of deviations At the closing meeting, a document called "closing meeting - non conformity agreement" containing the non-conformities is given for signature to conclude the inspection. At the end of the audit within a maximum period of 14 days, the auditor will give you a corrective action plan detailing potential observed deviations. 7) Proposal of a corrective actions plan Upon receipt of the action plan, you must complete and return the corrective action plan to the auditor within 14 days. It is your responsibility to propose corrective actions for each observed deviation and to specify for each one the implementation deadlines and as

5 ID-IFS-06 July 2017 Page 5 sur 12 well as the name of the staff responsible for it. These actions must be relevant and complete and should allow the elimination of the deviation and avoid its reappearance. Otherwise, we will ask you to propose a new action plan. For deviations rated C or D and B for KO, the action must be put in place before the next renewal audit and translated into English. Caution! If you do not return the action plan with appropriate corrective actions and within the deadline, ECOCERT France could not deliver the certification. 8) Validation of the corrective action plan The auditor validates the relevance of the proposed corrective action plan and may have to ask you to reconsider some correctives action and / or their delay of realisation. D. Review of the elements of the evaluation and decision of certification See stage 19 in the flowchart in annexe I. Once the auditor approves the corrective action plan, the file containing the audit report and the corrective action plan is submitted for review to the person in charge of the certification. The time allocated to file processing is of 42 days between the audit and the certification decision (maximum 56 days). The delivery of the certificate is therefore conditioned by the final score (see below) and by the corrective action plan (respect of the deadline + relevance and completeness of the corrective actions). In case of negative decision, the reasons for the certification refusal are communicated and a new initial audit must be organized at earliest 6 weeks after the audit. Conditions for granting the certificate: ECOCERT YOU Max 2 semaines Certification audit Proposal of a corrective action plan In case of major NC or KO, Suspension of the certificate on the portal at the latest 2 working days after the audit ECOCERT Checking of the action plan At earliest 6 weeks after the audit 75% score < 95% Certificate at Basic level score 95 % Certificate at High level max 1 maj. + score >75% Refusal before any other action 1KO and/or 2 maj. and/or score <75% Refusal IFS Follow-up audit Document of complementary audit Basic level certificate if the maj. has been higher since the complementary audit. At earliest 6 weeks and at latest 6 months after the audit

6 ID-IFS-06 July 2017 Page 6 sur 12 Follow-up audit: audit should take place at earliest 6 weeks but no later than 6 months after the audit. During this audit, auditors will focus on the checking of corrective actions in particular on that dealing with major non-conformities. E. Documents of certification See steps 15 and 16 in the flowchart in annexe I. After the certification decision and if your situation allows it, a certificate indicating the scope of the audit will be issued. You will receive by the certificate (if the decision is positive), the audit report and the corrective action plan. These documents will be posted online on the IFS portal giving you access to the documents, allowing you to download and/or to print them. The validity and authenticity of the certification may therefore be checked on the website at any time. Costs that would be incurred (eg : manufacturing, printing labels ) in anticipation of a certification decision not yet issued are under your responsibility and cannot be supported by ECOCERT France. F. Surveillance and continuation of the certification process 1) Audit renewal See stages 17 and 18 in the flowchart in annexe I. An audit renewal should take place annually and must be scheduled at the earliest 8 weeks before the audit anniversary and no later than two weeks after the audit anniversary (reminder on the IFS portal 3 months before the due date). In cases the audit would be scheduled beyond this period, the certification cycle would be interrupted leading to a lack of certification during a temporary time period (between the end of validity of the previous certificate and the beginning of validity of the new certificate). All requirements of the standard must be assessed (as for the initial audit). A particular attention is given to the deviations identified during the last audit as well as to the efficiency and implementation of corrective actions. Whatever the length of the time period between the two audits (rupture of the certification cycle or not), the auditor should always evaluate the corrective action plan from the previous audit. When programming the audit renewal, a review of the application is done again and is based on the updated information we ask you to communicate and/or information collected during audits and other investigations. Back to Stage 3 in the flowchart. 2) Extension audit It is possible to perform an audit extension in order to integrate new products and / or processes in the scope of the IFS certificate or when products/processes that could not be seen in operation during the main audit. The duration and content of the audit are assessed by the certification body. An audit of extension is always announced.

7 ID-IFS-06 July 2017 Page 7 sur 12 3) Additional Audit Additional audit: audit that comes in addition to the annual audit. Its aim can be to verify the implementation of corrective actions or to check requirements of the standard and / or site's activities. Thus, an additional audit may be done when Ecocert considers that: o The time spent on the site during the annual audit has proven to be insufficient, o Some information suggesting that the company is not able anymore to be in conformance with the requirements of the standard (eg. complaint, withdrawal or recall of products, health crisis, deterioration of the production tool after a natural disaster...) o A verification of the corrective action is necessary before the renewal audit. o Requirements of the standard have been modified and an audit is required to verify the conformity of the company to new requirements. You therefore agree to accept any additional audit required by ECOCERT, which will announce these audits in advance except in the case ECOCER has good reasons to believe that food safety or product safety in general is in danger and/or that misuses or breaches will be suppressed. G. Changes affecting the certification Changes in the certification scheme (new requirements or changes in the requirements) In case of renewal audit, IFS will inform you directly by (contact on the IFS portal) of the changes that can be introduced into the standard (new requirements or revisions to requirements). Depending on the case, the amended dispositions will be immediately applied or transitions measures may be implemented by the IFS. It is your responsibility to make the changes and that of ECOCERT to verify their application. If the changes have not been implemented, ECOCERT can notify you nonconformities that, if not resolved, can lead to the suspension or even the withdrawal of your certification. Change of your certification scope It is your responsibility to inform ECOCERT of any changes that may affect your compliance to the requirements of certification within 3 working days after the event. For example these changes could be: o Recall, warning on products, crisis situation o Structural changes (change of ownership, status...) o Change in your organisation and management o Changes introduced in the products or production processes o Etc. These changes may lead to reassess your certification (changes of the scope of certificate, suspension...) and lead to the realisation of an additional audit or an extension audit (in case of new products / processes).

8 ID-IFS-06 July 2017 Page 8 sur 12 H. Suspension or withdrawal of the certification There are 2 kinds of sanctions Suspension of certification: This involves the interruption of certification for a specific period of time until compliance of the product / system. Examples: - In case of major nonconformity given during the renewal audit with a final score higher than 75%, - Case of a KO or a major nonconformity assigned during an audit carried out by the "Program Integrity", - Situation involved during the year questioning the compliance with the requirements of the standard (example: problem turned out questioning the safety of products, recall etc.) - non-payment. In case of major non-compliance assigned during the renewal audit, the suspension should take place on the IFS portal no later than 2 working days after audit. Depending on the case, a follow-up audit or an additional audit shall take place in order to verify compliance of the deviations that were the subject of the suspension of certification. The terms of the audit will be defined by ECOCERT. Withdrawal of certification: This involves the immediate interruption of certification. The withdrawal of certification occurs when: - The access to the auditor is denied (except in cases of force majeure) - There is a failure of certification during the renewal audit. - There is a situation involved during the year making impossible to the compliance with the requirements of the standard (example: hidden breaches of rules, closure of a production site, etc.) In case of major non-conformities ( 2) or KO assigned during the renewal audit, the withdrawal must take place on the IFS portal at the latest 2 working days after the audit. The withdrawal goes along with the termination of the contract with ECOCERT. A company whose certificate has been suspended / withdrawn cannot communicate on certification. This interdiction applies to any communication medium. The suspension or withdrawal of the certificate implies the immediate end of validity of the document. You have to inform your clients that you are no more certified, and should not claim this certification anymore. I. End of the certification Termination modality and effects on your certification At any time, you can ask to stop certification. In case you want to cease the certification and stop at the same time your contract, you must do it in accordance with the conditions defined under in the terms and conditions.

9 ID-IFS-06 July 2017 Page 9 sur 12 The end of the certification and the termination of your contract imply the end of validity of your certificate with immediate effect. Consequently, from the date of the termination of the certification (and the cancelation of the contract, if any), you cannot refer anymore to the certification and / or to ECOCERT. Certification Body Change In case of certification body change, your file must be transferred to your new certification body, and this regardless of your situation (expired certification, failure to certification, suspension...). For that purpose, you need to give the access to your file on the IFS portal so that previous reports may be accessible and we can inform the audit date in the agenda of the portal. COMPLAINTS AND APPEALS You can send to ECOCERT a complaint about our service, or an appeal against the decision taken by ECOCERT. ECOCERT acknowledges receipt of your complaints or appeals within 5 working days and commits to treat them on time according to our internal procedures. Complaints Following a complaint, ECOCERT analyses its content and provides a full written response. All these complaints are registered, as well as measures taken and an analysis is made on a regular basis to improve our service. Appeals You may appeal any certification decision, within 15 days following the date of receipt of this decision. This appeal must be made by writing to ECOCERT ( or letter) and be duly motivated (by providing new items that have not previously brought to ECOCERT attention). The appeal is then treated within 20 working days by ECOCERT management. If you refute the outcome of your first appeal, you can make a second appeal to ECOCERT. This appeal must be paid for and has to be performed within 15 days after the date of receipt of the new information of the adverse decision following the first appeal. Appeals are not suspensive of the decisions previously taken. These decisions therefore apply until a new decision has been made after evaluation of your appeal. Your obligation with respect to third parts claims You are responsible for managing third parts claims that are addressed to you directly. You must keep a record of all complaints made known to it relating to compliance with certification requirements and makes these records available to ECOCERT. These records must keep track of the appropriate action taken and these actions must be documented.

10 ID-IFS-06 July 2017 Page 10 sur 12 COMMUNICATION ON THE CERTIFICATION, AT IFS FOOD AND ECOCERT FRANCE The terms of use of references of the IFS certification and / or Ecocert France are defined in the following documents: - Rules for the IFS certification reference: in the IFS standard and / or IFS doctrine notes, - Rules for references to Ecocert: Document Ecocert TS17 available on request. - General Terms and Conditions Furthermore, the applicant for certification agrees not to suggest that ECOCERT and / or the owners of the standard are responsible for the fulfilment of the certification requirements. A misuse of the trademark or an incorrect reference to the IFS certification or to Ecocert by a client may lead to the implementation of appropriate measures such as suspension or withdrawal of certification. Ecocert is also required to inform the owners of the IFS. THE INTEGRITY PROGRAM OF IFS Any company agreeing to an IFS certification process must be aware of the IFS "Integrity Program", which is described in the IFS and accept its rules. The Integrity Program is a group of measures intended to ensure the quality of the IFS certification process. It focuses on the verification of the audits made by accredited certification organism and by their auditors. This program is managed by the owner of IFS, IFS Management GmbH. As a company joining the IFS certification program, you could be audited by IFS Management, either as part of audits of general supervision, or as part of an investigation following a complaint or for any other reason. IFS Management audits are usually unannounced, but according to the case, at discretion of the IFS Management, you can be notified at least 48 hours in advance. The IFS Management may also participate to IFS audits IFS as an observer. In this case, the auditor of the " Integrity Program" follows the auditor during an IFS audit on site.

11 ID-IFS-06 July 2017 Page 11 sur 12 ANNEXE 1: THE STEPS OF YOUR CERTIFICATION YOU 1. Request information for the IFS Food certification ECOCERT 2. Send the Questionnaire Information for Food Safety Certification 3. Send the information: audit scope, exclusion, employee number, product scope(s), technology scope(s), trade products etc. 4. Review of the information (feasibility of the product and time of the mission using the IFS calculation tool) and send a cost-estimate 5. Accept the cost-estimate, send back the contract: including terms and conditions + hereby IFS certification process 6. Suggest the audit's conditions: IFS qualified auditor(s) for the product scope(s) and technology scope(s), date (if announced audit) and audit duration, audit scope 7. Send documents for the documentary review 8. Documentary review and audit plan suggested by the auditor 9. Send back the completed audit plan 10. INITIAL CERTIFICATION AUDIT 11. Send the list of deviations (Maximum 2 weeks after the audit) 12. Suggest a corrective actions plan (max. 2 weeks after receiving the deviations list) 13. Check of the corrective actions plan by the auditor (pertinence, delay) 14. Review of the result of evaluation and the actions plans by the certification body Initial audit no Decision of certification Yes 15. Award the certificate (initial audit date + 8 weeks) and send the final report to the audited company 16. Upload the audit data s into the IFS audit portal 17. Schedule a new audit At earliest 8 weeks before and at latest 2 weeks after the renewal audit due date. Reminder by the portal (3 months before the audit expires). 18. RENEWAL AUDIT Upload the expected date in the IFS audit portal at latest 2 weeks before the audit due date. Go to step 3. Assessment of the corrective action plan from the previous audit + check the reference to IFS Food certification (logo, other)

12 ID-IFS-06 July 2017 Page 12 sur 12 ANNEXE 2: RULES OF EXCLUSION By definition, all food processes which are managed by the company / legal entity, on the same site, and which are under their responsibility shall be included in the scope of an IFS Food audit. This means that, for companies managing the whole supply chain under the same legal entity and location (like e. g. slaughtering, deboning, meat cutting, meat processing, etc.), IFS Food certification shall apply to full activity. All processes and products shall be included in the audit scope. The identification of exclusions shall only be An exceptional situation and can only be related to product exclusions. It is only in the exceptional situation where the certified company wishes to exclude a product(s) from the IFS Food certification scope that the following decision tree should be used to determine whether the exclusion of product (s) is possible (subject to acceptance by the certification body). Definition: Documentary audit: Can only be performed if the product / tech scopes and / or HACCP study (incl. allergens, contaminants, etc.) are identical for seasonal / sporadic products and regular products. This audit shall address, at least, HACCP, production records, traceability test, client specifications and complaints. Differentiable: Being subjected to different product characteristics, like e.g. different product kind / type, different name, different packaging material, etc. Products which are fully equivalent but only having as different characteristics a different label is not enough to differentiate a product. Common initial steps: Applies to upstream processing steps or same raw materials which are common between included and excluded products. Examples of common initial steps: Cakes are coming from common initial steps (i.e. common processing), going then either on a packing line or on a freezing line In a milk processing factory: milk is commonly used, and then one part of the milk goes to a different workshop to process milk powder. Seasonal Product: Product which is only fully processed during a defined and limited period, due to e.g. specific events (e.g. Christmas chocolates). Regular Product: Product which is processed all year long, in opposite to seasonal or sporadic product. Sporadic Product: Product which is irregularly processed (on order / tailor made), whose process cannot be scheduled in advance. Different area: Different location or zone of the company, with or without physical segregation. Examples of different area: In a winery, part of the wine goes to bottling section and another part of the wine goes to a specific line for packing in huge bag-in-boxes, located in the same workshop but not on the same line In an egg processing company, part of the eggs goes to packing station, another part goes to a specific workshop for processing egg products In a bakery company, sweet cookies are produced in one workshop and salty puff pastry products are produced in a different specific workshop.

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