GFSI BENCHMARKING REQUIREMENTS GFSI GUIDANCE DOCUMENT VERSION 7.1

Transcription

1 GFSI BENCHMARKING REQUIREMENTS GFSI GUIDANCE DOCUMENT VERSION 7.1 PART I THE BENCHMARKING PROCESS

2 CONTENTS Introduction Application GFSI Scopes of Recognition...4 Defining the Scope...5 Benchmarking Options Benchmarking Re-benchmarking Extensions to Scope of Recognition for Schemes Benchmarked Against V Significant Change The GFSI Benchmark Methodology Introduction The Key Procedural Steps Step 1: Scheme Owner Fills out the Self-Assessment Step 2: Preliminary Desk Review of the Self-Assessment Step 3: Call to Go through Findings Step 4: Scheme Owner Updates (where applicable) Resends Final Self- Assessment Step 5: Office Visit Step 6: Public Stakeholder Consultation Step 7: GFSI Board Final Decision Communication Step 8: Annual Assessment Based on GFSI Integrity Programme Sanctioning GFSI Appeals Procedure - GFSI Recognition The GFSI Benchmarking Requirements PART I THE BENCHMARKING PROCESS

3 PART I THE BENCHMARKING PROCESS Introduction The Global Food Safety Initiative works closely together with stakeholders Scheme Owners to provide continuous improvement in food safety management systems to ensure confidence in the delivery of safe food to consumers worldwide. We have used this input to develop the version 7 (V7) Benchmark criteria, also adopt a new approach towards our Benchmarking procedure. We seek to increase transparency streamline the Benchmarking procedure in a more uniform manner, thus enabling GFSI Benchmarked Scheme Owners to efficiently comply with the criteria laid out in the GFSI Benchmarking Requirements V7. It will contribute to the following GFSI objectives: 1. Reduce food safety risks by delivering equivalence convergence between effective food safety management systems. 2. Manage cost in the global food system by eliminating redundancy improving operational efficiency. 3. Develop competencies capacity building in food safety to create consistent effective global food systems. 4. Provide a unique international stakeholder platform for collaboration, knowledge exchange networking This section is the first part of the GFSI Benchmarking Requirements, which has been developed published by the Global Food Safety Initiative (GFSI) to specify the requirements for the recognition of food safety schemes. The detailed steps procedures developed by GFSI serve to demonstrate that the GFSI benchmarking process is carried out in an impartial transparent manner by a technically competent Benchmark Leader under the supervision of GFSI Technical Manager. The objective of this document is to give stakeholders a clear insight into the benchmark process for GFSI Benchmarking Requirements V7. Further clarification will be provided during the application process. The benchmarking process carried out by GFSI is the method by which a food safety Scheme Owner is objectively compared to the defined requirements as set out in the GFSI Benchmarking Requirements V7 to determine equivalence. GFSI shall ensure that the process of GFSI benchmarking associated procedures are transparent open to stakeholder scrutiny. The systems procedures associated with the GFSI benchmarking process will be reviewed, maintained updated to ensure consistency integrity. 1 Application Any Scheme Owner that wishes to be recognised must apply via the GFSI website. The Scheme Owner downloads an application form template finds detailed guidance for the completion of the application supporting documents. The Scheme Owner s application must include GFSI Benchmarking Requirements Part II (Requirements for the Management of Schemes) at least one industry scope. The GFSI Technical Manager shall review the application, if in agreement, shall send a contract to cover all aspects of the benchmarking process as well as terms conditions. The GFSI Technical Manager reserves the right to reject or refer an application back to the Scheme Owner if the quality of the application is poor. An applicant Scheme Owner shall be permitted to lodge multiple benchmarking applications with GFSI, but shall only be permitted to submit one re-submission within a twelve-month period, if the initial application is deemed to be unsuccessful. A list with available Benchmark Leaders will be presented on the GFSI website. The GFSI Technical Manager will appoint a Benchmark Leader for the Scheme record the selection in the application file. The Technical Manager may assign additional Benchmark Leaders to ensure that the benchmarking takes place within the desired timeframe. This will be done with the written consent of the Scheme Owner. Once the GFSI Technical Manager accepts the Scheme for benchmarking, the benchmarking process will only progress once a contract has been signed between the applicant Scheme Owner GFSI. The GFSI Benchmarking Requirements 3

4 After the signed contract is received, the GFSI Technical Manager shall transfer all appropriate excel files for selfassessment to the Scheme Owner present a work plan. This work plan of activities key dates will be agreed upon by the GFSI Technical Manager, the Benchmark Leader the Scheme Owner based on the number of scopes volume of documentation submitted. Confirmation of acceptance of the work plan shall be published on the GFSI website Benchmarking DEFINING THE SCOPE Every Scheme Owner that applies shall have a defined scope in relation to food safety or services directly associated with food safety, which shall be subject to certification by accredited Certification Bodies. GFSI has set up several requirements for the management of the schemes. These requirements are described in Part II apply to all Scheme Owners wishing to go through the GFSI benchmarking process for V7. GFSI has clearly defined scopes in relation to products or services for which Schemes can seek recognition by GFSI. The Scheme shall clearly specify the scope of activity within its application to GFSI. GFSI has categorised the food supply chain into sectors sub-sectors in which there is a defined series of requirements for food safety criteria which are dependent upon the relevant sector. These requirements shall be clearly defined in the stard of the applicant s Scheme as these shall be assessed against the requirements of the relevant section of the GFSI Benchmarking Requirements (Reference Part III Scheme Scope Key Elements). A Scheme s stard may have a major focus or historical focus other than those related to food safety. Only those requirements relating to food safety shall be assessed by GFSI for the purpose of recognition. The GFSI sector sub-sector scopes for recognition are as follows; The GFSI sector sub-sector scopes for recognition are as follows; GFSI SCOPE OF RECOGNITION (Benchmarking Category Code) BENCHMARKING CATEGORY NAME EXAMPLES OF PRODUCTS / SERVICES AND METHOD OF PRODUCTION AI AII BI BII C Farming of Animals for Meat/ Milk/ Eggs/ Honey Farming of Fish Seafood Farming of Plants (other than grains pulses) Farming of Grains Pulses Animal Conversion Animals (other than fish seafood) used for meat production, egg production, milk production or honey production Growing, keeping, trapping hunting (slaughtering at point of hunting) Fish seafood used for meat production Growing, trapping fishing (slaughtering at point of capture) Growing or harvesting of plants (other than grains pulses) for food Growing or harvesting of grains pulses for food Lairage, slaughter, evisceration, bulk chilling, bulk freezing of animals Gutting, bulk freezing of fish Storage of game 4 The GFSI Benchmarking Requirements

5 D Pre-process hling of plant products, nuts grain De-shelling of nuts Drying of grain Grading of fruit vegetables Storage Cleaning, washing, rinsing, fluming, sorting, grading, trimming, bundling, cooling, hydro-cooling, waxing, drenching, packing, re-packing, staging, storing, loading / or any other hling activity that does not significantly transform the product from its original harvested form. E I E II E III Processing of perishable animal products Processing of perishable plant products Processing of perishable animal plant products (mixed products) Production of animal products including fish seafood Meat, eggs, dairy fish products Deboning, cutting, washing, trimming, grading, pasteurisation, cooking, curing, fermentation, smoking, chilling, freezing, packed in modified atmosphere, packed in vacuum packing Production of plant products (products (including grains, nuts, pulses) Washing, slicing, dicing, cutting, shredding, peeling, grading, pasteurisation, cooking, chilling, juicing, pressing, freezing, packed in modified atmosphere, packed in vacuum packing or any other activity that significantly transforms the product from its original whole state Production of animal plant products Mixing, cooking, chilling, freezing, packed in modified atmosphere, packed in vacuum packing E IV Processing of ambient stable products Production of food products from any source that are stored sold at ambient temperature Aseptic filling, baking, bottling, brewing, canning, cooking, distilling, drying, extrusion, fermentation, freeze drying, pressing, frying, hot filling, irradiating, milling, mixing blending, packed in modified atmosphere, packed in vacuum packing, pasteurising, pickling, roasting, salting refining The GFSI Benchmarking Requirements 5

6 FI G H I J K L M N Production of feed Catering Retail / Wholesale Provision of Food Safety Services Provision of Storage Distribution Services Food Feed Manufacture of Food Processing Equipment Production of (Bio) Chemicals (Additives, Vitamins, Minerals, Bio-cultures, Flavourings, Enzymes Processing aids) Production of Food Packaging Food Broker / Agent Production of feed from a single or mixed food source Drying, cooking, milling, mixing blending extrusion Production of food products from any source for consumption outside the home Cooking, mixing blending, preparation of component products Provision of finished food feed products to a customer Retailing wholesaling of food feed Supply of services related to the safe production of food Water Supply Pest Control Cleaning Services Test Laboratories Storage facilities for food feed Distribution vehicles for food feed Production of food feed processing equipment Production of food feed additives, vitamins, minerals, bio-cultures, flavourings, enzymes processing aids Production of food feed packaging, packaging materials, packaging components in the form of raw materials, part processed, semi converted, converted or fully finished packaging materials products for use in the supply chain. The supply of finished food feed products 6 The GFSI Benchmarking Requirements

7 BENCHMARKING OPTIONS Benchmarking The requirements specified within this clause shall apply to Schemes, which have: not previously undergone benchmarking by GFSI, been assessed previously, but have withdrawn the application without completing the benchmarking process. been previously recognised by GFSI, but have had recognition withdrawn. GFSI will require the applicant Scheme Owner to submit an application for recognition to GFSI together with supporting evidence proving that; the Scheme Owner is a legal entity. the Scheme Owner is not a Certification Body shall not be governed or owned by one or more certification bodies. there is an agreement with one or more Accreditation Bodies for Certification Bodies to operate to ISO/IEC or ISO /IEC for the scope of their Scheme. The Accreditation Bodies granting accreditation to the scope of the Scheme shall be members of the International Accreditation Forum (IAF) shall be signatories to the Multilateral Recognition Arrangement (MLA). contractual relationships exist with at least two Certification Bodies that have accreditation for the scope of the Scheme with an Accreditation Body. the Scheme has in place ten valid accredited certificates (for each relevant scope of the application) issued by Certification Bodies, including at least one valid certificate issued by each contracted Certification Body during a twelve-month period prior to the date of the application. the Scheme has been operational for a minimum period of twelve months prior to the date of application. During this period, certificates have been issued to a number of organisations. A Scheme is deemed to become operational on the date on which the first accredited certificate is issued by a Certification Body. the Scheme shall not be undergoing a significant change (See criteria for significant change to its stard, management, governance or operational procedures at the time of application of recognition by GFSI). the Scheme shall not have any practices that are deemed as restricting access to markets. the Scheme has undertaken a self-assessment to validate that the Scheme management requirements are in compliance with the GFSI Benchmarking Requirements Re-benchmarking The requirements specified within this section of the GFSI Benchmarking Requirements shall apply to: Schemes that have successfully undergone benchmarking by GFSI. All existing GFSI-recognised Schemes under V6 have to undergo re-benchmarking for all the scopes against the GFSI Benchmark criteria V7 within the time period of 12 months from publication of V7. GFSI Board has the authority to extend this period under special circumstances. Schemes which have been subject to suspension by GFSI or have temporarily or voluntarily agreed on withdrawal in accordance with the GFSI Executive Director for any other reason for a period of less than 1 year from suspension or withdrawal. GFSI will require the applicant Scheme Owner to submit an application for recognition to GFSI together with supporting evidence proving that: there is an agreement with one or more Accreditation Bodies for Certification Bodies to operate to ISO/ IEC ISO17065 or ISO /IEC for the scope of their Scheme. The Accreditation Bodies granting accreditation to the scope of the Scheme shall be members of the International Accreditation Forum (IAF) shall be signatories to the Multilateral Recognition Arrangement (MLA). there are contractual relationships with at least two Certification Bodies, who are accredited with an Accreditation Body for the relevant scope for which the Scheme is applying for recognition. the Scheme has in place 10 accredited certificates (for the relevant scope of the application) issued by Certification Bodies, during a twelve-month period prior to the date of the suspension or withdrawal. The GFSI Benchmarking Requirements 7

8 the Scheme shall not be undergoing a significant change to its stard, management, governance or operational procedures at the time of application of recognition by GFSI will have completed all activities that remedy or re-establish the Scheme after the suspension or withdrawal Extensions to Scope of Recognition for Schemes Benchmarked Against V7 The requirements specified within this clause shall apply to Schemes, which are: already benchmarked against V7 for different scope/ scopes seeking to apply for a new GFSI scope of recognition. seeking an extension for a new stard (scope of accreditation) within the GFSI scope of recognition, for which they are currently recognised. This will not include change to the governance or ownership or the management system. seeking an extension of an existing recognised scope, where there has been change to the Scheme s stard or operational normative documents, but these changes do not represent significant change which could compromise the Scheme s recognition by GFSI. GFSI will require the applicant Scheme Owner to submit an application for recognition to GFSI together with supporting evidence proving that; there is an agreement with one or more Accreditation Bodies for Certification Bodies to operate to ISO/ IEC or ISO /IEC for initial accreditation programme or the scope extension of their Scheme. The Accreditation Bodies granting accreditation to the scope of the Scheme shall be members of the International Accreditation Forum (IAF) shall be signatories to the Multilateral Recognition Arrangement (MLA). there are contractual relationships with at least two Certification Bodies, who are accredited with an Accreditation Body for the scope for which the Scheme is applying for recognition. the Scheme has in place ten certificates (for the relevant new scope of the application) issued by contracted Certification Bodies to demonstrate market dem, including at least one certificate issued by at least two Certification Bodies. There must be formal acknowledgment evidence provided that accredited certification for the scope extension shall be in place within one year. twelve months prior to the date of application. A Scheme is deemed to become operational on the date on which the first accredited certificate is issued by an Accredited Certification Body. From the moment when GFSI starts to finalise the new version of the benchmarking requirements, GFSI will no longer accept any applications from new Scheme Owners for a period of one year. A notice will be displayed on the GFSI website to indicate the starting date of this one-year period. Additionally, GFSI will not accept any applications for scope extension from existing Scheme Owners in the last 6 months of this one-year period Significant Change A Scheme seeking continued recognition prior to a Scheme change is defined as a Scheme which is: Recognised by GFSI on the Benchmark criteria V7 but will be making a change to its governance or ownership, or a significant change to its management system, stard or normative documents, which could compromise the Scheme s recognition by GFSI. Scheme Owners will inform the GFSI Executive Director in writing about the significant change. A significant change can lead to additional actions from the Benchmark Leader. The type of action will depend on the impact of the significant change. GFSI will require the applicant Scheme Owner to submit an application for recognition to GFSI together with supporting evidence proving that: there is an agreement with one or more Accreditation Bodies for Certification Bodies to operate to ISO/ IEC ISO17065 or ISO /IEC for the scope of their Scheme. The Accreditation Bodies granting accreditation to the scope of the Scheme shall be members of the International Accreditation Forum (IAF) shall be signatories to the Multilateral Recognition Arrangement (MLA). there are contractual relationships with at least two Certification Bodies, that have accreditation for the scope of the Scheme with an Accreditation Body. the Scheme has in place 10 accredited certificates (for each relevant scope of the application) issued by an accredited Certification Bodies, during a twelve-month period prior to the date of the application. the host Scheme has been operational for a period of 8 The GFSI Benchmarking Requirements

9 2 THE GFSI BENCHMARK METHODOLOGY 2.1 Introduction The benchmarking process is performed by a Benchmark Leader, who has been selected approved by the GFSI Board in order to ascertain whether a Scheme can demonstrate conformity with the requirements of the GFSI Benchmarking Requirements. The Benchmark Leader reports to the GFSI Technical Manager who will supervise all the Benchmark activities communication with the Scheme Owners. All Benchmark Leaders will undergo the same training. In addition to this, there will be harmonisation activities several times a year to maintain alignment of the evaluation approaches adopted by the various Benchmark Leaders. The Benchmark Leader will, under supervision of the GFSI Technical Manager, execute the benchmarking process as described in this document. GFSI will select the Benchmark Leader for the Scheme after signing an impartiality declaration from both the side of the Scheme Owner the Benchmark Leader. A Benchmark Leader may perform the benchmarking activities for a maximum period of 3 years per Scheme. The GFSI Executive Director may reassign the Benchmark Leader at any time, at his or her discretion, if it is deemed necessary to do so. 2.2 The Key Procedural Steps The benchmarking process shall be carried out in accordance with the following key procedural steps: 1. Scheme Owner fills out the Self-Assessment. 2. Preliminary desk review by Benchmark Leader. 3. Call to Go Through Findings. 4. Scheme Owner updates (where applicable) resends the final Self-Assessment. 5. Office Visit. 6. Public stakeholder consultation. 7. GFSI Board final decision communication. 8. Annual assessment based on the GFSI Integrity Programme. GFSI BENCHMARKING - Methodology SELF- ASSESSMENT Scheme Owner fills in the Self-Assessment (SA) Review of SA by Benchmark Leader (BL) under supervision of GFSI Technical Manager (TM) i BL details made available on GFSI website. GFSI appoints BL for Scheme. PRELIMINARY ASSESSMENT BL TM inform SO of preliminary results SO updates SA resends it i BL checks SA evidence, identifies need for additional info communicates it to GFSI TM. BL summary report recommendation Office visit carried out by BL GFSI TM i As part of BP GFSI performs an office audit. FINAL ASSESSMENT Public Consultation (PC) i Based on recommendation of BL TM, GFSI Board makes final decision on GFSI recognition. Board Decision Update S0 i Based on the assessment, BL drafts report to be shared during PC with stakeholders. SO COMMUNICATION WITH STAKEHOLDERS The GFSI Benchmarking Requirements 9

10 2.2.1 Step 1: Scheme Owner Fills out the Self- Assessment The objective of the Self-Assessment is to allow the Scheme Owner to demonstrate that the Scheme covers all the requirements listed in the benchmark documents of V7, including Part II Requirements for the Management of Schemes as well as the appropriate sections of GFSI Benchmarking Requirements Part III Scheme Scope Key Elements. GFSI will provide an Excel sheet with the relevant scopes that Scheme Owners may use to rank themselves against the GFSI V7 benchmark criteria. For each criterion, the Scheme Owner must evaluate: is the GFSI criteria covered in their Scheme? What is the justification for it? What is the name of the Scheme s document where the criteria are covered? On which page in what paragraph? Can objective evidence be uploaded to support this claim? Along with the application materials provided to the Scheme Owners, GFSI will also provide a detailed description of what is expected from the Scheme Owners throughout the process Step 2: Preliminary Desk Review of the Self-Assessment After the completed Self-Assessment is received, the Benchmark Leader, under the supervision of the GFSI Technical Manager, will perform a preliminary Desk Review. For each GFSI criterion, the Benchmark Leader will review the corresponding requirements in the Scheme Owner s stard check the reference given by the Scheme Owner on where it is covered. The Benchmark Leader will assess the objective evidence delivered by the Scheme Owner. The Benchmark Leader will take note of any criteria where additional information is needed /or where he or she does not agree with the ranking of the Scheme Owner. These comments will be supported by comprehensive explanations. All these findings are sent back to the Scheme Owner in writing form the basis of the conference call in step Step 3: Call to Go through Findings In a conference call, the Benchmark Leader the GFSI Technical Manager will exchange their findings in detail with the Scheme Owner. This will give the Scheme Owner greater insight into what extra information is needed or what needs to be adjusted. During the conference call the time frame for execution of actions will be agreed Step 4: Scheme owner Updates (where applicable) Resends Final Self-Assessment Within the agreed timeframe, the Scheme Owner will update the Self-Assessment /or send the necessary additional information. In order to limit a possible back-forth exchange of information the Scheme Owner will be required to deliver the requested information /or adjustments to the final Self-Assessment. The final version of the Self-Assessment must be signed off by the Director of the Scheme Owner Step 5: Office Visit The Benchmark Leader the GFSI Technical Manager will organise a visit to the nominated offices of the Scheme Owner. The purpose of the visit is to reconcile any discrepancies identified by the Benchmark Leader during the review of the Scheme Owner Self-Assessment check the implementation of the Scheme Owner Integrity Programme. Following the visits to the Scheme Owner s offices, the Benchmark Leader shall complete the report with the findings. The applicant Scheme Owner should ensure that all resources including expert staff members, documentation records are available to support the visit criteria verification process. The findings of this office visit will be reported the Scheme Owner will have to respond with a corrective action plan. Timelines on when the corrective action plan needs to be received will be agreed with the Scheme Owner will depend on the type of finding Step 6: Public Stakeholder Consultation The spreadsheet with the findings the Benchmark Leader s report will be made available by the GFSI Technical Manager on the GFSI website for stakeholder consultation for a period of four weeks. The Scheme Owner will be given the opportunity to approve the content of the report before it is made available in the public domain. The report will only be put to consultation once agreed by all above parties. Any comments, observations or objections made by stakeholders about the report will be collected by the GFSI Technical Manager shared with the Scheme Owner, who shall address these points. The Benchmark Leader the GFSI Technical Manager will evaluate every response from the Scheme Owner will inform the GFSI Board in the form of a final summary report previously agreed upon with the Scheme Owner Step 7: GFSI Board Final Decision Communication The GFSI Board will come to a decision based on consensus following the recommendation that will be presented by the Benchmark Leader the GFSI Technical Manager. If a vote is necessary, the votes of the majority 10 The GFSI Benchmarking Requirements

11 of a quorum of the GFSI Board shall determine the final decision. Records shall be kept of the numbers of votes for, against abstaining. The GFSI Board decision shall be communicated in writing to the Scheme Owner by the GFSI Executive Director, as soon as practicable after the GFSI Board decision, will be communicated on the GFSI website. The GFSI Technical Manager shall ensure that those stakeholders who submitted comments during the stakeholder consultation receive feedback.in the event of recognition by the GFSI Board, the GFSI Technical Manager shall prepare a news release confirming this decision with the co-operation of the Scheme Owner. The Scheme Owner will be expected to issue a similar news release. The timing of these announcements shall be agreed on by the GFSI Executive Director the Scheme Owner. The GFSI Technical Manager shall publish the confirmation of the Scheme s recognition on the GFSI website (Conformance Statement). In the event that the final decision of the GFSI Board is nonrecognition, the reasons for the Board decision shall be clearly documented the GFSI Technical Manager shall make the Scheme Owner aware of the reasons behind this decision. The Scheme Owner shall have the right of appeal against the GFSI Board decision the appeal shall be undertaken in accordance with the procedures specified in Scheme Owner Agreement Step 8: Annual Assessment Based on GFSI Integrity Programme The Global Food Safety Initiative has the responsibility to create a transparent level playing field for all Scheme Owners undergoing benchmarking against the criteria described in the GFSI Benchmarking Requirements V7. In order to ensure that benchmarked Scheme Owners have implemented all the controls necessary to ensure food safety, GFSI has introduced the Integrity Programme Execution of the Integrity Programme: The execution of the Integrity Programme will be managed by the same independent Benchmark Leader who performed the benchmarking process for V7. The execution will take place under the supervision of the GFSI Technical Manager ensure that the appropriate confidentiality is in place throughout the process Elements Frequency of Execution of Integrity Programme The GFSI Integrity Programme consists of three elements: 1. Rom record review - two times a year 2. Scheme Owner Office Audit - once a year 3. Complaint Investigation - incident driven Content of the Rom Record Review The rom record review is an administrative audit that is based on a sampling exercise. Twice a year, the Benchmark Leader will go on the platform of the Scheme Owner romly select 5 audits performed by CB s. From the selected audits, the Scheme Owner will receive a list with request for objective evidence of files related to these audits. These requests are all related to Part 2 Requirements for the Management of Schemes to the scopes against which the Scheme Owner is benchmarked. For example: Certificate report /or auditor notes Contract with the CB Examination file of the auditor Scope allowance of the auditor Etc. The Benchmark Leader will report back its findings. These findings will be discussed during the office audit Content of the Office Audit The focus of the office audit will be on the execution of the Integrity Programme of the Scheme Owner towards the CB s. Based on two rom selected audits on the day of the office visit, the Benchmark Leader will check the implementation effectiveness of the execution of the Integrity Programme of the Scheme Owner. The check will include: An investigation on the findings of the rom record review (when relevant) All elements of Part 2 Use of the GFSI logo The implementation of the corrective actions plan from previous audit (when relevant) The findings of this office audit will be reported Scheme Owner will have to respond with a corrective action plan. Timelines on when the corrective action plan needs to be received will be agreed with the Scheme Owner, will depend on the type of finding Complaint Investigation In the event of a serious complaint towards a GFSIrecognized Scheme, the GFSI Technical Manager has the right to investigate the complaint. This can be done by a desktop investigation or an office visit. The GFSI Technical Manager is responsible for the investigation of any complaints or suspected non-conformity in relation to the compliance of a GFSI-recognised Scheme with the requirements specified within the GFSI Benchmarking Requirements. The GFSI Benchmarking Requirements 11

12 In the event that a complaint or report is received by the GFSI Technical Manager regarding the non-conformity of a Scheme with the GFSI Benchmarking Requirements, the Technical Manager will promptly acknowledge, in writing, the receipt of the complaint or report to the party concerned. When a complaint is received, the GFSI Technical Manager will initiate investigative procedures to verify the accuracy of the complaint. The Technical Manager shall ensure that the details of the complaint are clearly understood documented, that any claims or comments made by the complainant are properly authenticated appropriately documented. This authentication shall be verified as being accurate correct by independent sources, in addition to the complainant. It is the responsibility of the complainant to provide information that can be appropriately authenticated. It is at the discretion of the GFSI Technical Manager to appoint the Benchmark Leader or an independent assessor at any stage during the investigation process. The GFSI Technical Manager must ensure impartiality preserve confidentiality. If the Benchmark Leader or an assessor is appointed, he or she shall carry out a thorough investigation of the complaint, where possible, provide a resolution for the issues, fully document the complaint process, provide a detailed report to the GFSI Executive Director Sanctioning Activities of the GFSI Integrity Programme may lead to sanctions for the Scheme Owner. In the event that evidence of nonconformity against the requirements specified in the GFSI Benchmarking Requirements is found by a Benchmark Leader during the annual assessment, the GFSI Executive Director shall promptly contact the Scheme Owner concerned. The GFSI Technical Manager shall fully document the process of investigation decision-making. The GFSI Technical Manager shall make a decision after the review of the submitted evidence will either: 1. take no action against the Scheme Owner, or 2. convene a meeting of GFSI Board members to gain agreement on one of three possible outcomes - continued recognition, suspension of recognition, or the withdrawal of recognition. Irrespective of the decision taken by the GFSI Executive Director, the Scheme Owner the GFSI Board members shall be informed in writing of the decision, this will include a full explanation for the actions taken. GFSI SUSPENSION OF RECOGNITION PROCEDURE If, following the review of the evidence gathered submitted by the GFSI Technical Manager consultation with the Scheme Owner, the GFSI Board considers that a period of suspension of recognition shall be imposed, the Scheme Owner shall be informed of this decision, any remediation conditions imposed by the GFSI Board to regain recognition status. The period of suspension of recognition expected outcomes shall be made known to the Scheme Owner. The Scheme Owner shall confirm to the GFSI Board that these remediation conditions can be achieved within the timescales set out by the GFSI Board, when evidence of the results of the corrective action can be expected, continued conformity to the requirements of the GFSI Benchmarking Requirements can be established. If the GFSI Board is not satisfied with the commitment of the Scheme under suspension to take the appropriate corrective action, they shall withdraw recognition. In the event that a period of suspension is imposed, the GFSI website shall clearly specify the details conditions of the suspension GFSI Withdrawal of Recognition Procedure If, following the review of the evidence gathered submitted by the GFSI Executive Director consultation with the Scheme Owner, the GFSI Board considers that a withdrawal of recognition is required, the Scheme Owner shall be informed of this decision. In the event that GFSI recognition is withdrawn, GFSI shall issue a news release the GFSI website shall clearly specify the details conditions of the withdrawal. A Scheme Owner may choose to voluntarily withdraw from GFSI recognition when unforeseen circumstances put the Scheme into contravention of GFSI requirements. In this instance, the Scheme Owner will make a request to withdraw voluntarily, a full dossier of the circumstances at the disposal of the GFSI Executive Director. The GFSI Executive Director will inform the GFSI Board regarding the circumstances convene a meeting to discuss the issue as soon as possible. It is at the discretion of the GFSI Board to grant voluntary withdrawal or to launch the suspension process GFSI Appeals Procedure - GFSI Recognition The Scheme Owner has the right to appeal against any decision made by the GFSI Board, the GFSI Executive Director or any person contracted to the GFSI in relation 12 The GFSI Benchmarking Requirements

13 to the benchmarking process, associated systems procedures. Only the Scheme Owner to which the decision relates to has the right to appeal to the GFSI Board. The Scheme Owner shall submit an appeal to the GFSI Executive Director within 30 days of the matter in dispute occurring. The appeal shall be submitted in writing to the GFSI Executive Director, shall clearly describe the reason provide a full explanation together with substantive evidence to support the thorough investigation of the appeal. When the appeal procedure is initiated, the status of the Scheme shall be amended on the GFSI website to reflect that the Scheme is subject to an appeal. Any appeal shall be heard by a Committee (the Appeals Committee), which is a body specifically assembled by the GFSI Board for the purposes of hearing an individual appeal. The GFSI Board shall ensure that such an Appeals Committee should not include any person or GFSI staff member involved with the decision that is being appealed. The Appeals Committee shall be assembled from members of the GFSI Board shall consist of a minimum of three members of the Board. The GFSI shall ensure that the investigation is conducted in an impartial professional manner, without any actual or perceived conflict of interest. The final outcome of the investigation by the Appeals Committee shall be heard by the GFSI Board, the decision made by the Appeals Committee shall be upheld by the GFSI Board. The decision submitted to the GFSI Board by the Appeals Committee shall be conveyed to the Scheme Owner that has raised the appeal. The decision of the Appeals Committee shall be final the appeal process will then be closed. The GFSI Benchmarking Requirements 13