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Welcome to the RA SAS Chain of Custody course

Welcome to the RA SAS Chain of Custody course. Standard module. Date | Location | Details. Key concepts. The importance of CoC standard. Use of trademarks. Traceability data. Ensures product integrity. Principle 1 CoC Management system. What is CoC Management System?

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Welcome to the RA SAS Chain of Custody course

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  1. Welcome to the RA SAS Chain of Custody course Standard module Date | Location | Details

  2. Key concepts The importance of CoC standard Use of trademarks Traceability data Ensures product integrity

  3. Principle 1 CoC Management system • What is CoC Management System? • A set of documents, procedures, processes and policies that allow tracking of certified products • CoC Management System of PO includes: • Planning, procedures and monitoring of responsible personnel and documentation for certified products • Vary in accordance with size and complexity of organisation

  4. Principle 1 CoC management system Criterion 1.1 1.1 The Participating Operator shall document the control procedures to ensure that its Chain of Custody Management System maintains the integrity of the certified products. The procedures shall include: a. A flowchart of the products originating from certified farms with the identification of all processing steps and points where the products from non-certified sources may enter or where certified products may leave the system; b. Procedures and records for controlling the reception, processing, mixing, storing, packaging, delivery, transport and resale of products coming from certified farms; and c. Responsibilities of the personnel involved with the Chain of Custody Management System.

  5. Principle 1 CoC management system Documentation of the procedures (i.e., work instructions) and the formats used to record and control the steps. Documentation that indicates the personnel responsible (i.e., by name or position) for each stage of the CoC Management System. Flow diagram with the processing steps. The critical points where non-certified product could enter should be clearly identified Evidence criterion 1.1

  6. Principle 1 CoC management system Criterion 1.2 The personnel involved with the handling and processing of certified products shall demonstrate that they have been trained and that they have the knowledge and skills to effectively implement the Participating Operator’s Chain of Custody Management System.

  7. Principle 1 CoC management system Interviews with the personnel in charge and observation of the way they carry out their tasks, to verify that they have the required knowledge and skills Training material used Records of participation in the training activities Evidence criterion 1.2

  8. Principle 1 CoC management system Criterion 1.3 The Participating Operator shall not be in material violation of any applicable laws relating to the handling, reception, processing, mixing, storing, packaging, delivery, transport and resale of certified products, including without limitation laws relating to the environment, occupational health and safety, and labour. The Participating Operator shall demonstrate the foregoing by providing a truthful representation as to the foregoing.

  9. Principle 1 CoC management system However… the auditor can issue a Major or a minor if they observe some serious non-compliance during the CoC audit process. Conformance confirmed Declaration signed by the PO that includes what is spelled out in Criterion 1.3. Evidence criterion 1.3

  10. Principle 1 CoC management system Criterion 1.4 The Participating Operator shall implement internal inspection procedures to ensure conformance with this standard. These procedures shall include: Documented internal inspections once per year, to evaluate conformance with the Rainforest Alliance Chain of Custody system; and A corrective action plan to eliminate the nonconformities.

  11. Principle 1 CoC management system Records of the internal inspections OR Corrective action plan Evidence of the implementation of the corrective action plan (if nonconformities are detected) Interview with the PO’s internal auditors Evidence criterion 1.4

  12. Principle 1 CoC management system Criterion 1.5 The Participating Operator shall enter into a binding agreement with any contractor to which processing, storing, packaging and/or labeling is outsourced.

  13. Principle 1 CoC management system The PO can prepare a template agreement that includes a disclaimer clause which states that the mere use of the agreement does not ensure compliance with the standard Interviews with the personnel in charge of contracting third-party services for the purpose of assuring that the agreement is known to them Agreement(s) signed with sub-contractors that handle certified material, including storage facilities (PROOF) Evidence criterion 1.5

  14. Principle 1 CoC management system Criterion 1.6 All documents generated to support the Chain of Custody Management System shall be kept for a period of at least three (3) years. All relevant records shall be available to Participating Operator staff and to external auditors

  15. Principle 1 CoC management system Accessibility to records for the auditors during the evaluation. When the law requires a longer period of time, the stipulations of the law take precedence. Policy about keeping all the records for at least three years. Interviews with personnel that show they are knowledgeable about this requirement. After 3 years of certification, the earlier records can be requested as evidence. Evidence criterion 1.6

  16. Principle 1 CoC management system Criterion 1.7 The Participating Operator shall document and implement a procedure for receiving and resolving complaints regarding its conformance with this standard

  17. Principle 1 CoC management system Interviews with the personnel responsible for addressing complaints. If the PO has had complaints, demonstrate how the procedure was followed. Documentation of the procedure for receiving and resolving complaints. Evidence criterion 1.7

  18. Principle 2 Traceability • Purpose of traceability: • Tracks the products from Rainforest Alliance Certified farms along the entire supply chain • Protects the credibility of the Rainforest Alliance Certified™ brand

  19. Principle 2 Traceability • Auditors focus on: • Traceability within a company • Volumes entering and leaving as well as conversion factors • Verifying whether reverse tracking can be done

  20. Principle 1 CoC management system Criterion 2.1 The Participating Operator shall demonstrate that the certified products handled in his facilities are covered by internal procedures to preserve the integrity of the product in accordance with the Participating Operator’s claim

  21. Principle 1 CoC management system • Observation of: • Movement of physical product through company • Automated control and processing systems Procedures and/or work instructions. Interviews with personnel involved in segregation and mixing. Evidence criterion 2.1

  22. Principle 2 Traceability Criterion 2.2 The Participating Operator shall implement a system for the physical or visual identification of the certified products.

  23. Principle 2 Traceability Observe that certified products can be distinguished from conventional products Documented procedures Interviews with the personnel in charge of identification of material Evidence criterion 2.2

  24. Principle 2 Traceability 1 Witness segregation techniques 2 Verify that PO has system of codes, labels, signs What is the procedure when handling certified and non-certified products 3 4 Is there any uncontrolled mixing? Criterion 2.2 Auditing best practices

  25. Principle 2 Traceability Criterion 2.3 The Participating Operator shall demonstrate that Transaction Certificates are requested and issued when required by the Rainforest Alliance. Relevant for banana, cocoa, coconut, coffee, orange juice, palm oil, tea

  26. Principle 2 Traceability Criterion 2.3 Traceability Guidelines Policy & Guidelines for Products Traded as Rainforest Alliance Certified™ All participating companies downstream from the farm, should issue TCs regularly for their sales of RAC products. At minimum, all sales conducted during a calendar quarter must be registered in Marketplace 2.0 within 30 days of the end of that quarter.

  27. Principle 2 Traceability Correspondence with CTT Procedures and demonstration of Marketplace use Interviews with the personnel in charge of requesting Transactions Certificates Evidence criterion 2.3

  28. Principle 2 Traceability Criterion 2.2 Auditing best practices 1 When no TC available, but other docs show RA certification – minor NC 2 Not auditor’s responsibility to say when TC are required 3 For non-TC products, check invoices, contracts or delivery docs 4 Check volumes and potential differences compared to TC 5 Volumes going in always BIGGER than volumes going out

  29. Principle 2 Traceability Criterion 2.4 The Participating Operator shall develop and maintain records to document quantities of product from certified farms for the following: a) purchased as inputs; b) inputs and outputs in stock; and c) outputs sold

  30. Principle 2 Traceability Interviews with responsible personnel, ask them to demonstrate the system Spend considerable time and ask for a demo from point of purchase all the way to sales Material accounting system: types of input, outgoing products, both certified and non-certified. Varies from ERP to excel Evidence criterion 2.4

  31. Principle 2 Traceability Criterion 2.4 Auditing best practices 1 Volumes certified out always smaller than or equal to volumes certified in 2 Conversion factors: traceability guidelines for standard factors 3 • Pay attention to checking: • Inventories of product • Receipts and invoices • Conversion rates, formulas and recipes 4 Receipt personnel very good information resources

  32. Principle 2 Traceability Criterion 2.5 The Participating Operator shall demonstrate and update accordingly the methodology for the calculation of conversion factors, including acceptable levels of contamination, for each product.

  33. Principle 2 Traceability Volume records Up-to-date, documented procedures how to calculate conversion factors and contamination Interviews with the personnel in charge, ask them to describe the conversion factor process Evidence criterion 2.5

  34. Principle 2 Traceability Criterion 2.5 Auditing best practices Check Transaction Certificates: volume sold is correct and represents conversion rate 1 PO submits % of contamination in each certified product 2 3 Auditor identifies whether contamination level is reasonable 4 Evaluate whether PO’s procedures adequately address contamination

  35. Principle 2 Traceability Criterion 2.6 The Participating Operator shall check supplier documentation to ensure it includes one of the following: A copy of a Transaction Certificate(s) from the Rainforest Alliance or associated Transaction Certificate number(s); or b. Supporting documentation (supply contracts, invoices, delivery documents, etc.) that indicates the Participating Operator’s claim for the product(s) purchased

  36. Principle 2 Traceability Documented procedures for checking supplier documentation Interviews with the personnel in charge and observation how they implement procedure Sample of supplier’s records Evidence criterion 2.6

  37. Principle 2 Traceability Criterion 2.7 The Participating Operator shall provide claim information to its customers, including: A copy of a Transaction Certificate(s) from the Rainforest Alliance or associated Transaction Certificate number(s); or b. Supporting documentation (supply contracts, invoices, delivery documents, etc.) to indicate the Participating Operator’s claim for the product(s) sold; and c. When an unlabelled product is sold that contains less than 100% Rainforest Alliance Certified content, the Participating Operator shall indicate the certified percentage.

  38. Principle 2 Traceability Documented procedures for creating invoices or other sales documentation and including relevant RA information Interviews with the personnel in charge and observation how they implement procedure Sample of PO’s sales records, including percentage when product is unlabelled and contains less than 100% RA content (2.7.c) Evidence criterion 2.7

  39. Principle 3 Trademarks No Participating Operator can use the Rainforest Alliance trademarks without the prior written approval of Rainforest Alliance. • Rainforest Alliance Rainforest Alliance registered trademarks

  40. Principle 3 Trademarks What should the auditor know? 1 Is the PO using any RA trademarks? 2 Has PO asked for approval for those uses? 3 Are they using the trademarks right in combination with the content of the product sold? All the requirements for using the Rainforest Alliance logo and seal are available in “Requirements and Guidelines for the use of the Rainforest Alliance Trademarks”

  41. Principle 1 CoC management system Criterion 3.1 The Participating Operator shall sign a License Agreement directly with the Rainforest Alliance prior to using any Rainforest Alliance trademark

  42. Principle 3 Trademarks Copy of the valid License Agreement (signed by both parties and in force) Audit prep report states presence of valid license agreement Evidence criterion 3.1

  43. Principle 3 Trademarks Criterion 3.2 The Participating Operator shall obtain and maintain records of prior written approvals granted by the Rainforest Alliance for the use of any Rainforest Alliance trademark on communication and marketing materials (on or off product) before such materials are issued, published or distributed

  44. Principle 3 Trademarks Demonstration of Marketplace, all approvals in there regarding “Rainforest Alliance”, “Rainforest Alliance Certified” and the RAC Seal. Sample of on-product and off-product logo usage – match with approvals in MP Interviews with the personnel in charge and observation of the way they carry out their tasks Evidence criterion 3.2

  45. Principle 3 Trademarks Criterion 3.3 A Participating Operator shall present evidence that any product bearing the Rainforest Alliance Certified seal meets the minimum percentage of certified content, or the claim made on the product package, in accordance with Annex I of this standard, excerpted from the Requirements and Guidelines for Use of the Rainforest Alliance Trademarks.

  46. Principle 3 Trademarks Multi-ingredient products: Auditor checks Option A, B or C is relevant Production recipes, observation of processing and automated control systems, records for volume accounting systems Products with RAC Seal meet Annex 1 of Standard Evidence criterion 3.3

  47. Principle 3 Trademarks Simple steps of Principle 3 Evaluation YES Criterion 3.1 Does PO have a Rainforest Alliance License Agreement? Complies with 3.1 NO Minor non-conformance • Criterion 3.2 • Are there Rainforest Alliance approval records? YES Complies with 3.2 NO Minor non-conformance

  48. Principle 3 Trademarks Simple steps of Principle 3 Evaluation Criterion 3.3 Does the product comply with the minimum % and package declaration? YES Complies with 3.1 NO Major or minor non-conformance Criterion 3.3 could be major because it affects the product integrity

  49. Principle 3 Trademarks Percentage of certified ingredient determines use of seal Percentage of certified ingredient in final product formula determines type of seal that can be used. For products with several ingredients, percentage applies to main ingredient.

  50. Principle 3 Trademarks Scope of the auditor’s responsibilities in evaluating the use of registered trademarks auditor

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