GFSI BENCHMARKING REQUIREMENTS

GFSI BENCHMARKING REQUIREMENTS GFSI GUIDANCE DOCUMENT VERSION 7.2 PART I THE BENCHMARKING PROCESS www.mygfsi.com

PART I THE BENCHMARKING CONTENTS PROCESS Introduction... 5 1. Application... 5 1.1 Defining the Scope... 6 1.2 Benchmarking... 8 1.3 Re-Benchmarking... 9 1.4 Extensions to Scope of Recognition... 9 1.5 Significant Change... 10 2. The GFSI Benchmarking Methodology... 11 2.1 Introduction... 11 2.2 The Key Procedural Steps... 11 2.3 Sanctioning... 14

PART I THE BENCHMARKING PROCESS Introduction The Global Food Safety Initiative (GFSI) works closely with stakeholders Certification Programme Owners to provide continuous improvement in Food Safety Management Systems ensure confidence in the delivery of safe food to consumers worldwide. We have used this input to develop the latest benchmarking criteria to adopt a new approach towards our benchmarking procedure. The benchmarking process carried out by GFSI is the method by which a food safety Certification Programme Owner is objectively compared to the defined requirements as set out in the latest version of the GFSI Benchmarking Requirements. GFSI seek to increase transparency streamline the benchmarking process, thus enabling GFSI benchmarked Certification Programme Owners to efficiently comply. 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 capability in food safety to create consistent effective global food systems. 1.Application Any Certification Programme Owner that wishes to be recognised must apply via the GFSI website. The Certification Programme Owner will find an Application Form template detailed guidance for the completion of this form on the GFSI website. This form should be completed sent to the GFSI Senior Technical Manager with all required supporting documents. The Certification Programme Owner s scope of application must include GFSI Benchmarking Requirements Part II (Requirements for the Management of Certification Programmes) at least one industry scope (Part III). The GFSI Technical Manager reviews the application. The GFSI Senior Technical Manager reserves the right to reject or refer an application back to the Certification Programme Owner if the quality of the application is poor. 4. Provide a unique international stakeholder platform for collaboration, knowledge exchange networking. 5. Part I of the GFSI Benchmarking Requirements specifies the process for the recognition of food safety certification programmes. The objective of this document is to give stakeholders a clear insight into the benchmark process for the latest version of the GFSI Benchmarking Requirements. Further details may be provided on request during the application process. These detailed steps procedures ensure that the GFSI benchmarking process is carried out in an impartial transparent manner by a technically competent Benchmarking Leader under the supervision of the GFSI Technical Manager. GFSI will 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. An applying Certification Programme Owner will be permitted to lodge multiple benchmarking applications with GFSI, but will only be permitted to submit one re-submission within a 12 month period, if the initial application is deemed unsuccessful. A list with the available Benchmarking Leaders is on the GFSI website. The GFSI Technical Manager will appoint a Benchmarking Leader for the Certification Programme assessment record the selection in the application file. The Technical Manager may assign additional Benchmarking Leaders to ensure that the assessment takes place within the desired timeframe. This will be done with the written consent of the Certification Programme Owner. Once the GFSI Senior Technical Manager accepts the Certification Programme s application, the The GFSI Benchmarking Requirements Version 7.1 3

benchmarking process will only progress once a contract has been signed between the Certification Programme Owner GFSI. Once the signed contract is received, the GFSI Senior Technical manager transfers all appropriate Excel files for self-assessment to the Certification Programme Owner presents a work plan. This work plan of activities key dates will be agreed upon by the GFSI Technical Manager, the Benchmarking Leader the Certification Programme Owner based on the number of scopes the volume of documentation submitted. Confirmation of acceptance of the work plan shall be published on the GFSI website. 1.Defining the scope Any applying Certification Programme Owner shall have a defined scope in relation to food safety or services directly associated with food safety, which shall be subject to certification by the accredited Certification Bodies. GFSI has set up several requirements for the management of the Certification Programmes. These requirements are described in Part II apply to all Certification Programme Owners wishing to be recognised against the latest version of the GFSI Benchmarking Requirements. GFSI has defined scopes in relation to products or services a series of food safety requirements specific to each food supply chain sector sub-sector. This is all documented in Part III of the GFSI Benchmarking Requirements. When selecting the scope of their application, the Certification Programme Owner shall ensure that those requirements related to their selected scope of application are clearly included in their normative documents as these shall be assessed against them. A Certification Programme 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. GFSI SCOPE OF RECOGNITION (Benchmarking Category Code) AI AII BI BII C BENCHMARKING CATEGORY NAME 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 EXAMPLES OF PRODUCTS / SERVICES AND METHOD OF PRODUCTION 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

D E I E II E III E IV FI G H I Pre-Process Hling of Plant Products, Nuts Grains Processing of Perishable Animal Products Processing of Perishable Plant Products Processing of Perishable Animal Plant Products (mixed products) Processing of Ambient Stable Products Production of Feed Catering Retail / Wholesale Provision of Food Safety Services 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, repacking, staging, storing, loading / or any other hling activity that does not significantly transform the product from its original harvested form 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 (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 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 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 The GFSI Benchmarking Requirements 5

J K L M Provision of Storage Distribution Services for Food Feed Manufacture of Food Processing Equipment Production of (Bio) Chemicals (Additives, Vitamins, Minerals, Bio-cultures, Flavourings, Enzymes Processing Aids) Production of Food Packaging Storage facilities for food feed Distribution vehicles for food feed Production of food feed processing equipment Production of food feed additives, vitamins, minerals, biocultures, 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 N Food Broker / Agent The supply of finished food feed products BENCHMARKING OPTIONS 1.2.Benchmarking The requirements specified within this clause shall apply to Certification Programmes, 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 their recognition withdrawn. GFSI will require the Applicant Certification Programme Owner to submit an Application Form with supporting evidence proving that: the Certification Programme Owner is a legal entity, the Certification Programme 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 17065 or ISO / IEC 17021 for the scope of their Certification Programme. The Accreditation Bodies granting accreditation to the scope of the Certification Programme 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 Certification Programme with an Accreditation Body, the Certification Programme Owner 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 12 month period prior to 6 The GFSI Benchmarking Requirements

the date of the application. These certificates shall be issued against the version of Certification Programme concerned by the application, the Certification Programme has been operational for a minimum period of 12 months prior to the date of application. During this period, certificates have been issued to a number of organisations. A Certification Programme is deemed to become operational on the date on which the first accredited certificate is issued by a Certification Body, the Certification Programme Owner 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 for recognition by GFSI), the Certification Programme Owner shall not have any practices that are deemed as restricting access to markets, the Certification Programme Owner has undertaken a self-assessment to validate that the Certification Programme management requirements are in compliance with the GFSI Benchmarking Requirements. 1.3.Re-Benchmarking The requirements specified within this section of the GFSI Benchmarking Requirements shall apply to: Certification Programmes that have successfully undergone benchmarking against a previous version of the GFSI Benchmarking Requirements. All existing GFSI-recognised Certification Programmes have to apply for re-assessment for all their scopes of recognition against the latest version of the GFSI Benchmarking Requirements within nine months of their date of publication. The GFSI Board has the authority to extend this period under special circumstances. Certification Programme Owners who have been subject to suspension by GFSI or have temporarily or voluntarily agreed on withdrawal with the GFSI Executive Director for a period of less than one year. GFSI will require the applying Certification Programme Owner to submit an Application Form 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 ISO 17065 or ISO / IEC 17021 for the scope(s) of their Certification Programme. The Accreditation Bodies granting accreditation to the scope(s) of the Certification Programme 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 Certification Programme Owner is applying for recognition, the Certification Programme Owner has in place 10 accredited certificates (for the relevant scope of the application) issued by Certification Bodies, during a 12 month period prior to the date of the suspension or withdrawal, the Certification Programme Owner shall not be undergoing a significant change to its stard, management, governance or operational procedures at the time of application for recognition by GFSI will have completed all activities that remedy or re-establish the Certification Programme after the suspension or withdrawal. 1.4. Extensions to Scope of Recognition The requirements specified within this clause shall apply to Certification Programmes already benchmarked against the latest version of the GFSI Benchmarking Requirements for different GFSI scope(s) seeking to apply for a new GFSI scope of recognition. GFSI will require the applying Certification Programme Owner to submit an application for recognition to GFSI together with supporting evidence proving that: there is an agreement with one or more Accreditation The GFSI Benchmarking Requirements 7

Bodies for Certification Bodies to operate to ISO / IEC 17065 or ISO / IEC 17021 for initial accreditation programme or the scope extension of their Certification Programme. The Accreditation Bodies granting accreditation to the scope of the Certification Programme 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 Certification Programme Owner is applying for recognition, the Certification Programme Owner 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, the host Certification Programme has been operational for a period of 12 months prior to the date of application. A Certification Programme is deemed to become operational on the date on which the first accredited certificate is issued by an Accredited Certification Body. in the year prior to the publication of a new version of the GFSI Benchmarking Requirements, no new application will be accepted. 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 Certification Programme Owners in the last six months before the publication of a new version of the GFSI Benchmarking Requirements. This does not apply to sub-versions of the GFSI Benchmarking Requirements. recognised by GFSI on the latest benchmarking criteria 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 Certification Programme s recognition by GFSI. Such Certification Programme Owners shall inform the GFSI Executive Director in writing about the significant change confirm their application for continued recognition. The type of action required to maintain recognition will be decided by the GFSI Senior Technical Manager GFSI Executive Director. It will depend on the impact of the significant change. In any case, GFSI will require the applying Certification Programme 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 ISO 17065 or ISO / IEC 17021 for the scope of their Certification Programme. The Accreditation Bodies granting accreditation to the scope of the Certification Programme 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 Certification Programme with an Accreditation Body, the Certification Programme Owner has in place ten accredited certificates (for each relevant scope of the application) issued by an accredited Certification Body, during a 12 month period prior to the date of the application. 1.5.Significant Change A Certification Programme Owner seeking continued recognition prior to a Certification Programme change is defined as a Certification Programme Owner who is 8 The GFSI Benchmarking Requirements

2.THE GFSI BENCHMARKING METHODOLOGY 2.1.Introduction The benchmarking process is performed by a Benchmarking Leader, who has been selected approved by the GFSI Board in order to ascertain whether a Certification Programme can demonstrate conformity with the requirements of the GFSI Benchmarking Requirements. The Benchmarking Leader reports to the GFSI Senior Technical Manager who will supervise all the benchmarking activities communication with the Certification Programme Owners. All Benchmarking Leaders will undergo the same initial training annual calibration activities to maintain alignment of the evaluation approaches adopted by the various Benchmarking Leaders. Under supervision of the GFSI Technical Manager, the Benchmarking Leader will, execute the benchmarking process as described in this document. GFSI will select the Benchmarking Leader for the Certification Programme; upon request from the Certification Programme Owner, additional impartiality or confidentiality agreements may be signed between GFSI the Benchmarking Leader. A Benchmarking Leader may perform the benchmarking activities for a maximum period of three years per Certification Programme. The GFSI Executive Director may reassign the Benchmarking 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. The Certification Programme Owner fills out the selfassessment. 2. Preliminary desk review by the Benchmarking Leader. 3. Call to go through findings. 4. Certification Programme 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. The GFSI Benchmarking Requirements 9

2.2.1 Step 1: Certification Programme Owner Fills out the Self-Assessment The objective of the self-assessment is to allow the Certification Programme Owner to demonstrate that the Certification Programme covers all the requirements listed in the latest version of the GFSI Benchmarking Requirements, including Part II Requirements for the Management of Certification Programmes as well as the appropriate sections of GFSI Benchmarking Requirements Part III Certification Programme Scope Key Elements. GFSI will provide an Excel sheet with the relevant scopes that Certification Programme Owners may use to rank themselves against each criterion evaluate: is the GFSI criteria covered in their Certification Programme where exactly. Clear precise justification is expected in the self-assessment form, including the exact reference to the document, page clause covering each criterion. 2.2.2 Step 2: Preliminary Desk Review of the Self- Assessment After the completed self-assessment is received, the Benchmarking Leader, under the supervision of the GFSI Technical Manager, will perform a preliminary desk review. For each GFSI criterion, the Benchmarking Leader will review the evidence provided by the Certification Programme Owner to ensure it satisfies the benchmarking requirement. The Benchmarking 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 Certification Programme Owner. These comments will be supported by comprehensive explanations. All these findings will be sent back to the Certification Programme Owner in writing form the basis of the conference call in Step 3. 2.2.3 Step 3: Call to Go Through Findings In a conference call, the Benchmarking Leader the GFSI Technical Manager will exchange their detailed findings with the Certification Programme Owner. This will give the Certification Programme Owner an opportunity to further clarify their evidence. It will also give greater insight into what additional information amendment to the self-assessment form are required. During the conference call, the time frame for the execution of actions will be agreed. 2.2.4 Step 4: Certification Programme Owner Updates (where applicable) Resends Final Self- Assessment Within the agreed timeframe, the Certification Programme Owner will send an updated self-assessment form with any necessary additional information. In order to limit a possible back--forth exchange of information, the Certification Programme Owner will be required to provide the requested information / or adjustments in the final self-assessment. The final version of the self-assessment must be complete formally approved by the Director of the Certification Programme Owner before the office visit. 2.2.5 Step 5: Office Visit The Benchmarking Leader the GFSI Technical Manager will organise a visit to the nominated offices of the Certification Programme Owner. This visit can only occur once the self-assessment is finalised signed. The purpose of the visit is to check the implementation of the Certification Programme Owner s Integrity Programme through a sample record review. Following the visits to the Certification Programme Owner s offices, the Benchmarking Leader shall complete the report with the findings. The Applicant Certification Programme Owner should ensure that all resources including expert staff members, documentation records are available to support the visit criteria verification process. The Benchmarking Leader will sum up all findings on a report that will be signed between the Certification Programme Owner, the Benchmarking Leader the GFSI Technical Manager before leaving the Certification Programme Owner s premises. The findings of this office visit will be reported the Certification Programme 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 Certification Programme Owner will depend on the type of finding. 2.2.6 Step 6: Public Stakeholder Consultation The spreadsheet with the findings the Benchmarking 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 Certification Programme 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 10 The GFSI Benchmarking Requirements

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 Certification Programme Owner, who shall address these points. The Benchmarking Leader the GFSI Technical Manager will evaluate every response from the Certification Programme Owner will inform the GFSI Board in the form of a final summary report previously agreed upon with the Certification Programme Owner. 2.2.7 Step 7: GFSI Board Final Decision Communication The GFSI Board will come to a decision based on consensus following the recommendation presented by the Benchmarking Leader the GFSI Technical Manager. If a vote is necessary, the votes of the majority 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 will be communicated in writing to the Certification Programme Owner by the GFSI Executive Director, as soon as is 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 cooperation of the Certification Programme Owner. The Certification Programme 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 Certification Programme Owner. The GFSI Technical Manager shall publish the confirmation of the Certification Programme s recognition on the GFSI website (Conformance Statement). In the event that the final decision of the GFSI Board is non- recognition, the reasons for the Board decision shall be clearly documented the GFSI Technical Manager shall make the Certification Programme Owner aware of the reasons behind this decision. The Certification Programme Owner shall have the right to appeal against the GFSI Board decision the appeal shall be undertaken in accordance with the procedures specified in the Certification Programme Owner Agreement. 2.2.8 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 Certification Programme Owners undergoing benchmarking against the criteria described in the current version of the GFSI Benchmarking Requirements. In order to ensure that benchmarked Certification Programme Owners have implemented all the controls necessary to ensure food safety, GFSI has introduced the Integrity Programme. 2.2.8.1 Execution of the Integrity Programme The execution of the Integrity Programme will be managed by the same independent Benchmarking Leader who performed the benchmarking process for the current version of the GFSI Benchmarking Requirements. This will be implemented under the supervision of the GFSI Technical Manager in order to ensure that the appropriate confidentiality is in place throughout the process. 2.2.8.2 Elements Frequency of Execution of the Integrity Programme The GFSI Integrity Programme consists of three elements: 1. Rom record review - twice a year. 2. Certification Programme Owner office audit - once a year. 3. Complaint investigation - incident driven. 2.2.8.2.1 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 Benchmarking Leader will remotely select five rom audits, performed by various Certification Bodies. From the selected audits the Certification Programme Owner will receive a list with requests for objective evidence of files related to these audits. These requests are all related to Part II Requirements for the Management of Certification Programmes to the scope(s) against which the Certification Programme Owner is benchmarked. For example: Certificate report / or auditor notes. Contract with the Certification Body. Examination file of the auditor. Scope allowance of the auditor. The GFSI Benchmarking Requirements 11

The Benchmarking Leader will report back their findings. These findings will be discussed during the office audit. 2.2.8.2.2 Content of the Office Audit The focus of the office audit will be on the execution of the Integrity Programme of the Certification Programme Owner towards the Certification Bodies. Based on two rom selected audits on the day of the office visit, the Benchmarking Leader will check the implementation effectiveness of the execution of the Integrity Programme of the Certification Programme Owner. The check will include: An investigation on the findings of the rom record review (when relevant). All elements of Part II. Use of the GFSI logo. The implementation of the corrective actions plans from previous assessments (when relevant). The findings of this office audit will be reported the Certification Programme 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 Certification Programme Owner, will depend on the type of finding. 2.2.8.2.3 Complaint Investigation The GFSI Technical Manager has to investigate any serious complaint towards a GFSI-recognised Certification Programme. 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 Certification Programme with the requirements specified within the GFSI Benchmarking Requirements. In the event that a complaint or report is received by the GFSI Technical Manager regarding the non-conformity of a Certification Programme 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 appropriately authenticates the complaint can be confirmed as genuine. It is at the discretion of the GFSI Technical Manager to appoint the Benchmarking Leader or an independent assessor at any stage during the investigation process. The GFSI Technical Manager must ensure impartiality preserve confidentiality. If the Benchmarking 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. 2.3.Sanctioning Activities of the GFSI Integrity Programme may lead to sanctions for the Certification Programme Owner. If evidence of nonconformity against the requirements specified in the GFSI Benchmarking Requirements is found by a Benchmarking Leader during the annual assessment, the GFSI Executive Director shall promptly contact the Certification Programme Owner concerned. The GFSI Technical Manager will fully document the process of investigation. Based on their findings, the GFSI Technical Manager will make a make a recommendation to either: 1. take no action against the Certification Programme Owner, or 2. maintain recognition, or 3. suspend recognition, or 4. withdraw recognition. This recommendation is passed to the GFSI Executive Director the GFSI Board for final decision. The GFSI Senior Technical Manager informs the Certification Programme Owner of the final decision, including a full explanation for the actions taken. 2.3.1 GFSI Suspension of Recognition Procedure If the GFSI Board considers that a period of suspension of recognition shall be imposed, the Certification Programme Owner shall be informed of this decision, the period of the suspension any remediation conditions imposed by the GFSI Board to regain recognition status. 12 The GFSI Benchmarking Requirements

The Certification Programme 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 will be expected, continued conformity to the GFSI Benchmarking Requirements can be established. If the GFSI Board is not satisfied with the commitment of the Certification Programme 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. 2.3.2 GFSI Withdrawal of Recognition Procedure If the GFSI Board considers that a withdrawal of recognition is required, the Certification Programme 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 Certification Programme Owner may choose to voluntarily withdraw from GFSI recognition when unforeseen circumstances put the Certification Programme into contravention of GFSI requirements. In this instance, the Certification Programme Owner will make a request to withdraw voluntarily, make a full dossier of the circumstances available to the GFSI Executive Director. be submitted in writing to the GFSI Executive Director, shall clearly describe the reason provide a full explanation together with substantive evidence to support a thorough investigation of the appeal. When the appeal procedure is initiated, the status of the Certification Programme shall be amended on the GFSI website to reflect that the Certification Programme is subject to an appeal. Any appeal shall be heard by a Appeals Committee, which is a body specifically assembled by the GFSI Board for the purposes of hearing an individual appeal. The Appeals Committee shall be assembled from members of the GFSI Board shall consist of a minimum of three members of the Board. No members of the appeals committee can have been involved with the decision that is being appealed. 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 Certification Programme Owner that has raised the appeal. The decision of the Appeals Committee is final. Once the final decision is given, the appeal process will be closed. 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. 2.3.3 GFSI Appeals Procedure - GFSI Recognition The Certification Programme Owner has the right to appeal against any decision made by the GFSI Board, the GFSI Executive Director or any person contracted to GFSI in relation to the benchmarking process, associated systems procedures. Only the Certification Programme Owner to which the decision relates has the right to appeal to the GFSI Board. The Certification Programme Owner shall submit an appeal to the GFSI Executive Director within 30 days of the matter in dispute occurring. The appeal shall The GFSI Benchmarking Requirements 13