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CONFIDENTIAL MATERIAL

(For authorised use only)

IFFO RS CoC V2 (DRAFT1)


Global Standard for Responsible Supply
Company Details
Site-Code :

Company Name :

Site Name :

Address :

Country : Postcode :

Telephone : Fax :

Company Email :
Representative Name :

Site Email :
Representative Name :
Audit/Auditor Details
Auditor Names : GMP+/FEMAS(or
equivalent) Cert No and
Expiry Date:
Audit Date : Previous Audit Date :

Key Personnel

Name/Job Title Present at Audit (x)


Opening Site Procedure Closing Meeting
Meeting Inspection Review

Audit Duration Details

On-site audit duration man hours

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Summary

Company / Site Profile

This report shall not be reproduced in part without the permission of IFFO RS Ltd.
List of Non-Conformities
No. Status Clause Detail of Non-Conformity Corrective
(Critical, No. Action
Major or Timescale
Minor)

This report shall not be reproduced in part without the permission of IFFO RS Ltd.
Clause No & Requirement Conforms Details

Y, N or NA

SECTION 1 – General Principles of Traceability


1.1 The applicant shall have a documented Same clause as “must “ changed to “shall”
policy that states that they are committed in V1.
to achieving and adhering to the Bullet points added
requirements of the IFFO RS Chain of Modified clause.
Custody Standard signed by the person Inclusion of
with overall responsibility for the site. extra
requirements
1.1.1 The applicant shall communicate the New sub- clause
documented policy outlined in clause 1.1
to all staff.

1.2 The applicant shall have a documented New clause The company must document its procedure for supplier approval and monitoring.
supplier approval and monitoring system This needs to include the methods of approval, frequency of monitoring,
to ensure that incoming raw materials responsibilities and how the process will be managed.
intended to be identified as certified are
In order to preserve the origin of the product as IFFO RS, only IFFO RS or IFFO RS
sourced from a certified supplier that holds CoC certified/compliant sites shall be the approved suppliers.
valid IFFO RS or IFFO RS CoC certification.
The approval list must be up to date and the site should therefore consider
reviewing the assessment whenever there is a significant change (e.g. new
suppliers, new countries of origin or new materials).

Note: The list of certified sites can be found in the IFFO RS website

1.3 Where certified products are New clause Information to enable the approval of the producer, manufacturer, packer or
purchased from agents or brokers, the consolidator, as in clause 1.2, shall be obtained from the agent/broker or directly
applicant shall know the identity of the last from the supplier, unless the agent/broker is themselves certificated to the IFFO RS
CoC Standard.
Producer, manufacturer or packer, or for
bulk certified material the consolidation
place of the material.

1.4 A record of all certified raw material Was clause 3.8 “IFFO Responsible Supply certified fishmeal and fish oil inputs received must”
inputs received shall be maintained, changed to “certified raw material receipt received shall”
in V1
showing the name of the supplier, their
unique certificate number, evidence of Modified “those inputs” changed to “the certified raw material”
certificate validity, their site address, and wording
sufficient other details to allow the tracing
of the certified raw material back to the
supplier and the certified factory.
1.5 Certified products that wish to make a Was clause 3.3 “fishmeal and fish oil must” changed to “product shall”
claim shall be labelled or otherwise be in V1 and
identified in a manner that ensures “during processing, packaging, storage, handling and delivery.” changed to “from
traceability is maintained from receipt, overlapped w/ receipt, during intake, rework, work in progress, packaging, storage, dispatch,
handling and delivery to immediate customer.”
during intake, rework, work in progress, 1.5 in V1
packaging, storage, dispatch, handling and Modified
delivery to immediate customer.
wording. More
explicit in the
material
processing side
to consider 3.3
and 1.5 in this
clause

This report shall not be reproduced in part without the permission of IFFO RS Ltd.
1.6 Segregation of Certified product from Was clause 2.2 First sentence completely reworded from
non-certified product shall be maintained “Certified fishmeal and fish oil inputs must be kept separate from non‐
in V1 certified fishmeal and fish oil inputs throughout processing, distribution and market
from receipt, during intake, rework, work
in progress packaging, storage, dispatch, Modified ing if they are to carry the official certified label.”
handling and delivery to immediate wording
customer. This may be achieved by:
• Physical separation
• Temporal separation.
1.7 The applicant shall have a documented Was clause 1.7 “must “ changed to “shall”
system in place to ensure that certified in V1
product is not mixed with non-certified “noncertified fishmeal and fish oil products” changed to “non-certified product”
product during third party storage and Modified
“and in third party storage, if applicable.” removed from last sentence
transportation to and from the site. wording
1.8 Procedures shall be established by all Was clause 2.5
Applicants in the value chain to deal with in V1 and
any non-conformity in the traceability
system. overlapped w/
3.11 in V1
1.8.1 Corrective actions in response to Was clause 3.12
non-conformances shall be accurately in V1
documented; identifying authorised
responsible personnel and with specified
time limits to complete the plan.
1.8.2 The Applicant shall operate a Was clause 2.6
documented product recall system that will in V1.
be activated if non-conforming product is
released into the supply chain. The
relevant certification body must be notified
in the event of a certified product being
recalled.

SECTION 2 – Traceability Verification


2.1 The company shall test the traceability Was clause 3.1 First sentence completely reworded from “The Applicant must test the efficacy of
system across the range of certified their batch control and traceability system through a thorough documented interna
in V1 l audit conducted no less than once per year. ”
products or batch of certified products
produced to ensure traceability can be Modified
Bullet points added
determined from raw material supplier to wording,
finished product and immediate customer inclusion of
and vice versa. This shall:
details for
• Be carried out every 12 months;
• Include a traceability challenge internal audit.
(backwards and forwards); May overlap
• Be documented and the results with clause 2.4
shall be retained for inspection for at least
3 years. herein.

2.2 Documentation shall be retained for a Was clause 3.2 “RS Factory” changed to “IFFO RS supplier”
period of at least 3 years or the shelf life of in V1
the final product that verifies the identity
of the raw materials and products as Modified
coming from a Certified IFFO RS supplier. wording
Traceability records shall be accurate,
legible and unadulterated.
2.3 Product shall not be identified as Was clause 2.3 Completely reworded from “Where certified and non-certified fishmeal and fish oil
certified if certified and non-certified inputs are mixed they are not eligible for carrying the official Certified label as comi
in V1 ng from an Certified RS Factory under this programme.”
product is mixed.
Modified
wording

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SECTION 3 – Subcontractors
3.1 Where the applicant utilises the New clause
services of a subcontractor (carrying out
contract processing, packing or labelling
activities), the subcontractor shall be
audited by the certifier and be compliant
to the IFFO RS Chain of Custody Standard.

3.2 Where the applicant utilises the New clause


services of a subcontractor for storage and
distribution activities, the subcontractor
shall be able to be assessed remotely by
the auditor. The subcontracted party shall
be audited and be compliant to the IFFO RS
Chain of Custody Standard, If required as
necessary by the certifier

3.2 The applicant shall maintain an up-to- New clause


date record of the names and addresses of
all approved subcontractors handling
certified products.

3.3 If subcontracted storage facilities are New clause


used, the applicant shall have the ability to
request certified product records from
subcontractor storage facilities and to
allow certifiers access to certified products
at any point in time
3.4 The applicant shall have an agreement New clause
with all subcontractors that handles
certified products and this shall cover:

3.4.1 The subcontractor has documented New clause


systems in place to ensure traceability,
segregation, and identification of certified
products at every stage of handling. These
systems must be in compliance with
sections 1 and 2 of the standard.
3.5 Applicants that use contract processors New clause
or perform contract processing of certified
products shall maintain records of all
contract-processed certified products,
including:
 Volumes and product details received;
 Volumes and product details
dispatched;
 Dates of dispatch and receipt.
3.7 Where an applicant utilises the services New clause
of third party transport companies a
contract or equivalent documentary
evidence shall be in place demonstrating
that product integrity is ensured during
transportation.

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3.8 For bulk transported material, internal New clause
procedures and contractual agreements
shall include provisions that preclude the
use of transport that may adversely affect
the safety and integrity of any marine
ingredients materials due to the
composition of a previous cargo.

SECTION 4 – Labelling, Certification Logo/ Claim


4.1 The applicant shall only use the New clause
certification logo or claim if it has valid
certification to the IFFO RS Chain of
Custody Standard.

4.2 The applicant shall only use the New clause


certification logo or claim if it has
documented evidence demonstrating that
it has been granted approval to do so by
the standard owner i.e Terms of logo for
certificate holders – signed agreement.

4.3 The applicant shall follow the current New clause


IFFO RS logo guidelines for any logo used in
their products.

4.4 Product intended for sale as IFFO RS


certified shall:

4.4.1 Identifiable as certified on the item New clause


line of the associated invoice;

4.4.2 Labelled with all necessary Was clause 3.5 “Each certified labeled product must be” removed from start of first
information to enable the product to be sentence.
in V1
traced back to the IFFO RS certified
factory. As a guide, this may include the Modified “Certified RS” changed to “IFFO RS certified”
following, although this is not an wording
exhaustive list;
• Country of origin,
• Product description,
• Product code or production code
number,
• Production date, or lot
number/identifier.

4.4.3 Identifiable as certified during Was clause 3.6 Completely reworded from
storage and transportation; each unit shall “During storage and transportation of certified fishmeal and fish oil
in V1 products each unit must have its identification number stated
have identification on the attached label or
Modified on the attached label or documentation.”
associated documentation.
wording

4.5 The applicant must operate a secure Was clause 3.7 “certification mark” added
system for the production, storage and in V1
application of product labels bearing the “and will” changed to “which”
certification logo/certified claim which Modified
ensure that only compliant marine wording “certified fishmeal and fish oil product” changed to “compliant marine
ingredient product is labelled as such. ingredient product”

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SECTION 5 – Training
5.1 The applicant shall appoint an New clause, will Guidance from MSC CoC clause 5.1.4
individual (IFFO RS contact person) who this be
will be responsible for all contact with the
certifier and for responding to any requests relevant?
for documentation or information related
to CoC conformity.

5.2 The company shall put in place New clause


documented programmes covering the
training needs of all relevant personnel
specific to this CoC standard. These shall
include as a minimum:
• Identifying training needs and
providing training or other action to ensure
staff have the necessary competencies to
meet the requirements of this standard;
• Reviewing the effectiveness of
training.
5.3 The company shall routinely review the New clause
competencies of its staff in relation to this
standard, at least annually. As appropriate,
it shall provide relevant training. This may
be in the form of training, refresher
training or coaching, mentoring or on-the-
job experience.
5.4 Records of all training shall be New clause
available. This shall include as a minimum:
• The name of the trainee and
signed confirmation of attendance;
• The date of the training;
• The title or course contents, as
appropriate;
• The training provider.
SECTION 6 – Social Accountability
6.1 The Applicant shall have a documented New clause
policy that demonstrates compliance with extracted from
their national legislation to ensure that
their marine ingredient products are IFFO RS V2 and
processed/stored/traded in compliance to modified to be
all relevant employment, welfare and suited for
safety requirements as stated in this
purpose
section. If no legislation is documented by
their national government the applicant
will need to have its own polices to comply
with all the requirements of this section.
6.2 The Applicant shall have a written New clause
policy on fair operating practice, which is extracted from
made available to all staff both full /part
time and contractors of the company. At a IFFO RS V2
minimum, this shall cover bribery,
corruption and inappropriate political
lobbying or contributions.

6.3 The Applicant shall ensure that all staff New clause
have the correct visa/work permit to extracted from
comply with their current national
employment regulations. IFFO RS V2

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6.4 The Applicant shall conduct a New clause
documented annual self‐assessment extracted from
against all relevant social laws. All non‐
compliance shall be documented, with IFFO RS V2
action plans to address and monitor the
non‐compliance.
6.5 The Applicant shall have a procedure New clause
stating how to record health and safety extracted from
related accidents and incidents with the
associated corrective actions available to IFFO RS V2
employees. As a minimum, this shall cover
the process to record the incident in a
database and to take corrective action.

6.6 The Applicant has documentation New clause


available which demonstrates that a clearly extracted from
identified, named employees’
representative and / or an employees’ IFFO RS V2
council representing the interests of the
employees to the management is elected,
or appointed or nominated by all
employees and recognised by the
management. This person shall be able to
communicate complaints to the
management.
6.7 The Applicant shall have a complaint New clause
procedure for employees, the employees extracted from
have been informed about its existence
that complaints or suggestions can be IFFO RS V2
made.
6.7.1 The complaint procedure shall specify New clause
a time frame to resolve complaints. extracted from
IFFO RS V2

6.7.2 Complaints and their solutions from New clause


the last 3 years are documented and extracted from
accessible.
IFFO RS V2

6.8 The Applicant can document that the New clause


management and the employees’ extracted from
representative have signed and displayed a
self-declaration assuring good social IFFO RS V2
practice and human rights of all
employees.
6.8.1 The employees have been informed New clause
about the self-declaration and it is extracted from
reviewed at least every 12 months and
after any incident or appeal relating to this IFFO RS V2
policy.
6.9 The Applicant can demonstrate that New clause
the responsible person for workers’ health extracted from
and safety and the employees’
representative(s) have proven knowledge IFFO RS V2
and/or access to national regulations
concerning: gross and minimum wages,
working hours, union membership, anti-
discrimination, child labour, labour

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contracts, holiday and maternity leave,
medical care and pension/gratuity.

6.10 The Applicant shall have a contract for New clause


each employee containing the following: extracted from
IFFO RS V2

6.10.1 Both the employees as well as the New clause


employer have signed them. extracted from
IFFO RS V2

6.10.2 Records contain at least full names, New clause


nationality, a job description, date of birth, extracted from
the regular working time, wage and the
period of employment. IFFO RS V2

6.10.3 Records of all employees (also New clause


subcontractors) shall be kept in a secure extracted from
location and are accessible for at least 3
years upon approved request. IFFO RS V2

6.11 The Applicant can show written or New clause


electronic evidence of the salary transfer extracted from
(e.g. employee’s signature on pay slip,
bank transfer). IFFO RS V2

6.11.1 Employees sign or receive copies of New clause


pay slips / pay register that make the extracted from
payment transparent and comprehensible
for them. IFFO RS V2

6.11.2 Regular payment of all employees New clause


during the last 3 years is documented. extracted from
IFFO RS V2

6.13 If payment is calculated per unit, New clause


employees shall be able to gain at least the extracted from
legal minimum wage (on average) within
regular working hours. IFFO RS V2

6.13.1 If not covered by national New clause


legislation, children below the age of 15 extracted from
are not employed.
IFFO RS V2

6.13.2 If personnel between the ages of 15 New clause


to 18 are hired part time, they are not extracted from
engaged in work that is deeemed
dangerous, based on a risk assessment, to IFFO RS V2
their health and safety that jeopardises
their development or prevents them from
finishing their compulsory school
education.

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6.14 The Applicant shall demonstrate that New clause
they have communicated with their raw extracted from
material suppliers the national social
regulation requirements and will not deal IFFO RS V2
with any supply that has been successfully
prosecuted for violations to the national or
international social regulations.
SECTION 7 – Environmental Accountability
7.1 The applicant shall have a New clause
documented policy that demonstrates extracted from
compliance with their national legislation IFFO RS V2 and
to ensure that their marine ingredient
modified to be
products are processed/stored in
suited for
compliance to all relevant environmental
requirements as stated in this section. If no
purpose
legislation is documented by their national
government the applicant will need to
have its own polices to comply with all the
requirements of this section

7.2 The applicant shall provide copy New clause


of permits (when applicable) for extracted from
environmental emissions regulations as the IFFO RS V2
legislation relates to:

Emissions to air
Discharge to water
Release of toxic or hazardous substances
Noise, smell and dust pollution
Ground pollution

7.3 The applicant shall provide New clause


documentation in order to demonstrate extracted from
compliance with the requirement specified IFFO RS V2
in permits from 7.1. In the case of non-
compliance, all non‐compliance shall be
documented, with action plans to address
and monitor the non‐compliance.

7.4 The applicant shall have a written New clause


assessment that identifies relevant extracted from
environmental issues and the provisions IFFO RS V2
made to address the associated risks have
been conducted.

7.4.1 Management is able to demonstrate New clause


awareness of the identified issues and the extracted from
provisions made to address the associated IFFO RS V2
risks.

7.3 There shall be records of community New clause


complaints and the associated corrective extracted from
action taken to address their concerns. IFFO RS V2

This report shall not be reproduced in part without the permission of IFFO RS Ltd.
This report shall not be reproduced in part without the permission of IFFO RS Ltd.