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Version February 2014 Supplier Quality Booklet This booklet is compiled as a communication document for our 3rd party suppliers and it includes Wessanen Europe quality and food safety requirements for Wessanen branded products.

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Page 1: Wessanen EU Supplier Quality Booklet€¦ · Supplier Quality Declaration (SQD) and monitoring evaluations performed by the Wessanen Market Quality Department. In this booklet, Wessanen

Version

February 2014 Supplier Quality Booklet

This booklet is compiled as a communication document

for our 3rd party suppliers and it includes Wessanen

Europe quality and food safety requirements for

Wessanen branded products.

Page 2: Wessanen EU Supplier Quality Booklet€¦ · Supplier Quality Declaration (SQD) and monitoring evaluations performed by the Wessanen Market Quality Department. In this booklet, Wessanen

Wessanen EU Supplier Quality Booklet

Page 1

T A B L E O F C O N T E N T S

1 INTRODUCTION .................................................................................................. 2

2 WESSANEN QUALITY REQUIREMENTS ................................................................ 3

2.1 Wessanen Quality Policy ..................................................................................... 3

2.2 Regulatory Compliance ....................................................................................... 3

2.3 Corporate Ethics & Sustainability policy ................................................................ 3

2.4 Organisation and Responsibility ........................................................................... 3

2.5 Quality Management System .............................................................................. 4

2.6 Food Defense .................................................................................................... 4

2.7 Hazard Analysis and Critical Control Points (HACCP) .............................................. 4

2.8 Procurement Controls ........................................................................................ 4

2.9 Manufacturing Controls ...................................................................................... 4

2.10 Warehouse & Transportation Controls .................................................................. 5

2.11 Traceability ....................................................................................................... 6

2.12 Allergen management ........................................................................................ 6

2.13 Genetically Modified Organisms (GMOs) ............................................................... 6

2.14 Pesticide Residues ............................................................................................. 6

2.15 Palm Oil ........................................................................................................... 6

2.16 Finished Product Controls (Physical, Chemical, and (Micro)Biological Properties) ........ 6

3 ISSUE & CRISIS MANAGEMENT .......................................................................... 7

3.1 Communication ................................................................................................. 7

3.2 Issue Handling .................................................................................................. 7

3.3 Complaint Handling ........................................................................................... 7

4 FINISHED PRODUCTS ......................................................................................... 8

4.1 Finished product specification ............................................................................. 8

4.2 New Product Approval ........................................................................................ 9

5 WESSANEN SUPPLIER QUALITY MANAGEMENT SYSTEM ................................... 10

5.1 Supplier Selection & Approval ............................................................................ 10

5.2 Supplier Quality Monitoring ................................................................................ 10

6 WESSANEN NUTRITIONAL POLICIES ................................................................ 11

7 APPENDICES ..................................................................................................... 12

7.1 Appendix A – Wessanen Supplier Code of Conduct ................................................ 12

7.2 Appendix B – Allergen Management Policy ........................................................... 15

7.3 Appendix C – Non-GM Policy .............................................................................. 17

7.4 Appendix D – Non-GM Packaging Policy ............................................................... 19

7.5 Appendix E – Pesticide Policy ............................................................................. 20

7.6 Appendix F – Palm Oil Policy .............................................................................. 22

7.7 Appendix G - Packaging Policy ........................................................................... 24

7.8 Appendix H – Whole Cereals Policy ..................................................................... 25

7.9 Appendix I – Sugar Quality Policy ....................................................................... 27

7.10 Appendix J – Salt Policy..................................................................................... 28

7.11 Appendix K – Lecithin Policy .............................................................................. 30

7.12 Appendix L - Claim Policy .................................................................................. 31

7.13 Appendix M – Nutritional Profile Guideline ............................................................ 32

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1 INTRODUCTION

This booklet includes Wessanen general and specific (per product category) quality requirements

applicable to Wessanen brands finished product1. These requirements must be complied with by

all suppliers.

Satisfactory compliance with the different components of this booklet will be controlled by the

Wessanen Market Quality Department.

Approval to supply Wessanen brands finished products will be based on Wessanen required

Supplier Quality Declaration (SQD) and monitoring evaluations performed by the Wessanen

Market Quality Department.

In this booklet, Wessanen brands finished products will be referred to as finished products. A

manufacturer of such products (own factory, co-packer or third party supplier) will be referred to

as supplier.

Many of the expectations in this booklet are based not only on regulatory requirements, but also

industry best practices and expectations from our consumers and customers.

This booklet does not eliminate a supplier’s responsibility to comply with all applicable European

or local legal requirements, Wessanen Purchasing terms and/or other contract obligations.

Wessanen reserves the right to make modifications to this booklet as required. Suppliers will be

notified of these changes.

The supplier will be deemed to have accepted the requirements applicable to Wessanen brand

finished products if the supplier has not raised any objection in writing within 10 working days

after receipt of this booklet. In case of conflict between the Supplier Quality Booklet and the

General Purchase Terms and Conditions of Wessanen and its affiliated companies or the supply

agreement with the supplier, the Supplier Quality Booklet will prevail.

Wessanen will be monitoring the supplier status against the requirements in this booklet, and any

deviation may constitute a breach of the terms of conditions of trading, as stated in Wessanen

General Purchase Conditions.

For questions on the documents, please contact us at the following address:

[email protected].

1 Wessanen brands:

UK: Clipper, Kallo, Whole Earth

France: Bjorg, Bodad, Bonneforme, Bonneterre, Clipper, Evernat, Gaylord Hauser, Le Gout

de l’Essenti, Le Sillon, Tanoshi, Tien Shan, Vivis

Germany: Allos, Culinessa, Cupper, De Rit, Dr Ritter, Molenaartje, Sesamstrasse, Tartex,

Whole Earth

Benelux: Biorganic, Chocoreale, Clipper, De Rit, Merza, Molenaartje, Natufood, Royal Mail,

Whole Earth, Zonnatura

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2 WESSANEN QUALITY REQUIREMENTS

2.1 Wessanen Quality Policy

It is the policy of Wessanen and its operating companies:

o To produce and market food with superior product quality as expected by our consumers

and customers.

o To achieve this target with the cooperation and compliance of our suppliers to the

Wessanen Quality Requirements as defined in this booklet.

2.2 Regulatory Compliance

All finished products supplied to Wessanen must comply with all European legislation and with

any relevant codes of practice applicable to the product or process. Any changes to, or proposals

of change which impact the regulatory compliance of Wessanen branded products in the market

must be advised immediately to the appropriate Wessanen representative.

All products supplied must comply with the appropriate regulations:

o Relevant European legislation

o Relevant legislation of the country where the product is manufactured and packed

o Relevant legislation of the country where the product is delivered to Wessanen

subsidiary

2.3 Corporate Ethics & Sustainability policy

Wessanen focuses on 3 sustainability pillars:

Healthier food

o Mainly organic and/or vegetarian products

o Products compliant with our nutritional policies

Healthier people

o Organic Expertise Centre (OEC) to increase internal and external awareness and

knowledge

o Nutrition workshops for consumers and customers

o Healthier farmers due to organic and/or fair trade products

Healthier planet

o Wessanen factories are certified ISO14001

o Sustainable palm oil

Suppliers must be committed to:

Adhering to Wessanen’s Supplier Code of Conduct, see Appendix A.

Promoting environmental performance by reviewing and analysing environmental impacts

related to the production process and supply chain and seeking ways to reduce their

impact on the environment. Preferably suppliers maintain a certified environment

management program, i.e. ISO14001 certification.

2.4 Organisation and Responsibility

o Suppliers must have procedures in place that define the organizational structure,

procedures and training programs that will be executed to ensure that the products

manufactured under Wessanen brands will be safe and meet the quality

expectations of Wessanen.

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2.5 Quality Management System

o It is required for suppliers to maintain a quality management system and that its

effectiveness is verifiable. A GFSI2 recognized certified quality management system

is recommended.

2.6 Food Defense

o It is essential to Wessanen to protect its consumers, employees, brands and other

assets from product contamination, by organising and promoting efforts to prevent,

deter, identify, respond to and contain threats or acts of deliberate contamination.

o Each supplier location shall assess the hazard posed to finished products produced

in its facilities by potential acts of sabotage, vandalism or terrorism and shall put in

place proportional protective measures.

o Food Defense plans must be documented, reviewed and revised as required by

regulation and/or minimally once a year.

2.7 Hazard Analysis and Critical Control Points

(HACCP)

o Suppliers must have a documented food safety program in place: HACCP, including

hazards identified (in particular allergens, pesticides and GMO, see appendices for

Wessanen policies) and a process-flow diagram.

o HACCP program must comply with Codex Alimentarius (latest approved version),

and ideally validated by an external party.

o HACCP must be reviewed and revised, when any changes are made to the products

or processes, when repetitive issues occur, if required by regulation and/or

minimally once a year.

o HACCP documentation and process-flow diagrams must be made available to

Wessanen upon request.

2.8 Procurement Controls

o Suppliers must have controls in place to ensure that raw materials, other

intermediate products and food-contact packaging materials comply with their

specifications.

o Suppliers must provide Wessanen with the following information on the raw

materials, packaging and other intermediate products used in the finished

products:

Name of ingredient

All possible countries of origin of the agricultural ingredient

o Supply chain information must be made available upon request:

Supplier name and supplier location

2.9 Manufacturing Controls

Facility and equipment controls 2.9.1

o Suppliers must produce finished product in facilities with equipment that is properly

designed, built and maintained to ensure the production of safe food products.

o The facilities must be operated in a sanitary manner, according to procedures.

o Procedures must be in place to prevent and identify potential extraneous material

contamination of products, such as:

o Verification of water source for potability.

o Glass, wood (including pallets) and brittle plastic management policy.

2 Global Food Safety Initiative – for more information, go to www.mygfsi.com

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Foreign material controls 2.9.2

o A program to control foreign material must be in place. Based on the process and

the manufacturing environment, it could include devices such as magnets, sieves,

screens, bone detection devices, metal detectors, optical sorters and x-rays.

In process controls 2.9.3

o Effective in process controls must be in place to ensure the product is produced

according to specifications and/or regulatory requirements.

In particular, process controls must be in place to ensure the

allocation of the correct ingredients, processes and packaging (and

labelling) to the appropriate production batch.

o In process controls must be done at a pre-established frequency (based on risk

assessment) to ensure product safety, results must be documented, held for one

year past the product shelf life or as required by applicable regulations, and must

be made available to Wessanen upon request.

Product hold & release 2.9.4

o Effective controls must be in place to manage product that does not conform to

specifications and/or regulatory requirements, including:

Record keeping procedures to log and track all batches put on HOLD to

ensure correct disposition.

Secure location to store product retained for non-compliance issues.

o Without prejudice to Wessanen’s right to claim damages, nonconforming Wessanen

brand products may be:

reworked following strict rework and traceability control procedures,

donated subject to Wessanen’s prior written consent,

disposed of, in which case the supplier will denature the product and its

packaging prior to disposal.

Laboratory controls 2.9.5

o For product testing, laboratories with publicly recognized accreditation for the

particular testing scope must be used. This is not mandatory for routine quality

control tests.

o When an internal laboratory is used, the following systems and practices must be in

place:

Written sampling plans must be in place for all materials to be tested.

All laboratory methods must be based on accredited methods.

The laboratory must have quality control procedures in place to ensure the

accuracy of results, and tests must be performed by properly trained staff.

Pathogen testing can be performed only if the appropriate laboratory

controls and laboratory design/location is in place to protect the production

facility.

Pest prevention 2.9.6

o Suppliers must have effective integrated pest management program in place to

ensure that the facility and its surroundings are maintained in a sanitary and pest-

free condition.

2.10 Warehouse & Transportation Controls

o Suppliers must have procedures in place to ensure that products are stored and

distributed in a timely, safe and secure manner, and can be effectively traced if

necessary.

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Receiving and dispatching 2.10.1

o Procedures to ensure control of incoming and dispatch of raw materials, packaging

materials, intermediates and/or finished products must be in place, including

inspection of trailers, taking of product temperatures (if relevant) , and inspection

of loads. Receiving and dispatching activities must be documented.

Returned good controls 2.10.2

o A documented program must be in place describing the management of any

finished product returned to the facility after it has left the control of the supplier’s

company, including methods of segregation and evaluation of the product.

2.11 Traceability

o Suppliers must have procedures in place that will permit traceability of all product

ingredients, product contact packaging, and finished products by individual lot

number or other identifying code, one step back and one step forward in the

supply chain.

o Records of production must be maintained for one year past the shelf-life of the

product or as required by applicable regulations.

2.12 Allergen management

o Allergen management for all Wessanen brand products must comply with the

Wessanen Allergen Management Policy (see 7.1 - Appendix B).

2.13 Genetically Modified Organisms (GMOs)

o Wessanen brand products do not contain any GMOs, GMO ingredients or

ingredients derived from GMOs.

o All suppliers which produce products containing ingredients such as soybean, corn

and/or rapeseed must apply the Wessanen Non-GM Ingredient Policy (see 7.2 -

Appendix C) and all packaging materials must comply with the Wessanen Non-GM

Packaging Policy (see 7.3 - Appendix D).

2.14 Pesticide Residues

o Wessanen consumers have high expectations when it comes to pesticide residues in

our branded products, in particular in organic products.

o All Wessanen branded products must comply with Wessanen Pesticide Policy (see

7.4 - Appendix E).

2.15 Palm Oil

o As an integral part of our sustainability policy, Wessanen adheres to the production

of certified sustainable palm oil as managed by Roundtable for Sustainable Palm Oil

(RSPO).

o Suppliers are required to adhere to Wessanen Certified Sustainable Palm Oil Policy

(see 7.5 - Appendix F).

2.16 Finished Product Controls (Physical, Chemical,

and (Micro)Biological Properties)

o Physical, chemical and (micro)biological product testing against legal determined

limits and/or specific Wessanen requirements specified in this booklet must be

performed at a reasonable frequency (risk-based approach).

o All testing results must be documented and be made available to Wessanen upon

request.

o Retained finished products samples must be held for the duration of the products’

shelf life, and be made available to Wessanen upon request.

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3 ISSUE & CRISIS MANAGEMENT An issue is defined as any act or event that has the potential to have a negative effect

on the Wessanen brands, typically associated with the production or supply of unsafe,

illegal or non-conforming product.

3.1 Communication

o The supplier must provide Wessanen with an emergency contact, including

individual name, telephone numbers and email address.

o There are 2 routes of issue identification:

Internal (Wessanen): employees; monitoring plan results

External: authorities; consumer or customer; media; suppliers

o If any defect in the goods (including packaging) becomes known to one of the

parties, the party is obliged to inform the other party immediately of such defect,

stating:

Route issue identification (see above);

Type of defect;

The goods affected (name, brand, article code, lots concerned);

Any other information known that may be relevant.

o Records of production of the relevant batches (traceability data) must be sent to

Wessanen within 4 hours after request.

o The supplier should not communicate externally on behalf of Wessanen.

3.2 Issue Handling

o A team must be in place at the supplier to manage major situations involving food

safety, major regulatory issues, natural disasters or significant public relations

problems.

o When Wessanen informs the supplier of an issue, the supplier must conduct a full

investigation to analyse the root cause. Wessanen will request updates as needed.

A final investigation report must be sent to Wessanen within the agreed timeline.

o If a recall3, a withdrawal4 or a quarantine5 is decided, conditions defined in the

Wessanen General Purchase Conditions (§11) or in the contract apply.

o All suppliers must regularly review the product adequacy of their incident

management and product recall procedures.

o In case of issues, product analytical tests must be performed in accredited

laboratories that have a proven track record in the analysis in scope and in the

material product matrix, including the participation in ring trials.

3.3 Complaint Handling

o The supplier will have in place a procedure to investigate, manage and correct,

analyse trends and respond to consumer complaints.

o Consumer complaints reports will be sent to the supplier so that improvement

plans can be put in place as necessary. The supplier should reply within the agreed

timelines.

3 Recall is when finished products are removed from the market via a public announcement 4 Withdrawal is when finished products are removed from the shops and distribution center / supply without a public

announcement 5 Quarantine is when finished products are put on hold in warehouse

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4 FINISHED PRODUCTS

o Wessanen requires that suppliers provide a technical specification, otherwise

known as a finished product specification for every finished product.

o Specific product category food safety and quality requirements are described in the

Supplier Quality Declaration (See chapter 5 – Wessanen Supplier Quality

Management System)

4.1 Finished product specification

o The finished product specification, signed by the supplier, in the Wessanen

requested format, includes at minimum:

Recipe information:

o full list of ingredients and sub-ingredients (including processing aids)

with percentages in final product, countries of origin, quality marks

(e.g. organic, MSC, etc.)

o allergen declaration

o nutritional values per 100 ml/gr (see 4.1.1)

o health and nutritional claims agreed during development

o consumption serving size

o country of manufacturing and country of packaging

o whether the product is produced in a supplier facility or outsourced

to a third party

o shelf life details & shelf life validation test information

o storage (before and after opening) and transport conditions

o preparation instructions

o organoleptic characteristics, dimensions

o supplier mandatory statements & logo details (EU logo)

Packaging information (see 7.6 – Appendix G).

o description and type of packaging, food grade declaration

o materials used (including inks), weights, environmental marks, and

disposal information

o shelf life and traceability codes descriptions and examples

o declaration on content of phlatates and bisphenols

o net weight (e-mark), number of servings per consumer unit

o packaging treatment details (e.g. modified atmosphere)

Please note that a declaration of compliance for materials and articles

intended to come into contact with food, conforming with EU regulation

1935/2004 (art.16), will be required from suppliers for Wessanen own

brands. This declaration must be made in the Wessanen format.

The supplier must have all appropriate documentation and evidence of

compliance with the above regulation readily available to be sent to

Wessanen upon request.

Nutritional value declaration: 4.1.1

o WSN requires the supplier to deliver nutritional data allowing a correct declaration

on packaging and supporting agreed nutritional and health claims.

o The supplier will be held responsible in case of incorrect nutritional data in the

specification. He will be asked to provide Wessanen with corrected data from

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analysis. Costs linked to incorrect data (fees from authorities, packaging

destruction, analysis by Wessanen) will be charged to the supplier.

4.2 New Product Approval

o New product approval by Wessanen will include

o Approval of prototypes, preferably industrial trials

o First production run sample(s)

o Analytical tests (when relevant)

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5 WESSANEN SUPPLIER QUALITY MANAGEMENT SYSTEM

5.1 Supplier Selection & Approval

o Wessanen Market Quality Department reserves the right to approve all supplier

facilities.

o Each prospective supplier facility must undergo an evaluation prior to approval. The

purpose of this evaluation is to assess the prospective facility’s quality systems

against the expectations found in this booklet.

Step 1

All prospective supplier facilities must complete a Supplier Quality

Declaration, and return it to the relevant Wessanen representative.

Step 2

Upon receipt of the completed declaration, the content will be reviewed by

the Market Quality team and if needed more information will be requested

from the supplier.

The Market Quality team will make a risk assessment considering the

specific Wessanen policies relevant to the supplier and the products to be

produced.

The evaluation of the completed supplier declaration and the risk

assessment results will be used to determine the final approval status of the

supplier’s facility and if a site visit is necessary.

After a site visit, a report with the result of the visit and any non-

conformances identified against Wessanen requirements will be issued.

Step 3

The supplier will be assigned a status:

Approved

Approved under restriction: non-conformances identified during

supplier visit must be resolved for the supplier to gain status

approved. The supplier will need to confirm in writing the corrective

action plan (including details for each non-conformance and

timelines). After the correction action plan and confirmation of its

results have been verified, the supplier approval can be given.

Rejected: Supplier deemed not suitable for producing Wessanen

branded products.

The relevant Wessanen representative will inform the supplier and explain

the reason for this decision.

o Periodic on-site evaluations performed by Wessanen representatives may be

necessary to assess quality and food safety systems. This will be planned and

agreed upon with the supplier in advance.

5.2 Supplier Quality Monitoring

o Supplier quality monitoring will be based on periodic evaluation of the following

parameters:

Number of complaints per million units sold

Number of quarantines, withdrawals, and/or recalls

Product monitoring plan compliance results

Reliability factor

o Supplier Quality Monitoring reports will be sent and discussed with the supplier to

define and execute together a Supplier Quality Plan for continuous improvement.

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6 WESSANEN NUTRITIONAL POLICIES o In order to achieve its mission “Healthier food, healthier people, healthier planet”,

Wessanen has defined some nutritional policies and guidelines which apply to our

nutritional organic brands portfolio. They apply to innovations, and in some cases,

to existing products.

o The current policies and guidelines are:

Whole cereals policy (see Appendix H).

Sugar quality policy (see Appendix I).

Salt policy (see Appendix J).

Lecithin policy (see Appendix K)

Claim policy (see Appendix L).

Nutritional profile guideline (see Appendix M).

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7 APPENDICES

7.1 Appendix A – Wessanen Supplier Code of Conduct

Introduction 7.1.1

The mission of Wessanen is Healthier food, Healthier people, Healthier planet. We believe that

healthier food makes healthier people and a healthier planet.

Wessanen is concerned not only about its results, but also how those results are achieved. We

recognize that we are part of a larger system and we take responsibility in managing our impact

on the world around us. We are committed to upholding the interests of our stakeholders and

acting as responsible corporate citizens. We observe best business practices, labour, health,

safety and environmental standards in all countries in which we operate, which forms the basis of

our Supplier Code of Conduct. The Supplier Code of Conduct defines how Wessanen want to do

business and interact with its suppliers. Wessanen expects its suppliers (and their subsidiaries

and their suppliers) to share the principles which are expressed in this Supplier Code of Conduct

and to ask their suppliers to comply with it as well.

General principles 7.1.2

o Compliance with law: Suppliers are a responsible partner in society, acting with

integrity towards all its stakeholders and others who can be affected by their

activities. Suppliers shall observe the applicable laws of the countries in which they

operate. Additionally, suppliers shall ensure that their products, services and

shipments adhere to all applicable international trade compliance laws, rules and

regulations.

o Environment: Suppliers – in line with their commitment to sustainable

development- shall do all that is reasonable and practicable to minimize adverse

effects on the environment

o Product safety: Suppliers shall aim at all times to supply safe products and

services

o Free market competition: Supplier shall support free market competition as the

basis for conducting their business and shall observe applicable competition laws

and regulations

o Human rights: Supplier shall support and respects human rights and strives to

ensure that their activities do not make them accessory to infringements of human

rights

o Labour: Suppliers shall uphold the human rights of workers and treat them with

dignity and respect. Accordingly, suppliers shall comply with the following ILO

based principles.

Forced Labour: Suppliers shall not use forced labour, whether in the form of

prison labour, bonded labour, or otherwise.

Child labour: Suppliers shall not employ people younger than 14, or the

minimum age for completing compulsory education in the country of

manufacture, whichever is higher.

Harassment and Abuse: Suppliers shall treat every employee with respect

and dignity, and shall not subject any employee to physical, sexual,

psychological, or verbal harassment or abuse.

Non-discrimination: Suppliers shall not subject any person to discrimination

in employment (including hiring, salary, benefits, advancement, discipline,

termination, or retirement) on the basis of gender, race, religion, age,

disability, sexual orientation, nationality, political opinion, or social or ethnic

origin.

Health and Safety: Suppliers shall comply with applicable environmental

laws and regulations and provide a safe and healthy working environment to

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prevent accidents and injury to health occurring within or arising out of the

course of work, or as a result of the operation of employer facilities.

Freedom of Association and Collective Bargaining: Suppliers shall recognize

and respect the right of employees to freedom of association and collective

bargaining.

Wages and Benefits: Suppliers shall pay employees at least the minimum

wage required by local law, or the prevailing industry wage if no minimum

wage law applies, and shall provide legally mandated benefits.

Hours of Work: Employees should not be required to work more than 60

hours a week except in extraordinary business circumstances. Employees

should be granted at least one day off in every seven-day period.

Overtime Compensation: In addition to compensation for regular hours of

work, suppliers shall compensate employees for overtime hours at the

applicable premium rate in their country. In countries that have not

established premium overtime rates, suppliers shall not pay their employees

less than their regular hourly rate for overtime hours.

Commitment towards consumers 7.1.3

Wessanen is convinced that it is contributing to the longer-term well-being of its consumers by

delivering healthier products. That is why Wessanen expects all of its suppliers to manufacture

the products with the greatest care, guaranteeing the highest degree of food safety, and a

reliable and transparent supply chain. The products and services will be accurately and properly

labelled, advertised and communicated. Suppliers shall respect consumer privacy and will always

deal with consumers in a fair and forthright manner, maintaining the highest levels of integrity.

Commitment towards business partners 7.1.4

Wessanen’s objective is to pursue mutually beneficial relationships with its customers, suppliers

and business partners. Wessanen expects its suppliers to have a shared responsibility for supply

chain transparency as well as on the other aspects of sustainability. Wessanen seeks to award

business to business partners who are committed to act fairly and with integrity towards their

stakeholders and who observe the applicable laws in the countries in which they operate.

Commitment towards the world around us 7.1.5

Supplier shall recognize that they are part of a larger system and it takes responsibility in

managing their impact on the world around us. Suppliers shall be committed to act as a

responsible corporate citizen, observing best business practices, labour, health, safety and

environmental standards in all countries in which it operates. Suppliers shall strives to minimise

the negative impact of the products and processes on the environment, as it regards themselves

as part of the ecological chain. Suppliers shall respects and support fundamental human rights of

all parties in society affected by its business. Suppliers shall support the principle of fair

competition as the proper basis for conducting their business and observes applicable competition

laws and regulations.

Principles regarding assets and resources 7.1.6

Suppliers will safeguard and only make appropriate use of Wessanen assets and resources and

confidential information disclosed to them by Wessanen. This includes Wessanen properties,

assets, proprietary interests, financial data, trade secrets, corporate information and other

Wessanen rights. Wessanen assets and resources as well as corporate opportunities are only to

be used to pursue and achieve Wessanen goals and not for the suppliers’ benefit.

Information security 7.1.7

Confidential information is defined as that which is not generally known outside Wessanen and

which, if released in the public domain, could be detrimental to the commercial and other

interests of Wessanen. Suppliers are required to ensure that this kind of information which has

been disclosed to them is not revealed to any third party without Wessanen’s prior approval.

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Bribery/corruption and records of transactions 7.1.8

Wessanen expects from its suppliers to compete for business fairly, on the merits of its products

and services. Bribes in any form are unacceptable to Wessanen. Any personal payments or bribes

to individuals employed by Wessanen’s suppliers, to government or regulatory officials or receipts

of bribes or personal payments by Wessanen employees are strictly prohibited. Wessanen expects

its suppliers to strive for compliance with the highest

levels of transparency and accountability throughout its company. Records of transactions should

be maintained in an accurate, complete and timely manner in accordance with the relevant

accounting principles. No unrecorded funds or assets should be established or maintained.

Gifts and favours 7.1.9

In general, personal gifts or favours of a commercial value of €250.- (or the equivalent) or above,

may not be made or accepted by any Wessanen employee.

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7.2 Appendix B – Allergen Management Policy

Introduction 7.2.1

Allergens in foods are a food safety risk and, as such, must be managed to ensure the safe

consumption by the allergenic consumer.

Consumers affected by the allergen or intolerance reactions should be given the possibility to

choose food products that are safe for them, by having timely access to complete and accurate

information. The latest is the purpose of the European Regulation No. 1169/2011 to become

applicable on 14th December 2014.

Scope 7.2.2

Products

This policy applies to Wessanen EU own branded products, organic and conventional, and will be

gradually introduced with a deadline of 14th December 2014.

Allergens

This policy refers to all allergens listed in Annex II of European Regulation No. 1169/2011 or in

local specific regulation where the product is sold, whether they are present in Wessanen

products as ingredients or they could be present as a result of cross-contamination. Allergen

cross contamination means that an allergen not intentionally added could be present as a result

of a contamination through the supply chain.

Wessanen Quality Expectations 7.2.3

a. Wessanen product formulation should avoid the use of allergenic ingredients

whenever possible (taking into consideration costs, technological and other

constraints).

b. Suppliers must deliver safe products for our consumers, including people who suffer

from allergies and/or intolerances.

c. Suppliers must maintain an allergen management program based on risk-

assessment (HACCP principles) which effectively controls the risks of:

i. inadvertently incorporated allergen ingredients in the product

ii. presence of cross contamination in the product

Please note that cross-contamination information shall not be used as a substitute for

an effective food allergen control program.

d. All allergen information must be indicated in the product specification.

Please note that the supplier must inform Wessanen proactively and timely of any

change occurring at production site and/to the product specification, to allow changes

to the product labelling if needed.

e. Supplier must implement an effective employee allergen training program.

f. Wessanen will carry out its monitoring plan and will share the results with the

supplier if necessary.

Allergen labelling 7.2.4

Labelling of allergens should help allergic consumers identify quickly and easily foods of concern

and must conform to the European and local regulations.

Supplier must comply with the following:

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o When cross-contamination is unavoidable, the supplier must declare this possibility

in the product specification, including source, and analytical result of the

contamination (allergen).

o In case of allergen free claim:

i. The claim must be mentioned in the specification approved by the

supplier;

ii. It is the responsibility of the supplier to take all measures deemed

necessary to guarantee the conditions required for the claim, and to state

them in the specification;

iii. Wessanen will carry a random testing based on risk management.

Please note that failing to declare an allergen cross-contamination in the product

specification by Supplier, will result in immediate withdraw of the product from the

distribution. All costs related to this action will be borne by the supplier.

References 7.2.5

I. EU Regulation:

http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32011R1169:EN:NO

T

II. Swiss Regulation: www.admin.ch/ch/f//rs/c817_022_21.html

III. Swedish food section guideline:

http://www.slv.se/upload/dokument/risker/allergi/guidelines_allergy_2005.pdf

IV. Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25

October 2011

V. Allergene in Lebensmitteln, Allergologie-Ernährungswissenschaft- Recht- Praxis,

Behr`s Verlag

VI. Best Practices Allergen Risk Assessment:

Risk assessment: http://www.foodallergens.info//Manufac/Assess.html

Allergen HACCP list:

http://www.foodallergens.info//Manufac/management/checklist.pdf

Allergen management guidance:

http://www.food.gov.uk/multimedia/pdfs/maycontainguide.pdf

VITAL (Voluntary Incidental Trace Allergen Labelling):

http://www.allergenbureau.net/vital/vital/

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7.3 Appendix C – Non-GM Policy

Introduction 7.3.1

Genetically Modified Organisms (GMO) are vegetable ingredients produced from seeds of which

DNA has been modified to express a specific function (production of a toxin, resistance to a

chemical molecule, production of a nutrient…).

According to regulation EU 1829/2003, the presence of GMO derived ingredients in a product

must be labelled on pack, unless the proportion is below 0.9%. Organic regulation prohibits the

use of GMO derived ingredients. According to a survey in 2010, roughly 70% of the European

consumers do not want food containing GMO derived ingredients (1) and they see it as a threat

for the environment (2). French authorities have defined labelling rules for claim “GM free” (text

Nr. 2012-128 of 30/01/12), establishing a maximum threshold of 0.1% of GMO contamination,

and conditions for the use of claim. There is no European alignment on this claim.

Scope 7.3.2

This policy applies to Wessanen EU own branded products, organic and conventional.

Policy 7.3.3

Our products do not contain any GMOs, GMO ingredients or ingredients derived from GMOs.

Ingredients “at risk” are: soybean, corn and rapeseed.

Requirements from the suppliers:

According to Wessanen’s Supplier Quality Management policy, suppliers are expected to maintain

a risk based approach to GMO contamination risk and share the results with Wessanen upon

request. They are asked to:

o for ≪ at risk ≫ ingredients, which do not contain proteins and so where GM contamination

cannot be detected (no PCR possible), provide upon request a certificate of non-use of GM

ingredient ;

o for “at risk” ingredients (containing proteins), have a PCR analysis, made by an accredited

laboratory on each batch and provide this PCR analysis upon request;

o do not use the ingredient batch if contamination is:

≥ 0.1% for all organic raw materials;

≥ 0.1% for conventional ones if there is a GMO free claim on the final product;

≥ 0.9% for other conventional raw materials;

unless a stricter limit is defined in the specifications;

o propose alternatives to “at risk” ingredients.

Wessanen will perform a monitoring plan based on a risk analysis. The following cases are

considered:

o Organic or conventional product

o Presence of a “GMO free” claim

o GMO ingredients allowed or not allowed in Europe

The levels below apply unless stricter rules are specified in the product or raw material

specification.

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Actions in case of presence of GMO contamination of a product:

Final product Level of

contamination

Isolated case Recurrent case (more

than once on the same

finished product or raw

material)

Organic LOD< x ≤ 0.1% - the supplier is asked to

provide his analysis

results on raw materials

used.

Organic without

“GM free” claim

0.1% < x < 0.9% - the supplier is asked to provide his

analysis results of the raw material;

- the supplier must analyse the

product before the next delivery and

send the result to Wessanen.

- the supplier must

implement preventive

actions agreed with

Wessanen.

- the supplier must

analyse each batch of the

product before delivery

and send the result to

Wessanen until the

problem is solved (at least

5 batches analysed).

Organic and

conventional

with a “GM-

free” claim

0.1% < x < 0.9%

- block the product;

- the supplier must investigate;

provide to Wessanen the

analysis results on the raw

material

make new analysis of finished

product of the same batch

and provide the results to

Wessanen.

- Wessanen will release or reject the

product based on the decision table

below;

- the supplier will make analysis

before sending the next delivery of

finished product and provide the

result to Wessanen.

Organic or

conventional

product

x ≥ 0.9%

GMO not

allowed in

Europe

detected

Decision table if new analysis required:

Second analysis Third analysis (in an accredited

lab)

Course of Action

Conform (Below

contamination level)

Conform The product is accepted.

Not conform The product is rejected

Not Conform Not applicable

o All costs related to the actions above shall be borne by the supplier.

Literature 7.3.4

I. Eurobaromètre Survey Nr 55.2 (EU commission)- September 2010

http://ec.europa.eu/public_opinion/archives/ebs/ebs_154_fr.pdf

II. Eurobaromètre Survey 365 “Attitudes of European citizens towards the

environment”

http://ec.europa.eu/public_opinion/archives/ebs/ebs_365_en.pdf

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7.4 Appendix D – Non-GM Packaging Policy

Introduction 7.4.1

Use of non-genetically modified ingredient is a key principle of the European organic regulation.

Organic products do not contain any genetically modified ingredient, derived ingredient or

additive.

However no restriction is applied to packaging, though packaging can be sourced from vegetal

sources, potentially genetically modified, for example PLA plastic.

Therefore, the use of GM derived packaging for organic products is considered by Wessanen as

misleading to consumers and so not acceptable for our organic products.

Scope 7.4.2

Wessanen organic brands.

Policy 7.4.3

Wessanen organic brands’ products will not use GM-derived packaging materials.

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7.5 Appendix E – Pesticide Policy

Introduction 7.5.1

The terminology “pesticides” refers to all chemical plant protecting agents.

The appropriate management of pesticide residues is important and regulated in food. For organic foods

however, it is critical, and of course, it is one of the most essential expectations of organic food consumers.

This document has been written to facilitate our suppliers and us to work together in ensuring the organic quality

of our products.

Supplier Quality Expectations 7.5.2

According to Wessanen’s Supplier Quality Management policy, suppliers are expected to maintain a risk based

approach to residue testing and share the results with Wessanen upon request. Main risks to be taken into

consideration are:

o Type of raw material o Origin of raw material o Size of batches o Homogeneity of received raw material batch

Analytical tests must be performed in ISO17025 accredited laboratories and have a proven track

record in the analysis of pesticides residues in the material product matrix, including the

participation in ring trials.

Wessanen will carry out its own risk assessment and accordingly, a supplementary monitoring

plan and will, when appropriate, share the results with the supplier.

Policy 7.5.3

All products, conventional or organic, must comply with EU regulation for residue

contaminations.

An organic product is considered not to conform for Wessanen when analysis result in

presence:

1 residue > 10 ppb and

sum of all residues > 20 ppb

Analytical variance (given by the laboratory) is taken into account only if a maximum 2

molecules are detected.

Reconstitution factors are applied to mono ingredients only. The following table can be considered as orientations and are valid for dried foods. Raw Material Factor

Dried fruits: General

Exception: Dates 5 1

Dried herbs: General 4

Dried vegetables: General 10

Spices and Seeds: General

Exception: Aniseed, Fennel, Caraway and similar seeds 5 1

Either the supplier or Wessanen must inform each other immediately on the findings in case of

non-conforming products.

The product will be put on hold by both the supplier and Wessanen pending the outcome of the

investigation and the recommendations of the respective certification bodies.

Wessanen will require the supplier to investigate the possible source of the residue(s) and

document a report with the root cause and improvement action plan. Minimum investigation

done by the supplier and with results presented to Wessanen will include:

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Second analysis Third analysis

(in a different accredited lab)

Course of Action (unless different from Wessanen’s organic certification body recommendation):

Conform Conform The product is accepted

Not Conform The product is rejected

Not Conform Not applicable

When the product is rejected, it will be withdrawn from the market.

Both the supplier and Wessanen will inform their own respective organic certification bodies in

the case of not-conforming products. In any case, Wessanen’s certification body

recommendation will be followed.

Wessanen and the supplier will produce and implement a shared corrective action plan

whether the product is accepted or rejected.

All costs linked to the issue, if confirmed, shall be borne by the supplier.

A product is considered in the warning area if more than 2 residues are between LOQ and 10

ppb. In this case, Wessanen will ask the supplier to investigate and may involve the

Certification Body for a final decision.

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7.6 Appendix F – Palm Oil Policy

Introduction 7.6.1

Wessanen is committed to the sourcing of certified sustainable palm oil. This oil is produced by

palm oil plantations which have been independently audited and found to comply with the globally

agreed environmental standards devised by the Roundtable on Sustainable Palm Oil (RSPO).

The following text is from RSPO Supply Chain Certification Standard Final Document; as approved

by RSPO Executive Board on 25 November 2011:

The Roundtable on Sustainable Palm Oil (RSPO) is a global, multi-stakeholder initiative on

sustainable palm oil products. Members of RSPO and participants in its activities come from many

different backgrounds, including plantation companies, manufacturers and retailers of palm oil

products, environmental and social NGOs and from many countries that produce or use palm oil

products.

The principal objective of RSPO is “to promote the growth and use of sustainable palm oil through

cooperation within the supply chain and open dialogue between its stakeholders”.

The methods used by the RSPO to deliver its objective include:

The development of a standard for certification of sustainable palm oil production

and associated mechanisms for verification of responsible palm oil production. The

RSPO Standard for Sustainable Palm Oil Production, approved in October 2007, is

presented as a series of Principles, Criteria, Indicators and Guidance, and is

designed to be used by palm oil producers to implement sustainable production

practices, and by certification bodies for field verification.

The development of an RSPO Supply Chain Certification Standard, which describes

requirements related to the control of RSPO certified palm oil products along the

supply chain, including flows of material and associated claims.

The palm oil products may go through many production and logistical stages between the grower

and the product. Any individual batch of palm and palm kernel oil can be traded through one of

four supply chain mechanisms that are approved by RSPO:

Identity Preserved

Segregated

Mass balance

Green Palm certificates

For the first three of these, supply chain controls from the plantation through to the certified end

product are required.

Wessanen has signed up an umbrella membership with RSPO, which can be used by local

operating companies to gain their RSPO supply chain certification.

Scope 7.6.2

Wessanen is committed to the use of sustainable palm oil in both its organic and conventional

branded products.

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Policy 7.6.3

When palm oil is needed, we strive to have Certified Sustainable Palm Oil (CSPO), preferably

Identity Preserved (IP) or segregated (SG), and tolerate Mass balance (MB).

By exception, we will compensate use of non-sustainable palm oil with Green Palm (GP)

certificates.

Implementation 7.6.4

Wessanen’s commitment to certified sustainable palm oil will be achieved by end 2013:

By involving 100% palm oil containing products suppliers, so that they become RSPO

certified

By certifying our own local supply chains, and using the RSPO logo in our products

when appropriate

By substituting palm oil whenever possible

By preferably developing new products without palm oil

RSPO Certification by local operating companies 7.6.5

Wessanen operating companies must obtain audited RSPO supply chain certifications and

incorporate RSPO certified logos when appropriate.

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7.7 Appendix G - Packaging Policy

Under construction.

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7.8 Appendix H – Whole Cereals Policy

Introduction 7.8.1

An important aspect of organic production is careful processing. Though not documented, this can

mean limited refining, in order to keep the food as close as possible to its original state. Unrefined

cereals contain more fibres and micro nutrients (e.g. magnesium) than refined ones (I).

It is widely acknowledged that fibres are beneficial to health, mainly promoting good digestive

and heart health (II), and maybe other health benefits (III; IV). Though a general

recommendation is a minimum intake of 25 g/day, most of the population falls well short of these

healthful goals. This value is considered as the Guidelines Daily Amount (GDA) (V).

Fibres are naturally present in whole cereals (also called whole grains or grains). Cereal fibres are

composed of both soluble and insoluble fibres which have complementary beneficial impacts on

health. EFSA has recently approved a claim linking beta-glucans and reduction of cholesterol

blood level (VI), and another on oat or barley fibres and digestive health (VII). Main clinical

studies have been carried out on whole grains, rather than with added fibres. Consuming whole

grains or as least refined as possible is a good way to increase significantly the fibre content of

the diet.

The health advantages of whole grains are largely associated with consuming the entire whole-

grain “package” (IX). Whole grain definition (VIII):

• Whole grains shall consist of the intact, ground, cracked or flaked kernel after the removal of

inedible parts such as the hull and husk. The principal anatomical components - the starchy

endosperm, germ and bran - are present in the same relative proportions as they exist in the

intact kernel.

• Small losses of components - i.e. less than 2% of the grain/10% of the bran - that occur

through processing methods consistent with safety and quality are allowed.

Though the definition of whole grain/cereal is international, the definition of semi refined wheat

flour has only been found in France and US.

Wheat flour can be classified according to the ash content with the following classifications:

Name Description Classification in

France

Classification in

Germany

Classification in

Italy

Whole wheat

flour

flour made with

minimum 98% of

the kernel. Ash*

> 1,5%

Type T 150 Type 1700 Wheat flour

“integrale”

Semi-refined

wheat flour

Ash* > 0,8% Type T80 to T110 Type 850 to 1050 Type 1 and 2

Fully refined

wheat flour

Ash* <0,55% Type T45 to 55 Type 405 to 550 Type 00 to 0

* Ash measured on dry matter

No such classification has been identified in UK and NL.

Scope 7.8.2

Wessanen respects the careful processing principle of organic food by applying its whole cereals

policy.

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This policy applies to Wessanen nutritional organic brands, Bjorg, Zonnatura, Allos, Kallo, Tartex

and Evernat (cf. Introduction - General).

Policy 7.8.3

Product containing cereals in the following product categories are developed as following:

o Cereal cakes: only whole cereals/ grains.

o Breakfast cereals: minimum 50% of whole cereals/grains in the finished product.

o Biscuits: minimum 15% of whole cereals/flour in the finish product or 30% of semi-refined

cereals/flour in the final product.

o Other categories (ready meals…): use whole or semi refined cereals, except if not

technically possible.

Literature 7.8.4

I. Nutritional value (macro- and micro-nutriments) of French flours and bread. Bourre

J.-M. and al. 2008, Médecine et Nutrition Vol.44, N°2.: http://www.medecine-

nutrition.org/index.php?option=com_article&access=standard&Itemid=129&url=/ar

ticles/mnut/abs/2008/02/mnut2008442p49/mnut2008442p49.html

II. Dietary fibre intake and mortality in the NIH-AARP diet and health study – June

2011.: http://www.ncbi.nlm.nih.gov/pubmed/21321288

III. Cochrane Database of Systematic Reviews 2008 Issue 2. Priebe MG, van

Binsbergen JJ, de Vos R, Vonk RJ. Whole grain foods for the prevention of type 2

diabetes mellitus.: http://summaries.cochrane.org/CD006061/whole-grain-foods-

for-the-prevention-of-type-2-diabetes-mellitus

IV. High fiber diet linked to reduced risk of colon rectal cancer, Nov 2010:

http://www.bmj.com/press-releases/2011/11/10/high-fibre-diet-linked-reduced-

risk-colorectal-cancer

V. Guidelines Daily Amount:

http://gda.ciaa.eu/asp2/gdas_portions_rationale.asp?doc_id=127

VI. Health claim on beta glucans:

http://www.efsa.europa.eu/en/efsajournal/pub/1254.htm

VII. Health claim on barley and oat fibres:

http://www.efsa.europa.eu/en/efsajournal/pub/2249.htm

VIII. Definition of whole grain: http://www.healthgrain.org/webfm_send/44

IX. Whole grain fact sheet: http://www.eufic.org/article/en/expid/Whole-grain-Fact-

Sheet/

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7.9 Appendix I – Sugar Quality Policy

Introduction 7.9.1

Organic consumers expect organic products to be minimally processed to keep the nutrients from

the plant. For example, the level of calcium in sugar goes from 195 mg/100g in whole sugar

(dried cane juice), to 135 mg/100 g in semi refined sugar (brown sugar), to 2 mg/100g in white

refined sugar (I; II).

White refined sugar is obtained via several processing steps, including a chemical reaction with

lime, while less refined sugar is obtained only through physical steps. This is more aligned with

the careful processing principle of organic production and helps to maintain micro nutrients from

the plant.

Scope 7.9.2

The Sugar quality policy applies to all products of Wessanen nutritional organic brands: Bjorg,

Zonnatura, Allos, Kallo, Tartex and Evernat.

Policy 7.9.3

The principle of this policy is to avoid fully processed sugars (empty calories, highly processed).

Development of sweet products (biscuit, bar, cereal, drink) is done by selecting sugars based on

their content in nutrients (N) and/or their low refining process (P), as following:

Preferred:

o honey (N,P)

o agave syrup (P)

o fruit syrup (apple syrup, grape juice concentrate…) (N,P)

o raw cane sugar (Rapadura®, Sucanat®), etc. (N,P)

o unrefined cereal syrup made from grain (ash > 0.6% DM) (N,P)

o Red / brown sugar from cane (N,P)

Tolerated:

o cane sugar with molasses like Demerara (saccharose < 99.5%) (N,P)

o cereal syrups non demineralised (P)

o Semi white / Golden sugar from cane (P)

Forbidden:

o refined sugars made from sugar beet, cane

o White sugars (cane or beetroot)

o Semi white / Golden sugar from beetroot

o Beetroot red sugar

o demineralized cereal syrups (ex. High Fructose Corn Syrup)

Literature 7.9.4

I. Guerra M.J. et al. Physical and chemical properties of granulated can sugar “panelas”, Ciencia e Technologia de Alimentos, 2010, Vol.30, N°1 Jan/Mar, 30.

II. Répertoire général des aliments-CIQUAL/ANSES: sucre blanc / sucre roux:

http://www.anses.fr/TableCIQUAL/

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7.10 Appendix J – Salt Policy

Introduction 7.10.1

Salt has been used for ages as a preservative agent in food, as well as a taste enhancer. It is

broadly added to manufactured food.

Quantitative aspects of salt consumption

However, salt and especially sodium are key nutritional concerns at global level. Most

epidemiological studies show that sodium in excess increases risk of hypertension (I).

Although sodium is an essential nutrient for life, the WHO recommends limiting its daily

consumption to below 2g/day, so 5 g of salt as sodium chloride. The current daily salt

consumption in most European countries is estimated or measured to range between 8 to 12

grams per day, with few Member States above and few below this intake level. Studies reveal

that the principle sources of salt/ sodium in the diet are processed foods and foods eaten in

restaurants, as opposed to foods cooked at home or to which salt has been added during the

meal (II).

At global level, the NGO WASH (World Action on Salt and Health) was established in 2005 with

the mission to improve the health of populations throughout the world by achieving a gradual

reduction in salt intake. WASH works to encourage multi-national food companies to reduce salt

in their products and with Governments in different countries highlighting the need for a

population wide salt reduction strategy.

Some European member states (NL, UK) have set up upper limits or recommendations per food

categories; others encourage salt reduction initiatives from food companies. Many food

companies have adopted and communicated plans to reduce sodium in their products.

Qualitative aspects of salt consumption

Salt may have different origins: sea, rocks or bittern. Most of the salts used at home or in the

food industry are refined salt obtained by dissolution of rock salt and evaporation at high

temperature. White refined salt, also called table salt, is purified, contains more than 97% sodium

chloride and most of it is treated with anti-caking agents, like sodium or potassium ferro cyanide.

These additives are considered as technical aids and so not labelled. Table salt is also often

complemented with iodine. Organic regulation only tolerates the use of treated salt (with

anticaking) in case of absolute necessity.

Unrefined sea salt is originally grey and contains between 94 and 97% of sodium chloride. It does

not contain additives. It contains predominantly sodium chloride but also other minerals,

especially potassium. Though sodium is associated with higher risk of cardiovascular disease,

epidemiological studies have shown a positive effect of potassium on reduction of cardio vascular

disease risk (III).

Scope 7.10.2

This policy applies to all products of Wessanen nutritional organic brands: Bjorg, Zonnatura, Allos,

Kallo, Tartex, Evernat (cf. Introduction, General).

Policy 7.10.3

Quantitative aspects

o Products are developed respecting maximum sodium/salt constraints set up in countries

where they are sold.

o All innovations will be developed respecting these sodium/salt limits per product category.

o Via product renovation, all Wessanen products will be brought into conformity with these

limits.

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o An yearly progress assessment (KPI measurement) will be perfomed toward 100%

conformity of our portfolio to these limits.

o Limits for core categories are highlighted in the green cells in table below.

Qualitative aspects:

o When developing an organic product, unrefined sea salt (between 94 and 97% of sodium

chloride) is used whenever possible, in order to balance the ratio of sodium and potassium

and respect the principle of careful processing.

Core Category Wessanen

Sub categories UK Target for 2012 (g salt or mg sodium per 100 g) [FDA, UK]

Target for 2012 (g salt or mg sodium per 100 g) [Dutch guidelines, NL]

Product examples

Dairy alternatives

100 mg sodium (maximum)

soy beverage, soy cooking…

Sweet in-between

16.1 Sweet biscuits – unfilled Includes all unfilled sweet biscuits. 16.2 Sweet biscuits – filled Includes all sweet biscuits with fillings, e.g. fig rolls, custard creams etc.

1.13g salt or 450mg sodium (maximum)

dry and spread biscuits and ginger bread

Bread replacers

2.1 Bread and rolls Includes all bread and rolls: pre-packed, part-baked and freshly baked (including retailer in-store bakery) white, brown, malted grain and wholemeal bread or rolls including seeded products, French bread, ciabatta, focaccia, pitta, na

1.0g salt or 400mg sodium (average)

Plain rice & other cereal cakes, crisp bread and crackers

11.2 Extruded snacks All extruded snacks e.g. cheese flavour corn puffs, potato hoops, all flavours except salt and vinegar

2.5g salt or 1000mg sodium (maximum)

Flavoured rice cakes

Breakfast cereals

3.1 Breakfast cereals Includes all breakfast cereals, e.g. muesli, cornflakes, hot oat cereals, etc.

1.0g salt or 400mg sodium (maximum)

muesli and puffed cereals

Hot drinks/Tea

20 mg sodium (maximum)

herbal, instant, infusions (Mineral) water, coffee, tea, soft drinks, dried beverages, etc.

Juices & cold drinks

100 mg sodium fruit & vegetable drinks min. 98% fruit juice

Sweet spreads

400 mg sodium (maximum)

sweet spreads no sugar, etc. Jam, marmite, chocolate paste

Savoury spreads

no target vegetarian pates yeast based, etc.

For other categories, refer to R&D contact at Wessanen.

Literature 7.10.4

I. MacGregor G A. Nutrition and blood pressure. Nutr Metab Cardiovasc Dis.

1999;9:6-15.

II. European Commission Salt Campaign.:

http://ec.europa.eu/health/nutrition_physical_activity/high_level_group/nutrition_s

alt_en.htm

III. Urinary Sodium and Potassium Excretion and Risk of Cardiovascular Events.:

http://jama.jamanetwork.com/article.aspx?volume=306&issue=20&page=2229

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7.11 Appendix K – Lecithin Policy

Introduction 7.11.1

Consumers expect organic food to be as untreated and as organic as possible and to be produced

in line with the rules and regulations that apply to organic food. Protecting organic integrity is a

top priority at Wessanen.

Organic regulation tolerates some non-organic ingredients, when they are not available in the

expected quality or sufficient quantity as organic. This is the case for conventional lecithin

considered as an additive of agricultural origin listed in annex VIII A of regulation EU 889/2008.

Lecithin is an emulsifier extracted from vegetable oil, and especially soybean, rapeseed or

sunflower lecithin. It is difficult to guarantee a non GM origin for soy or rapeseed lecithin, as DNA

is not present in lecithin (no detection possible).

Scope 7.11.2

The lecithin policy applies to all Wessanen organic products containing lecithin.

Policy 7.11.3

In order to guarantee a non GM source, our products are developed without use of

conventional (not organic) soy or rapeseed lecithin.

Our products are developed preferably without lecithin

If lecithin is deemed necessary, the following types will be used:

o Organic soy, organic rapeseed or organic maize lecithin

o Sunflower lecithin (conventional or organic)

It is forbidden the use of conventional soy, rapeseed or maize lecithin for all new products

developed since mid 2013.

This applies to primary ingredients added, and if possible to composed ingredients (e.g.

chocolate).

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7.12 Appendix L - Claim Policy

Introduction 7.12.1

Organic consumers expect healthy products.

Organic production is based on the principle of careful processing in order to keep most of the

intrinsic nutrients of the sourced raw material. Most organic products are made of unrefined

cereals, sugars and salt.

Expert organic consumers have also traditionally been looking for specific raw materials or old

varieties with nutritional benefits. In recent years, old varieties of wheat like spelt, and exotic

products, like amaranth, agave syrup or even coconut water, which were unknown in Europe but

consumed in other parts of the world, have been (re)discovered.

These new or re-discovered raw materials combined with careful processing can help to improve

the nutritional profile of food products, allowing us to develop products with nutritional claims,

according to regulation EU 1924/2006.

Scope 7.12.2

This policy applies to nutritional organic brands (cf. Introduction).

Policy 7.12.3

Our new products are developed with a nutritional claim (e.g. low in saturated fat, source of

protein, vitamins, minerals) or an ingredient claim on final product (e.g. only pomegranate juice,

whole cereals).

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7.13 Appendix M – Nutritional Profile Guideline

Introduction 7.13.1

A balanced diet is an essential requirement for good health and should provide adequate amounts

of energy and nutrients for health and well-being. To this end regulatory bodies over the world

have defined nutrient recommendations and reference values for adequate intake of nutrients.

Organic products have traditionally been consumed by people aware of a link between diet and

health. Though organic products are not dietetic, they are expected by organic consumers to be

designed in a conscious way. This is why Wessanen has defined in this guideline his strategy to

achieve an optimised nutritional profile of our products.

In doing so, the various developments in the field of nutrition and health are taken into account.

This includes for example the increase of obesity in Western countries mainly caused by a lack of

physical exercise and energy intake exceeding daily needs. For all countries for which data is

available, the underlying determinants of non-communicable diseases are largely the same.

Factors that increase the risks of non-communicable disease include elevated consumption of

energy-dense, nutrient-poor foods that are high in fat, sugar and salt; reduced levels of physical

activity and use of tobacco (I).

There is a consensus that diets in Europe are too rich in some nutrients. The WHO Global

Strategy on Diet, Physical Activity and Health (2004), recommended the private sector to limit

the levels of trans fatty acids, saturated fatty acids, salt and free sugars in existing products (I).

Furthermore, European regulation on health and nutritional claims proposed to establish

nutritional profiles as conditions for a product to carry a claim (I). However, these nutritional

profiles have not been established yet. In the meantime, there have been private initiatives to

develop standards allowing identifying products with a better nutritional profile (II). An

international standard is Choices Product Criteria. These criteria define per product category the

maximum amount of added sugar, saturated fatty acids (SAFA), trans fatty acids (TFA), sodium

and minimum amount of dietary fibres (III). These and future new developments will provide the

basis for definition of the Wessanen product quality charter on Nutritional Profile Guidelines.

Scope 7.13.2

The Nutritional Profiles guidelines apply to all products from the organic nutritional brands (cf.

Introduction –General).

Guidelines 7.13.3

The following steps will facilitate definition of a portfolio at Wessanen containing products in line

with nutritional profile guidelines:

Selecting an optimised nutritional profile based on international advisory bodies and state-

of-the-art scientific insights and keeping this information updated, while applying the

Choices system.

Defining priorities for Wessanen product categories based on this optimised nutritional

profile.

Optimizing the nutritional profile of the products in our product portfolio via innovations.

When these constraints are judged incompatible with the taste profile expected, it is

possible to develop the product outside of the constraints.

Following up the level of conformity with these nutritional profiles in the different

categories and monitor progress.

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Literature 7.13.4

I. World Health Organisation (2004). Global Strategy on Diet, Physical Activity and

Health. Fifty-seventh World Health Assembly. WHA57.17.:

http://www.who.int/dietphysicalactivity/strategy/eb11344/strategy_english_web.pd

f

II. REGULATION (EC) No 1924/2006 OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL of 20 December 2006 on nutrition and health claims made on foods

III. Development of international criteria for a front of package food labelling system:

the International Choices Programme. AJC Roodenburg1, BM Popkin2 and JC

Seidell- European Journal of Clinical Nutrition (2011) 65, 1190–1200.:

http://www.nature.com/ejcn/journal/v65/n11/pdf/ejcn2011101a.pdf

IV. Choices Product Criteria – Version 2.3 – 1st December 2011.:

http://www.choicesprogramme.org/what-choices/science-research/product-criteria