CHAIN OF CUSTODY POLICY

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1 CHAIN OF CUSTODY POLICY May 2012 Date of latest review: March 2013 Sustainable Agriculture Network and Rainforest Alliance Sustainable Agriculture Network (SAN): Conservación y Desarrollo, Ecuador Fundación Interamericana de Investigación Tropical, Guatemala Fundación Natura, Colombia ICADE, Honduras IMAFLORA, Brazil Nature Conservation Foundation, India Pronatura Sur, Mexico Rainforest Alliance SalvaNatura, El Salvador

2 Copies of this document are available for free at the Sustainable Agriculture Network and Rainforest Alliance websites: If you are not able to access this document electronically, you may request hard copies for a reasonable cost-covering price at: Sustainable Agriculture Network Secretariat Rainforest Alliance P. O. Box San José Costa Rica Please send your comments or suggestions concerning the content of this Sustainable Agriculture Network Rainforest Alliance document to: Or via regular mail to: Sustainable Agriculture Network Secretariat Rainforest Alliance P. O. Box San José Costa Rica SAN-P

3 CONTENTS Introduction... 4 The Sustainable Agriculture Network s Mission... 4 Sustainable Agriculture Network, Rainforest Alliance and the Chain of Custody certification process... 4 Summary of the CoC Process... 5 Sources... 5 Terms and Definitions... 6 Objectives Scope Implementation Dates of the General Conditions Types of Participating Operators Single Participating Operator Multi-site Participating Operator Chain of Custody Certification Requirements for Participating Operators Obtaining and Maintaining a Participating Operator s Certification Cancelation of a Participating Operator s Certification Chain of Custody Audit Cycle Audit Scope and Rules Single Participating Operator Multi-Site Participating Operator Conformity Evaluation Rules for the Multi-Site Participating Operator s Certificate Contents Force Majeure SAN-P

4 Introduction The Sustainable Agriculture Network (SAN) is a coalition of independent nonprofit conservation organizations that promote the social and environmental sustainability of agricultural activities by developing standards. Standard and policy development and review are coordinated by the SAN Secretariat based in San José, Costa Rica. Accredited Certification Bodies certify farms, group administrators, cattle production systems or Participating Operators that comply with SAN s standards and policies. Certified farms, group administrators or Participating Operators can apply for use of the Rainforest Alliance Certified seal for products grown on certified farms. Since 1992, more than 1000 certificates for more than 400,000 farms - including smallholders, as well as plantations - in over 30 countries have met the SAN standards. These certificates include more than 1,000,000 hectares (ha) for more than 25 crops including coffee, cocoa, banana, tea, pineapple, flowers and foliage, and citrus. Other crops include, apple, avocado, cherry, grapes, heart of palm, kiwi, macadamia, mango, pear, rubber and vanilla. The SAN is composed of the following members: Conservación y Desarrollo (C&D), Ecuador; Fundación Interamericana de Investigación Tropical (FIIT), Guatemala; Fundación Natura, Colombia; ICADE, Honduras; IMAFLORA, Brazil; Nature Conservation Foundation, India; Pronatura Sur, Mexico; SalvaNatura, El Salvador; and Rainforest Alliance. The Sustainable Agriculture Network s Mission The SAN promotes efficient agriculture, biodiversity conservation and sustainable community development by creating social and environmental standards. SAN fosters best management practices across agricultural value chains by encouraging farmers to comply with SAN standards and by motivating traders and consumers to support sustainability. SAN pursues its mission by: Integrating sustainable production of crops and livestock into local and regional strategies that favor biodiversity conservation and safeguard social and environmental well-being. Raising awareness among farmers, traders, consumers and business leaders about the interdependencies among healthy ecosystems, sustainable agriculture and social responsibility. Impressing upon business leaders and consumers the importance of choosing products grown on environmentally sustainable and socially responsible farms. Stimulating dialog among environmental, social and economic groups, North and South, about the benefits of sustainable agriculture. Sustainable Agriculture Network, Rainforest Alliance and the Chain of Custody certification process The SAN and Rainforest Alliance define the standard and policy for Chain of Custody (CoC) audits and certification of Participating Operators. They also develop and maintain the accreditation system for Certification Bodies that provide CoC certification. The Certification SAN-P

5 Body certifies that Participating Operators comply with the CoC Standard and Policy, and conducts CoC audits with authorized CoC auditors. A CoC Committee supports the standard and policy development and facilitates ongoing stakeholder outreach in order to improve the CoC program. The Rainforest Alliance works with companies to comply with the CoC requirements in order to protect the credibility of the Rainforest Alliance Certified seal; assuring farmers, businesses and consumers that the seal only appears on products from certified farms. The Rainforest Alliance also manages ongoing compliance by monitoring the traceability of products from farms to final products, a requirement to use the Rainforest Alliance Certified seal. Summary of the CoC Process Interested companies should contact the Rainforest Alliance or a SAN/Rainforest Alliance (SAN/RA) authorized Certification Body to receive application information and obtain relevant documents. Certification Bodies can be found at the following Sustainable Agriculture Network website: Companies are also required to register at the Rainforest Alliance Marketplace, Once the organization has registered on the Rainforest Alliance Marketplace and submitted the CoC application, the Certification Body will supply certification information, including but not limited to: an initial quote for services, an agreement for services, and an audit date and plan. Once all services are agreed upon and payment for the audit is made, the newly named Participating Operator and the audit team will prepare for and execute the audit. Once the audit report has been finalized, it is analyzed by the Certification Body for a decision as to if the Participating Operator has earned their CoC Certificate. Certification is therefore effective as of the date that the Certification Body issues the certificate. If the certification is not awarded, the Participating Operator has to make the necessary changes to address nonconformities and request a Verification Audit. Upon being awarded the CoC Certification the Certified Participating Operator is listed on the Certification Body s website. Sources The following sources have been consulted: FSC-STD Standard for Multi-site Certification of Chain of Custody Operations CoC-01 SmartWood Chain of Custody Supplementary Guide to Evaluation G-28 SmartWood Evaluation Handbook (Version November 25, 2009) Rainforest Alliance Certified Sustainable Agriculture Use of Seal Guidelines SAN-P

6 Terms and Definitions Term Annual Audit Audit Audit Cycle Authorized Auditor Buyer Cancellation Cancellation Notification Certification Agreement Certification Audit Certification Body Certified Farm Certified Participating Operator Certified Product Definition Annual audits evaluate corrective actions of previous minor non-conformities and the Traceability Principle. For the latter, the SAN/RA accredited Certification Body receives a report from the Rainforest Alliance about the Participating Operator s transactions for the previous twelve (12) months. Annual audits shall be conducted to start respectively year 2 and year 3 of the audit cycle as a desk audit (first and second annual audits). A systematic, independent and documented process for evaluating an individual entity or an entity with more than one site regarding to compliance with the SAN/RA Chain of Custody Standard and Policy. Audits can be on-site or desk audits, that are conducted based on the stage of the audit cycle for the entity; presence of major or minor nonconformities; and complaints. A three (3)-year period that begins with the certification audit and is followed by two (2) annual audits. The following cycle begins again with a certification audit. Person contracted by a SAN/RA accredited Certification Body and that meets the SAN requirements for conducting an external audit of the Chain of Custody Standard and Policy. Any person or organization that takes legal or physical ownership of Rainforest Alliance Certified products, for example, traders, brokers, auctioneers, processors, intermediaries, exporters. This status applies immediately when the Participating Operator receives the official notification from the Certification Body it did not meet the requirements of the Chain of Custody Standard or Policy. The Participating Operator is deactivated from the traceability system and is no longer premised to use the Rainforest Alliance Certified seal on the products that they sell from that date onward. A document issued by the accredited Certification Body to the Participating Operator indicating the cancellation of its Chain of Custody certificate. The document signed by the Certification Body and the client wherein is detailed the rights and responsibilities of both parties regarding Chain of Custody. An audit which takes place to start year 1 and evaluates conformity with all current and relevant SAN policies and standards. A SAN/RA accredited organization that is responsible for deciding if a Chain of Custody certification is granted, pending verification or cancelled. It can subcontract Inspection Bodies for performing audits in which case it is then responsible for ensuring the quality of the Inspection Body s services. A farm that complies with the requirements of the respective SAN standards and policies proven by a certification audit process led by a SAN accredited Certification Body. A Participating Operator is considered Chain of Custody Certified, once it has been awarded the Chain of Custody certification and only while the certification is valid. Products and byproducts produced on a farm in compliance with applicable SAN standards and policies. The certified product complying with the Chain of Custody System may use the Rainforest Alliance Certified seal, as long as SAN-P

7 Term Chain of Custody Chain of Custody System Client Corrective Action Critical Mixing Points Desk Audit Document Exceed Volume Farm Financial Service Entities Inspection Body Internal Inspections Legal ownership Local/Regional Entities, Offices Management System Marketplace Definition there is compliance with the Rainforest Alliance Certified Sustainable Agriculture Use of Seal Guidelines. All the steps in the value chain that are taken from primary production in a SAN certified farm through to final consumption, including all processing, transformation, manufacturing, storing, and transportation stages, where progress of the product towards the following stage in the value chain implies a legal change in materials or products. Set of documents, procedures, processes and policies that must be implemented by the Participating Operator for carrying out the Chain of Custody certification. Company, organization or any other entity that has not applied for Chain of Custody certification. The client is considered a Participating Operator once it has applied for the Chain of Custody certification. Action which corrects a nonconformity. Effective corrective actions focus on addressing the specific nonconformity identified during an audit, as well as the root cause to eliminate and prevent recurrence of the nonconformity. Places or situations in the supply chain where the products from non-certified sources may enter or where certified products may leave the system. Evaluation conducted without a site visit. A desk audit can be performed if sufficient evidence can be collected from documents and interviews only; and a physical site visit is not required to demonstrate conformance. The information and means of support. It can be on paper, sample, photograph or magnetic, optic or electronic disk. The solicitant is exceeding the volume when the volume requested for a Transaction Certificate is higher than the volume available for that specific supplier during a specific time period. A unit of agriculture or cattle production may be comprised by several adjacent or geographically separated plots subject to audit certification (e.g., one plantation, ranch or small producer farm). Those entities which service is granting capital using the product as guarantee; (e.g., bank, credit agencies). Unit that conducts Chain of Custody certification, annual, verification, research and non-programmed audits of Participating Operators. An Inspection body must comply with the sub-contract conditions defined by the Certification Body. First party evaluation of the Participating Operator to the SAN/RA Chain of Custody Standard and Policy. The right to the possession, the privilege use of and the power to convey the rights and privileges over a product. Units of property or a member of a head office that acquires a Rainforest Alliance Certified product. The system whereby an operation is able to trace and keep separate the movement of Rainforest Alliance Certified products across its facilities. The management system includes the documented policies and procedures, recording of product movements and processing points, as well as the mechanisms to ensure the integrity of products from certified farms during receiving, handling, storage, processing, clearance, outsourcing and shipping processes. Rainforest Alliance s Marketplace is an online platform that provides traceability of certified product from the farm to the market through transaction certificates. It is also used as the Rainforest Alliance Certified Use of Seal SAN-P

8 Term Mass Balance Minimum Percentage of Content Multi-site Participating Operator Multi-site System Administrator Nonconformance Complaint Non-Programmed Audit On-site Audit Participating Operator Processes Rainforest Alliance Certified Products Rainforest Alliance Certified Seal Definition approval system for all Participating Operators. All Rainforest Alliance Certified farms and entities involved in the supply chain of products from Rainforest Alliance Certified farms must register at The Chain of Custody mass balance system consists of the reconciliation of inputs and outputs of the certified product through the manufacturing process, including all product variants or derivates resulting from the original certified product. Permitted products are listed in the SAN/RA List of Permitted Mass Balance Products. There must always be compliance with the Rainforest Alliance Certified Sustainable Agriculture Use of Seal Guidelines. Requirements for making claims on single ingredient products as defined in the current version of the Rainforest Alliance Certified Use of Seal Guidelines. This is an entity registered on Marketplace that administers two or more sites where processing of certified product occurs It is the entity that signs the certification agreement with a SAN accredited Certification Body and takes responsibility for the development, execution and maintenance of the internal management system and for verification of each individual site s compliance with the Chain of Custody standard and policy documents. Products coming from sites covered by a Multi-site certificate can be of different types and can be produced or manipulated following different methods and procedures. The Multi-site Participating Operator shall have consent from each site to participate in the certification. The sites do not have to be in a legal relationship with each other nor with the Multi-site administrator. The legal or administrative representative of a Multi-site Participating Operator. It ensures compliance of all sites with the Chain of Custody system through internal annual audits. A document sent to the Certification Body which includes reason that the party submitting the claim believes a Participating Operator is not in conformance with the Chain of Custody Standard or Policy. An audit planned by the Certification Body as a method of supervision with respect to the Participating Operator s year-round compliance with the Chain of Custody Standard and Policy. This process is not announced to the Participating Operator. It can occur at any time during the audit cycle. This type of evaluation is conducted at the Participating Operator s sites or facilities. The aim is to evaluate the compliance to the Chain of Custody requirements by observing practices, analyzing documentation, evaluating existing infrastructure and interviewing the employees, management, and/or administration. Any company, association, factory, processing unit or other entity that applies for SAN/RA Chain of Custody certification. The actions of transforming a product, by mixing or making any changes, from its original state to a different, new and/or end product. Products derived from crops grown on a farm and products derived from cattle at cattle production systems that comply with the respective SAN standard and policies. These include processed or semi-processed products that have not been mixed with products from non-certified farms. Rainforest Alliance Inc. is the owner of the Trademark governed by a license agreement and other rules associated with the use of seal. Once a client has been certified to the SAN/RA Chain of Custody standard, it can request a SAN-P

9 Term Rainforest Alliance Certified Use of Seal approval Rainforest Alliance Traceability System Research Audit Single Participating Operator Site Supply Chain Transaction Certificate Validation Verification Audit Volume Reconciliation Definition license for using the Rainforest Alliance Certified seal. The continuous use of the seal is subject to maintaining the SAN/RA certification and demonstrating compliance according to the license and Rainforest Alliance Certified Sustainable Agriculture Use of Seal Guidelines. Authorization that Rainforest Alliance or its assigned representative grants to client to use the Rainforest Alliance Certified seal on its products or promotional documents. This approval is known as a License Agreement. The Rainforest Alliance System that tracks products from Rainforest Alliance Certified farms throughout the supply chain. A non-programmed process that corresponds to a complaint about a certified Chain of Custody Participating Operator. Its objective is to evaluate the Participating Operator s compliance with the Chain of Custody Standard and Policy. The cost of the process is covered by the authorized Certification Body. Participating Operator that buys, sells, processes or packages products from SAN certified farms claimed as Rainforest Alliance Certified. The facility/location being subject to evaluation in a Single Participating Operator s certification; or a facility/ location that participates with other sites in the Multi-site certification scope. In this last case, these sites do not possess individual certificates, as they are covered by the Multi-site system administrator s Multi-site certification. The network of supply, manufacture, and distribution of certified or noncertified materials as Rainforest Alliance Certified within intermediary and/or finished products that ultimately are distributed to end consumers. A document which certifies that a product has been bought or marketed as Rainforest Alliance Certified. The process of reviewing the date of and total volume of a sale in order to verify that the product comes from a Rainforest Alliance certified farm and/or supplier. A verification audit is conducted to evaluate compliance with at least one (1) major nonconformity or more than ten (10) minor nonconformities that were detected in a certification, annual, research or non-programmed audit. It shall be conducted no later than four (4) months after the initial audit in which the non-conformities were detected and notification is received from the Certification Body that a verification audit is authorized. A report in which the Participating Operator submits to the Rainforest Alliance the quarterly total of volume of product packed into their packaging bearing the Rainforest Alliance Certified seal. SAN-P

10 Objectives This SAN-P-3-1 defines the requirements to be met and maintained in order to qualify as a certified Chain of Custody Participating Operator. The objectives of this policy are to: a) Explain the scope of the Chain of Custody system for Participating Operators (Single or Multi-site); b) Describe the traceability systems permitted by the SAN and Rainforest Alliance; c) Set the implementation date for the Chain of Custody system; d) Explain the Chain of Custody audit cycle; e) Determine the type and frequency of Chain of Custody audits; f) Classify the status of the Participating Operator; g) Clarify the conditions and consequences of cancelation of the Chain of Custody certification. Scope The Chain of Custody system applies to any Participating Operator that legally owns or manipulates the product originating from a certified farm and matches with any of the following categories: a) Certified farms that handle, buy or mix products originating from non-certified farms. b) Certified group administrators that handle, buy or mix products originating from noncertified farms. c) Entities that buy or sell product from certified farms or group administrators and mix it with product originating from non-certified farms or group administrators; d) Entities exporting, importing or commercializing, brokers, warehouses or auctioneers that handle and claim products originating from certified farms or group administrators as Rainforest Alliance Certified; e) Entities processing, selling or packaging final products with Rainforest Alliance Certified claims; f) Entities receiving the approval to use the Rainforest Alliance Certified seal on packaging of the final product. The Chain of Custody system does not apply to: a) Certified farms that do not handle, buy or mix products from non-certified farms; b) Certified group administrators that do not handle, buy or mix products from non-certified farms; c) Entities that only provide financial services and who act on behalf of a third party who claim product originating from certified farms; d) Entities that only provide transport, storing, or brokerage services and come into physical, but not legal ownership of certified product; e) Subcontracted entities or any outsourcing activity in which legal ownership of Rainforest Alliance Certified product is not taken; f) Entities retailing to the end consumer that have physical possession of product bearing the Rainforest Alliance Certified seal on the final packaging for consumption; g) Entities and their subsequent supply chain that do not wish to recognize, offer or commercialize their product as Rainforest Alliance Certified or make claims to that effect. SAN-P

11 Implementation Dates of the This SAN-P-3-1 becomes effective on May 1, The SAN/RA Chain of Custody system requires that all entities defined within its scope achieve chain of custody certification in order to have the right to use the Rainforest Alliance Certified seal and participate in the Rainforest Alliance Marketplace and traceability system. Due to the need to implement this requirement across a large number of operations in many different supply chains, SAN/RA believe that a transition period is necessary for an appropriate phase-in. The rules for this are currently under development and will soon be added to this policy and communicated to the entities participating in the SAN/RA system. All entities defined within the scope of the SAN/RA Chain of Custody system above and registered on Marketplace by February 1, 2012, must apply for Chain of Custody certification by May 1, These entities shall be audited no later than October 31, Entities registered on Marketplace after February 1, 2012, shall apply for certification within twelve months following their registration. These operators shall obtain the Chain of Custody audit within 18 months following their registration in the system. If an entity registered on Marketplace does not apply for the Chain of Custody certification by the dates indicated above, the following applies: a) The right to use the Rainforest Alliance Certified seal may be cancelled; b) The registered entity may be deactivated in the Rainforest Alliance Marketplace; therefore, Transaction Certificates will be denied. SAN-P

12 1. General Conditions a) The Participating Operator shall contact a SAN/RA accredited Certification Body to apply for the Chain of Custody certification. b) The Participating Operator shall comply with the Chain of Custody Standard and Policy, and with the Rainforest Alliance Certified Sustainable Agriculture Use of Seal Guidelines, as well as any subsequent policies and advice that support the Chain of Custody requirements. c) Participating Operators shall comply with the following types of audits: i. Certification Audit: First time applicants and/or Participating Operators that are reapplying after receiving a cancelation shall be subject to an on-site certification audit. ii. On-site Audit: The audit shall be conducted on-site if the Participating Operator has applied for the first time or if it is applying after a cancelation of certification. It shall also be an on-site audit when the Participating Operator is applying for the next audit cycle and during the previous cycle major or minor nonconformities were detected. iii. Desk Audit: Desk audits are conducted when starting a new cycle, and the Participating Operator did not have any major or minor nonconformities or nonconformance claims filed against it during the last audit cycle. iv. Annual Audit: Annual audits evaluate corrective actions of previous minor nonconformities and the Traceability Principle through desk or onsite audits. For the evaluation of the Traceability Principle, the SAN/RA accredited Certification Body receives a report from the Rainforest Alliance about the Participating Operator s transactions for the previous twelve (12) months. Annual audits shall be conducted to start respectively year 2 and year 3 of the audit cycle as a desk audit (first and second annual audits). If there are doubts, the SAN/RA accredited Certification Body requests information from the Participating Operator and if the evaluation detects nonconformities, this would result in a verification audit. v. Verification Audit: Nonconformities found during annual audits shall be subject to either on-site or desk verification audits. A verification audit shall be conducted to evaluate compliance with at least one (1) major non-conformity or more than ten (10) minor nonconformities that were detected in a certification, annual, research or nonprogrammed audit. It shall be conducted no later than four (4) months after the initial audit in which the non-conformities were detected and notification is received from vi. the Certification Body that a verification audit is authorized. Research and Non-programmed Audits: Research audits and non-programmed audits can be conducted at any time through either on-site or desk audits. d) Certified farms that handle, buy or mix products originating from non-certified farms will be audited against the SAN-S-5-1 Chain of Custody Standard in addition to the standards defined in SAN s SAN-P-1-1 Farm Certification Policy within the scope of a farm audit. The farm s evaluation with Sustainable Agriculture Standard s critical criterion 1.10 on traceability will consequently be replaced with the criteria of the SAN- S-5-1 Chain of Custody Standard. e) Certified group administrators that handle, buy or mix products originating from noncertified farms will be audited against the SAN-S-5-1 Chain of Custody Standard in addition to the standards defined in SAN s SAN-P-2-1 Group Certification Policy within the scope of a group administrator audit. The group administrator s evaluation with SAN-P

13 Group Certification Standard s critical criterion 2.3 on traceability will consequently be replaced with the criteria of the SAN-S-5-1 Chain of Custody Standard. f) Upon being awarded the Chain of Custody Certification, a Participating Operator may make claims that products come from certified farms and may use the Rainforest Alliance Certified seal as established by the Rainforest Alliance Certified Use of Seal Guidelines. g) Upon cancelation of a certification, any product sold prior to the cancelation and during the certification effective period will be a Rainforest Alliance Certified product, as long as documentation proves that the available product was sold while the certificate was valid. h) The following traceability models are permitted by the SAN and Rainforest Alliance: i. Identity Preserved allowed for all products ii. iii. Segregation allowed for all products Mass balance Permitted products are listed in the SAN-S-6-1 SAN/RA List of Permitted Mass Balance Products. All other products require formal written authorization of the Rainforest Alliance. 2. Types of Participating Operators The following operators are subject to the SAN RA Chain of Custody system: 2.1 Single Participating Operator This is an entity registered on Marketplace that has only one processing and/or storage site but may have multiple sales offices. The Chain of Custody certificate issued for a single Participating Operator is for one single entity, for example: a single raw material exporter; a cocoa processor that has only one processing facility and produces cocoa butter, liquor and powder. 2.2 Multi-site Participating Operator This is an entity registered on Marketplace that administers two or more sites where processing of certified product occurs. The Multi-site Participating Operator shall have consent from each site to participate in the certification. The sites do not necessarily have to be in a legal relationship with each other nor with the Multi-site administrator. The Multi-site administrator uses a central office or shared administration with one evaluation and reporting system to certify all its sites within one country, known as the Multi-site certification in countries of origin with a national scope, which applies to countries where the farms are certified that supply the products that are within the Chain of Custody audit scope. In countries that import these products, the Multi-site scope can be regional. Defined regions are Europe, the United States and Canada, and exclusively importing countries in the Asia-Pacific region. Any proposal for an additional region must be presented by the Certification Body to the SAN and Rainforest Alliance for approval. SAN-P

14 3. Chain of Custody Certification Requirements for Participating Operators 3.1 Obtaining and Maintaining a Participating Operator s Certification a) Chain of Custody Certification for Participating Operators is based on the Chain of Custody Standard and Policy, including each individual site in the case of a Multi-site participating operator. b) The certification is valid for three (3) calendar years and begins from the date that the first Chain of Custody certificate is granted by a SAN/RA accredited Certification Body. c) The maintenance of the Chain of Custody Certification is subject to annual audits and the renewal of the certificate. d) In order to obtain Chain of Custody certification, a Participating Operator must: i. Be evaluated in a certification audit conducted by a SAN/RA accredited Certification Body. ii. Comply with the contents of the Chain of Custody Standard and Policy. iii. Sign a Certification Agreement with the authorized Certification Body. iv. Comply with all administrative processes defined by the Certification Body. e) In order to maintain the status of Chain of Custody Certification, the Participating Operator must: i. Comply with the audits of the three (3) year audit cycle. ii. Collaborate with any type of audit justified by the Certification Body. iii. Comply with the conditions defined in the Certification Agreement. f) All cases that are not covered by this policy will be analyzed and decided upon by the respective SAN accredited Certification Body, which may consult the Rainforest Alliance and the SAN Secretariat for special cases. 3.2 Cancelation of a Participating Operator s Certification a) The status of cancelled applies to a Participating Operator s certification from the date of the notification from the SAN/RA accredited Certification Body that it did not meet the requirements of the Chain of Custody Standard or Policy or when it voluntarily withdraws. This can occur at any time during the Chain of Custody audit cycle. b) If a Participating Operator receives the communication from the Certification Body about the cancelling of its Chain of Custody certification, no sale or transfer of ownership of its product as Rainforest Alliance Certified products will be recognized as such from that date onward. c) Upon cancellation of the Chain of Custody Certificate, Participating Operators are required to inform their buyers about the implications for the use of the Rainforest Alliance Certified seal as laid out in this Policy. d) The cancelled Participating Operator can only sell its product as Rainforest Alliance Certified product if the sales contract is dated prior to the date of the cancelation notification from the Certification Body and if it does not exceed the volume registered with the Rainforest Alliance. e) As part of the cancelation process, the Participating Operator remains deactivated in all the systems, including the Traceability System of Rainforest Alliance. f) The cancelled Participating Operator shall not use the Rainforest Alliance Certified seal on any product or packaging, physical or electronic promotional material or media, as brochures or Web pages, signs or other type of documentation. SAN-P

15 g) In the case of a cancelled Participating Operator that opts to reapply for certification, product that enters into their possession after cancelation but before being newly certified shall not be sold as Rainforest Alliance Certified product. 4. Chain of Custody Audit Cycle a) The audit cycle lasts three (3) years, and is applicable to any type of Participating Operator. b) To start year one (1), the Certification Body conducts a Certification Audit of the Participating Operator to assess the conformity with the Chain of Custody Standard and Policy. c) During the first and second annual audit, the Traceability Principle will be assessed by means of a desk audit. Minor nonconformities will be assessed either by means of a desk or an on-site audit. These audits need to be conducted between twelve (12) and fifteen (15) months after the last audit. d) The Certification Body can decide to conduct a Research Audit or a Non-programmed Audit at any time during the Chain of Custody audit cycle. e) The three-year Chain of Custody audit cycle is illustrated by the following diagram: Verification Audit required after an annual or certification audit Annual Audit 1 to start Year 2 Research Audit or Non- Programmed Audit at any moment Certification Audit to start Year 1 Annual Audit 2 to start Year 3 SAN-P

16 5. Audit Scope and Rules 5.1 Single Participating Operator a) During an on-site audit, the auditor conducts a site visit to the office, factory, warehouse, or other location of a Single Participating Operator. b) At a desk audit, the Certification Body receives documentation requested or conducts telephone interviews of a single participating operator. 5.2 Multi-Site Participating Operator a) To apply as a Multi-site participating operator, the Multi-site system administrator acts as representative of all sites. b) The application of Multi-site Participating Operators includes a list of all the sites to be included in the certification scope. c) During an on-site audit, the auditor conducts a site visit to the office, factory, warehouse, or other location of the audit sample of sites selected for a Multi-site Participating Operator. d) At a desk audit, the Certification Body receives documentation from all the sites of the Multi-site Participating Operators where the certification audit was previously conducted. e) The Multi-site System Administrator of a Multi-site Participating Operator will receive one (1) on-site audit during each Chain of Custody audit cycle. f) A sample of sites will be audited and will be partly different during each certification cycle up until all sites included in the Chain of Custody scope have been visited. However, during an annual audit of minor nonconformities the same sites will be audited for conformity. g) The sample of sites will be determined by using the square root of the total number of sites. h) The sample size shall be rounded up to the next whole number; for example, indicates that 4 sites must be audited. i) The sites of the Multi-site Participating Operator that will be visited by the auditor must be selected in such a way that they represent statistically the complete list of all participating sites, processes and products, by means of risk-based samples and random selection. The applied sampling method is stratified sampling. j) The strata can be selected with the following parameters: i. Geographic distribution; ii. Activities and/or products produced; iii. Size of participating sites; iv. Areas of improvement of the management system identified by internal reports or certification body audits. 6. Conformity Evaluation a) Conformity evaluation is based on the action taken in order to comply with the SAN-S-5-1 Chain of Custody standard evaluating the degree of integrity of a Rainforest Alliance Certified product. b) A SAN/RA accredited Certification Body is assuring that the product handled by the Participating Operator is certified. SAN-P

17 c) The evaluation findings are classified by an authorized Chain of Custody auditor as conformities or nonconformities. d) Conformities are the actions taken to assure the compliance with the standard and the transparency of the system. e) Nonconformities are the actions that compromise the compliance with the standard or the transparency of its system. Nonconformities may also result from a lack of action or refusal to act in conformance with Chain of Custody requirements. Non-conformities are further divided into major and minor. f) A major nonconformity shall be corrected into conformity before the verification audit and prior to award of the Chain of Custody certification, maximum four (4) months after the Certification Audit. g) A minor nonconformity shall be corrected into conformity before the annual audit, or maximum twelve (12) months after the certification audit. h) Observations shall be considered before the next certification audit s cycle. i) The following table defines the three (3) evaluation finding categories - major and minor nonconformities and observations: Concept Rule Consequence Further characteristics Major Nonconformity (MNC) Poses proven risk to certified product integrity due to mixing with uncertified product, significant system gaps, untrained personnel or seal use violation No MNC s permitted for CoC certification CoC certification not awarded, or cancelled. Certified product chain broken and seal use of end product affected. A systemic fault, not due to an isolated incident Affects more than one unit of the participating operator The basis of the system and procedure is not functional The Participating Operator shows intentional indifference regarding minor non-conformities, with the same minor nonconformities being repeated from the previous year. This translates to a MNC of a system criterion. A minor non-conformity of a previous audit cycle will be minor nonconformity (mnc) Finding of medium impact for the CoC-system, product or seal integrity Maximum 10 (out of a total of 20 criteria) mnc s permitted for CoC certification Participating Operator has to correct all mnc s within 12 months One-time occasion finding, but the respective system elements are in place Only affects one unit, but all other units of the Participating Operator are performing well Observation (obs) A comment to improve the CoC system on the long run or on a document level No consequence for CoC certification status Participating Operator has to correct all observations within 3 years Like an mnc, with broader timeline of correction SAN-P

18 Audit and certification process implications Major Nonconformity (MNC) scored as a MNC if the mnc is not addressed by the next audit cycle. A Major Non-Conformity can be closed before the final meeting of an audit, if it relates to the lack of or an improvement to a required document. If evidence to correct the MNC is not presented before the final meeting of the CoC-audit, then the Participating Operator will be submitted to a Verification Audit. minor nonconformity (mnc) A CoC-auditor can consider upgrading a mnc from a previous audit to a MNC proven that the Participating Operator s CoC-system is not able to conduct corrective actions. If eleven (11) or more mnc s are detected during the first certification audit, then the Participating Operator can present documentation to reduce the number of mnc s to ten (10) or less before the final meeting of a CoC-audit, if it relates to the lack of or an improvement to a required document and there is no proven potential impact to the certified product or seal integrity. If evidence to reduce the number of mnc s is not presented before the final meeting of the CoC-audit, then the Participating Operator will be submitted to a Verification Audit. Observation (obs) A CoC-auditor can consider upgrading an observation from a previous audit to a mnc. SAN-P

19 7. Rules for the Multi-Site Participating Operator s Certificate Contents a) A Multi-site Participating Operator may hold a certificate for less than the total number of sites registered to its name. b) A Participating Operator may hold more than one Chain of Custody certificate and have a combination of Single and Multi-site certificates, depending on how the Participating Operator manages the sites. c) A Multi-site Participating Operator may add up to but not more than 25% of the total actual sites included in the certificate scope without a new external audit, if these new sites were inspected internally beforehand and found to be compliant with the Chain of Custody Standard and Policy. If the Participating Operator decides to add more than 25% of the total sites then a Certification Audit shall be required with a Certification Body. d) The awarded certificate will include the names and locations of all sites included in the Multi-site Participating Operator s certification. 8. Force Majeure a) Participating Operators may be subject to special circumstances that limit their ability to be audited. b) In these cases, the SAN and Rainforest Alliance have the authority and the responsibility to analyze these on a case-by-case basis and grant exceptions when it applies. c) Exceptional situations which may lead to exceptions being granted may include: Natural disasters (earthquakes, hurricanes, floods and others); Wars or other demonstrated acts of violence; Policy or regulatory circumstances beyond the control of the participating operator; and, Situations of unexpected disability in members of an audit team. SAN-P

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