GENERIC MANUAL ON QUALITY MANAGEMENT SYSTEM FOR SMALLHOLDER HORTICULTURAL FARMER GROUPS IN KENYA FOR CERTIFICATION TO EUREPGAP OPTION 2

Transcription

1 Page 1 of 127 GENERIC MANUAL ON QUALITY MANAGEMENT SYSTEM FOR SMALLHOLDER HORTICULTURAL FARMER GROUPS IN KENYA FOR CERTIFICATION TO EUREPGAP OPTION 2 Prepared by: Agribusiness & Allied Kenya Ltd (Nairobi Kenya) Standards & Solutions Consulting Ltd (Nairobi Kenya) The International Centre of Insect Physiology & Ecology (Nairobi Kenya) November 2006

2 Page 2 of 127 TABLE OF CONTENTS ACKNOWLEDGEMENT... 7 PREAMBLE... 7 PART 1: QUALITY MANAGEMENT SYSTEM... 8 Introduction Structure of Internal Quality Management and Control System (ICS) Organization brief Legality (Legal entity) Administrative structure Management structure Responsibilities and duties Group overall policy Group s goals Training and advice to farmers Quality Manual Document control Record control Complaints handling Internal audit/ inspection and management review Traceability and product segregation Sanctioning Withdrawal of certified products Use of EUREPGAP logo Subcontractors/service providers Sales and Distribution PART II: CONTROL POINTS AND COMPLIANCE CRITERIA Processes in KSHG Production Traceability Record keeping and internal self-inspection Choice of variety Site history and site management Risk assessment for new agricultural site Site management Crop rotation Soil management Fertilizer usage and storage KSHG fertilizer use policies Fertilizer application records Fertilizer application machinery Fertilizer stores Irrigation... 24

3 Page 3 of Predicting water requirements Irrigation method Quality of irrigation water Effective ways of irrigating Pesticide usage and storage KSHG pesticide policies Sprayer calibration and maintenance Disposal of empty pesticide containers, surplus pesticide, tank washings and obsolete pesticides Pesticides application records Pre-harvest interval Pesticides stores Personal protective equipment Harvesting Collection centres Waste and pollution management Pollution management plan Waste management Worker health, safety and welfare Environmental issues Bibliography Terms and definitions ANNEX 1: STANDARD OPERATING PROCEDURES PART 1 (QMS) A Procedure for Training A Document and Record Control Procedure A Complaints Handling Procedure A Internal Audit Procedure A Corrective Action Procedure A Traceability Procedure A Procedure for Sanctions and Appeals A Produce Recall Procedure A Use of EUREPGAP Logo, Trademark and Registration Number Procedure A Procedure for Sub-Contractors ANNEX 1 STANDARD OPERATING PROCEDURES PART II (CPCC) B Seeds Procurement Procedure B Site History and Site Management Procedure B Fertilizer Use Procedure B Water Management Procedure B Compliance With Pre-Harvest Intervals Procedure B Maintenance and Calibration of Equipment Procedure B MRL Sampling Procedure B Pesticide Preparation and Mixing Procedure B Harvesting Process Hygiene Procedure... 67

4 Page 4 of B Collection Centre Hygiene Procedure B Emergency Procedures B Personal Protective Equipment Cleaning Procedure ANNEXES 2 FORMS - PART 1 (Quality Management System) A Farmer Register A Training Attendance Record A Training Record A Internal Documents Master List A External Documents Master List A Record Master List A Documents/Records Issue Register A Complaints Logs A Audit Program Form A Audit Plan Form A Audit Summary Report A Corrective Action Report Form A Approved Suppliers/Subcontractor List A Inputs Checklist A Transport/Vehicle Checklist A Supplier Evaluation Checklist ANNEX 2 FORMS PART II (CPCCs) B Planting Calendar B Seed Variety List B Seed Treatment Record B Crop History Record B Crop Rotation Plan B Scouting Record B Calibration Record B Farmer MRL Testing Plan B Stock Inventory B Cleaning Schedule B Waste and Pollution Management ANNEX 3: CONTRACTS A Farmer vs. Farmer Group Contract (A guide to drawing a contract) B Farmer Group vs. Service Provider Contract (A guide to drawing a contract) C Farmer Group vs. Exporter Company(s) Contract (A guide to drawing a contract) ANNEX 4: JOB DESCRIPTION AND SPECIFICATION Production Manager Technical Manager Agronomist EUREPGAP Internal Auditor Technical Assistant Collection Center Head

5 Page 5 of Sprayer Operator ANNEX 5 RISK ASSESSMENT GUIDELINES ANNEX 6. ENVIRONMENT MANAGEMENT PROTOCOL

6 Page 6 of 127 LIST OF ABBREVIATIONS ADM - Administration BSMDP - Business Services Market Development Project CAR - Corrective Action Request CB - Certification Body CC - Collection Centre CCP - Critical Control Point CPCC - Control Points Compliance Criteria DFID - Department for International Development of the United Kingdom GMO - Genetically Modified Organism GTZ - Gesellschaft fur Technische Zusammenarbeit GmbH PSDA - Promotion of Private Sector Development in Agriculture HACCP - Hazard Analysis Critical Control Point ICIPE - International Centre of Insect Physiology and Ecology ICS - Internal Control System ID - Identification IPM - Integrated Pest Management KSHG - Kenya Smallholder Growers LPO - Local Purchase Order MD - Managing Director MN - Manual MRL - Maximum Pesticide Residue Level NGO - Non - Governmental Organization PCN - Produce Collection Note PHI - Pre-Harvest Interval PL - Plan PMO - Produce Marketing Organization PPE - Personal Protective Equipment PR - Procedures PRN - Produce Receipt Note QMR - Quality Management Representative. QMS - Quality Management System REC - Records REV - Revision SCH - Schedule TA - Technical Assistant WHO - World Health Organization

7 Page 7 of 127 ACKNOWLEDGEMENT Development of the Generic Manual on Quality Management System for Smallholder Horticultural Farmer Groups in Kenya for EUREPGAP Certification under Option 2 was financially supported by BSMDP (DFID funded Project) and GTZ Germany. Technical facilitation in the development of the manual was provided by GTZ Germany. The support of GTZ-PSDA (Ministry of Agriculture Kenya) in this initiative is highly appreciated. Equally appreciated is the enthusiastic participation of export smallholder horticultural farmer groups, especially through their animated discussions and experiences, which contributed more to the development of this manual than they would realize. Contribution of horticultural exporters in this endeavour is duly acknowledged. This manual is an output of the BSMDP / GTZ Generic QMS Manual Testing Project managed by the International Centre of Insect Physiology and Ecology (ICIPE) Technology Transfer Unit. It has been moderated and prepared by Agribusiness & Allied Kenya Ltd (Nairobi Kenya), Standards & Solutions Consulting Ltd (Nairobi Kenya) and ICIPE (Nairobi Kenya) PREAMBLE The Internal Quality management and Control System (ICS) is a key element in group certification under option 2 of the EUREPGAP Standard. The ICS is described in different documents that have been compiled in this "Quality Manual" for a smallholder farmer group. The manual defines an outline structure of the quality system and serves as a reference in the implementation and maintenance of the quality system. It contains policies and procedures that demonstrate that the group is able to control the principal requirements of the EUREPGAP Standard. In this document a fictional group referred to as Kenya Smallholder Growers (KSHG) has been considered. This doc)ment can /e )sed as a startin1 2oint to de3e4o2 a 1ro)2 5)a4it6 man)a47 ada2tin1 its contents accordin1 to the sit)ation o8 the 8armers and the s2eci8ic circ)mstances 9ithin the 1ro)2:s; /)t ens)rin1 that the re5)irements o8 EUREPGAP Standard are neither 4o9ered nor com2romised. The EUREPGAP normative documents (EUREPGAP General Regulations, EUREPGAP ;P;;, EUREPGAP <=S ;hec?list, and EUREPGAP ;P;; ;hec?list) are not attached to this manual but are freely accessible from EUREPGAP website :htt2cdd999ee)re2eor1; In this document it is assumed that smallholder farmer groups lack the technical capacity required for the running of the EUREPGAP quality management system. The farmer groups may therefore rely on the services from either private service providers (e.g. private consulting companies, produce marketing organizations) or exporters.

8 Page 8 of 127 PART 1: QUALITY MANAGEMENT SYSTEM Introduction This Quality Manual, documents the Internal Quality Management and Control System (ICS) of the Kenya Small Holder Growers (KSHG) as required by the EUREPGAP Standard. It contains the quality policy and quality goals of KSHG. Processes and procedures as well as responsibilities are described in detail. The manual is obligatory for all permanent and subcontracted staff of KSHG involved in the operation of the ICS. The ICS is based on the normative documents of EUREPGAP to which reference is made in the individual sections. The same applies to relevant national or European legislation. The contents of the manual are reviewed periodically to ensure that they continue meeting the requirements of the EUREPGAP Standard and those of KSHG 2.0 Structure of Internal Quality Management and Control System (ICS) 2.1 Organization brief The Kenya Small Holder Growers (KSHG) was established in... Currently the group has 72 registered members coming from three rural villages in the Mt. Kenya region. Members are dedicated to fresh fruits and vegetables production on a total of...hectares. Twenty-five out of the 72 members are currently EUREPGAP registered farmers cultivating an area of. hectares. KSHG runs a collection centre that is located at the local market. KSHG provides an environment, which fosters the growth of cooperative marketing through longterm contracts with reliable buyers. The group is seeking representative dialogue with authorities and is offering opportunities for education, networking and training to its members. Special emphasis is given to information of members concerning legislative changes in the area of food safety and quality. A general description of the work of KSHG, rights and obligations of their members, different types of membership etc. can be found in the constitution of the group. KSHG operates on the basis of funds that come from membership fees, deductions from produce payment, bank interest and fines imposed as per the group by-laws. Additional funding may be obtained from the government, industry and/or NGOs. Contact details: Group Chairman, Kenya Smallholder Growers, P.O. Box XXXX, Kenya. Tel: xxxx KSHG@xxxx

9 Page 9 of Legality (Legal entity) KSHG is a non-political, non-sectarian, non-profit organization that was formally registered on the.. day of.. under the "Ministry of Culture and Social Services". Registration Number: YYYYY. With regard to EUREPGAP, there are well-defined relations between farmers and KSHG, mainly through the ICS and contractual agreements. A Farmer Register will be maintained and regularly updated of all farms and produce collection sites according to the standard form (KSHG/REC/2.1.4A, Annex 2). A contract is drawn with the individual farmers (See Annex 3 for Guidelines). This contract details the respective obligations of KSHG and the farmer, especially his/her commitment to comply with the requirements of the EUREPGAP Standard and his/her agreement to comply with KSHG's documented procedures, policies and technical instructions. Procedure for Sanctions and Appeals (KSHG/PR/2.10A, Annex 1) of the ICS, which defines sanctions and appeals in the case of non-compliance, is an integral part of the contract Administrative structure Figure 1 illustrates the administrative structure of KSHG. It shows the extent to which farmers are involved in the decision making process related to horticultural growing and marketing Management structure As pointed out, KSHG lacks the technical capacity required for the running of the EUREPGAP quality management system. The farmer group therefore relies on the services from private competent service providers in order to ensure effective and efficient management of the KSHG QMS. KSHG has contracted private service provider firm to manage its system. KSHG has signed a technical contract (KSHG/PR/2.13A) (Annex 2 for Guidelines) with the service provider for the provision of various services in order to comply with the EUREPGAP Standard. The following are the key staff provided by the contracted service provider involved in the management of KSHG (Figure 2): Production Manager/EUREPGAP Management Representative. Technical Manager who also acts as the Quality Management Representative (QMR) Agronomist who is in charge of agriculture technical advice department and its staff EUREPGAP Internal Auditor Collection Centre Head However, in terms of function, a single individual can hold more than one position. For example, a Technical Assistant can carry out duties of Agronomist ; A Technical Manager can be in charge of Internal Audits (Figure 2).

10 Page 10 of 127 GENERAL ASSEMBLY GROUP MANAGEMENT COMMITTEE -EXECUTIVE MEMBERS (Chairperson, Secretary, Treasurer) -ORDINARY MEMBERS INDIVIDUAL MEMBER/FARMER KEY Reporting Channel Authority Channel Figure 1. Relationship between KSHG and registered farmers

11 Page 11 of 127 Technical manager /QMR EUREPGAP management representative/production manager Agronomist Internal auditor Collection Centre Head Technical Assistant Sprayer operators Individual farmer Private Service provider(s) / Extension personnel of exporter(s) or PMO(s) Provide technical services to individual farmers of the group KEY Reporting Channel Authority Channel Figure 2. Management structure

12 Page 12 of Responsibilities and duties The staff involved in the ICS has specific qualifications, competence and experience required to make technical judgments, carry out internal inspections and implement quality management policies. Qualifications, duties and responsibilities of key staff are defined in a job description (Annex 4). Every staff has to keep abreast of developments, legislative changes and other issues relevant in the certification process. Performance reviews are carried out routinely to find out training needs. Personnel training to update on recent developments of the standard, improve the quality of work and promote personnel development are carried out annually (Training Procedure KSHG/PR/2.3A, Annex 1). Contracts (KSHG/PR/2.13A) specify that work has to be done in accordance with the requirements of the EUREPGAP Standard and KSHG's quality policies and procedures. Who evaluates competence, is there a matrix? Group overall policy KSHG is committed to quality and safety of all fruits and vegetables produced by its members in a view of increasing their shares in international, especially European markets. KSHG is promoting socially, ecologically and economically sustainable farming practices in a pro-active way. Members are assisted in implementing integrated crop and pest management in their farms. KSHG is particularly committed to reducing the risk of pesticide use through adoption of the safest viable pest management practices, which can reduce residues, worker exposure, and ground water contamination. KSHG considers the implementation of good agricultural practices and particularly compliance with local and international pesticide legislations as important competitive advantages for maintaining and expanding access to export markets. Members are enabled to comply with the ever-increasing quality and safety requirements. Group certification is intended to reduce the overall cost of certification to the EUREPGAP Standard. KSHG is fully aware that successful work requires competent staff. For this reason, great importance is attached to training and equipment of its staff Group s goals The Group s goals and ongoing commitments vis-à-vis their members are to: Grow and market horticultural produce that meets quality, safety and legal requirements. Provide training and advice to its members on production and post-harvest handling, storage practices and technology Organize events and disseminate information to its members Provide up-to-date market and trade opportunities information to its members Achieve EUREPGAP group certification with all of their members through implementing systems of good agricultural practices and internal quality control that meet the requirements of the EUREPGAP Standard Collaborate with other organizations with similar interest in pushing legislative action to change and/or improve government policies and regulation affecting the industry

13 Page 13 of 127 Carry out any other activity that is considered to be of benefit to the members but within the legal framework of the group 2.3 Training and advice to farmers KSHG is convinced that technical assistance and training for their members are indispensable services in order to minimize risks that may arise from ignorance, misunderstandings etc and may result in having the group certificate suspended or cancelled. Practical advice on how to implement the EUREPGAP CPCC and information about any modification and/or revision of the EUREPGAP Standard is given by the service provider. This is compulsory for all contracted farmers. Further training is provided on special events (e.g. field days), by the service provider in close collaboration with Government extension agencies, NGOs, etc. KSHG commits itself through the service provider in the production of training materials (e.g. IPM manuals) that are not otherwise available, and to elaborate standardized forms / instructions for the recording system on the farms. KSHG through the service provider also publishes the KSHG newsletter annually where frequently asked questions and related answers are featured in the EUREPGAP section. The training is done as per the Training Procedure (KSHG/PR/2.3A, Annex 1). The trainings records are maintained (Training Attendance Record, KSHG/REC/2.3.1A; Training Record KSHG/REC/2.3.2, Annex 2) 2.4 Quality Manual KSHG has documented its ICS in this document that provides the Quality Management System of the group. The Farmer Group policies and procedures are provided in this manual. The contents of the manual are reviewed periodically to ensure that they continue meeting the requirements of the EUREPGAP Standard and those of KSHG. 2.5 Document control The documentation relevant for the operation of the ICS comprises the Quality Manual including operational procedures, work instructions (where applicable), recording forms and external standards. KSHG has created a system of documents and records keeping, which guarantees integrity and transparency of all the relevant operations of the ICS. Procedure for document/record control (KSHG/PR/2.5A, Annex 1) defines this. Internal and external document master list are maintained (KSHG/REC/2.5.1A, KSHG/REC/2.5.2A,Annex 2) 2.6 Record control KSHG recognizes the fact that Records form part of the documentation to provide evidence that the system is being implemented as planned. It is therefore a responsibility of each personnel to ensure that records generated are maintained as per the procedure for document/record control. The minimum retention period for records is 2 years. A record master list is maintained (KSHG/REC/2.5.3A, Annex 2). A document/record issue register (KSHG/REC/2.5.4A, Annex2) is used when issuing documents or records.

14 Page 14 of Complaints handling The ability to effectively manage customer complaints is considered essential to the success of KSHG. If a buyer has reason to complain, for example on the presence of a pesticide residue above set MRL, this may have serious consequences for individual farmers, such as the withdrawal (recall) of products, cancellation of individual registrations etc. Depending on the circumstances, such events may also result in a loss of credibility of the entire Farmer Group. For this reason complaints are handled by the Production Manager him/herself in order to find out whether the problem is a singular event or reveals a general lapse in the system. KSHG has a Complaints Handling Procedure (KSHG/PR/2.7A, Annex 1) & Corrective Action Procedure (KSHG/PR/2.8.4A, Annex 1) in place that guarantees that customer complaints are thoroughly recorded, investigated and followed up. Records associated with the complaints (KSHG/REC/2.7A, Annex 2 and corrective action (KSHG/REC/2.8.4A, Annex 2) are maintained. 2.8 Internal audit and management review KSHG has implemented a system for internal audits as required by EUREPGAP Standard. Each registered farmer shall be audited once per year against the EUREPGAP CPCC based on the current EUREPGAP Checklist. Procedures for internal audits (KSHG/PR/2.8A, Annex 1) describe in detail, how audits are to be undertaken and how results are documented. Based on the audit report that reveals the result of the evaluation including any non-compliance, the internal auditor will decide on the farmer's status: approved, suspended or cancelled (KSHG/PR/2.8.4A and KSHG/PR/2.10A). The adequacy and compliance of the quality management system with the EUREPGAP Standard will be assessed annually by an internal audit under the responsibility of the internal auditor. The evaluation follows an audit program (KSHG/REC/2.8.1A, Annex 2, audit plan (KSHG/REC/2.8.2A, Annex 2) and includes all elements of the ICS as per the audit checklist (EUREPGAP CPCC Checklist). It is ensured that the current EUREPGAP QMS Checklist for farmer group quality management system is being used.the main purpose of the audit is to find out, if the operating procedures have proven feasible and produce the expected results. In addition, an annual management review is carried out in order to verify the continued effectiveness and efficiency of the ICS. After the audit or inspection is done, a summary audit/inspection report is prepared (KSHG/REC/ A, Annex 2). 2.9 Traceability and product segregation KSHG operates a traceability system to ensure that all EUREPGAP registered products are traceable to the production site and tracked forward to the immediate customer. The system also ensures that the products are handled in a manner, which prevents mixing with non-eurepgap registered products. This traceability system forms a key element of the contractual agreements with farmers and farmers groups. The traceability and product segregation policy and procedure (KSHG/PR/2.9A, Annex 1) is binding to all individual member farmers.

15 Page 15 of 127 KSHG farmers place clear and unique visual identification on each and every block where the produce is grown. Produce is traced to the farmer level and also to the individual block where the crop is grown. Specific records concerning particular block production activities are also available at the collection centre office. These records are used to identify possible sources of problems at farmer level. The KSHG traceability and segregation procedure details how a KSHG EUREPGAP registered product can be traced back to the individual farmer and production block where the crop was grown and tracked forth to the immediate customer. Products meeting the requirements of the EUREPGAP Standard and marketed as such are traceable and handled in a manner that prevents mixing with non-eurepgap registered products. The traceability system is tested once per year to ensure that all of the relevant production, harvesting and packing information can be successfully retrieved Sanctioning The types of sanctions that will be applied to non-compliances of control points and to contractual issues are defined in accordance with EUREPGAP General Regulations and include the levels of warning, suspension and cancellation. The Sanctions Procedure and Appeal (KSHG/PR/2.10A, Annex 1) contains a catalogue of sanctions and is an integral part of the contracts with individual farmers. Suspensions or cancellations of registered farmers are immediately notified to the CB. Records are maintained of all sanctions including evidence of subsequent corrective actions and decision making processes Withdrawal of certified products KSHG has established a Product Recall Procedure (KSHG/PR/2.11A, Annex 1) containing the operating plan which will be executed in the event that a product problem is discovered which has the potential to affect the health of consumer, violates food safety regulations of the importing country, or could cause adverse public consequences for KSHG. The procedure will be tested annually in order to make sure that it can be effectively operated at any time should that be required 2.12 Use of EUREPGAP logo Use of the EUREPGAP logo, trademark and registration number is made in accordance with the EUREPGAP scheme requirements. KSHG has established a procedure (KSHG/PR/2.12A, Annex 1), which describes in detail the conditions of use and its control. Farmers have the contractual obligation to refrain from any unauthorized use of EUREPGAP trademark, logo and/or registration number.

16 Page 16 of Subcontractors/service providers KSHG contracts service providers through contract agreement that specify that the service providers must work in accordance with the Farmer Group Quality System and relevant procedures (Annex 3 for Guidelines). Service providers are evaluated before engagement as per supplier evaluation checklist (KSHG/REC/ A, Annex 2) and re-evaluated at least once in a year. An approved suppliers list (KSHG/REC/2.9.1A, Annex 2) is maintained. Inputs are verified as per the Inputs checklist (KSHG/REC/ A, Annex 2) are verified and when non-conformances are detected, the Corrective Action Procedure (KSHG/PR/2.8.4A, Annex 1) is applied. 3.0 Sales and Distribution KSHG sells their produce at the collection centre. Long-term links with a small number of exporters or produce marketing organization are preferred to a large number of different clients. The main advantage is seen in a reduced number of product specifications, which allow for concentration on the essential quality and safety aspects. Further benefits are better communication and higher commitment. This is particular important when problems have to be sorted out. Exporters/PMO are supposed to be an important source of information, e.g. on new market requirements or legislative changes in importing countries. Exporters may also be allies in the struggle for better infrastructure, legislation etc in our country. Close contacts to our customers are therefore a top priority. Vehicles transporting the produce are subject to quality checks as per transport/vehicle checklist (KSHG/REC/ A,Annex 2). PART II: CONTROL POINTS AND COMPLIANCE CRITERIA 4.0 Processes in KSHG 4.1 Production Traceability KSHG requires all its members to divide their plots into smaller production units called blocks. The size of the blocks must be measured accurately for the purposes of estimating the amount of inputs needed. Each block must be identified with a signboard indicating the name of the farm and block number. Any seed received and planted must have all details recorded including, the name of the supplier, date of purchase, lot number or batch, variety and name of particular seed treatment(s). Records of all inputs and outputs to a block including fertilizers and pesticides must be recorded as well as the personnel involved.

17 Page 17 of 127 Other traceability measures taken by the group include: Not mixing produce coming from different farms. Packing produce by batches depending on the origin of production. Establishing the list of the personnel used both for the harvest as well as in the plant and keep attendance sheets. Keeping technical sheets of the chemical products and detergents used for cleaning or controlling parasites or pests. The system of traceability used includes a minimum of documents indicating the origin of the product as well as a means of marking (e.g. crate label) which, ideally would enable to follow it throughout the whole commercialization process. Please refer to Farm Processes Flow chart (Figure. 3) for a summary of the traceability system. Risk assessments are carried out before each major process is implemented. A summary of guidelines on the various risk assessments appears in Annex Record keeping and internal audits A master list of all records (KSHG/REC/2.5.3A, Annex 2) as required by the quality system is kept and indicates the responsibility for records. KSHG requires that all records are up to date, legible, genuine and accurate. The Agronomist and QMR periodically check the integrity of all records as a basis for planning and follow-up. Every year a new set of records is started and old ones stored safely as described in Documents and Record Control Procedure (KSHG/PR/2.5A, Annex 1) for at least 2 years. Besides records, all growers are audited once a year as per EUREPGAP CPCC Checklist and a yearly farm audit record (KSHG/REC/2.2B, Annex 2) kept. Any non-conformances found are recorded on a corrective action report form (KSHG/REC/2.7A, Annex 2) and addressed as required Choice of variety KSHG farmers plant varieties that are recommended by KSHG Agronomist in liaison with market requirements. The variety choice is usually dependent on the prevalent pest and disease resistance, the climatic conditions of the geographical regions where KSHG farms are located (local farm ecology) and the quality specification of the client. The schedule of recommended varieties (KSHG/REC/3.1B, Annex 2) for all crops and planting schedule (KSHG/REC/3.0B) are made available. KSHG farmers plant only certified seeds. Seeds are the only propagation material used in KSHG farms. KSHG supplies the farmers with these seeds from the customers or when necessary from licensed seed vendors listed in the approved supplier list (KSHG/REC/2.9.1A, Annex 2). The supply of seeds is done according to the Seed Procurement Procedure (KSHG/PR/3.0B, Annex 1) and input procurement checklist (KSHG/REC/ A, Annex 2). Seeds certificates/delivery notes and

18 Page 18 of 127 seeds lot numbers records are maintained. The seed certificates/delivery notes and lot numbers are issued together with delivered seeds by the seed vendors. The individual farmers are regularly trained on the group quality management requirements to ensure among other things that they only source and plant certified seeds through the modalities laid down. KSHG may carry out additional seed dressings when necessary and this is done under the supervision of the KSHG Agronomist who is the technically responsible person. Seeds treatments and dressing s records (product name, target pests/diseases, date of treatment, concentrations used, special handling requirements, etc.) are kept and maintained for a minimum of two years in a record sheet (KSHG/REC/3.4B, Annex 2). Where visible signs of disease or substantial damage are found in delivered seeds, this must be brought to the attention of the KSHG Agronomist who is responsible for recording the nature of the problem, decision based on own observations and any action taken. KSHG does not grow any crop genetically modified (GMOs) Site history and site management Risk assessment for new agricultural site KSHG carries out a risk assessment (KSHG/PR/4.1B) on food safety, operator health and safety and environmental protection for new agricultural sites. The results of the assessment (KSHG/REC/4.1.1B, Annex 2) are used to determine whether or not the site is put into crop production. The risk assessment shows the potential impact of production on the adjacent crop and other areas. Within the risk assessment identified risks are quantified by likelihood of occurrence and degree of negative impact in the event of occurrence. This assessment is used to develop appropriate control measures and monitoring procedures. Where necessary, records are maintained to establish that effective control measures are in place. The risk analysis is well documented and covers the following:- a) Previous land use Previous crops and pesticides used on them Unacceptable wastes Natural vegetation and possibility of environmental degradation Animal production b) Type of soil Drainage patterns and liability to flooding and erosion c) Quality and level of ground water

19 Page 19 of 127 An appropriate laboratory capable of performing microbial analysis up to ISO level or national equivalent is used to determine water quality. d) Availability of sustainable water Authorization for use through a permit from the ministry of water or local authorities e) Impact of farming to adjacent areas. Spray drift At farm level risk assessment will consider: 1. Farm ownership status (in case of legal land issues) 2. Location of farm and area 3. Common history of land use (farm history in relation to crops outside vegetables which may have been grown e.g. cotton which is a heavy pesticide user) 4. Type of soil 5. Water source Figure 3: Farm production processes flow chart PROCESS ACTIVITY DOCUMENT CONTROL CPCC Section Planting Seed Issue and Dressing Planting Planting Schedule Planting Quantity vs. Acreage planted 1,2,3,4,5 Treatments Chemical/ Nutrient Chemical/Nutrient Issue Related Documents Spray nozzles, Frequency, Quantities 1,2,6,8,11,12, 13,14 Chemical/Nutrient Application Spray Application Details Spray application Programme Irrigation Irrigation Irrigation Application Details Irrigation Programme 1,2,7,11,12, 13,14 Farm Block Data Crop History record Farm Block Data Update

20 Page 20 of 127 Harvesting Collection at Shed Produce Receipt Note (PRN) Quality check and grading 1, 2, 9,10,11, 12,13,14 Crate Label Block Data Vs Crate Details Delivery to Pack house Produce collection Note(PCN) Block details PCN Details Site management A sign-post on the main access path to the plot identifies each plot or field. The sign incorporates the following information: - Farmer s code Block no Crop variety Area/quantity Planting date Expected harvesting date Every block is physically identifiable. KSHG holds key information about each farm under its control that details the layout of the farm and the subdivisions within the farm. The cropping history of each block is recorded (KSHG/REC/4.1.2B) and any incidents or accidents affecting any block are recorded with the actions taken to prevent adverse effects in subsequent crops [Traceability Procedure (KSHG/PR/2.9.2A, Annex 1)] Crop rotation Since different crops have different nutrients requirements KSHG recommends regular changing of the type of crops grown in a block. By this KSHG farmers reduce the risk of depleting the soil of specific nutrients and also reduce the incidence of pests and diseases. This rotation program helps add essential elements to the soil and builds and maintain up soil structure over the years. An annual cropping schedule (KSHG/ADM/KSHG/REC/4.2.3B, Annex 2, Crop Rotation Plan) has been developed by KSHG and farmers are recommended to adhere to it. Training of the farmers on this schedule is done by the Technical Assistants.

21 Page 21 of Soil management The type of soil on each farm is identified based on soil analysis and /or local cartographic soil-type maps. This information is used to determine the most suitable cultivation methods and use of land. Surface drainage is controlled to prevent erosion. Measures in place to prevent erosion include cross line planting on slopes, appropriate drainage channels and planting on borders of growing areas. Soil map information can be obtained from the Ministry of Agriculture for the farms to show the types and contents of the soil that exist in each farm. These are useful tools for planning planting crop rotations and planting programmes. KSHG Technical Assistants advise farmers on the suitable cultivation techniques. Cultivation techniques used are those considered suitable for particular area so as to improve or maintain soil structure and to avoid soil compaction. Hoeing is however indispensable for aerating the soil but it is not practiced in areas with loose loams to avoid damage of soil structure and thus erosion. Cross line techniques are recommended on slopes. These include terracing, planting along contours, planting grass/trees and bushes strips on borders of sites. Some of the specific practices are: Growing deep-rooted crops to bind soil particles Avoiding cultivation along river banks Growing trees in rows to act as wind breaks Contour ploughing (ploughing land across the slopes) Adding humus to soil by green manuring to bind soil particles together Making terraces on steep hillside to reduce the spread of water Growing cover crops to avoid movement of loose soil KSHG carries out no soil fumigation in all its farms to eliminate pests, diseases and weeds. Alternatives are recommended by the Technical Assistants to the farmers; these are:- Crop rotations Use of resistant and tolerant varieties Use of thermal/solar sterilizations where applicable. KSHG farmers do not use substrates in growing their produce. All crops are planted in the soil in situ Fertilizer usage and storage KSHG has established fertilizer stores near the produce collection centre and office. Farmers get fertilizers from the fertilizer store or buy from licensed fertilizer vendors. Fertilizer stock inventory (KSHG/REC/ 6.4.1B, Annex 2) are maintained. When buying from the latter, farmers obtain receipts and keep them in their farm files, which form part of the fertilizer usage and storage records. The receipts must have details of the type of fertilizer, quantity and date purchased. It is recommended

22 Page 22 of 127 that farmers buy only what they will apply. Should there be need to store fertilizer on the farm for later use the storage facility must meet the guidelines shown in Section Farmers are free to obtain fertilizers elsewhere as long as it is accompanied by proof of purchase (receipts) and a document to show content of the fertilizer. KSHG has ensured that the Agronomist and Technical Assistants responsible for determining the quantities and types of fertilizers to use are competent. Documentary evidence (KSHG/ADM/REC/6.1.1B, Annex 2) is available at the administration office that demonstrates training and competence of the technical assistants KSHG fertilizer use policies KSHG farmer(s) strictly adhere to the following policy. Failure to comply in any respect may render the produce from the farm unacceptable. The Group Agronomist or the Technical Assistants are the only authorized persons to give all fertilizer application advisory to the KSHG farmers. Fertilisers are only applied after a proper evaluation of the need for treatment and a justification recorded by the Group Agronomist or Technical Assistants. The justification for fertilizer (KSHG/PR/6.1B) is made after consulting the available soil fertility data and reference information of soil analysis for the blocks/farms in question, nutrient requirements of the growing crop and phase of growth. Soil analysis considers the ph, nitrogen, potassium, phosphorous and micronutrients levels in the soil prior to planting A decision to treat the crop shall be justified and specific instruction given to the farmers in their farm. The technically responsible person signs against it. This instruction includes; Name of the fertiliser Crop location to be treated Method of application Required equipment Dosage rate/equipment settings Name of the authorising person Instructions about any PPE required (as per label instructions) Fertilizers herein include inorganic fertilizers such as NPK and foliar liquid fertilizers, organic fertilizers such as farm yard manure, rock phosphates; composts and other related plant based decomposed/un-decomposed matter. A risk assessment shall be carried out for organic manure (for disease and weeds) used by the KSHG farmers and appropriate control measures taken and recorded to ensure that this manure does not carry a significant risk of transmitting diseases or weeds to crops being grown (KSHG/RAG/01). Organic fertilizer does not include treated or untreated domestic or industrial sewage. KSHG does not allow its growers of vegetables and fruits to use treated or untreated human sludge as fertilizer. Soil analysis of the farms shall be conducted according to the sampling procedure provided by the laboratory responsible. Updated soil maps are kept for reference. Where necessary, soil analysis is carried out at nationally recognized laboratories.

23 Page 23 of Fertilizer application records The actual fertilizer applied is recorded (KSHG/REC/4.1.2B, Annex 2). The production form contains the following information: Field identification number Application date Type of fertilizer Amount of fertilizer applied Method of application Name of the operator/person who applied the fertilizer Fertilizer application machinery All solid fertilizers are manually applied by hand using a cup of a known measure. Liquid fertilizers are applied using knapsack sprayers and these are hereby considered as the fertilizer s application machinery. There are documented records stating that technically qualified people or companies have carried out the repair and calibration of the equipments (KSHG/REC/8.5B, Annex 2, Calibration Report). For knapsacks calibration can be done as detailed in the Equipment Calibration Procedure (KSHG/PR/8.5.2B, Annex 1). Fertilizer machinery maintenance schedules/records are kept for all equipment; these include (where applicable): Date serviced/ repaired Next service date Spare parts bought and available Calibration records Other machinery here includes fertilizer weighing machines for which external verification is done annually by Weights and Measures Department of the Ministry of Trade; and records /receipts/invoices from contracted parties maintained Fertilizer stores KSHG ensures that fertilizer storage meets the following requirements:- Stores have an updated inorganic fertilizer inventory. This indicates the date bought or brought to the store, the date moved from the store and any balances (stock inventory KSHG/REC/8.8.15B, Annex 2). Inorganic fertilizers are stored separate from pesticides. The store is always clean, dry and covered from weather elements. Storage is in a manner that reduces risk of contamination of water courses. Liquid fertilizer stores are bunded. Organic and inorganic fertilizers are stored away from seeds and produce. The fertilizer store is a controlled area and entry restricted to authorized personnel only. The universal symbol of hazard is placed at the entrance.

24 Page 24 of 127 The risk of disease transmission from organic fertilizers is assessed. This assessment also considers weed seed content, method of composting, etc and is done before organic manure application. Fertilizers are stored in a manner that reduces risk to the environment. Purchased fertilizers are accompanied by documentary evidence of their pesticide content. This information is available for all the inorganic fertilizers used on EUREPGAP registered crops within the last 12 months Irrigation KSHG water use policy Water is a scarce resource, which needs to be managed efficiently. KSHG requires that all water for irrigation purposes is used within the restrictions of legal abstraction permits and licenses (KSHG/PR/7.2.2B). Weather information will be sourced through the media (e.g. radio). Irrigation application timings and rates will be determined following consideration of predicted rainfall, soil type, evaporation rates and crop needs. A water management plan will be developed by KSHG for all growers. Suitable practices might include: use of direct application rather than flood irrigation; application during cooler periods rather than in the heat of the day; the use of mulches and the addition of organic matter to the soil. These policies are contained in the KSHG water management plan Predicting water requirements KSHG farmers are recommended to predict the need for irrigation of their crops by conducting a soil hand test. This involves the farmer taking a handful of soil from several regions of his/her farm and feeling the soil for texture, moisture content and malleability. This helps the farmer to estimate the soil moisture content and thus make a decision on whether or not to irrigate. KSHG relies on the existing regional meteorological data, crop condition and hand test to predict when to irrigate. Farmers are therefore made to understand that plant water requirements depend on factors like a) Amount of rainfall received in the area b) Rate of evaporation and evapo-transpiration c) Depth of plant roots d) Type of plants and plants growth stage e) Soil properties like water-holding capacity Irrigation method KSHG recognizes that irrigation system also determines the water-use efficiency. For KSHG farmers, there are two methods used to irrigate and these are overhead and furrow Irrigation. These are the most cost effective method for the farmers currently. They are more effective than flood irrigation but not as efficient as drip irrigation.

25 Page 25 of 127 Where possible records are kept which indicate the date and volume used per irrigation unit. All legal extraction permits and licenses pertaining to the farm are maintained Quality of irrigation water Water quality is important, to both plant growth as well as a human health. Samples of water are collected and taken for analysis annually to determine its suitability for irrigation in terms of microbial, pesticide and physical contaminants where necessary. Surface water is open to contamination by sewage and/or pesticides. This is a potential human health risk, especially when the produce is eaten raw. Sources of contamination shall therefore be identified and controlled. KSHG farmers do not use sewage water. Risk assessment is done annually to determine potential microbial pesticide and physical contamination of all sources of irrigation water. A competent, locally recognized laboratory analyzes irrigation water. The risk assessment justifies the frequency necessary to analyze irrigation water and the results for the analysis maintained in KSHG/REC/7.3.2B, Annex 2. Microbial contaminants, pesticide pollutants, heavy metal pollutants are determined by a reputable laboratory. Any adverse effects are adequately acted upon according to the Complaints Procedure (KSHG/PR/2.7A, Annex 1) and Corrective Action Procedure (KSHG/PR/2.8.4A, Annex 1) and records of these kept. Water is always abstracted from sustainable water sources i.e. sources that can provide adequate water throughout the growing season and with the necessary approval Effective ways of irrigating Efficient ways of irrigation have been promoted. Farmers are recommended to: Irrigate during cooler periods of the day when humidity is low and thus evaporation rate low e.g. late evening and at night. Avoiding high weeds especially when using overhead sprinklers Proper maintenance of the sprinklers and piping network Pesticide usage and storage KSHG encourages usage of IPM (Integrated Pest Management) to minimize the use of pesticides. All pesticides application are justified and documented. When pesticides are applied anti resistance recommendations are followed as per product label instructions. KSHG receives IPM assistance from experts and also trains its own personnel.

26 Page 26 of KSHG pesticide policies Sprayer operators and all persons handling pesticides are trained on handling and safe use of pesticides. KSHG adheres to strict policies failure of which to comply in any respect renders the produce unacceptable. Its pesticide policies include: All sprayer operators and technical assistants adhere to the procedures for pesticides application, pesticide mixing, use and maintenance of personal protective equipment, disposal of excess tank mixes, and disposal of empty crop protection containers (KSHG/PR/8.8B). Minimal use of pesticides is employed to achieve an economic control of weeds, pests and diseases. This is achieved by using information obtained from crop scouting. This information is recorded in scouting records (KSHG/REC/8.1B) KSHG has current details of those pesticides whose use is banned in the European Union and other markets where produce from KSHG is destined or whose use is severely restricted as well as the approved crop protection product list. KSHG does not use pesticides contained in the banned list for any crop. Only those products in the updated approved pesticides list are stocked and recommended for use. Pesticides are only used for their intended crop and pest. Off label approvals are sought from the manufacturer of the product if the product label is not crop specific or does not have specific details. KSHG collaborates with its customers to ensure that pesticide residue analysis is carried out in order to monitor MRLs in the produce. KSHG has developed an annual MRL testing plan (KSHG/PL/8.7.3B, Annex 2) for all the registered produce and farms. This programme indicates the produce sample size [as per Sampling MRL Procedure (KSHG/PR/8.7.4B)] and the farms, which will be analyzed in a year. In case of excess MRLs the following remedial steps and actions are taken:!the affected persons are notified immediately by phone or Fax/ .!The batch is recalled for analysis and replacement (if possible).!an action report is generated and kept as a record of the incident.!the supplier is contacted to advice them of the problem.!produce from affected blocks is isolated until problem is corrected. Excess MRL problem is addressed and solved by checking the following:!phi observed!correct pesticide used!correct dose rates applied!proper application procedure followed!sprayer operator re-trained!right application machinery used and properly calibrated KSHG maintains a list showing the current acceptable MRLs levels for European Union or other markets. It is the responsibility of KSHG to maintain an accurate record of pesticides used on each crop. These include;!pesticide trade name and active ingredient.

27 Page 27 of 127!Pre- harvest interval!references to any legislation from which an approval for that pesticide s use on a particular crop has been taken Sprayer calibration and maintenance KSHG has a Calibration and Maintenance Procedure (KSHG/PR/8.5.2B), which is followed in calibrating and maintaining knapsacks sprayers, weighing scales and other equipment as may be specified. Knapsack sprayers used to apply pesticides are properly maintained. The equipment is calibrated annually. Records of calibration and maintenance of equipment are kept and maintained as detailed in the Equipment Calibration and Maintenance Procedure Disposal of empty pesticide containers, surplus pesticide, tank washings and obsolete pesticides. The pesticide Handling, Mixing and Disposal Procedure (KSHG/PR/8.6B) details the steps followed in disposal of empty pesticide containers, surplus pesticide, tank washings and obsolete pesticides. Overstocking of pesticides in the store is avoided by ensuring only the required amounts for the season are purchased Pesticides application records Comprehensive records of all pesticide applications to all crops supplied via KSHG are kept. All details are recorded in the production records (KSHG/REC/4.1.2B, Annex 2) Pre-harvest interval All crop protection applications are recorded in the relevant format - production records (KSHG/REC/8B, Annex 2). In the event that observation of PHI Compliance Procedure (KSHG/PR/8.4.1B, Annex 1)) is not followed by farmer, the consignment in question is rejected and disposed off at the expense of the farmer at the collection centre Pesticides stores The following are the requirements for all KSHG pesticides stores: Compartments are created within the store for the following: -!Pesticides to be used on fruits and vegetables.!only pesticide meant for use on the registered crops and those pesticides to be used on crops recorded in a crop rotation plan are kept in the same pesticide store but in different labeled compartments.!all liquid pesticides are stored on shelves below powder pesticides within the same group to prevent contamination in the case of a spillage or leak.!obsolete pesticides Each store or compartment (where applicable) is split into 3 sections and clearly labeled as fungicides, herbicides and insecticides

28 Page 28 of 127 Store is bunded to prevent any spillage leaking into the outside. Pesticides storage facilities are built in a manner, which is structurally sound and robust. Concrete and stone blocks have been used to construct the store hence it is fire resistant. Pesticides storage facilities are built in a manner that allows constant ventilation of fresh air to avoid buildup of harmful vapors and protect against temperature extremes. Shelves are made of non-absorbent material in case of spillage. The store clearly marked with the appropriate signs to indicate hazardous and dangerous materials. Pesticides are stored in an area with sufficient illumination both by natural or artificial lighting to ensure that all product labels can be read easily on the shelves. The stores are bundied up to 110% the volume of the largest liquid pesticide container to ensure that there cannot be any risk of spillage to the exterior of the store in case of an accident. The store is locked. Only authorized KSHG personnel having access. Only personnel with training on safe handling and use of pesticides have access to the store. This security is achieved using a key holder system A general stock inventory (KSHG/REC/8.8.15B, Annex 2) is completed to show movement of the pesticide stock. Stock control measures within the group are maintained and updated for each pesticide as each one is added to the store or used. The movement form indicates which field/block was sprayed and which crop the pesticide was used on. The pesticide store has measuring and weighing equipment for mixing and measuring the pesticides in cases where this is done at the pesticide store. Always the measuring device is triple rinsed before measuring a different pesticide. These are also available at pesticide mixing stands at the farms to ensure that the correct handling and filling of the pesticide as stated in the pesticide label has been followed. A container of sand, a floor brush, a dustpan and plastic bags which are placed in a sign-posted area in the pesticide store are available to be used in case of spillage of pesticides during mixing and filling. All crop protection products are stored in their original package Personal protective equipment KSHG ensures that personnel coming into contact with pesticides use appropriate personal protective equipment (PPE). PPE including waterproof overall, gloves and boots as well as a face shield or goggles and respirator are worn when measuring, mixing or spraying any pesticide as per the label instructions. Each set of PPE is permanently marked with a number or letter. Sprayers are also marked with the same letters. All the equipments are issued with the same number identification to one person who becomes responsible for that equipment s maintenance and upkeep. PPE are washed at the end of each use with clean running water (KSHG/PR/12.5.2B, Annex 1) near the pesticide store. Workers are not allowed to take overalls home as they could pose a health risk. The PPE and knapsacks are stored in a separate store, not in the pesticide store.

29 Page 29 of 127 All PPE are examined for tears and holes each month; the results of this check are recorded on the equipment calibration record. Any PPE that is damaged is repaired immediately Harvesting A harvest risk analysis (KSHG/RAG/01, Annex 5) is performed annually for the harvesting process of all KSHG produce. This risk analysis has been used to develop harvesting procedures, which have been implemented in each farm (KSHG/PR/9.1B). No ice is used in harvesting or processing in any of KSHG farms. Toilets are located within 500 meters of any harvesting activity and these are regularly inspected for cleanliness. Hand washing facilities and points are also checked regularly to ensure that they are in good condition and usable. Prior to harvesting, all pickers are instructed on hygiene (personal and general) requirements by the farmer where necessary. Farmers have been trained on personal and general hygiene requirements when working produce. Refer to KSHG/PR/10.1.4B, Annex 2 for personal hygiene instructions. Farmers are recommended to have a copy of the hygiene instructions. KSHG strives to deliver produce of the required specifications. The buyer s specifications must be adhered to. The Collection Centre Head inspects each farmer s produce to ensure it meets the required specifications. Farmer s produce failing to meet the specifications is rejected. Particular attention is paid to ensure produce is harvested at the correct maturity stage. A simple harvest lath/shed is available at every farm for placing the harvesting containers before transporting to the collection centre. This is to avoid contamination and dehydration of the produce Collection centres A risk assessment is done for produce work at the collection centre annually (KSHG/RAG/01, Annex 5). This has been used to design a set of procedures that prevent hygiene risks and these have been implemented as part of the collection centre procedures. The procedures include hygiene procedure (KSHG/PR/10.1B). Where washing of produce is done water samples from all water points around the collection centre are tested to ensure that it meets WHO threshold limits for potable water. Water samples are sent for laboratory analysis once every 12 months. KSHG collection centre serves as a facility where all produce from all farms is sorted, graded, and placed into marked crates for dispatch to customers. It is a permanent structure with an iron sheet roof to provide protection from the sun and rain. It has a concrete floor that is easy to clean. The sides are made of iron/wood planks and wire mesh guarding to ensure maximum light inside and to prevent entry of pests, domestic animals and birds.

30 Page 30 of 127 Inside the centre are benches made of galvanized iron sheets/plastic top where the produce is sorted. The floor of the collection centre is designed in such a way to allow free drainage. Cleaning pesticides such as soap and sanitizers are properly labelled and are kept away from stored produce. The cleaning pesticides and equipment are stored in a segregated area separate from any produce working activities. Safety information is held for all of the pesticides held on site in the form of a safety management data sheet. The Collection Centre Head is in charge of hygiene and hygiene records of the collection centre. He / she is also in charge of the produce weight and quality information. The Collection Centre Head ensures that no glass objects such as soda bottles, glass cups, etc are brought into the collection centre. KSHG glass policy is that no glass object, material shall be brought into the collection centre. If any illuminating equipment must be brought into the collection centre, then it should be adequately covered to contain any glass fragments in case of breakage. The collection centre has a procedure for safely clearing any glass breakage in the produce storage and working areas (Glass and Hard Plastic Handling Procedure, KSHG/PR/10.1.4B, Annex 1) A notice board is provided at the centre to hold the hygiene procedure, personal hygiene instructions, cleaning schedule (KSHG/SCH/9.1.3B, Annex 2) cleaning roaster and other relevant updates of information for the farmers, pickers and sorters from KSHG or the farmer group officials. Produce is transferred from the fields to the KSHG collection centre as soon as possible after picking. The KSHG ;ollection Centre Head checks the quality of the produce to confirm that it is of the required quality and it meets the buyer s specifications. It is sorted then put into the buyer s crates and labeled awaiting collection by transport vehicles. It is the duty of the KSHG Collection Centre Head to check that the vehicle is clean before the produce is loaded into it. This is recorded in transport/vehicle checklist KSHG /REC/ A,Annex 2. He / she is also responsible for ensuring the cleanliness of the collection centre. 5.0 Waste and pollution management 5.1 Pollution management plan KSHG farmers are responsible for the managing their land and for the development of socially and environmentally sound management policies. KSHG has provided training and support to ensure that negative impact of the farming activities on the local ecology are minimized. All farmers are recommended to participate in local environmental initiatives. KSHG has a waste and pollution management plan (KSHG/ENV/01, section A, Annex 6) and waste and pollution record (KSHG/REC/11.2B, Annex 2). 5.2 Waste management All processes in KSHG registered farms and in the collection centre together with the delivery of produce have been assessed and this assessment includes the waste materials generated from

31 Page 31 of 127 these activities. The possible pollution from exhaust systems of vehicles, etc. has been considered. These waste materials and pollutants are catalogued and this information has been used to develop a waste and pollution management plan to reduce waste through recycling, where this is practical. Each farm is responsible for reducing the adverse environmental impact of its activities and for the encouragement of biodiversity in the farm conducive with the maintenance of good plant health and sustainable production. The collection points for waste are clearly identified in each site (farm level, collection centre level or vehicle washing points) and these are adequate for the quantities of waste produced. The sites are managed to ensure that litter is contained. 6.0 Worker health, safety and welfare. KSHG has formulated a workers health, safety and welfare policy. KSHG recognizes that healthy workers are vital for its business and that in order to achieve this, workers must be provided with a safe environment to work in. To achieve this, KSHG operates its facilities within Kenyan Law and the requirements of EUREPGAP Standard and its customers A risk assessment based on relevant national and local regulations on worker health, safety and welfare issues is done. Health and safety sub-committee meetings are held every 3 months and group members and management are represented at all meetings. KSHG has appointed the QMS Representative as the management representative to ensure compliance with existing, current and relevant national and local regulations on worker health, safety and welfare issues. The discussions of the health and safety sub-committee are minuted and these minutes include the review of accidents and suggestions for improvements in safety and action planning to prevent accidents. KSHG has set up a policy of providing basic health and safety training to all group members. Where group members operate dangerous equipment undergo additional specific training related to the work they carry out. All training is being documented with attendance lists and a summary of the content of the training. Where external training is provided the qualifications and experience of the trainer are recorded and copies of certificates of attendance or achievement are held in the employees training record (KSHG/REC/2.3.2A, Annex 2). Visitors and contractors are instructed on the rules of the site, collection centre or the farms. Where a visitor or contractor makes regular visits they are required to sign a declaration that they will abide by the instructions. Signs are posted at hazardous locations such as pesticide store, pesticide mixing stands, empty pesticide containers pit, pesticide disposal area, PPEs store, seeds store and other hazardous areas in a local language as well as English. Signs are also posted at entrances to stores and other enclosed hazardous areas alerting group members, employees and visitors of accident prevention measures. In particular sand buckets for fire fighting and master points for evacuation are clearly

32 Page 32 of 127 indicated and pesticide hazards are accurately and clearly identified, where possible symbols are used. Each collection centre has an Accident and Emergency Procedure (KSHG/PR/12.2.4B, Annex 1) that indicates what actions should be taken in the event of an accident. The procedure includes a list of responsible people on site and the local health clinics with up to date telephone numbers. All accidents and incidents are recorded and reviewed by the health and safety sub-committee. The procedure is posted prominently in all pesticide handling areas and a copy is included in the first aid boxes. The following list gives details of recommended contents. Waterproof container First Aid booklet 1 absorbent compress (32 sq. in.) 16 adhesive bandages (1 x 3 ) 5 yd adhesive tape. 4 bandages, compress (2 in.) 4 bandages, compress (3 in.) 4 bandages, compress (4 in.) 2 Roller bandages (2 in.) 2 Roller bandages (4 in.) 1 Triangular bandage (40 x40 x56 ). 4 sterile pads (3 x3 ) 2 knuckle bandages 1 pair of scissors 2 tweezers 10 antiseptics (0.5g each) 10 antiseptic wipes (0.5g each) 6 antiseptic towelette (0.5g each) 2 cold packs 4 oz. calamine lotion 2 pairs medical examination gloves 2 eye coverings/shields 2 Drinking cups 2 oz. salt 6 safety pins 8 oz. eye wash 6 acetaminophen capsules 6 antacid tablets 6 hay fever/allergy tablets 1 CPR rescue breather 1 ammonia inhaler 6 oz. insect repellent 6 antihistamine capsules Insect sting treatment 1 flashlight/ batteries

33 Page 33 of emergency signal horn 6 oz. Baking soda 1 pack matches Paper & pencil All personnel handling pesticides and other hazardous substances have had specific training in the safe handling of these materials and training certificates are held in their personnel files. Only personnel who have the appropriate training may work with dangerous substances. All employees handling dangerous substances are subject to regular medical examination as outlined in Kenyan legislation. Records of the medical examinations are retained in the personnel files of employees. Personal protective clothing (e.g. rubber boots, waterproof clothing, protective overalls, rubber gloves, face masks, etc.) is provided to all personnel handling hazardous substances. This equipment is maintained in a clean and serviceable condition, stored in the PPE stores and is subject to regular inspection. Label instructions on pesticides indicate what personal protective equipment is appropriate when handling specific hazardous substances. Pesticide store and all pesticide filling/mixing stands at the farms have eye wash facility, a source of clean water no more than 10 meters away, a complete first aid kit and a clear accident and emergency procedure with contact telephone numbers. Farmers are recommended to ensure that their employees are trained in the safe and effective execution of their duties. First Aid boxes are provided at the central office and/or farms. It is recommended that for their own protection, farmers keep records of all incidences of work related accidents on their farms. 7.0 Environmental issues An impact assessment is conducted for all sites intended for farming and their suitability determined with regard to impacts on the environment. In all farming activities growers consider the impact of their operations on the environment. Whenever applying pesticides, considerations are given to the habitats around the area to be sprayed. Efforts are made to conserve and enhance the biodiversity of the local farm environment. Unproductive sites are managed to provide conservation areas for fauna and flora where possible. In all cases, all actions are planned to minimize their negative impact on the environment. KSHG and all of the registered farms are committed to wildlife conservation and have conservation management plans based on the National Wildlife Conservation Policy and consistent with sustainable agriculture and reduction of negative environmental impact. These plans are reviewed and updated each year. The contents and objectives of the conservation plan are clearly stated and prioritized to achieve increased biodiversity. (Environmental management protocol, KSHG/ENV/01, Annex 6)

34 Page 34 of Bibliography EUREPGAP General Regulations Version 2.1 Jan 04 EUREPGAP Control Points and Compliance Criteria Version 2.1 Oct 04 ISO 9000:2000, Quality Management Systems-Fundamentals and Vocabulary ISO 9001:2000, Quality Management Systems-Requirements EUREPGAP Smallholder Manual, Building Up An Internal Control System for Certification to EUREPGAP Option 2 in Horticultural Sector. GTZ Version 1.0 October Terms and definitions Terms and definitions given in EUREPGAP General Regulations apply Terms not defined retain their normal dictionary definition. Audit: Systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which audit criteria are fulfilled. Auditee: Person or organization being audited. Auditor: Person with the competence to conduct an audit. Audit criteria: Set of policies, procedures or requirements used as a reference. Competence: Demonstrated ability to apply knowledge and skills. Corrective action request: Action required to eliminate the cause of detected nonconformity or other undesirable situation Inspection: Conformity evaluation by observation and judgment accompanied as appropriate by measurement, testing or gauging. Procedure: Specified way to carry out an activity or a process (Procedure can be documented or not) Quality management system: Established policies and objectives to direct and control an organization with regard to quality. Quality objective/goal: Something sought, or aimed for related to quality. Quality policy: Overall intention and direction of an organization related to quality as formally expressed by the Top Management.

35 Page 35 of 127 Record: Document stating results achieved or providing evidence of activities performed. Supplier/subcontractor: A person or an organization that provides a product or a service. Top management: Person or group of people who directs and control an organization at the highest level. Traceability: Ability to trace the history, application or location of that which is under consideration.

36 Page 36 of 127 ANNEX 1: STANDARD OPERATING PROCEDURES PART 1 (QMS) 2.3A Procedure for Training Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Procedure for Training KSHG/PR/2.3A ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to outline the steps followed in training personnel and farmers in order to ensure that all personnel meet the required competency as described in the competency matrix in the quality manual. The aim of the training is improve the competence of personnel and farmers to implement good agricultural practices on their farms. In particular the farmers shall be enabled to comply with the EUREPGAP Standard and to keep abreast of any changes and/or modifications to it. Scope This procedure is applicable to all personnel who are responsible for ensuring compliance to EUREPGAP Standard Requirements (as detailed in the Competency Matrix) and all the EUREPGAP registered farmers. Responsibility: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. Description Training needs shall be identified through internal audits/inspection, determination of the competency gaps and job performance. A training program shall be developed of the identified training needs for the personnel or the farmers. Training may be conducted through: Classroom training (internal or external), on-the-job training, farmers field days, etc. The training records (name of the trainer, list of participants, topics covered, and copies of certificates) shall be maintained by the QMR. Evaluation of the training done includes: Testing on the material presented in the classroom, Certificates of completion for externally provided training, determining EUREPGAP Control Points and level of compliance to them before and after training and job performance before or after training.

37 Page 37 of A Document and Record Control Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Document and Record Control Procedure KSHG/PR/2.5A ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to describe the control of documents and records that fall within the KSHG management system. Scope The procedure is applicable to all documents and records supporting the KSHG EUREPGAP Quality Management System. The documents include: The quality manual, EUREPGAP operating procedures, work instructions, recording forms, external standards e.g. EUREPGAP requirements, water permits, analysis results, training records, seed certificates, receipt and invoices. Responsibility: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. Description 1) Document control The Quality Management Representative (QMR) shall maintain a master record of documents; both internal and external that requires to be controlled. The master register shall specify the document title, revision status and location of the document. Any employee within KSHG may suggest the need to modify an existing document/form or create an entirely new document The QMR considers the employee s suggestion to modify/create the document/form in consultation with the relevant persons. If in agreement, the QMR in consultation with the relevant person modify and approves the document. Once the modified/new document is approved, the previous document version is considered obsolete and is withdrawn and disposed. The QMR then updates the master list and then issues the current document/form. Documents shall be issued using the document issue register. Copies of documents issued to users are stamped controlled except for forms. Photocopying of such copies is prohibited. Forms to be photocopied for use are stamped controlled at the back.

38 Page 38 of 127 Document users are required to ensure that documents remain legible. Any illegible documents are submitted to the QMR for replacement. Controlled documents are identified by means of a document number, issue number, revision status number, effective dates and the document title. All documents initially issued are Issue A and documents not revised are Revision 0. For minor changes i.e. for sections of the document, the Revision changes to the next number i.e. 1. In case of major organizational changes, the Issue goes to the next letter of the alphabet. 2) Record ;ontrol The QMR shall maintain a master list of all records specifying the name of the record, revision status (for forms), location, and retention period. Records are identified by means of the record name and date. Entries for records are done in ink. Cancellations and erasures are discouraged. However, any cancellation made must be countersigned. The QMR is responsible for the filing of all the records. Before submitting records for filing, staffs are required to verify the accuracy of the records. Records are stored in designated areas and filed by following the dates to facilitate ease of retrieval. The QMR ensures that records are stored safely, in designated areas/shelves away from any risk of damage. Where soft copies of records are kept, the QMR ensures that a suitable back up is done. The retention period for the various records is specified in the master list. Records shall be retained for at least two years. Records that have attained the end of their retention period or the documents that have been superseded are either disposed or filed in a separate file marked obsolete if they need to be retained for any reference purposes.

39 Page 39 of A Complaints Handling Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Complaints Handling Procedure KSHG/PR/2.7A ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose of this procedure is to outline the steps followed to effectively manage customer complaints. SCOPE The procedure is applicable to the handling complaints to the farmer group and against individual farmers, farms or produce handling sites, the resolution of sanctions imposed on non-conforming farmer/farmer groups, customer, general public, government authority and suppliers. RESPONSIBILITY: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. DESCRIPTION All complaints are directed to the QMR to log these into the complaint log that indicates the date the complaint is received, the reference number of the complaint, the complainant and details of the complaint. An investigation is initiated to establish actual cause of complaint. The QMR shall acknowledge the receipt of the complaint to the complainant. The relevant section head in liaison with the QMR among others shall investigate to determine the root cause of the problem and determines the necessary corrective action. A trace back to the date of production may be carried out and source of raw material may need to be established depending on nature of the complaint. Once the necessary corrective action has been effected, the action is documented and the complainant informed. The procedure shall be available to customers as required. The QMR shall maintain a record of all complaints received and the action taken. The customer complaints are subject to review at the management review meetings.

40 Page 40 of A Internal Audit Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Internal Audit Procedure KSHG/PR/2.8A ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to define how the process of internal audit shall be conducted in order to verify the implementation of the quality management system and compliance to EUREPGAP requirements. Scope The procedure is applicable for conducting of internal audits. Responsibility: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. Description The QMR prepares an annual program of audit to be conducted. Internal audit shall be conducted to determine the effectiveness of the quality management system. They are done against the EUREPGAP Checklists to determine the farmers compliance. The annual program shall take into consideration the status and importance of the areas of the QMS and the farms to be audited as well as the results of the previous audit. The QMR may increase the number of audits for areas of QMS and registered farmers that the previous audit results indicate so. The QMR prepares an audit plan indicating the areas of QMS and farmer group/farms to be audited, purpose, scope, audit criteria and the auditors. The QMR ensures that the audit plan is communicated to the auditors and auditees before the audit day. In selecting the auditors, the QMR shall ensure that the auditors do not audit their own work and that they are competent to do so.( trained to at least internal auditor level.) The auditors conduct the audit as per the audit plan and compile the internal audit/report summary report. Non-conformities raised during internal quality audits shall be brought to the attention of the QMR. On completion of the audit, the farmer shall sign the report confirming that he/she accepts the findings.

41 Page 41 of 127 The QMR then logs in the non-compliance/corrective action log The internal audit reports are maintained/filed. The relevant person in liaison with the QMR determines and effects the necessary corrective action The QMR fills out his closure comments on the log The QMR reviews the audit reports and follows up activities and updates the audit program accordingly.

42 Page 42 of A Corrective Action Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Corrective Action Procedure KSHG/PR/2.8.4A ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose of this procedure is to outline the various measures to be taken incase of nonconformities. SCOPE The procedure is applicable to both products and services RESPONSIBILITY The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. DESCRIPTION 1) Incoming products (e.g. seeds, fertilizer, pesticides, equipment, containers, etc) Should incorrect or damaged produce be received, it is isolated. A note is recorded on the delivery note. The supplier is contacted to advise them of problem. Should the supplier be uncooperative or a solution is not found, the material/item will be returned (without payment). An attempt will always be made to find a solution without having to return the item(s). A correction action request (CAR) is entered and followed up and kept as record of the incident. The problem is addressed and solved. The item(s) is returned or kept On hold. Where problem persist, the supplier /sub- contractor may be removed from the approved supplier / sub contractor list. 2) Produce damaged injhouse Once damaged produce is identified in-house, the EUREPGAP Team Leader / Management Representative is advised Where nonconforming produce cannot be used, it will be separated from the others, awaiting the action initiated by raising a CAR. An investigation is done to determine the root cause of the problem. Corrective action (with the corresponding preventive action) is implemented to prevent recurrence. Customer is notified (were applicable) 3) Produce returned from the customer Upon receipt, the produce is inspected to confirm nonconformance condition.

43 Page 43 of 127 Produce is destroyed where necessary (where produce integrity is not compromised) The customer is advised of immediate action taken. A CAR is entered to record the details and for follow up. The reasons for nonconforming produce / materials shall be discussed during management review meetings. 4) ;ustomer complaints Customer complaints, whether received by phone or fax, and whether justified or not, are recorded in the customer complaint log. The root cause of the complaint is investigated and documented. The customer complaints are also subject to review at Management review Meetings. K) LonJconforming produce All the analytical information of produce is captured by the Technical Assistant and the information about the process is documented by the Production Manager / Management Representative, who will also record and process information regarding non-conformances. Non-Conformances are any characteristics that do not comply with the customer s Specifications / EUREPGAP / Regulatory Requirements, such as MRLs, presence of physical defects, yeasts and moulds and physical blemishes, etc A CAR is raised where applicable in order to find the root cause and do follow up. M.) InJhouse corrective action Problems which are persistent and cannot be fixed through normal operations of daily wok, a CAR is generated (change and corrections, which are described in work instructions, do not necessarily form part of the Corrective Action Process) The CAR is entered in the corrective action report form (KSHG/REC/2.7A.In all cases root causes should be determined. The root cause analysis involves a specific analysis by considering all possible causes of the nonconformance. The least likely are eliminated and the most likely are considered finding the most probable cause of the nonconformity. Appropriate action is decided to ensure that the cause of the non-conformity is eliminated. Analyses of corrective actions forms an integral part of the management review meetings agenda. 7) Preventive action Should any member of the farm / farmer group find a situation developing in the company that has the potential to result in loss of produce / equipment / efficiency, the TA / Manager / Process Owner has to be advised. Attention has to be brought to everyone concerned through the generation of a CAR and action taken to prevent any potential loss. All possible cause of the potential non-conformance(s) must be considered. The least likely are eliminated and the most likely are considered to find the most probable cause of the potential non-conformity. Appropriate action is decided to ensure that the cause of the potential nonconformity is eliminated.

44 Page 44 of 127 Management systems records, management review meeting minutes and results from the analysis of data are also used as inputs for preventive actions. Analysis of preventive actions form an integral part of the Management Review Meeting agenda

45 Page 45 of A Traceability Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Traceability Procedure KSHG/PR/2.9A ISSUE NO. A REVISION: 0 Page-of- Purpose The procedure describes how the history of the produce should be maintained in order in order to ensure that the produce is traceable back to and traceable from the registered farm where it is grown. The procedure also ensures that the registered produce is handled in a manner that prevents mixing with non-eurepgap approved products. Scope The procedure is applicable to all production, transport and produce packaging sites. Responsibilities The effectiveness of this procedure lies with the Quality Management Representative, the technical assistants, the collection centre heads and the group officials Description 1) Physical field identification Every field of each registered farmer of the farmer group is identified through a permanent record that stipulates size, cropping history and location. During any growing season there is a permanent board indicating the unique field identification, size/quantity, variety of crop grown, planting date and expected harvesting date. All field activities including soil analysis and crop rotation programs are then referenced to the unique field identification number on the permanent board. The unique field block identification label is maintained for so long as the farm (er) is contracted by the farmer group. The field identification system used is well defined with all the characters or codes previously set with a meaning. 2) Traceability All EUREPGAP registered products are easily identified through a traceability tag bearing the above information placed on all crates or packing containers. The quantities, time received and the unique field identification number is also included in the goods receipt note. Segregation of EUREPGAP registered products To prevent mixing of EUREPGAP certified produce with the non certified one, in the produce working sites, all produce is received with the traceability tag and is graded, stored and packaged separately either by time and space or combination of both.

46 Page 46 of 127 Testing of this procedure is done at random but at least once in a crops life cycle for any farm (er) to ensure compliance with these requirements of the standard. The technical assistant who is independent of the area of operation carries out this activity and documents it. Any nonconformity or irregularity is reported immediately to the relevant process owner who institutes an investigation as per the laid down procedure for the control of non conforming products. If the results of this investigation confirm a deviation from Farmer Group procedure, then a product recall procedure is instituted.

47 Page 47 of A Procedure for Sanctions and Appeals Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Procedure for Sanctions and Appeals KSHG/PR/2.10A ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to outline the system of sanctions followed in effecting actions to ensure farmers and farmer group, farmer group and exporting companies, farmer group and service provider adhere to their contractual obligations as stipulated in their respective contracts, for the effective operation of the EUREPGAP quality management system. Scope The procedure is applicable to farmer and farmer group, farmer group and service providers and exporters contract and farmer group and customer/exporter contract. Responsibilities The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. Description During routine inspections by group management, internal audits / inspections and external audits any failure noted as not complying with the EUREPGAP Standard is a non-compliance and may results in sanctions which are meant to correct these failures. Different types of sanctions are imposed by the disciplinary committee of the farmer group, or the Service provider depending on the type of failure and party involved; the individual farmer or the farmer group as a whole, service provider or the export company. The affected party is informed as per the contract clauses. Sanctions, subsequent corrective actions and decision making processes are recorded as per the contract agreement. Any other arising defaults, commercial or otherwise, on other clauses in the terms of contracts will also lead to imposition of sanctions as per the contract clauses. Farmer vs Farmer Group Any farmer, who joins a farmer group in the farmer groups scheme, must sign a contract with the farmer group. The contract has by-laws and a constitution which governs the running of the day to day activities of the group and disciplinary measures taken when a member fails to adhere to the by-laws and the constitution.

48 Page 48 of 127 The contract sets out disciplinary measures, which are taken in case of breach of this contract by either party. The disciplinary measures that may be taken cover: Narning; EUREPGAP non-compliances of minor issues agreed in this contract will lead to a Warning. The maximum time allowed for correction will be 28 calendar days. If the cause of the warning remains unresolved on expiry of this period, a complete suspension will be imposed. EUREPGAP non-compliances will involves a written caution to the offending farmer, the nature of the offence, the corrective actions expected, monitoring of the corrective actions to verify they have been implemented and the likely consequences of not complying. Suspension; warnings are of two types; deferred and immediate Deferred Suspension EUREPGAP non-compliance of any minor must control point will lead to deferred suspension. The farmer will be given up to 28 calendar days for resolution of the problems the suspension originated from. Once this period has elapsed without resolution, the sanction imposed will be an immediate suspension. Immediate suspension Immediate suspensions result in a removal of the farmer from the farmer register for a limited period (maximum 6 months). Suspensions will be lifted once there is written / visual evidence that its causes do not longer exist. Non-compliance of any major must control point will lead to immediate suspension. The extent of the suspension can be limited to a clearly identified, traceable part of a registered crop (field or batch). Non-compliance with any of the agreements signed in this contract or any issue found during the inspection that leads to doubts about the farmer s way of proceeding will lead to an immediate complete suspension of the farmer. Immediate suspension will be imposed when the farmer has not paid the contracted services or when modifications, changes or adjustments of procedures formally announced and communicated by PGAF have not been followed. Other contractual non compliances will involve a formal documented a temporarily barring of the offending farmer from participating and enjoying the benefits of being a member of the farmer group for a certain duration. The nature of offence is clearly explained, the expected remedial action and accompanying monitoring actions spelt out and the consequences of not complying explained. EOpulsion/cancellation If there is no written / visual evidence during the period of suspension that the farmer has put in place suitable corrective actions to avoid the re-occurrence of non-compliances, the farmer group or service provider shall cancel its contract with the farmer or farmer group and exclude him/her from the farmer register. Further reasons for cancellation of the contract are serious mismanagement on EUREPGAP related procedures, fraud and bankruptcy of the farmer.

49 Page 49 of 127 Defaulting on other contractual obligations will involve a complete ban of a farmer from participating in any farmer group activities and benefits. This occurs when a farmer commits an offence that attracts this measure. The decision is written and communicated to the concerned farmer. The expulsion is not permanent and will vary in length depending on the farmer groups constitution. Appeals The farmer has the opportunity to appeal against any of the above decision according to the laid down constitution. Farmer Group vs Service Provider A farmer group which receives technical services from a service provider, signs a contract between itself and that service provider. The contract governs the relationship between the service provider and the farmer group, the nature of services, the roles, obligations and responsibilities of each party as well as the measures to be taken when either party defaults on any relevant part of the contract. The contract sets out the role and obligations of each party, the rules and regulations to be followed, nature and scope of services offered the payment modalities and other financial arrangements. The contract sets out disciplinary measures, which are taken in case of breach of this contract by either party. The disciplinary measures that may be taken cover: Narning: This involves a written caution to the offending party, the nature of the offence, the corrective actions expected, monitoring of the corrective actions to verify they have been implemented and the likely consequences of not complying. Suspension: This involves formal documented a temporarily suspension of the contract for a certain duration. The nature of contractual default is clearly explained, the expected remedial action and accompanying monitoring actions spelt out and the consequences of not complying explained. Termination: This involves a complete withdrawal of either party from the contractual arrangement. This occurs when either party defaults on the contractual requirements that attract this measure. The decision is written and communicated to the concerned party. The termination may not be permanent and can be reinstated depending on how willing both parties are to work to resolve the points of departure. Appeals. Either party has the opportunity to appeal against any of the above decision according to the laid down contract. Farmer Group vs Customer/Exporter Company A farmer groups sign a contract with the exporter company(s)/customer(s) to whom they sell their produce. This contract stipulates the customer requirements on type of product, quality, quantity and prices offered for the produce. It also stipulates mode of payment to the group and other financial arrangement, the roles and obligations of each party, the rules and regulations and the

50 Page 50 of 127 disciplinary actions taken should either party violate the terms of the agreement. The disciplinary measures that may be taken cover: Narning: This involves a written caution to the offending party, the nature of the offence, the corrective actions expected, monitoring of the corrective actions to verify they have been implemented and the likely consequences of not complying. Suspension: This involves formal documented a temporarily suspension of the contract for a certain duration of time. The nature of contractual default is clearly explained, the expected remedial action and accompanying monitoring actions spelt out and the consequences of not complying explained. Termination: This involves a complete withdrawal of either party from the contractual arrangement. This occurs when either party defaults on the contractual requirement that attracts this measure. The decision is written and communicated to the concerned party. The termination may not be permanent and can be reinstated depending on how willing both parties are to work to resolve the points of departure. Appeals. Either party has the opportunity to appeal against any of the above decision according to the laid down contract. NOTIFICATION MECHANISM Any suspensions or cancellation of the contract between farmer and farmer group, farmer group and export company, farmer group and service provider is recorded. The reason and how the decision to suspend or cancel/terminate a contract is arrived at, are indicated in the record. The farmer group, service provider or export company will make a decision on what needs to be communicated to the relevant EUREPGAP approved Certification Body. The specific situations which warrant sanctions, warnings, probation, suspension and cancellations are highlighted in the contracts documents or the constitutions. Specific actions taken when concerned parties fail to adhere to specific rules and regulation concerning group functions and stipulations of the Eurepgap standard are contained in the contract documents. These documents are made available to the concerned parties.

51 Page 51 of A Produce Recall Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Produce Recall Procedure KSHG/PR/2.11A ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to describe the process for withdraw of produce incase there is a need to do so. Scope Applicable to EUREPGAP certified produce Responsibility: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. Description If ever produce should be suspected of being unsafe (usually microbiologically) for consumption, as a result of an internal finding (MRL, etc) or customer complaint the affected persons / customer(s) will be notified immediately by phone and fax / E- mail and the batch recalled for analysis and replacement (if possible) and a corrective action report generated. In order to recall the correct batch of produce, the list of produce dispatched to the customer is used to trace which batch was sent to the customer (and when). In order to get to the root cause of the problem, the recall produce batch is traced back to the field block and seed. The seed lot number linked back to record of seed receipt and issue and seed delivery notes. Corresponding sowing and harvesting records will also be investigated and stock reconciled. A trial / test recall will be done by the management Representative on an annual basis and records of such kept.

52 Page 52 of A Use of EUREPGAP Logo, Trademark and Registration Number Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER EUREPGAP Logo, Trademark and Registration Number Procedure KSHG/PR/2.12A ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to prevent any misleading use of EUREPGAP logo, trademark and registration number by registered farmers and their farmer group. Scope Applies to EUREPGAP registered farmers. Responsibilities The Quality Management Representative and the farmer group officials are responsible for the implementation of this procedure. The Collection Centre Head is responsible for the correct labeling of all outgoing produce. Description According to their license agreement with EUREPGAP, the farmer group as a supplier member will use the EUREPGAP logo in relation to membership claims and in business to business communication only. This means that the farmer group uses the logo as proof of its membership to EUREPGAP. This proof is required when seeking new markets for its products, when negotiating new contracts with export companies and also when engaging in official communication with other businesses. The farmer group makes sure that the logo never appears on products, consumer packaging of the product, crates or crate/traceability tags or at any other point of sale. The use of the full EUREPGAP registration number with reference to the certified product and/or the certified organisation is restricted to the farmer group as the certificate owner. The name and address of the registered farmers will appear in the appendix of the EUREPGAP farmer group certificate. Farmers and the farmer group are not authorized to use the EUREPGAP trademark, logo and/or registration number.

53 Page 53 of A Procedure for Sub-Contractors Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Procedure for Sub-Contractors KSHG/PR/2.13A ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to describe the process for selection and evaluation of suppliers and subcontractors. Scope The procedure is applicable to all suppliers of inputs and subcontractors supplying materials and services (e.g. seeds, fertilisers, sprayers, chemicals, training, laboratory analysis, calibration and consultancy) that have a significant impact on the quality of products and services. Responsibility The QMR is responsible for the effective implementation of this procedure Description The criteria for selection of suppliers shall include: Acceptance of the subcontractor to comply with the hygiene, safety and quality requirements of the quality management system/eurepgap Standard Availability of a form of quality certification depending on the type of goods/services offered e.g. ISO for analytical laboratories. Ability to supply quality products/services at the agreed time and the supplier track record. Price Location Suppliers of non-critical materials are selected principally on the basis of quality and price. An approved suppliers/subcontractor list indicating suppliers of critical materials/services shall be maintained. Routine evaluation and re-evaluation of suppliers/subcontractors of critical material is to be conducted in order to check on the adherence of suppliers to the relevant EUREPGAP Control Points and Compliance Criteria. Supplier performance evaluations are to be conducted at least once a year and shall involve assessing the supplier s previous performance in meeting of the selection of suppliers criteria among others. The supplier who fails to comply with EUREPGAP Standard and to the quality management system shall be notified and if he/she fails to take the required corrective action within the agreed period

54 Page 54 of 127 shall have his/her name deleted from the approved list. The approved list shall be kept updated by the QMR. ANNEX 1 STANDARD OPERATING PROCEDURES PART II (CPCC) 3.0B Seeds Procurement Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Seeds Procurement Procedure KSHG/PR/3.0B ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose of this procedure is to outline the steps that should be followed to acquire certified seed for planting. SCOPE The procedure is applicable for the farmer group and individual farmers within the farmer group. RESPONSIBILITY: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. DESCRIPTION A planting calendar (REC/3.0B) is prepared by the farmer group considering the strength of the grower and future market requirement. The group sources seed centrally from reputable suppliers. This assures the quality and identity of the seed as all seed must be accompanied by copies of seed certificates from seed vendors. Where research and past performance has shown benefits from seed treatment, the group purchases the seed pre-treated, or the seed is treated/dressed centrally with pesticide prior to issuing the grower. Farmer requests for good quality seed, which has been appropriately treated, in order to maintain economic yields and achieve product of consistent quality. The use of seed treatment can also reduce pest and disease pressure on the growing plant and reduce the need for pesticide applications during the first stages of crop growth. The seed is issued to grower in reference to the variety list (KSHG/REC/3.3.1B). Only varieties agreed with the customer will be issued for planting based on the planting programme.

55 Page 55 of 127 On receipt of seed each grower is required to check its visual quality and bag integrity, and to sign acceptance of it. Once accepted the seed must be planted according to the agreed planting schedule. Records must be kept of all seed receipts and distributions.

56 Page 56 of B Site History and Site Management Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Site History and Site Management Procedure KSHG/PR/4.1B ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to describe the control of sites and their management. Scope The procedure is applicable to all growers and on all sites used within the rotation plan. Responsibility: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained on all sites. Description A risk assessment report is completed for all agricultural sites whether new or old provided that no such risk assessment report is available. In all risk assessments a corrective action report (KSHG/REC/2.8.4A) is completed, setting out strategies to minimize all identified risks. When the assessment identifies a non-controllable risk that is critical to health and/or the environment, the site is not used for food production. A recording system is established for each field or block by means of full set of records referring to it. The location of each production block is individually identified by means of a permanent block label. For each grower, a plan of the farm is produced with the location and size of each production block marked. The acreage must be recorded for each particular block excluding the pathways and grass strips. A route map or area location map is produced for the group and is displayed in the group office. A farmer group farm location map is produced. This map indicates growers names and distances of their plots from the central farmer group administration office. This map is then displayed on the grading shed notice board. All growers then individually mark their blocks to provide identification at farm level by their reference codes. A signboard is used for this identification. Finally, with assistance from farmer group Technical Assistant, a crop rotation plan for all annual crops is prepared.

57 Page 57 of B Fertilizer Use Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Fertilizer Use Procedure KSHG/PR/6.1B ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to prevent misuse and overuse of fertilizers with regard to food safety, worker safety and environmental protection. Scope The procedure applies to all growers who use fertilizers whether organic or inorganic. Responsibilities The Quality Management Representative and the farmer group officials are responsible for the implementation of this procedure. The Technical advisor is responsible for the correct advice on fertilizer use. Description All growers should seek advice from Technical Advisors on quantity and type of fertilizers (both organic and inorganic) to be used. Should it be decided to use fertilizer or foliar feeds to enhance plant growth then all such applications must be recorded on crop history record (Form 8B) and must only be made after consideration of the plant requirements. Plant nutrient requirements can be determined from Soil analysis reports with corresponding fertilizer use recommendations from experts. When applying liquid fertilizers, there must be dedicated application machinery (knapsack, measuring devices, etc) different from those used for veterinary acaricides and pesticides. Calibration and validation of the machinery and equipment must be routinely done and calibration/validation records kept, with assistance Technical Advisors. Inorganic fertilizers should be purchased based on recommendations from technical personnel. All fertilizers purchased must have a valid purchase receipt bearing date; amount; type and chemical composition of the fertilizer. Fertilizer must be purchased in the original packaging and not repacked or decanted into other containers. Inorganic fertilizers must be stored in a sound and secure fertilizer store. It must be protected from the weather; free from moisture and rodents and; the area where they are stored must be clearly signed and marked with a warning triangle. A risk assessment should be carried out for organic fertilizer, which considers its source and characteristics, before application. The following potential risks should be considered: disease

58 Page 58 of 127 transmission, weed seed content, method of composting, etc. fertilizer risk assessment record (Form 6.0) must be completed for each farm. Finally, the addition of organic matter is encouraged where it will benefit the soil. Fresh produce growers must not use untreated human sewage sludge. Well rotten farmyard manure is permitted but should only be applied to the land during the production of break crops. However, if it is applied during the production of crops grown it should be applied prior to seedling emergence. The manure used must be well composted using composting guidelines on the composting guidelines below (6.5.2B). All applications of organic manure must be recorded. M.K.PQ ;omposting guidelines a). The following materials must not be used for composting. Diseased crop waste. Synthetic materials such as: Irrigation pipes, broken crates and fertilizer bags. Papers such as scrap paper and damaged cartons. Glass and metals such as pesticides bottles, broken windows, nuts& bolts and worn-out machinery parts. Rubber such as worn-out tyres and gloves. Dangerous wastes such as expired pesticides and excess tank mix. Donkey wastes. Pig wastes. Sewage/ human sludge. b). Dig a pit deep and large enough to accommodate the amount of materials to be composted. The pit should be away from water courses. c). Cover the compost materials with ash at intervals of 30cm as you build up the compost. d). Water the materials once you complete each layer. e). The first turning over should be done after four weeks then at intervals of three weeks up to 16 weeks. f). Deep a stick through the compost to a depth of at least 30 cm to test the microbial activity. If warm, the compost not ready. g). Ready compost breaks easily as soil and is not hot/ warm (decomposition by microbes is complete). h). The ready compost should be stored under shade away from water courses and direct sunlight. i). Apply compost under instructions from technical personnel.

59 Page 59 of B Water Management Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Water Management Procedure KSHG/PR/7.2.2B ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to describe recommended water use practices for efficient water use. Scope The procedure is applicable to all growers within the farmer group who use water for irrigation of their crop. Responsibility The QMR is responsible for the effective implementation of this procedure Description Remember water is a scarce resource, which needs to be managed efficiently. Irrigation should be done to prevent plant growth being limited by water shortage. Used efficiently it can be seen as a husbandry aid and hence an addition to otherwise sound practices. All water used for irrigation purposes must be used within the restrictions of legal abstraction permits and licenses. Weather data should be collected. This should include records of both temperatures and rainfall. Irrigation application timings and rates should be determined following consideration of predicted rainfall, soil type, evaporation rates and crop needs. A hand-feel method is the fastest method of determining irrigation timing. If the soil does not stick together when pressed between the fingers or palm then irrigation is necessary. Adopt cultural practices can assist with minimizing water loss and hence enhancing water use efficiencies. Suitable practices might include: use of direct application rather than flood irrigation; application during cooler periods rather than in the heat of the day; the use of mulches and the addition of organic matter to the soil. Untreated sewage water must not be used for irrigation. The microbiological content of irrigation water is a concern to customers and samples should be taken from time to time to monitor their levels.

60 Page 60 of 127 All irrigation applications should be per block should follow the guidelines below: Maintain valid extraction permits where applicable and with accordance with Nater Act ;ap RSP. Use the most efficient means of irrigation for particular farm situations. Avoid overhead sprinkler systems as much as possible. Use methods of irrigation that minimize water usage to apply water directly adjacent to the root zone. Water management decisions should be made taking into account soil moisture deficits, evapotranspiration, rainfall, temperature and other meteorological data. Train responsible personnel to recognize and rectify irrigation deficiencies such as pipe bursts to ensure remedial action is taken promptly to avoid water wastage. Maintain water consumption records of ground water. Do not divert or dam rivers/streams without written permission from relevant water authorities. Endeavor to collect rainwater and attempt to recycle water used within the farms to reduce reliance on natural sources. Construct and maintain artificial wetlands to provide very efficient and cost effective cleaning and decontamination of wastewater. Monitor and record water quality at least every 3 months to minimize pollution. Construct dams so as to feed water to downstream users from their floors, not spillways.

61 Page 61 of B Compliance With Pre-Harvest Intervals Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Compliance With Pre-Harvest Interval (PHI) Procedure KSHG/PR/8.4.1B ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose of this procedure is to outline the steps to be observed in compliance with Pre- Harvest Intervals (PHI) to ensure food safety. SCOPE The procedure is applicable to all farmers using pesticides in crop protection. RESPONSIBILITY: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. DESCRIPTION Pesticides will be chosen based on their PHI and phonological (growth) stage of the crop. A red flag must be displayed in the block sprayed until the recommended PHI is over. Pesticide application records on the production record will be checked to confirm clear-to-pick date before harvesting is done. Add an additional day above the PHI to ensure PHI clearance is observed.

62 Page 62 of B Maintenance and Calibration of Equipment Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Maintenance and Calibration of Equipment Procedure KSHG/PR/8.5.2B ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose of this procedure is to outline the steps followed in the selection, use and maintenance of chemical application machinery. SCOPE The procedure is applicable to the use and maintenance of pesticide and fertilizer application machinery. RESPONSIBILITY: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. DESCRIPTION T.K.P.UQ Selection, Use and =aintenance of Application Equipment Suitable spray equipment should be selected for pesticide application. The actual type used will depend on the form of pesticide being used and the scale of the operation. The selection of equipment that is suitable, desirable, repairable and reliable is important. All operators of spray equipment must have received training on its correct operation and use. This training must be documented. Such training may be provided by reputable organizations or may be provided in-house. It is recommended that refresher courses be taken on an annual basis. Prior to each use, the knapsack must be checked to ensure that it is in good working order, that it has no leaks, and that its lid fits securely. Using poor quality or faulty equipment may result in contamination of the operator with pesticide and/or poor quality application of the pesticide to the crop. Poor application may in turn cause damage to the crop, or result in the pesticide being less or even ineffective. Measuring devices (e.g. weighing scales, measuring cylinders, jugs, cups, etc.) are checked annually by either a recognized body or by a qualified/competent person.

63 Page 63 of 127 After use, knapsacks must be rinsed. Care must be taken when disposing of tank washings. When not in use knapsacks must be kept in a secure area away from food, animals and children, but not in the pesticide store. Spray equipment must be calibrated on a regular basis. During calibration the equipment must also be checked to ensure that it is functioning correctly. Calibration checks may indicate that such equipment needs repair or replacement of parts. If this is so, these should normally be effected without delay. It is important that the correct nozzle is used. To this end advice and checks on nozzles should be included in all calibration checks. T.K.P.PQ Simple ;alibration Steps for Wnapsac? 1. Set up the sprayer and first check that it was cleaned the last time it was used. If in doubt, clean again. 2. Check the product label to confirm dosage i.e. how much chemical is needed for a quantity of water, volume rate or how much mixture is needed for an area e.g. 1 hectare of 200l volume and lastly confirm dosage e.g. 10ml in of 15L water. 3. Modify the operation considering weather changes, density of crop or leaves, and behavior of the pest or disease. 4. Choose the right nozzle, the right pressure, the right forward speed (1m/s). 5. Obtain clean water and proceed to calibrate. a) Fill the tank with clean water. b) Check the forward speed: 1m/s for a normal human being. c) Pump the right pressure. Some sprayer types have a pressure gauge. d) Check the nozzle capacity or the nozzle flow rate in the following way: Get a graduated cylinder or jug. Set the pressure that you will use on the farm and have a stop watch ready. Open the nozzle and time the flow per minute as well as the volume in the jug. Repeat these not less than 3 times and obtain the average flow rate of the nozzle. For example, 3 bar pressure and size 10 nozzle gives a flow rate of 0.46 l/min and size 14 gives 0.91 l/min. this helps to confirm how long you will take to spray a certain volume. e. Fill the tank as per label instructions. Consider the height of the nozzle. A general recommendation is 40cm between the nozzle and the crop. A practical example: If you want to confirm the volume you need per hectare at your walking speed, Take a portion of the farm and peg 10m by 10m. Note the nozzle swath (width) by spraying a flat ground and measuring the width of the pattern. Divide the 10m by 10m area into swaths e.g. 1m swath gives 10 of them. Find out the amount of water per swath. Find out the amount per row and multiply by the total rows. To find out volume required per hectare, multiply with the total rows for the entire hectare.

64 Page 64 of 127 Therefore, if the volume is not given for the area, calibration will confirm. If this does not agree with the recommendations on the product label, you may have to reduce or increase the forward speed, or/and change the nozzle B MRL Sampling Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER MRL Sampling Procedure KSHG/PR/8.7.4 B ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose is to outline steps to be followed when sampling fresh produce for MRL analysis SCOPE The procedure is applicable to all farms growing EUREPGAP registered crops. RESPONSIBILITY: The QMR or Technical Assistant (under guidance of QMR) has overall responsibility for ensuring that this procedure is effectively implemented and maintained. QMR is also responsible for drawing up a MRL testing plan (KSHG/REC/8.7.3B) DESCRIPTION A random selection of group members in farmer register for sampling as per MRL testing plan must be done. The selected farmers must be documented in the farmer MRL testing plan. Samples must be collected for analysis from each of the registered farmers by end of the year Take random samples of export quality produce (1 kg of composite sample) at harvest from selected farmers at the collection centre Samples should be placed in Seal-a-Pack freezer bags (available in all supermarkets), sealed and properly labelled in and on the freezer bags. The bags should be kept in a cooler box for dispatch to a designated laboratory (accredited to ISO 17025) within 24 hours. On the labels the following information should be given: Code of the farmer group Code of the selected farmer as per farmer register Name of crop / variety Code of the production block / field Date of sampling

65 Page 65 of B Pesticide Preparation and Mixing Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Pesticide Preparation and Mixing Procedure KSHG/PR/8.8B ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose of this procedure is to outline the steps followed in the preparation, mixing and handling of pesticides. SCOPE The procedure is applicable to the all persons handling pesticides. RESPONSIBILITY: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. DESCRIPTION Determine from the pesticide label the correct dose rate and mixing instructions appropriate to the area to be treated and the application equipment to be used. Adhere to the recommended dose rates and dilutions. High doses will not produce better effects, and low doses will be less effective. Wear protective clothing and equipment when mixing pesticides. It is essential to avoid skin and eye contamination. Therefore, ensure protective clothing is worn correctly. Follow the instructions for mixing and tank filling on the product label. If none are given, half- fill the tank with water before adding the product. Make sure the spray unit is on level ground before filling. Do not measure out or mix pesticides in or near living accommodation or where livestock is kept. If measuring is necessary, use a dedicated measuring device, which must be rinsed immediately after use with the rinsing being added to the spray tank. If you are measuring powder do so in still air. If you are tank mixing, make sure the products are compatible and add them one by one to the water following the order recommended on the label. Keep children and animals away from the mixing area. Use clean water as far as is possible.

66 Page 66 of 127 Never take water direct from a stream or watercourse. Use an intermediate water bowler or other suitable vessel. Take care not to contaminate water supplies, particularly those used for cooking and drinking. Equally, take care not to contaminate or create puddles from which animals may drink. If a tap is used as the water source, the water should be carried at least a distance of 4metres away before being mixed with any pesticide. Use suitable mixing equipment. Mixing apparatus may include a mixing stick, scoop, a graduated measuring jug, a pre-mix container, and a funnel. All mixing apparatus must be kept in a dedicated room when not in use. Never dip hands and arms into liquids when stirring or decanting out into the spray unit. Pour liquids carefully to avoid spillages and splashes. Handle dusts and wettable powders carefully to avoid fluffing up. Stand up wind so that the dust or splashes blow away. Thoroughly rinse empty packs and add the rinsing to the tank. Ensure containers are closed properly after use. Store empty packs securely ready for disposal. Return any unused pesticide to the store. Wash all mixing apparatus and spray equipment after use. When doing this use the minimum amount of water necessary as this has to be disposed of. Routinely wash waterproof clothing such as gloves, face shields, goggles and gumboots after pesticide mixing, and immediately after any accidental contamination.

67 Page 67 of B Harvesting Process Hygiene Procedure Farmer Group Name Document Title KENYA Harvesting Process Hygiene SMALLHOLDER Procedure Document Number KSHG/PR/9.1B ISSUE NO. A REVISION: 0 Page-of- Purpose The purpose of this procedure is to describe the control of the harvesting process with specific emphasis on food hygiene and food safety. Scope The procedure is applicable to all growers within the farmer group, from their individual blocks to the shared group produce handling site(s). Responsibility: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. Each grower supervises activities at the farm level. Description Prior to harvesting produce, ensure that the block is 'clear to pick', i.e. pesticide pre-harvest intervals have been observed. For each crop to be harvested, a raw material specification from the customer detailing the standard of product required must be followed. It must be ensured that there is crop available to meet this specification before selecting product to be harvested. Particular attention needs to be paid to ensure produce is harvested at the correct pick (maturity) stage. All produce will be harvested by hand into harvesting trays, crates or buckets (perforated) dedicated only for harvesting. The use of plastic bags, kiondos or khangas is not acceptable. All picking containers must be washed on a daily basis after each picking with treated (chlorinated) water as per manufacturer s recommendations. Rinse the containers thoroughly and allow to dry (inverted/upside down) on crate racks (do not use cloth to wipe). They must be maintained in a clean and sound condition at all times. Once harvesting is completed transport produce to the grading shed using basic means (carried by pickers on the head or back; wheelbarrows; on bicycle) or by pick-ups and carts. In all cases hygiene procedures as described below must be followed:

68 Page 68 of 127 All pickers must be instructed as to basic hygiene requirements for food handlers before commencing the harvesting operation. A hygiene record must be completed by the harvesting supervisor for personnel involved in the harvesting. Personnel must have access to clean and appropriate toilet facilities at the vicinity of work. In addition, hand washing facilities, unscented bactericidal soap and water must be available in close proximity to the toilet for hand washing. Facilities for washing hands must be provided at the grading shed as well. After transportation from the field, produce is transferred to the customer s crates and labeled at the grading shed. Containers and packing material coming into contact with fresh fruit and vegetables must be made out of non toxic materials. They must be designed and made to facilitate washing, disinfection and upkeep.

69 Page 69 of B Collection Centre Hygiene Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Collection Centre Hygiene Procedures KSHG/PR/10.1.4B ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose of this procedure is to outline the various measures to be taken to ensure hygiene and food safety are observed in the collection centre. SCOPE The procedure is applicable to on farm and collection centre. RESPONSIBILITY The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. DESCRIPTION ;ollection Sheds Each production unit must have a grading shed for collection, pre-selection and holding of product awaiting transportation to the customer. The collection shed should be a permanent structure with a roof to provide protection from the sun and rain. It must have a finished floor ideally of concrete although other materials may be accepted. The provision of walls is not mandatory but may be advisable. The shed should have tables, which should ideally have non-absorbent tops for use when grading field picked product to the required quality standard. Under no circumstances may produce be permitted to sit directly on the floor. A notice board should be provided at this shed to hold updates of information for growers, pickers and graders, and for display of the mandatory documents. Ideally, this board should be designed such that it and items affixed to it do not pose a foreign body threat to the product, e.g. use a covered unit, or glue notices to it. Produce should be transferred from fields to the collection shed and kept In a charcoal cooler (or clean cool place) as soon as possible after picking. It should be held therein both prior to and following grading whilst awaiting collection by contracted a buyer(s). All crates approved for dispatch to customer must be clearly labeled with the picking date and production unit identification number. The grower must take all harvested produce to the collection shed no later than the afternoon on the day it is picked. No produce may be held overnight, and all produce must be sent to customer on the harvesting day.

70 Page 70 of 127 In addition, each collection shed must provide toilets, hand washing, crate washing and crate storage facilities. A pit latrine is considered an adequate toilet facility. Unscented soap and water must be available in close proximity to the toilet for hand washing. ;leaning Clean the harvesting containers, toilets and the collection shed each day produce is harvested. Cleaning should be done using clean water. Use unscented detergent particularly for dirty areas. Each day, before use, clean buckets and crates and dry them naturally (e.g. in the sun, do not use cloths to wipe dry). Clean the toilets at the start and end of each day's work. Clean the collection shed before and after each day's work. Pay particular attention to the grading tables to ensure that all produce debris is cleared away at the end of each day. Keep a cleaning schedule of all cleaning done. Glass ;ontrol Glass must be excluded from produce collection areas (e.g. the grading shed) wherever possible. If this is not possible then there must be a system in place to record that any glass in place is intact at the start and end of each day's production. If lighting is put up in the collection shed, then the light fitments should have covers so that should a bulb break it would not fall to the floor or onto the tables. Should glass breakage occur, the supervisor or Quality Management Representative must be notified immediately. All produce in the vicinity of the breakage must be thrown away. The area must then be thoroughly cleaned before produce is brought to collection shed. Pest ;ontrol Rodent, insect and bird pests must be excluded from the collection shed and its produce holding areas. During routine cleaning the area should be checked for signs of the public health pests. Should any sign be noted then this should be recorded in the comments section of the cleaning record. The QMR should then be notified to advise on the most appropriate action to take to eliminate such pests. Generally prevention can be effected with good hygiene and housekeeping. All waste material should be disposed of as promptly as possible. All vegetation around the collection shed should be removed or at least kept to a minimum.

71 Page 71 of 127 Xygiene for growers, harvesters and graders All personnel on each farm who work with produce or harvest or grade must receive personal hygiene training. Hygiene training sessions must be organized each year for growers, harvesters and graders. These sessions will teach basic requirements to growers, harvesters and graders at work and give advice on good hygiene practices in the home. Attendance at these training sessions will be recorded and/or certificates issued for all attendees. Hygiene training attendance register and/or certificates should be kept at group s administration office All harvesters and graders, must adhere to the following procedures whilst working: Personnel must maintain a high standard of personal hygiene. Personal clothing must be kept clean. Women must wear headscarves and men hats or caps. Jewellery with the exception of wedding rings (i.e. a plain gold band) must not be worn. Prior to harvesting and grading, at the start of the day, after using the toilet, before and after eating or drinking, all personnel must wash their hands. Where hygiene hand drying facilities are not available, hands should be allowed to dry naturally. All fingernails must be kept short and clean. Nail vanish must not be used. Any cuts or sores must be covered with a waterproof dressing. Personnel must not smoke, eat or drink whilst working with produce, whether in the field or collection shed. Personnel must not work with produce), if suffering from sickness or diarrhea. Children and animals must be excluded from all picking and packing areas, and both Hessian and charcoal coolers. Visitors in the field and particularly in the collection shed must respect the measures of hygiene established when they touch fresh produce. The state of health of the personnel Personnel known to carry a certain disease or infection must not be authorised to go into the area where produce is packed. Any person in this situation must immediately inform management of the disease or symptoms. A training programme must be set up to familiarize personnel with the typical symptoms of infectious diseases. Any person with cuts or wounds must protect themselves in order to avoid any direct contact with the produce. Xygiene during transport Whether it is at the farm production level (on-farm transport) or in the collection shed (at dispatch), all those in charge of transporting fresh produce must make sure that the hygiene requirements are satisfied before loading the produce onto the trucks and other means of transport.

72 Page 72 of 127 At each stage, the hygiene conditions of the transport of fresh produce must be observed. Fresh produce must be separated from other foodstuffs and from any source of contamination by pathogens. Inspection and verification of containers / crates must be done The transporters must check their containers / crates before loading the produce. The person in charge of loading at each farm must also check the transport vehicle to ensure that it is in good operating condition and corresponds to the transport requirements of the produce. If sub-contractors are used for transporting fresh produce, the person in charge of loading within the farm must ask the transporter for guarantees of hygiene standards.

73 Page 73 of B Emergency Procedures Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Emergency Procedure KSHG/PR/12.2.4B ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose of this procedure is to outline the various measures to be taken in case of an emergency in the farming operation. SCOPE The procedure is applicable to all farms and farmer group central administration RESPONSIBILITY The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. DESCRIPTION In case of Yire Shout fire!!!!!!, do not panic, be calm Make people collect at a safe place Explain carefully what has happened Delegate responsibilities Phone the emergency police number 999 Inform the overall in-charge using recognized emergency communication channels The nearest telephone is available at. Provide first aid as necessary Ensure your personal safety and that of others Put off the fire using appropriate facilities and/or call in the fire brigade In case of InZuries Call the person trained in first aid. Determine the types of injuries. Provide appropriate first aid. Call the ambulance: Number The nearest telephone is available at. Remember Always inform the in-charge about potential/likely hazardous situations. Supervisors should be always informed about conditions at work

74 Page 74 of B Personal Protective Equipment Cleaning Procedure Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Personal Protective Equipment Cleaning Procedure KSHG/PR/12.5.2B ISSUE NO. A REVISION: 0 Page-of- PURPOSE The purpose of this procedure is to outline the steps followed after applying pesticides and pesticides. SCOPE The procedure is applicable to the cleaning of personal protective clothing after use by all personnel working with pesticides. RESPONSIBILITY: The QMR has overall responsibility for ensuring that this procedure is effectively implemented and maintained. The sprayer operator does the actual cleaning. DESCRIPTION Gloves are an essential part of personal protection. However contamination may occur through or inside the glove, or that the glove is pierced. In such a case no protection is provided and on the contrary, skin penetration by the product is made possible. Gloves should be washed both inside and outside each day. Make sure that boots have been washed both inside and outside before putting them on. Face screens and glasses should be washed frequently with water to clean off deposits and to ensure good visibility. Clothing should be washed regularly in a separate wash to avoid contamination of household linen! Work wear should be kept in good condition to ensure that pesticide cannot penetrate and contaminate skin through tears or worn areas. Shoes should be inspected regularly to check for leaks and should be changed or repaired if necessary. Work wear and shoes (or boots) should be washed using soap and/or detergent after each working day. Wearing unwashed protective clothing is a serious health hazard. As a general rule, water is adequate for correct cleaning of protective equipment - soapy water may be used. Never soak masks and filter cartridges in cleaning water: it is sufficient to wipe them on the outside with a damp cloth.

75 Page 75 of 127 ANNEXES 2 FORMS - PART 1 (Quality Management System) 2.1.4A Farmer Register Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Farmer Register KSHG/REC/2.1.4A ISSUE NO. A REVISION: 0 Page-of- CONTACT ADDRESS: CONTACT PERSON: # FARMER NAME CODE ID. NO. CONTACT ADDRESS ENTRY DATE EXIT DATE EUREPGAP REGISTERED CROPS FARM SIZE(HA) PRODUCE HANDLING SITE INTER NAL AUDIT DATE CURRENT EUREPGAP STATUS Prepared by (Name) Approved by (Name) Effective Date

76 Page 76 of A Training Attendance Record Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Training Attendance Records KSHG/REC/2.3.1 A ISSUE NO. A REVISION: 0 Page-of- TRAINING ATTENDANCE RECORD GROUP: DATE TRAINER: # Name of Trainee ID.NO. Signature Prepared by (Name) Approved by (Name) Effective Date

77 Page 77 of A Training Record Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Training Records KSHG/REC/2.3.2 A ISSUE NO. A REVISION: 0 Page-of- Date: Venue: Course Duration: Course: Training Content: Name of Trainer: Institution/Organization Signature: Date: Declaration (Trainee or on behalf of Trainee(s)) Name: Position: Comments on the quality of the training in achieving the training objectives: Signature: Date: I confirm that the training was conducted as stated above and undertake to follow and implement the requirements and recommendation from this training. Prepared by (Name) Approved by (Name) Effective Date

78 Page 78 of A Internal Documents Master List Farmer Group Name Document Title Document Number Internal Documents Master List KSHG/REC/2.5.1A ISSUE NO. A REVISION: 0 Page-of- Document Title Document Number Revision status Issue No. Revision No. Reason and nature of change (where applicable) Effective Dates Location & Responsible Person Prepared by (Name) Approved by (Name) Effective Date

79 Page 79 of A External Documents Master List Farmer Group Name Document Title Document Number External Documents Master List KSHG/REC/2.5.2A ISSUE NO. A REVISION: 0 Page-of- Document Title Document Number (where applicable) Revision status Location & Responsible Person Prepared by (Name) Approved by (Name) Effective Date

80 Page 80 of A Record Master List Farmer Group Name Document Title Document Number Record Master List KSHG/REC/2.5.3A ISSUE NO. A REVISION: 0 Page-of- Record/Form Title Form Number Revision status Issue Version Effective Dates Location & Responsible Person Retention period (minimum 2 ears) Prepared by (Name) Approved by (Name) Effective Date

81 Page 81 of A Documents/Records Issue Register Farmer Group Name Document Title Document Number Documents/Records Issue Register KSHG/REC/2.5.4A ISSUE NO. A REVISION: 0 Page-of- Document/Record Title Document Number Revision status Issue Version Issued by (Name). Sign Issued to (Name) Sign Prepared by (Name) Approved by (Name) Effective Date

82 Page 82 of AB Complaints Logs Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Complaints Logs KSHG/REC/2.7A B ISSUE NO. A REVISION: 0 Page-of- Date Complaint is received Complaints Ref No. Complaints description Root Cause Corrective action By who By when Action status Prepared by (Name) Approved by (Name) Effective Date

83 Page 83 of A Audit Program Form Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Audit Program Form KSHG/REC/2.8.1A ISSUE NO. A REVISION: 0 Page-of- Year:. Crop:.. # Kind of Audit/Inspec tion Auditor/Ins pector Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 1 Farm Inspections Technical Assistant 2 Internal Audits QMS Representa tive 3 Pre Audits Certification Body 4 Certification Audits Certification Body Code =!!!for planned Y for carried out X for failed Prepared by (Name) Approved by (Name) Effective Date

84 Page 84 of A Audit Plan Form Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Audit Plan Form KSHG/REC/2.8.2A ISSUE NO. A REVISION: 0 Page-of- Date: Audit Objective: Audit Scope: Audit Criteria: Auditor(s): Areas/Farms to be Audited Time Auditee Prepared by (Name) Approved by (Name) Effective Date

85 Page 85 of A Audit Summary Report Farmer Group Name Document Title Document Number Audit Summary Report KSHG/REC/ A ISSUE NO. A REVISION: 0 Page-of- Date: Farmer/farmer group: Auditor(s): Registered products: Audit scope Audit criteria Audit objectives Strength identified Details of non-conformances identified Obstacles encountered (if any) Conclusion/EUREPGAP status: Auditor (name &signiture) Auditee (name & signiture) Prepared by (Name) Approved by (Name) Effective Date

86 Page 86 of A Corrective Action Report Form Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Corrective Action Report Form KSHG/REC/2.8.4A ISSUE NO. A REVISION: 0 Page-of- Date Farmer code (Where applicable) Non-conformance description Root Cause Corrective action By who By when Action status Prepared by (Name) Approved by (Name) Effective Date

87 Page 87 of A Approved Suppliers/Subcontractor List Farmer Group Name Document Title Document Number Approved Suppliers/Subcontractors List KSHG/REC/2.9.1A ISSUE NO. A REVISION: 0 Page-of- No. Name of supplier Supplier contacts (Address, telephone) Description of goods/ services Action status Corrective actions Quality certificate available Prepared by (Name) Approved by (Name) Effective Date

88 Page 88 of A Inputs Checklist Farmer Group Name Document Title Document Number Inputs Checklist KSHG/REC/ A ISSUE NO. A REVISION: 0 Page-of- Date Type of inputs. Quantity. Supplier.. PARAMETER SPECIFICATIONS REMARKS Broken Seals/open Seal not broken/closed Damaged products No damage Unhygienic/contaminated Hygienic and free from any contamination Not in the original Must be in the manufacturer s packaging package Expired Not expired Quantity not as LPO As per LPO Labeling not clear Documents to accompany the product not available Product not as per LPO OTHERS Must be visible Necessary documents to accompany the product e.g. Delivery notes must be available. As per LPO in regards to quality and quantity Accepted (YES/NO). Comments.. Prepared by (Name) Approved by (Name) Effective Date

89 Page 89 of A Transport/Vehicle Checklist Farmer Group Name Document Title Document Number TRANSPORT/VEHICLE CHECKLIST KSHG/REC/ A ISSUE NO. A REVISION: 0 Date Vehicle.. Page-of- PARAMETER SPECIFICATIONS REMARKS Odours e.g from preceding Odour free deliveries or incompatible goods. Residues of toxic chemicals Must be absent Infested by insects Must not be infested Remains of rotting Must be clean agricultural produce Clean and of good hygienic Must be clean and no moulds standards Vehicle corresponds to the Must meet the requirements transport requirements of the produce to be transported.e.g (Availability of pallets, Right temperature and humidity, adequate air circulation) Vehicle is road worthy Must be roadworthy Vehicle/container in good Must be in good condition condition (Floor, Roof, Walls e.t.c ) OTHERS Accepted (YES/NO). Comments Prepared by (Name) Approved by (Name) Effective Date

90 Page 90 of A Supplier Evaluation Checklist Farmer Group Name Document Title Document Number Supplier Evaluation Checklist KSHG/REC/ A ISSUE NO. A REVISION: 0 Page-of- SUPPLIER/SERVICE PROVIDER NAME: DATE: TYPE OF GOODS OR SERVICES: PARAMETER REMARKS Score (1-5) 1-Least 2-Average 3-Above average 4-Good 5-Excellent Ability to comply with the Farmer group Quality system and relevant procedures specified in the contracts (chec? incidences where there has been lapses, chec? at the commitment to implement corrective actions when required) Ability to supply goods/services within the agreed time.(;hec? instances of late deliveries) Ability to supply quality products/services (chec? on the level of rezects) Competitive prices (;ompare the prices with other similar service providers) Corrective action Status (Issues have been addressed within the agreed period) Availability (;hec? on availability when required to supply goods or services) Public Image (;hec? on the general public view on how good the service provider is) Quality System (Availability of some form of quality system and customer focus aspects) OTHERS Corrective Action required [AST \EAR A]ERAGE S;^RE (Nhere applicable): ;URRELT A]ERAGE S;^RE: L/Q:A corrective action shall be required for every parameter that the supplier has scored U or P. RETAIL SUPP[IERS (If the average score is R and above) DE[ETE YR^= APPR^]ED SUPP[IERS [IST (If the score is less than R and the action required has not been ta?en by the supplier) Prepared by (Name) Approved by (Name) Effective Date

91 Page 91 of 127 ANNEX 2 FORMS PART II (CPCC) 3.0B Planting Calendar Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Planting Calendar KSHG/REC/3.0B ISSUE NO. A REVISION: 0 Page-of- Farmer group/area Crop Planting interval Year Variety Days to maturity Farmer s Code Scheduled Plantings Week to plant Quantity to plant Actual Plantings Week planted Date planted Quantity planted Expected Harvest Date Remarks (e.g. reasons not to schedule) Prepared by (Name) Approved by (Name) Effective Date

92 Page 92 of B Seed Variety List Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Seed Variety List KSHG/REC/3.1B ISSUE NO. A REVISION: 0 Page-of- # Crop Variety Type Special Properties Area Suitable Seed Distributor Prepared by (Name) Approved by (Name) Effective Date

93 Page 93 of 127 Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Seed Treatment Record KSHG/REC/3.4B ISSUE NO. A REVISION: 0 Page-of- 3.4B Seed Treatment Record Date Seed type/variety Trade name Active ingredient(s) Rate of application Reason for treatment/dressing PHI Operator sign Comments Prepared by (Name) Approved by (Name) Effective Date

94 Page 94 of 127 Farmer Group Name Document Title Document Number Farm Group Name Site Risk Assessment 4.1.1B KSHG/REC/4.1.1B ISSUE NO. A REVISION: 0 Page-of- Farm Name Assessment by Date For Probability and Severity 1 = Low 2 = moderate 3 = high 4 = danger Total = Probability x Severity If Total > 8 raise CA # Points to Assess Remarks Consideration of Local Regulations with regard to Land Ownership (Title Deed or [ease Agreement) Previous Crops (Yor eoample, cotton farmers are heavy users of residual herbicides that can have later longjterm effects on later cereal and other crops) Industrial or Military use (Yor eoample, former vehicle pac?s may have considerable petroleum contamination) Landfill or Mining sites (=ay have unacceptable wastes in their subsoil that can contaminate subsequent crops, or be subzect to sudden subsidence endangering persons wor?ing on the land) Natural vegetation (=ight harbour pests, diseases, and weeds) Soil structural suitability for intended crops Probability Severity Total 7 Soil structural susceptibility to soil erosion 8 Soil chemical suitability for intended crops Soil Erosion 9 (Are there, or could there be, uneven losses of topsoil that may affect crop fields, and affect land and water downstream`) Landform 10 General Good Agricultural Practice Drainage Patterns 11 ([iability to flooding and/or erosion) Conformation and Slope 12 (Erosion of the soil) Safety of persons operation machinery 13 (Transportation of the harvested crop) Wind Exposure 14 (EOcessive wind speeds can cause crop losses) Water Quality 15 (To be determined by an appropriate laboratory Water Availability 16 (Adequacy throughout the year, or at least the proposed growing season) Authorization for Water Use 17 (Assurance of the predicted quantities required by the crop) Water rights of other Users 18 ([ocal laws or customs may recogniae other users whose needs may prejempt agricultural use at times) Environmental Impact of water use 19 (Nhile legal, some eotraction rates could adversely affect flora and

95 Page 95 of 127 Prepared by (Name) Approved by (Name) Effective Date

96 Page 96 of B Crop History Record Farmer Group Name Document Title Document Number Farm Code Address Farmer Name Crop History Record KSHG/REC/4.1.2B ISSUE NO. A REVISION: 0 Page-of- Crop Block No. Expd. Harvest Date Variety Block Size Max qty per pick Seed Lot No Date Planted Min. Qty per Pick Amount Planted Week planted Total Yield Exptd. Seed dressing use Reason for dressing Technical Advisor IRRIGATION RECORD NUTRIENT APPLICATION RECORD HARVESTING Irrigation Date Total water applied. Trade Name Composition Applic. Method Applic. Machinery Operator Appl. Date TA Sign Date Quantity of water per min or water can) Total Time or No. of water cans Maximum Rate per hectare Total Qty applied KGS Harvested PESTICIDE APPLICATION RECORDS Scouting Date Pest Problem % seen/ severity Trade Name Active Ingredient Rate of Applicat Total Qty Applicat. Machinery Operator TA Sign Applic. Date PHI Clear Date Comments (Reason for over or Under Production) TOTALS

97 Page 97 of 127 Germination % PHI = Pre-Harvest Interval Check Date Signature Name Erosion Control Techniques: 1) 2)

98 Page 98 of 127 Farmer Group Name Document Title Document Number Crop Rotation Plan KSHG/REC/4.2.3B ISSUE NO. A REVISION: 0 Page-of B Crop Rotation Plan Farm name Group/area Code Year Total acreage Block Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Farmer s Sign Technical Assistant s Sign.

99 Page 99 of B Scouting Record Farmer Group Name Document Title Document Number Scouting Record KSHG/REC/8.1B ISSUE NO. A REVISION: 0 Page-of- Farm Name: Code: Area/Group: Scouting: Name of Scout: Crop Name: Farm Date of Time of Scouting Variety Scouting Major Pests Found point Totals % Recommendation Beneficials TAs Sign Block Crop Age Crop Stage Yor each scouting station consider Ub nearest plants. ;ount the number of plants infected/infested by the pest and record in the respective grid. Do li?ewise for beneficial organisms. Qase your interventions on Kc threshold for disease infections and Ubc for other pests. Preventive control may be done based on prevailing conditions. Instruction for Application Chemical to use: 1) Total Chemical Total Water 2) Total Chemical Total Water Date and time to apply Application Report Date applied Time applied Chemical Used 11) Total Chemical Total Water 2) Total Chemical Total Water Application machinery Prepared by (Name) Approved by (Name) Effective Date

100 Page 100 of B Calibration Record Farmer Group Name Document Title Document Number KENYA SMALLHOLDER Calibration Record KSHG/REC/8.5B ISSUE NO. A REVISION: 0 Page-of- Date Type of equipment Parts involved Calibration action Operator name Comments Maintainance action Service man Comments Technical assistant: Sign: Date: QMR Sign: Date Prepared by (Name) Approved by (Name) Effective Date

101 Page 101 of B Farmer MRL Testing Plan Farmer Group Name Document Title Document Number Farmer MRL Testing Plan KSHG/REC/8.7.3B ISSUE NO. A REVISION: 0 Page-of- Group Name:.. District: Year:. Code =!for planned Y for carried out X for failed Crop 1 Crop 2 Crop 3 Crop 4 Crop 5 Crop 6 # Farmers Name Farm Code Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Prepared by (Name) Approved by (Name) Effective Date

102 Page 102 of B Stock Inventory Farmer Group Name Document Title Document Number Stock Inventory KSHG/REC/8.8.15B ISSUE NO. A REVISION: 0 Page-of- Group/Farm Code: Stock inventory item: Bloc k No. Crop Receipt no./delivery note Received from supplier Storekeep er s signature Received Date Qty D M Y Issued Date Qty D M Y Balance Qty Prepared by (Name) Approved by (Name) Effective Date

103 Page 103 of B Cleaning Schedule Farmer Group Name Document Title Document Number Cleaning Schedule) KSHG/REC/9.1.3B ISSUE NO. A REVISION: 0 Page-of- TYPE OF EQUIPMENT/ FACILITY Plastic buckets Plastic crates Jerry cans Toilet CLEANING TIME ACTION BY CHECKED BY CHECK DATE SIGN After harvest or transporting produce to CC After harvest or transporting produce to CC. After receipt from clients Before use(for drinking or hand washing water. Daily Collection centre Day of Work Other Prepared by (Name) Approved by (Name) Effective Date

104 Page 104 of 127

105 Page 105 of B Waste and Pollution Management Farmer Group Name Document Title Document Number Waste and Pollution Management KSHG/REC/11.2B ISSUE NO. A REVISION: 0 Page-of- A Waste / Pollution Source It can be Eliminated Reduced Recycled Action Plan Completed Date D M Y Is there a documented plan to avoid or reduce wastage and pollution and avoid the use of landfill or burning, by waste recycling Has this waste management plan been implemented? Are the farm and premises clear of litter and waste? Do the premises have adequate provisions for waste production? A comprehensive, current, documented plan that covers wastage reduction, pollution and waste recycling is available There are visible actions and measures on the farm that confirm that the objectives of the waste and pollution action plan are being carried out. Incidental and insignificant litter and waste on the designated areas are acceptable as well as the waste from the current day's work. All other litter and waste has been cleared up. Areas where produce is handled indoors are cleared at least once a day. Farms have designated areas to store litter and waste. Different types of waste are identified and stored separately. Empty chemical containers are rinsed with water, crushed and stored in a secure area or room until disposal unless they are returnable to the distributor. Prepared by (Name) Approved by (Name) Effective Date

106 Page 106 of 127 ANNEX 3: CONTRACTS Company Logo/Farmer Group name. Document Title Contracts Document Number KSHG/CT/01 Page 106 of A Farmer vs. Farmer Group Contract (A guide to drawing a contract) To include the following clauses a) Declaration stating that the farmer is willing and is ready to comply with all the provisions in the contract b) The farmers group constitution. This constitution should include the following clauses: Aim, mission, goals and vision Organisational structure Roles, responsibilities and powers of the executive committee and the general assembly Membership criteria, rules of entry and exit Election of office bearers modalities, term limits, dissolution of executive, AGMs, procedures for amending the constitution By-laws which adequately cover the day to day running of the farmer group modalities; meetings, frequency of meetings, disciplinary actions and how they will be invoked, the circumstances to invoke the disciplinary measures and the levels of the disciplinary measures, appealing and the appeals body, how to realise farmer group s objectives, conflict resolution mechanisms A list of do s and don ts for drawn from the EUREPGAP QMS c) A general map of the farmer group indicating where each farm is located d) A list of members name with their signatures e) Farmers rules Hygiene, Group membership, use of pesticides, training, selling, Post harvest handling, Seeds and rootstocks, PHI, Pesticides application rules, record keeping (farm diary), disposal containers and chemicals- f) New farmer introductions into farmer group

107 Page 107 of 127 Application/declaration Water supply, land area, prior use - communication with PMO by grower group. Probationary period supervision rules once per week for the next 3 months. g) Changes to farmer groups membership h) The farmer group responsibilities/skills i) Farm identification j) Traceability codes and farms and blocks registration l) Checklist (Do s and don ts - applied by the service provider agronomist) m) Rights of access by the representatives of the farmer group and service provider n) Sanctions and appeals o) Contact address and locations p) Additional commercial details 2.1.3B Farmer Group vs. Service Provider Contract (A guide to drawing a contract) To include the following clauses: a) Aim, vision, mission and goals statement b) Organisational and management structure and how it relates to the farmer group c) Roles, responsibilities and powers d) EUREPGAP Standard compliance (This is a do s and don ts list drawn from the EUREPGAP QMS and covers all the requirements of the standard). e) The full EUREPGAP QMS should be included as an annex. d) Communication channels. e) Communication of problems f) Exclusion and management of unapproved farmers within the farmer group.

108 Page 108 of 127 g) Sanctions and appeals; enforcement and the sanctions procedure as laid down in the EUREPGAP QMS. h) Additional commercial details (Payment modalities/change of service provider/contract duration) i) Termination of contract. j) Contact address and locations 2.1.3C Farmer Group vs. Exporter Company(s) Contract (A guide to drawing a contract) To include the following clauses a) Aim, vision, mission and goals statement of export company b) Organisational and management structure and how it relates to the farmer group. c) Roles, responsibilities and powers of each party- a copy of the farmers register of all members of the farmer group. d) A declaration by the officials of the farmer group and those of the export company to abide by the terms of the contract. e) EUREPGAP Standard compliance This is a do s and don ts list drawn from the EUREPGAP QMS and covers all the requirements of the EUREPGAP Standard that the farmer group must meet f) The full EUREPGAP QMS should be included as an annex. g) Communication channels. h) Communication of problems i) Exclusion and management of unapproved farmers within the farmer group. j) Sanctions and appeals; enforcement and the sanctions procedure as laid down in the EUREPGAP QMS. l) Additional commercial details Payment modalities Price structure particularly during the low and high seasons Shared risk on the rejects levels of produce Production and planting programmes Volumes and types of produce

109 Page 109 of 127 Technical quality specifications of produce involved Inputs to be provided and terms of provision Change of service provider Contract duration m) Termination of contract. n) Contact address and locations ANNEX 4: JOB DESCRIPTION AND SPECIFICATION Company Logo/Farmer Group name. Document Title Job Description and Specification Document Number KSHG/JD/01 Page 109 of Production Manager Fo/ Descri2tions: Represents the group before third parties Acts as the EUREPGAP Management Representative as referred to in EUREPGAP GR , Annex; I and ii Signs contracts with the Certification Body and subcontractors Organizes and supervise the administrative and accounting procedures, finances and legal requirements of the association Appoints the Quality Director (together with the Governing Board) Evaluates staff performance Handles of complaints Manages the withdrawal of products Undertakes annual management reviews Fo/ S2eci8ications: Diploma or equivalent (minimum course duration of two years) in agricultural or horticultural production Practical skills in personnel management an added advantage Competence in the EUREPGAP standard and knowledge in certification processes English language skills suitable for negotiations and communication with EUREPGAP bodies Local working language skills

110 Page 110 of Technical Manager Fo/ Descri2tion: Designs and implement the Quality Management and Control System (ICS) Reviews and approve ICS documents before issue and distribution Undertakes annual internal audits to assess the adequacy and compliance of the ICS Follows up on corrective actions related to the internal audit Assigns internal inspectors Conducts personnel evaluations and performance reviews in order to find out training needs and organizes and supervises the training of the internal inspectors Supervises the training of farmers Documents all inspections/audits and produces a written briefing for the CB on results of the internal inspections/audits Participates in the decision-making concerning approval or sanctioning of farmers Follows-up on sanctions to the farmers Coordinates external inspection with the CB Keeps external contacts in all aspects concerning the inspection and certification Notifies the CB and/or EUREPGAP on all relevant matters Keeps the farmer register up to date Fo/ S2eci8ication: Diploma or equivalent (minimum course duration of two years) in agricultural or horticultural production Training either as part of the formal qualifications or by the successful completion of a formal course in: - auditing techniques - food hygiene, HACCP - pesticide and fertiliser use A minimum of 2 years post-graduate and 3 years overall experience in the horticulture industry. This shall involve work in the production of horticultural products, or a quality assurance or food safety function within the fruit and vegetable industry Practical auditing experience English language skills suitable for negotiations and communication with EUREPGAP bodies Local working language skills 3.0. Agronomist Fo/ Descri2tion: Co-ordinates all production and technical programs Allocates duties, supervises, coordinates and plans all the activities of the Technical Assistants and other members of the technical team. Sets farm inputs specifications and liaising with CC Manager to ensure that ordered inputs reaches the collection centre

111 Page 111 of 127 Provides technical advice to farmers Ensures and maintains good relations between farmers Trains the technical team on IPM and ICM and other areas of the quality management system Ensures the effective operation and functioning of farmer group Co-ordinates farmer groups promotion activities Other duties assigned by the Production Manager Management representative of employees welfare, health and safety Provides the Production Manager with weekly reports on production and other matters as outlined in the QMS Fo/ S2eci8ication: Diploma or equivalent (minimum course duration of two years) in agricultural or horticultural production Training either as part of the formal qualifications or by the successful completion of a formal course in: - auditing techniques - food hygiene, HACCP - pesticide and fertilizer use Two years experience in the production of horticultural crops in a smallholder scheme or exporter outgrower scheme 4.0. EUREPGAP Internal Auditor Fo/ Descri2tion: EUREPGAP Yarmer Group Audits Audits and assesses Quality Management System of farmer groups for compliance with the EUREPGAP Standard. Produces timely and accurate reports on such audits in accordance with the report format agreed with EUREPGAP. EUREPGAP Yarm Inspections Inspection of farms (of either farmers or farmer groups) to assess compliance with the EUREPGAP Standard. Produces timely and accurate reports on such inspections in accordance with the report format agreed with EUREPGAP. General To maintain up to date files of all quality policies, procedures, work instructions and documentation issued by the CB. To keep abreast of developments, issues and legislative changes pertaining to the sectors in which audits are carried out. To carry out any other tasks the CB may assign, outside the scope of EUREPGAP, so long as these activities do not contradict EN / ISO 65 principles or any stipulation set down by EUREPGAP General Regulations document.

112 Page 112 of 127 Independence and confidentiality Auditors are not permitted to carry out any activities, which may affect their independence or impartiality, and specifically shall not carry out consultancy or training activities for the Farmer or Farmer Groups on whom they perform audits. Auditors must strictly observe the Company's procedures to maintain the confidentiality of information and records. Fo/ S2eci8ication: Yormal qualifications: A least a diploma or equivalent (minimum course duration of 2 years) must have been obtained in agriculture /horticulture or related discipline. Technical s?ills and qualifications: Lead assessor training Practical auditing experience (minimum 15 days). Lead Assessor training course must have a minimum duration of 37 hours, which must be recognized by one of the Accreditation Bodies defined in Annex 5, point of the EUREPGAP Standard. Lead assessor training course must cover: applicable standards on quality auditing, auditing techniques, focus of the audits (psychological aspects and communication) and reporting, it must also include a practical case study. Yood safety and GAP training: Training in HACCP principles either as part of formal qualifications or by the successful completion of a formal course based on the principles of Codex Alimentarius. Food hygiene training either as part of formal qualifications or by the successful completion of a formal course. Pesticide and fertiliser training either as part of formal qualifications, or by the successful completion of a formal course. A minimum of 2 years post-graduate and 3 years overall experience in the horticulture industry. This shall involve work in the production of horticultural products, or a quality assurance or food safety function within the fruit and vegetable industry. ;ommunication s?ills: English language skills suitable for negotiations and communication with EUREPGAP bodies. "Working language" skills in the corresponding native/working language. This must include the locally used specialist terminology in this working language. Exceptions to this rule must be consulted beforehand with the EUREPGAP Secretariat.

113 Page 113 of Technical Assistant Fo/ Descri2tion: Ensuring the effective operation of the EUREPGAP Quality Management System. Carries out crop scouting Recording and maintaining records of production as required by the KSHG EUREPGAP Quality Management on behalf of the farmer group. Advising farmers on intervention methods to use on pests, diseases and good agricultural practices. Ordering inputs Confirming inputs meet the specification Responsible for all agronomic aspects of crop production. Authorizing spraying team where to spray, how and with what pesticides & rates on farm scouted. Authorizing cleaning of PPEs and other equipments Ensuring that planting is done according to production targets of the farmer group. Ensuring implementation & sustenance of EUREPGAP system Conducting EUREPGAP internal self-inspections of farmers farm. Training farmer groups in personal hygiene and other requirements of the EUREPGAP Standard Acting as farmer group promoter. Authorizing and documenting disposal of empty pesticide containers Ensuring that only the recommended pesticides are used Ensuring that planting program is met, and customer s specifications on quality and quantity are met. Fo/ S2eci8ication: Certificate or equivalent (minimum course duration of two years) in agricultural or horticultural production Training either as part of the formal qualifications or by the successful completion of a formal course in: - auditing techniques - food hygiene, HACCP - pesticide and fertiliser use Thorough knowledge of the EUREPGAP Standard 6.0. Collection Center Head Fo/ Descri2tion: Heads a collection centre Ensuring the effective operation of the EUREPGAP Quality Management System. In charge of documentation of produce details i.e. labeling, tagging, traceability coding according to EUREPGAP Standard. Assisting in sorting according to specifications. Recording and maintaining all yield data of all farmers in the farmer group.

114 Page 114 of 127 Recording all input requirements of farmers and forwarding them to the Production manager Ensuring sufficient supply of crates for his/her center Ensuring CC, containers/crates cleanliness Training farmers on sorting specifications. Weighing and recording of produce Fo/ S2eci8ication: At least form four level of education Food hygiene training Produce quality specification Good in record keeping Good communication skills 7.0 Sprayer Operator Fo/ Descri2tion Reporting to the Technical Assistant, follow recommendations on pesticide use. Read and interpret information on pesticide label before handling pesticides. Calibration and maintenance of pesticide application equipment and machinery. Accurate pesticide preparation and mixing. Proper pesticide application according to laid down procedures. Cleaning of PPE and application machinery. Proper disposal of pesticide wastes. Keep relevant records of the application and disposal of pesticides. Report any problems and issues arising from the routine operations. Observe personal hygiene in the use of pesticides. Collaborate fully with farmers and all others involved. Undergo periodic medical checks as required in the Quality Management System. Follow all procedures on farms regarding visitors and subcontractors. Fo/ S2eci8ication Able to read and write. Trained in safe and effective pesticide use. Physically fit and in sound health conditions. Able to keep records.

115 Page 115 of 127 ANNEX 5 RISK ASSESSMENT GUIDELINES Company Logo/Farmer Group name. Document Title Document Number Risk Assessment Guidelines KSHG/RAG/01 Page 115 of 127 STEP RISKS PREVENTIVE MEASURES CCP CRITICAL LIMIT FOLLOW-UP PROCEDURES Seeds Presence of Only use pesticides on official list Yes Seeds treated only with Check data sheets for prohibited of approved pesticides. approved pesticides. seeds. pesticides. Site selection & preparation Use of land without consideration of local regulations with regard to land ownership. Avoid land with disputes or which is likely not to be available before within 12 months. Yes Title Deed or Lease agreement must be acquired prior to planting. Documented lease agreement for a minimum period of one year. CORRECTIV E ACTION Inform seed /pesticide suppliers or the seed dresser. Conflict resolution whenever disputes arise. Acquire alternative site. Legal procedures instituted in case of crop loss.

116 Page 116 of 127 STEP RISKS PREVENTIVE MEASURES CCP CRITICAL LIMIT FOLLOW-UP PROCEDURES Contamination Do not use land known to contain Yes Comply with Collect and check site by pesticides. pesticide residues. requirements for new data. Evaluate history of Fertilizer management Contamination by heavy metals Contamination by waste water. Contamination of water by floodwater. Contamination from animal manure Overuse of Nitrogen fertilizers can cause high nitrate content in produce Do not use land known to contain traces of heavy metals. Do not use land after untreated sewage water has been applied. Reduce possibility of contaminated floodwater reaching crops by, e.g. ditches Do not apply manure directly to crops. Consider composting to reduce microbial load. Reduce runoff and leaching from manure heaps. Apply quantities according to crop requirements. Recommendations only from trained and competent advisors. Yes Yes Yes sites selection. Comply with requirements for new sites selection. Comply with requirements for new sites selection. Comply with requirements for new sites selection. previous crops. Collect and check data. Evaluate history of previous crops and water utilization from source. Evaluate onsite risks of flooding. No Soil analysis Register and check fertilizer application records. No Comply with fertilizer application plan. Check recommendations on fertilizers. Check fertilizer application records. CORRECTIV E ACTION Soil analysis prior to planting. Soil and water analysis prior to planting. Soil analysis and correction of growing practices. Drainage channels to be dug to divert away flood water Control organic fertilizer useonly properly composted manure to be used. Manure must be incorporated in the soil. Review fertilizer plan Irrigation Contamination Examine water sources in relation Yes Use irrigation water of Analyze irrigation water Change water

117 Page 117 of 127 STEP RISKS PREVENTIVE MEASURES CCP CRITICAL LIMIT FOLLOW-UP PROCEDURES from dirty good quality. irrigation water Crop protection Incomplete pesticide records Contamination by pesticides due to poor dosing and application practices. Incorrect pesticides applied to the crop. to water utilization on adjacent land. Consider avoiding sprinkler/overhead irrigation. All information on applications must be kept for at least 3 years Only trained and competent personnel to apply pesticides. Ensure availability of up-to-date list of approved pesticides. Yes Yes Yes Up- to- date records of all applications. Personnel training and competence records. MRL testing plan. List of approved pesticides available. periodically. Make risk evaluation of water sources and potential for contamination by human or animal faecal matter. Personnel training procedures. Double check system for application records. Annual MRL testing for each grower. Set up training and follow up procedures. Stores inspection. Check application records. Regular updates of approved pesticides. CORRECTIV E ACTION source if necessary. Avoid water souces with risk of contamination by animal or human faecal matter. Retrain personnel. Reject produce which has no clear pesticide records. Review MRL testing plan. Review training plan. Change personnel. Reject affected produce. Review approved pesticides list. Retrain/change personnel. Reject affected produce

118 Page 118 of 127 STEP RISKS PREVENTIVE MEASURES CCP CRITICAL LIMIT FOLLOW-UP PROCEDURES Contamination Conduct scheduled maintenance Yes Regular calibration of Check calibration by pesticides and calibration of application sprayers records and maintenance due to poorly equipment schedule. calibrated sprayers. Contamination by dirty water in spray solution Examine sources of water for spray mix preparation. Yes Use clean water for preparation of spray mix. Undertake risk assessment of water source. Periodic water analysis. CORRECTIV E ACTION Review maintenance/ca libration schedule. Retrain/change personnel. Reject affected produce. Avoid dirty water sources. Reject affected produce. Spray drift from adjacent fields. Contamination by poor disposal of pesticide wastes. Avoid spraying when windy. Introduce Integrated Crop protection programme with neighbors Stock management to minimize expired/obsolete pesticides. Soak pits for tank and PPE washings as well as excess spray mix. Disposal drums for official collection for empty pesticide containers. Yes Personnel spraying skills Supervise pesticide applications. Yes Comply with proper disposal practices Check pesticide waste disposal records. Reject affected produce. Conduct affected crop for unwanted/exces s residues. Personnel training. Enforce safe disposal measures.

119 Page 119 of 127 STEP RISKS PREVENTIVE MEASURES CCP CRITICAL LIMIT FOLLOW-UP PROCEDURES Harvesting Contamination Supervise personnel during Yes Comply with Good from jewellery, harvesting. Hygiene Practices clothing and Establish hygiene procedures. (GHPs) foreign matter Microbial contamination by farm workers Contamination from soil, glass, plastic, wood and stones. Provide appropriate training in hygiene and basic food safety. Provide sanitation and hand washing facilities near work place. Personnel must report any food borne afflictions e.g. jaundice, fever, diarrhea, wounds, skin problems, or discharges from eyes, nose, ears. Personnel behaviour e.g. spitting, sneezing or coughing over produce. Adapt harvesting methods to avoid contamination. Be sure that containers are intact and un damaged. Yes Yes Comply with Good Hygiene Practices (GHPs) Comply with Good Hygiene Practices (GHPs) Check hygiene procedure implemented. Check hygiene records. Check hygiene records for personnel. Cleaning schedules/ records for toilets, containers. Staff awareness programme. Training in personnel hygiene and responsible behavior. Inspect and record container data sheets. CORRECTIV E ACTION Retrain/change personnel Reject affected produce. Retrain/change personnel Discard affected produce. Retrain/ change personnel

120 Page 120 of 127 STEP RISKS PREVENTIVE MEASURES CCP CRITICAL LIMIT FOLLOW-UP PROCEDURES Contamination Produce must not be harvested Yes by pesticides before clear-to-harvest date Add 24 hours safety period to approved Pre harvest interval. A red flag must be displayed in the field until it is clear to harvest. Only pesticides with 1 day or less PHI permitted after first harvest date. Check Crop History record to verify clear date to harvest Cross check PHI with approved pesticides list. CORRECTIV E ACTION Discard affected produce. Retrain/ change personnel concerned. Revise pesticide list periodically. Grading Contamination due to dirty harvesting/ handling equipment or on farm transport. Contamination of produce due to poor maintenance of charcoal cooler, grading shed walls, floor and tables. Ensure harvesting equipment is in good condition Cleaning procedure Maintenance programme. Yes Yes Comply with Good Hygiene Practices (GHPs Comply with Good Hygiene Practices (GHPs) Check cleaning programme. Check cleaning and maintenance records. Ensure procedures are followed. Affected produce discarded. Retrain/change personnel. Discard affected produce. Review cleaning programme. Retrain/ change personnel.

121 Page 121 of 127 STEP RISKS PREVENTIVE MEASURES CCP CRITICAL LIMIT FOLLOW-UP PROCEDURES Contamination Supervise personnel during Yes Comply with Good from jewellery, harvesting. Hygiene Practices clothing and Establish hygiene procedures. (GHPs) foreign matter Worker health, safety and welfare Microbial contamination by farm workers Buildings/struct ures unsafe for work Provide appropriate training in hygiene and basic food safety. Provide sanitation and hand washing facilities near work place. Personnel must report any food borne afflictions e.g. jaundice, fever, diarrhoea, wounds, skin problems, or discharges from eyes, nose, ears. Personnel behaviour e.g. spitting, sneezing or coughing over produce. Ensure freedom from litter and debris. Work and movement areas well lit. Permanent ladders, stairs and steps are in good order. Yes Yes Comply with Good Hygiene Practices (GHPs) Work only in buildings/structures which are safe for work. Check hygiene procedure implemented. Check hygiene records. Check hygiene records for personnel. Cleaning schedules/ records for toilets, containers. Staff awareness programme. Training in personnel hygiene and responsible behavoiur. Regularly check the integrity of buildings/structures. Supervise personnel during work. CORRECTIV E ACTION Retrain/change personnel Reject affected produce. Retrain/change personnel Stop working under the prevailing conditions. Stored material properly stacked. Flammable chemicals such as paints and solvents stored in dedicated areas.

122 Page 122 of 127 STEP RISKS PREVENTIVE MEASURES CCP CRITICAL LIMIT FOLLOW-UP PROCEDURES Fire Outbreaks NO SMOKING signs placed in Yes Comply with fire office and stores. prevention Procedures. Emergency telephone numbers and phone locations and procedures prominently displayed. Routinely check emergency procedures and facilities are in good state. Staff awareness records. CORRECTIV E ACTION Revise procedures. Seek assistance promptly. Fields, drives and compounds risky for working. Appropriate fire buckets/extinguishers located strategically for easy access in case of fire. Equipment is kept off steep slopes where stability can be uncertain. Pathways and sewerage traps in good repair condition. Yes Comply with Preventive measures. Routine inspection and follow-ups. Review followups and inspection procedures. Farm tools and equipment are put away after use Protection from water sources such as tanks, wells and/or boreholes Children are kept away from storage areas Checks for nests of stinging insects done.

123 Page 123 of 127 STEP RISKS PREVENTIVE MEASURES CCP CRITICAL LIMIT FOLLOW-UP PROCEDURES Unsafe Only trained personnel to store and Yes Competent personnel Conduct competency Pesticide handle pesticides handle pesticides. checks for pesticide Storage and handlers. handling CORRECTIV E ACTION Retrain personnel. Check storage conditions.

124 Page 124 of 127 ANNEX 6. ENVIRONMENT MANAGEMENT PROTOCOL Company Logo/Farmer Group name. Document Title Environment Management Protocol Document Number KSHG/ENV/01 Page 124 of 127 # Kind of Waste Section A: Waste and pollution Management Plan 1 Crop Waste Harvest and grading waste. Crop residues in the field Dumping. 2 Synthetic waste Waste Removal method Encouraged management practice Irrigation pipes, Tarpaulin, Fertilizer bags, punnets, overwrapping films, Foils, broken crates. 3 Paper Scrap paper, damaged cartons, obsolete records. 4 Glass and Metal Broken light bulbs and tubes, bottles, broken window panes, Nuts and bolts, machinery and equipment worn out parts. 5 Rubber Worn-out tyres, gumboots, gloves and shoes. Feed to livestock. Composting(if no danger of disease transfer) Re-use (other uses which pose no risk to food safety and the environment); Recycle (return to manufacturer); Burning in designated areas away from residential sites and business premises, through incineration) Burning in designated areas away from residential sites and business premises, through proper incineration) Dumping in designated areas (in designated disposal area). Recycle (return to manufacturer); Re-use (other uses which pose no risk to food safety and the environment) Re-use worn-out tyres (e.g. for ox-carts), Burning in designated areas away from residential sites Composting if no risk of disease transfer. Disposal of synthetic materials by recognized transport or processing company. Separation of different types of synthetic material depending on recycling possibilities. Old paper and cartons to be recycled. Present glass and metals for recycling. Collect different metal types for recycling. Disposal by recognized body/organization. Present rubber tubes, tyres and PPE for recycling.

125 Page 125 of 127 # Kind of Waste 6 Dangerous Waste Waste Removal method Encouraged management practice and business premises, through proper incineration); Recycle (return to manufacturer) Obsolete/Expired pesticides, Excess pesticide tank mix, Batteries, Oils, Cartridges, Printing ribbons, Toners, Ink Dumping in designated licensed disposal areas and records kept. Disposal by authorized /approved channels. Buy materials creating as less as possible dangerous waste and pollution. Storage of waste in a safe place awaiting official collection and disposal. Disposal of dangerous wastes by a recognized processing/transport company. SECTION B: Impact of Farming on the Environment # Risks Control aspects 1 Dust from roads with heavy traffic nearby; Smoke and noise problems caused by operation of agricultural machinery Bumps to reduce speed of vehicles on roads near the farm. Machinery should be kept in good working condition to avoid unnecessary noise and excessive smoke. 2 Contamination of downstream sites by silt-laden or chemical-laden run-off. Control of soil erosion: Grass strips in between blocks. Trees around the farm as windbreaks. Gabions to prevent gully erosion. Contour ploughing and planting. 3 Spray drift Reduce over-use of pesticides: Low Dosage System (LDS) Proper pesticide Application Techniques. Integrated Pest Management (IPM). 4 Insects attracted by the crop, its waste, or manure operations 5 Silt-laden or chemical-laden run-off from upstream farming operations. Field Hygiene: Waste management as shown in Section A above. Water and soil analysis reports required in order to make informed decisions.

126 Page 126 of 127 # Risks Control aspects 6 Indiscriminate destruction of pests by use of non-selective pesticides damaging natural ecosystems. Reduce Over-use of pesticides: Low Dosage System (LDS) Proper pesticide Application Techniques. Integrated Pest Management (IPM). Improvement of Bio-Diversity: Control of Parcel Borders. Follow Wildlife and Conservation Policy Plan 7 Water extraction rates that could adversely affect flora and fauna dependent on the water sources. Reduction and control of Water Use. Planning Irrigation ( see Water Management Plan) Use efficient irrigation methods where possible. Water harvesting methods including reservoirs. 8 Clearing/trimming of vegetation Landscaping and reforestation. Maintenance of available vegetation and natural habitats where possible. 9 Generation of farm and domestic waste Ensure proper disposal of waste as per guidelines in Section A above.

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