FOOD SAFETY MANAGEMENT SYSTEM MANUAL (FSMS)

This document summarises our Food Safety policy, outlines our management system and details our key objectives and key principles for managing food safety. The priorities we place on Food Safety is based on our belief and experience that commercial success and good food safety practice and performance are longterm compatible goals. The intent of the policy is to provide a safe and healthy workplace for employees and to protect the food chain. We employ a systematic best practice review process to ensure Food Safety at all stages we are involved within the food chain. XYZ Foods operate a food safety management system based around HACCP and designed to control all Critical Control Points The HACCP is produced by following the Codex Alimentarius code of practice and using the most up to date EU legislation. XYZ Foods has the responsibility and authority for assuring compliance with appropriate regulatory law or guidelines. These shall be clearly assigned to a competent supervisory-level person or persons, and a functional organisational chart shall be maintained. The competent supervisory-level person shall ensure that all employees are aware of their responsibilities and mechanisms are in place to monitor the effectiveness of their operation. The company food safety policy statement will be placed in a suitably visible position and communicated to all staff during their induction training. A positive food safety culture is encouraged within the organisation and is actively supported by senior management. XYZ is committed to conducting its business taking all responsible precautions and ensuring due diligence is exercised to protect and preserve the human food chain at all stages of involvement. Allied is committed to conducting its business taking all responsible precautions and ensuring due diligence is exercised to protect and preserve the human food chain at all stages of involvement.

4. FOOD SAFETY MANAGEMENT SYSTEM 4.1 GENERAL REQUIREMENTS

This section describes XYZ food safety management system that has been developed to assist the company in its quest to continually seek improvements in its food safety performance. Figure 2 below shows the key elements of an effective management system. The international food safety management system standard EN ISO 22000:2005 has been used as best practice and provides the structure of this document

XYZ will ensure that: We comply with the requirements of all relevant food legislation and approved codes of practice; We implement the principles of HACCP as appropriate at food handling locations, clearly setting out the appropriate control and monitoring measures to be exercised to safeguard the food chain; We commit to the development and maintenance of appropriate systems and controls in conjunction with interested third parties, and ensure these are adequately communicated to all XYZ workers in the food chain.

4.2 DOCUMENTATION REQUIREMENTS

A procedure is in place to ensure that food safety documentation is available to those who need it. Documentation is periodically reviewed, revised as necessary and approved for adequacy by authorised personnel. Records that require maintaining for legal and knowledge preservation purposes are identified.

5. MANAGEMENT RESPONSIBILITIES 5.1 MANAGEMENT COMMITMENT

Management commitment to Food Safety is demonstrated in a number of ways: Food Safety, Health & Environment Committee: This committee comprises XYZ senior management team. This committee and other sub-committees are committed to reviewing and improving performance in the areas of Food Safety and Occupational Health, Safety and the Environment. Management Review: The senior management team shall review the suitability, adequacy and effectiveness of the Food Safety Management System. The management team will assess opportunities for improvement and the need for changes to the food safety management system, including the food safety

policy. The details will be communicated to the board by the monthly Dash Board Showing and demonstrating support: Senior management will provide leadership in Food Safety by: Setting appropriate goals and objectives that support and provide direction to the business on food safety aspects and issues.

Ensuring adequate resources are made available.

Establishing and supporting food safety initiatives and programmes

5.2 FOOD SAFETY POLICY

The XYZ Food Safety policy is provided in Appendix 1 of this document and sets out our management principles. The policy was produced and authorised by the XYZ Central Committee and is reviewed when required. The policy is communicated throughout the company and made available to interested parties.

5.3 FOOD SAFETY MANAGEMENT SYSTEM PLANNING

Hazard analysis is the basis of modern Food Safety management and is considered a primary function of management in all operational decisions and formulation of risk control measures. The internationally recognised Hazard Analysis Critical Control Points (HACCP) system forms the basis for our Food Safety Management System. HACCP plans are reviewed upon significant changes and routinely at least annually, resulting remedial actions are tracked through to completion. As well as considering the hazards and risks posed by activities carried out by XYZ personnel, we also consider hazard and risks arising from activities by the Customer, contractors and visitors, and the use of products or services supplied by third parties. Where hazard analysis activities affecting XYZ are carried out by the Customer, or other third party, a record is maintained in the site food safety file.

5.4 RESPONSIBILITY AND AUTHORITY

5.4.1 The Managing Director Will ensure that there is an effective policy for food safety within XYZ operations, and take a direct interest in the food safety programme. Will support all persons carrying out their responsibilities under this policy. Will ensure adequate resources are available to meet food safety requirements. Will ensure that responsibilities are properly assigned, entered into job descriptions and accepted at all levels.

5.4.2 Quality Assurance Manager Responsible for all food safety and hygiene for XYZ Foods ensuring at all sites staff are adhering to food hygiene legislation and following the HACCP plan for the site/contract and will ensure that the site managers provide sufficient

resources, in terms of personnel & equipment, are employed in order to achieve the required performance levels. Responsible for maintaining and improving the food safety management system and will also ensure the integrity of the food safety management system is maintained when business changes are made Will have developed the HACCP plan with each of the sites and will have knowledge of the site HACCP plan and an understanding of its importance. Responsible for communication on all food safety related matters and ensuring the company is informed of any legislation updates. 5.4.3 Local Level GENERAL MANAGERResponsible for all food safety and hygiene for site/contract ensuring all staff are adhering to food hygiene legislation and following the HACCP plan for site/contract. The GM will ensure that sufficient resources in terms of personnel & equipment are employed in order to achieve the required performance levels. Responsible for maintaining and improving the food safety management system and will ensure the integrity of the food safety management system is maintained when business changes are made. Will have knowledge of the site HACCP plan and an understanding of its importance. FIRST LINE MANAGERS / TEAM LEADERS Responsible for the supervision of staff with regard to food hygiene in your area, ensuring all staff are adhering to food hygiene legislation and following the HACCP plan for the site. Will have knowledge of the site HACCP plan and an understanding of its importance.

Will be a member of the HACCP team and is responsible for ensuring the HACCP plan is followed and any area identified as a potential breach in food hygiene or safety is logged and corrective action taken and documented

5.5 FOOD SAFETY SITE LEVEL

Each site will be responsible for appointing a Food Safety Co-ordinator who will have responsibility and authority: To manage a food safety team and organise its work To ensure relevant training and education of the food safety team members To ensure that the company food safety management system is implemented, maintained and updated To report to the Quality Assurance Manager on the effectiveness and suitability of the food safety management system HACCP TEAM Each site/contract shall establish and train a HACCP Team. This team should be multidisciplinary meet regularly and conduct regular audits. Audit records are an integral part of this requirement, and documentation of specific assignments and actual accomplishments shall be maintained. Follow-up audits should be done to ensure that items are corrected.

Regularly monitor documentation that may indicate trends of non-conformance and recommend corrective actions , ALL EMPLOYEES - GENERAL RESPONSIBILITIES Responsible for adhering to food hygiene relevant to your role and adhering to the site/contract HACCP plan. All staff must take ownership of the food safety and hygiene systems in operation. All Employees: Are responsible for adhering to food hygiene relevant to your role and adhering to the HACCP plan for the site. Adhere to food safety instructions Operate hygienically Report any problems relating to food safety or a failure in control measures Comply with the law. Work in accordance with any training or instruction given. Follow any food safety arrangements and rules established for the protection of the food chain. Make use of any food safety or protective equipment or devices supplied. Food handlers are expected to report illnesses that may impact on food safety. NOTE: Breaches of Food Safety rules will be handled through the Company disciplinary procedure in the same manner as any other breach of Company rules

5.6 COMMUNICATION
5.6.1 EXTERNAL COMMUNICATION It is important that we ensure sufficient information on issues concerning food safety is available throughout the food chain and, in order to do this, we have identified a number of key relationships that we intend to maintain: Suppliers and Contractors: All our suppliers will complete questionnaire and undergo a vetting and monitoring processes that ensures they have effective food safety arrangements in place. All contractors are briefed on food safety requirements before work commences. Customers: XYZ will, in collaboration with its customer, continuously examine the latest industry techniques, technology and equipment with a view to improving food safety performance. Such improvements may be required as a result of new or changing legislation. If Allied takes on additional work or contracts work out the process or company will be audited to ensure the food safety procedures are safe. Statutory and regulatory authorities: We have a procedure to record and communicate within the business all aspects of working with statutory and regulatory authorities. All commitments and plans agreed are documented and communicated to the central health and safety team in the monthly board report. Professional bodies: We work closely with consultancies, training providers and many other advisory bodies to ensure that we keep abreast of changing legislation and best practices in the area of food safety.

5.6.2 INTERNAL COMMUNICATION It is company policy to establish a HACCP team for all food sites The objectives of the HACCP team meetings are: Monthly Food Safety Review Meetings will take place to review food safety performance, although attendees may vary, generally attendees will include: Food Safety Representative Contract/General Manager As required, representatives from Warehouse, Stock and Admin and Transport management. As required, representatives from the shop floor. Note, this may be a separate meeting or may form part of a management team meeting or health and safety meeting. The following will items be discussed where applicable: Results from audits Review of HACCP system records and results Complaints involving food safety Local document amendments Corrective Actions Examine the site incidents involving food safety. Study food safety statistics and trends so that joint agreement can be reached on remedial measures. Examine food safety inspection reports. Discuss cleaning and sanitation programmes. Assist in developing site HACCP plans. Conduct (ideally as part of the Committee Meeting) periodic inspections of food safety arrangements. Monitor the effectiveness of food safety training, communication, publicity and signage. Discuss and resolve any problems that have previously been raised directly between safety representatives and management, but without resolution .

5.7 EMERGENCY PREPAREDNESS AND RESPONSE

The company will ensure that information is supplied quickly to senior management with regard a major food safety incident to alert key personnel in the event of a food safety incident, e.g. a Class 1 Recall, which may arouse media, legal or Customer interest. It ensures XYZ support services are deployed most effectively, and the reputation of the Company is safeguarded in the eyes of the media, our customers, suppliers and the general public. The site will have an updated Business continuity plan.

Food Safety Incidents A food safety incident can be considered as: An event which has potentially harmful implications to the public resulting from the consumption of food The identification of contaminated foodstuffs, that if consumed may lead to illness. The identification of serious human illness that may be linked to contaminated foods. The identification of unhygienic practices in a food business of such a degree as to present an immediate danger to consumers health. The identification of irregular or illegal practices in any food business or in the distribution network that could pose a threat to consumers health. Biological or chemical contamination resulting from deliberate tampering or a terrorist event. A process is in place to ensure that the business can, in the event of a major food safety incident occurring, ensure that the following activities are carried out: Deal with the incident effectively: Audit suppliers if necessary: Report to the relevant enforcing authority: Communicate effectively, both within the company and with local emergency teams, authorities and the community, as appropriate. Investigate the cause of the incident and learn lessons from it.

5.8 MANAGEMENT REVIEW

At least annually, the XYZ Executive will hold a management review. The review will demonstrate the effectiveness of all locations that operate to the standard. Decisions made will be communicated to key staff indicating the decisions made and the agreed actions. Input to the meeting is provided in a number of ways, as follows: Follow up actions from previous management reviews Analysis of results from verification activities, e.g. results of internal audits and self assessments Analysis of changing legislation and / or standards, best practices, etc. Analysis of major incidents involving food safety Progress on food safety campaigns and initiatives Organisation and business changes Output from HACCP Team meetings across the company External audits, inspections or statutory visits by enforcement authorities Customer focus Customer complaints and rejections Changes that could affect the quality management system Recommendations for improvement FOOD SAFETY STATISTICS Major food safety incidents Potential Legal Consequences Benchmark Statistics for the year where available

6. RESOURCE MANAGEMENT
A process is in place to ensure that all staff including permanent, temporary and agency staff, at all levels in the company receive appropriate training. A site induction procedure ensures that all new workers receive appropriate food safety training. The site HACCP team will be required to attend a HACCP workshop covering basic food hygiene, the food safety manual and the audit process. Staff holding Food Safety positions within the company will be competent to carry out their tasks. A system is in place for informing contractors and sub contractors of specific food safety requirements and hazards on site. This may take several forms including formal briefings, food safety reviews, Customer briefings etc. as appropriate. Managers will receive training in their food safety responsibilities under the law, the XYZ Food Safety Management Standards and Customer demands as

applicable. Refresher training will be provided at appropriate intervals.

XYZ site HACCP members will receive training in their food safety responsibilities. This will cover, as a minimum, compliance with legislation, Company policy and the minimum safety standards document and its associated procedures. XYZ employees will be trained in XYZ Site Specific Procedures as necessary, and this training documented in individual training records. Such training may include the role of packaging in food preservation, vehicle hygiene, good housekeeping, etc. Figure 3 - Summary of Training Requirements MANAGERS AND SUPERVISORS SUBJECTS TO BE COVERED Legal obligations Food microbiology Food poisoning vectors Principle of hazard analysis Effective temperature control techniques Control of visitors to site Industry guidance is instruction of 6-12 hours duration WAREHOUSE PERSONNEL AND DRIVERS SUBJECTS TO BE COVERED Stock rotation Role of packaging in food preservation Cool chain maintenance, statutory standards Good housekeeping Standards Vehicle hygiene (drivers) Industry guidance is instruction of 4-8 hours duration

7. PLANNING AND REALISATION OF SAFE PRODUCTS 7.1 GENERAL

In order to realise safe product during storage and distribution of food the company has developed a food safety management system based on the requirements of EN ISO 22000:2005 which is described in this document. The company has developed a food safety manual that provides guidance and direction to the business to help implement the food safety policy. Section nine of this document summarises the company food safety elements. These elements provide the structure of the company food safety procedure manual. Each element is documented in a procedure and some elements may comprise a number of procedures and additional guidelines. Each site has developed a HACCP plans each site also maintains records to demonstrate the effectiveness of the food safety management system.

7.2 PREREQUISITE PROGRAMMES (PRPS)

In order for the food safety management system to be effective a number of programmes are considered essential prerequisites, see Figure 4 Figure 4 - Prerequisite Programmes PROGRAMME Good Hygiene Practices GUIDANCE MATERIAL / STANDARDS I. S. 341:1998 Hygiene in food retailing and wholesaling (Ireland) Codex Alimentarius Food Hygiene Basic Texts Directive 92/25/EEC 94/C 63/03 Guidelines on Good Distribution Practice of Medicinal Products for Human Use ISO9001: 2000 XYZ Health and Safety Procedures Manual OHSAS 18001 XYZ Facilities Manual XYZ Food Safety Manual XYZ Food Safety Manual

Good Distribution Practice (GDP)

Quality Management Safety, Health and Environmental Management System Planned preventive maintenance Pest Control Foreign Body Detection / Identification Temperature Control Traceability

XYZ Food Safety Manual XYZ Food Safety Manual

7.3 PRELIMINARY STEPS TO ENABLE HAZARD ANALYSIS

The following seven-step approach is adopted to enable effective hazard analysis, refer to Figure 7 below. 1. Collate all relevant information needed to conduct hazard analysis. 2. Develop a food safety (HACCP) team. 3. Establish and identify packaging and delivery methods. 4. Establish and identify storage conditions and shelf life. 5. Establish and identify statutory and regulatory food safety requirements. 6. Develop flow diagrams to provide a basis for evaluation of food safety hazards. 7. Establish and document existing control measures for each process step.

7.4 HAZARD ANALYSIS

The principles of HACCP are used to: Identify food safety hazards and determine acceptable levels. Assess hazard to determine, for each food safety hazard identified, whether its elimination or reduction to acceptable levels is essential to food safety. Select and assess an appropriate combination of control measures capable of preventing, eliminating or reducing food safety hazards to acceptable levels. Control measures may be managed through PRPs or HACCP plans. Establish a documented HACCP plan, see below.

A HACCP plan will be established which will, as a minimum, include the following for each critical control point (CCP): a) Food safety hazards to be controlled at the CCP. b) Control measures. c) Critical limits. d) Monitoring procedure(s). e) Corrections and corrective actions to be taken of critical limits are exceeded. f) Responsibilities and authorities. g) Records of monitoring.

7.4 HAZARD ANALYSIS

The principles of HACCP are used to: Identify food safety hazards and determine acceptable levels. Assess hazard to determine, for each food safety hazard identified, whether its elimination or reduction to acceptable levels is essential to food safety. Select and assess an appropriate combination of control measures capable of preventing, eliminating or reducing food safety hazards to acceptable levels. Control measures may be managed through PRPs or HACCP plans. Establish a documented HACCP plan, see below. A HACCP plan will be established which will, as a minimum, include the following for each critical control point (CCP): a) Food safety hazards to be controlled at the CCP. b) Control measures. c) Critical limits. d) Monitoring procedure(s). e) Corrections and corrective actions to be taken of critical limits are exceeded. f) Responsibilities and authorities. g) Records of monitoring.

7.5 ESTABLISHING THE OPERATIONAL PREREQUISITE PROGRAMMES

Operational PRPs will be documented and will form an integral part of the food safety management system. If the PRP is part of an existing Allied management system, the food safety aspects of the programme will be identified and monitored, especially where food safety hazards are controlled by the programme.

7.6 VERIFICATION
The HACCP team (multidisciplinary in membership) will operate on a predetermined frequency, conducting complete inspections of the entire facility no less than once per month. Records of each inspection are an integral part of this requirement, and documentation of specific assignments and actual accomplishments shall be maintained. Follow-up inspections should be done to ensure that items are corrected. Regularly monitor documentation that may indicate trends of non-conformance and recommend corrective actions Ensure that all staff are aware of the food safety system in place, and that food hygiene maintains a high standard

7.7 TRACEABILITY PROGRAMME

XYZ allocates unique codes to supplier products delivered into depots. These codes and descriptions are common to all generated documentation. A system of product codes, warehouse location system, and picked cage/pallet identification ensure traceability of product from any delivered batch, throughout the Cool Chain from Goods Inwards to subsequent delivery to the customer. 7.7.1 Non-Conforming products Products that are identified as non-conforming or placed on hold by the customer will be placed in the non-conforming product area. They will be clearly labelled. Examples of reasons for products to be in a nonconforming area include but are not limited to: Products found that are not within the specified shelf life Products identified that are no longer within the customers tolerance but were accepted in with the customers approval. Products placed on hold due to a recall. Product returns from outlets. Products rejected due to poor quality. Damages identified after receipt into the warehouse.

7.8 CONTROL OF NONCONFORMITY

Procedures are in place for the control of non-conforming material, including rejection, acceptance by concession, or re-grading for an alternative use. Such procedures are implemented and worker made aware. Non-conformities will include, but not be limited to, temperature rejections, delivery times, damages, overs/shorts, and poor palletisation/packaging. All nonconforming products are handled or disposed of according to the nature of the problem and/or the specific requirements of the Customer. Procedures are in place to investigate (i.e. determine cause and consequence) and ensure final disposition by authorised person(s). Corrective action systems are established to identify and eliminate the cause of detected nonconformities, to prevent recurrence, and to bring the process or system back in control after nonconformity is encountered. Corrective actions are documented and effective records maintained. Such actions will include:

Reviewing nonconformities (including customer complaints). Reviewing trends in monitoring results that may indicate development towards loss of control. Determining the cause(s) of nonconformities. Evaluating the need for action to ensure that nonconformities do not reoccur. Determining and implementing the actions needed. Recording the results of action taken. Reviewing corrective actions taken to ensure they are effective. Corrective actions shall be recorded. Trend analysis will also be used to reveal non-compliance. Corrective actions will be discussed and agreed at regular food safety meetings. Trends will be monitored but not limited to those categories identified by HACCP Analysis.

8. VALIDATION, VERIFICATION & IMPROVEMENT 8.1 GENERAL

Following the process of developing site/contract specific HACCP Plans, the HACCP team will assess and evaluate the plans and associated PRPs and will validate that the established control measures and other programmes are capable of being effective. This must be done prior to the implementation of HACCP Plans for the site/contract

8.2 VALIDATION OF CONTROL MEASURE

The validation process must be documented and must include evidence. Examples of validation methods include but are not limited to: Process walkthrough to assess whether plans are realistic and achievable. Review actual results against requirements to determine whether parameters are acceptable, i.e. they meet Company and legislative requirements. Review of recording methods to determine whether data can be recorded and how. Are there appropriate forms or other means of recording? For example, temperature controls checks. Is the defined means of what to do when things go wrong appropriate and achievable?

8.3 CONTROL OF MONITORING AND MEASURING

Monitoring and measurement is key to ensuring that the Food Safety Management System is effective and involves the application of methods, procedures, tests and other evaluations and monitoring. Examples of monitoring and measurement activities include but are not limited to: HACCP Plan verification. Monthly self-assessment against the required level of the minimum food safety standards Local internal audits HACCP Team meetings

8.4 FOOD SAFETY MANAGEMENT SYSTEM VERIFICATION

8.4.1 Internal Audit Audits are carried out in accordance with an annual audit schedule and performance is measured against an established set of criteria. The audit report provides an opportunity for site management to agree the findings and to add their comments. The audit also includes a site inspection where points can be either added or deducted for good or bad behavioural observations and safe and unsafe practices. Site Food Safety tours are also typically carried out by site management. Each site carries out monthly self-assessment audits against the companys Best Practice standards. Audit reports are collated, analysed and distributed according to an established distribution list. The Quality Assurance Manager maintains records of audit and self-assessment audit results.

8.5 IMPROVEMENT 8.5.1 CONTINUAL IMPROVEMENT

Following a review of current food safety issues, management may identify actions designed to improve food safety at Allied. Such actions may be in the form of individual action items; through to establishing working groups, projects, initiatives or programmes. Food safety performance is measured and monitored to determine whether: Food safety policy statement and related objectives are being achieved. Corrective and preventive actions are implemented and are effective. Lessons are learned from food safety failures including near misses, illnesses, product recalls and major incidents. Awareness, training, communication and consultation programmes for employees and interested parties are effective. Committee Initiatives and activities are delivered on time and are effective. Information and data from review and monitoring processes are being produced and being used.

Proactive and reactive monitoring methods are used. Proactive methods include audits, self-assessments, site food safety tours and reactive methods may include environmental health reports. A number of measurement techniques are used as follows: Results of hazard identification, risk assessment and risk control processes. Systematic and regular self-assessments against established minimum food safety standards. Desktop exercises. Benchmark against industry standards. A variety of food safety equipment is used and is calibrated according to manufacturers instruction.

8.5.2 UPDATING THE SAFETY MANAGEMENT SYSTEM

Management System documentation is discussed at site level and Group Board meetings. Changes are requested and approved. Updated documents are issued to control copy holders who are informed as to the nature of the changes made and the impact on the business.

The board review this Food Safety Management System Manual annually and will update other Food Safety Procedures as necessary.