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AUDITING INSTRUCTIONS RELATED TO
THE COCOA POLICY May 2020 (last update 5th of June 2020)
2
INTRODUCTION
As part of the Cocoa Policy, Rainforest Alliance is publishing specific auditing instructions for the measures in the Cocoa Policy. The
auditing instructions in this document concern the audits against the UTZ Code of Conduct and Rainforest Alliance Sustainable
Agriculture Network, in Ivory Coast, Ghana, Nigeria and Cameroon. Specific auditing instructions on the Chain of Custody measures in
the Cocoa Policy document will be published separately.
In addition to those auditing instructions, Rainforest Alliance has also published instructions and clarifications for certified groups on
implementing the Cocoa Policy in Ivory Coast and Ghana as well as in Cameroon and Nigeria.
In case of a partial remote audit (see Audit Exception Policy for COVID-19), specific instructions for the remote part of the audit have
been indicated where applicable in the table below.
For the column on how to close the non-conformity, in addition to what is indicated there, the group must analyze and tackle the root
cause of the non-conformity. In addition to what it is specified below, the CB can conduct a follow up audit if deemed necessary.
PRODUCER CERTIFICATION CRITERIA IVORY COAST AND GHANA
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
1.1. Certification – Eligibility rules
1.1 a
no dual certification
RA/UTZ
This will be checked by RA during audit application
of the group.
N/A N/A
1.1 b
Pause on new groups
This will be checked by RA during audit application
of the group.
N/A N/A
1.1 c
No change of utz
certification cycle
This will be checked by RA during audit application
of the group.
N/A N/A
1.1 d
government
registration of certified
groups
Groups must be legally registered to trade cocoa. If
groups are not able to show legal registration, there
are not compliant with the law - the CB must take a
non-certification decision.
3
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
1.1 e
No membership of
multiple groups
The CB must verify this with the Data Validator Tool. N/A N/A If the certification body finds that a farmer is
part of several certified groups, this farmer as
well as his or her estimated volume must be
removed from all certified groups. If such a
case is found after the certificate is delivered,
the Rainforest Alliance reserves the right to
require the certificate holder to do so.
1.1 f
Waiting period for
recertification
This will be checked by RA during the audit
application of the group.
N/A N/A
1.1 g
use of RA/UTZ logo for
groups not certified
Not applicable – this concerns groups which are not
part of the certification program anymore.
N/A N/A
1.2. Growth in Group Membership
1.2 a
Limit in group
membership growth
The auditor checks the group registry and compares
the total number of group members with the one
from the previous certification year (the CB must
verify this with the Data Validator Tool). If the growth
is more than 10%, a non-conformity is raised.
If the group requests a group extension after the
certificate is issued, the auditor verifies that the total
growth is not more than 10% in comparison to the
previous certification year. If it is more than 10%, the
group extension is not issued.
G.A.8
1.13
The group must remove group members to be
compliant with the 10% maximum growth in
group membership.
1.2 b
Minimum compliance
standard for new
members
All new group members must be at the same
compliance level than the existing group members.
If auditor finds that new group members are not at
the same compliance level than existing group
G.A.11 1.14 Group must re-evaluate the compliance of all
new group members against the compliance
level of the existing ones and update their risk
assessment and group management plan
accordingly (G.A.16 and G.A.17 / 1.7.
4
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
members, the auditor must raise an NC on internal
inspections (G.A.11 / 1.14)
1.3 Group Member Registry
1.3 a
inclusion of
government issued ID
Prior the audit, the CB must check if the types of
government issued ID provided in the Group
Member Registry are part of the approved
government issued IDs mentioned in the document
“Instructions and Clarifications for certified groups in
Ghana and Côte d’Ivoire on Implementing the
Cocoa Policy”.
The CB must also check if the government issued ID
have been recorded in the format instructed by the
same document.
The CB must check if there are no duplicates of
government issued IDs within the group.
During the audit, the audit team must ask the
auditee to show the government issued ID, compare
with the information provided in the registry and
check for any discrepancy.
G.A.8 1.13 If duplicates are found in the Government
Issued IDs provided by the group, they must be
corrected.
If any discrepancy is found between the
Government Issued IDs indicated in the registry
and the ones checked during the interview,
the discrepancy must be corrected.
The CB must ask the group to send evidence
of Government Issued IDs for a sample of
producers in the group not originally included
in the audit sample.
1.4 Geolocation Data
1.4 a
100% GPS coverage for
group members
Quality of the geodata:
The CB must assess the quality of the geodata
provided by the member as part of the preparation
for the audit. This includes:
- Identifying unusual patterns for the location of the
farms/sites (e.g. perfectly squared grid in which all
points are equidistant from one another)
- Identifying geodata location in unusual locations
(e.g. in palm oil fields instead of the cocoa fields)
during the audit preparation
G.A.3
G.A.8
G.D.111
1.6
1.13
2.3
The group must provide a location point for
each of the group members if there were not
all provided before the audit. Each location
point which is found not credible or not
collected according to RA instructions must
be collected again by the group and
corrected in the registry.
Location points provided after the audit must
be checked by the CB regarding the format
5
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
- Identifying potential repetition of farms/farm
units/sites within this Certificate Holder (CH) and
between this CH and other UTZ or RA-certified CH(s).
- Determining whether geodata was taken following
the guidelines provided by RA.
The audit team must verify at least the following
during the onsite audit in order to evaluate the
quality of the geodata provided by the CH:
- Within the sample, the audit team must evaluate
whether the GPS location points/polygon provided
coincide with the actual farm location visited.
- The credibility of the location point/polygon
collected by the CH by comparing it with the one
collected by the auditor.
Deforestation:
The audit team must include a representative
sample of farms identified as risky with respect to
deforestation as per indicated in the RA risk maps.
During the visit, the audit team must verify sign of
deforestation. The Annex 1 below is providing
further guidelines on how to audit deforestation.
The audit team must verify that the activities of the
management plan have been correctly
implemented as defined in the management plan
timelines, including those of previous years if group
had members in buffer zones.
Based on the findings of the audit, a non-
conformity can also be raised on G.D.109, G.D.110 /
2.1, 2.2 .
and compliance with G.D.109, G.D.110,
G.D.111 / 1.6, 2.3. An onsite verification must
be done if the CB deems that it is necessary.
If during the audit, more than 10% of the GPS
point of the audited producers are not
credible, the group must collect again the
location points for all members of the group.
If deforestation is confirmed, the group must:
- exclude those group members from the
group as well as their respective volume from
the volume estimation.
- commit to not buy products from those
members.
- communicate to those group members their
exclusion from the group
- Implement awareness raising measures or
training
- Plan to collect polygons of farms units of all
producers of medium and high risk of
deforestation
For UTZ groups, if more than 5% of farms of the
audit sample have been found to have
deforested, the group cannot be certified
and the certifier must take a non-certification
decision.
For RA groups, please refer to the critical
criteria process.
6
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
As part of the license request process the CB must
provide:
1. Identification of all the group members’
farms included in the audit sample. The CB
must clearly record in the Group Member
Registry (column AR) the reason for choosing
a specific farm in the audit sample (i.e.
Deforestation risk, Risk of encroachment in
Protected Areas, Others).
2. To indicate the group members’ farms
included in the sample and visited during the
audit, the CB must indicate their location
points in columns AP and AQ of the Group
Member Registry.
3. Validate the Group Member Registry in the
tool provided by RA before submitting the
license in GIP or before completing the
certificate in Salesforce
1.4 b
non-certification of
groups in protected
areas
The CB must map the location points provided by
the member against the official Protected Areas
maps provided by RA and verify if the location points
are not located inside the Protected Areas unless
allowed by applicable law. In Ivory Coast,
applicable law refers to enclaves approved by
MINEF and in Ghana, to admitted farms with
polygons provided by the Forestry Commission of
Ghana.
G.A.3
G.D.111
1.6
2.3
If groups members are found within Protected
Areas (except enclaves or admitted farms),
the group must:
- exclude those group members from the
group as well as their respective volume from
the volume estimation.
- commit not to buy products from those
members.
- communicate to those group members their
exclusion from the group
7
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
The audit team must include a representative
sample of farm identified as risky with respect to
encroachment in Protected Areas in the RA risk
maps.
In case of admitted farms in Ghana, the CB must
map the polygon of the admitted farm and verify its
credibility on site.
The audit team must get in contact with the
excluded group members to verify that they
have been removed from the group.
1.5 Yield Estimates
1.5 a
GPS mapping required
to determine certified
Area
If group is in compliance year 3 or more, the group
has determined the certified area with a GPS tool.
Remote audit: the auditor checks the data in the
group registry – round numbers are a sign that the
area was not determined with a GPS tool. Based on
the contact information in the registry, the auditor
contacts a few producers and confirms whether or
not the certified area of their farm has been
determined with the use of a GPS tool by going over
the cocoa farm boundaries. If not, a non-conformity
is raised.
During the on-site audit, the auditor must confirm
with audited producers whether or not the certified
area of their farm has been determined with a GPS
tool. If not, a non-conformity is raised.
To verify the reliability of the information in the group
registry, the auditor checks the certified area by
going over the perimeter of the area with a GPS tool
for at least 15% of the audited producers (rounded
up to the next whole number and with a minimum of
5, including a large farm if existent in the group). If on
G.A.2 N/A To close this non-conformity, the group must
determine with a GPS tool the certified area
of all the certified producers in order to have
a credible certified area.
The group must also put in place a system
whereby the group collects the data on the
certified area with a GPS tool for any new
producers for their approval into the group.
8
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
average, a difference in area of more than 10% is
found, a non-conformity is raised.
1.6 Traceability
1.6 a
annual calibration of
weight/volume
equipment
A system is in place to ensure the calibration of
weight stations, records and calibration certificates
(in case applicable) are in place.
Remote audit: the auditor asks the IMS about the
existing weighing stations officially used to determine
the weight of the certified product and asks for the
group to send the proof of the latest calibration of
the weighing equipment. If not available, a non-
conformity is raised.
For the on-site audit, the auditor must:
• Ask the IMS about the existing weighing stations
officially used to determine the weight of the
certified product and for proof of their latest
calibration
• Interview responsible staff for weighing – staff
should demonstrate how the process of weighing
products and recording information takes place
• If applicable, ask the staff in charge of
calibrating to show how they do it
• If possible, the auditor can weigh him/herself to
detect important inaccuracy of calibration.
If group cannot show proof of the latest calibration,
if staff cannot properly demonstrate the process of
weighing or recording, or if important inaccuracies
are found, a non-conformity is raised.
G.A.29 1.2 The group must calibrate the weighing
equipment and send the documented
evidence to the CB.
If any important inaccuracy in weight is found
by the auditor (10% or more), the group also
sets up a regular monitoring system to ensure
internally that the weighing equipment is
calibrated (to be included in their procedures
or traceability manual).
9
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
1.6 b
product flow map
required
The explanations / instructions below explain not
only the product flow map, but other traceability
aspects as well:
The group has systems and procedures in place to
ensure that certified products are segregated and
traceable.
There is documented proof that products that the
group sells as certified can be traced back to the
certified farm(s) where these were produced
The map of the product flow is complete, and all
intermediaries are mentioned.
Remote audit: the auditor verifies the product flow
map shared by the group and compares it to the
information available in the registry. If information is
incomplete or incorrect, a non-conformity is raised.
Based on the contact information in the registry, the
auditor contacts a sample of producers (at least 10)
to ask them about their previous year delivery to the
group and estimated production, and compares it
with the information in the registry. If inconsistencies
are found, a non-conformity is raised.
For the on-site audit, the auditor must:
• Check that the map of the product flow
exists and corresponds to reality
• Verify that the system and procedures in place
ensure visual and physical segregation of
certified products
• Check purchase and sales documents linked to
physical deliveries of the group
management, from the certified, multi-certified
G.A.22 1.2 / 1.3 Depending on the inconsistencies found by the
auditor, the group must:
• provide the missing documentation,
and/or
• train the relevant intermediaries and
IMS staff, and/or
• amend the relevant procedure and
product flow map, and
• set up a regular monitoring system to
ensure that traceability is respected
throughout the year
• formally agree that the CB could do a
remote verification at a later stage
during the harvest period.
If inconsistencies cannot be justified by the
group and the checks on recent purchases by
the IMS show that the purchasing system is not
guaranteeing traceability, the certifier must
take a non-certification decision.
10
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
and non-certified products + Overall calculation
of input and output at group level
• Interview the IMS on their knowledge and
capacity to implement correctly their traceability
procedure
• Interview the producers on their production,
sales, estimated production and compare it with
the information available at the IMS/PC level (see
below under 1.6 d)
• Trace back up or down the traceability flow to
see if uninterrupted or lost at any point, starting
either from a recent transaction in the
traceability system, or starting from audited
producers up until the IMS (the auditor must
check on the most recent sales done by the
producers).
If there is missing information, lack of understanding
or poor implementation of traceability procedures,
inconsistencies in volumes, or if traceability is lost, a
non-conformity is raised.
If any of those inconsistencies cannot be justified by
the group, the certifier must take a non-certification
decision.
1.6 c
Intermediaries maintain
the traceability of
products purchased
from the group
members and sold to
the Group
There is documented proof that products that the
group sells as certified can be traced back to the
certified farm(s) where these were produced
The map of the product flow is complete, and all
intermediaries are mentioned.
Intermediaries keep certified products segregated
and traceable.
G.A.24 1.2 If any of those inconsistencies cannot be
justified by the group, the certifier must take a
non-certification decision.
Depending on the inconsistencies found by the
auditor, the group must:
• provide the missing documentation,
and/or
11
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
Remote audit: the auditor asks the IMS for their
traceability procedure and verifies that it is coherent.
The auditor interviews by phone a sample of
intermediaries to verify that:
• Intermediaries have been trained or
instructed by the IMS,
• are knowledgeable on the traceability
procedure and
• follow the system or procedure to
appropriately record traceability
information.
If inconsistencies are found or traceability procedure
not followed, a non-conformity is raised.
For the on-site audit, in addition to what can be
verified under ‘Remote audit’, the auditor must:
• Calculate on a sample basis the input and
output for intermediaries indicated on the map
of the product flow (balance exercise).
• Interview a sample of intermediaries (at minimum
the square root of the total number of
intermediaries) mentioned in the map of the
product flow: is the map complete? are they
aware of the traceability requirements? do they
have purchase and sales documents linked to
physical deliveries?
If there is missing documentation or missing
information, lack of understanding or poor
implementation of traceability procedures,
inconsistencies in volumes, or if traceability is lost, a
non-conformity is raised.
• train the relevant intermediaries and
IMS staff, and/or
• amend the relevant procedure and
product flow map, and
• set up a regular monitoring system to
ensure that traceability is respected
throughout the year
• formally agree that the CB could do a
remote verification at a later stage
during the harvest period.
If inconsistencies cannot be justified by the
group and the checks on recent purchases by
the IMS show that the purchasing system is not
guaranteeing traceability, the certifier must
take a non-certification decision.
12
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
If any of those inconsistencies cannot be justified by
the group, the certifier must take a non-certification
decision.
1.6 d
Group members keep
proofs of payment
(receipts or passbooks)
for each sale
The group management has a procedure to ensure
that group members receive a proof of payment
(receipt or passbook) for each delivery. Group
members have their sales receipts/passbooks.
Remote audit: the auditor asks the IMS for their
traceability procedure and verifies that it is coherent.
the auditor interviews by phone a sample of IMS staff
to verify that:
• relevant staff has been trained or instructed
by the IMS,
• are knowledgeable on the traceability
procedure and
• follow the system or procedure to
appropriately record traceability
information.
If inconsistencies are found or traceability procedure
not followed, a non-conformity is raised.
For the on-site audit, in addition to what can be
verified under ‘Remote audit’, the auditor must:
• Verify the receipt/passbook kept by the audited
producers
If 50% or more of the audited producers do
not have all their receipts/passbooks, a non-
conformity is raised against G.A.24 and 1.3.
G.A.24 1.3 If there is no inconsistency after auditors have
checked the volumes and dates but receipts
are missing at producer level, in order to close
the non-conformity, the group must:
• report back to the producers on its total
volume sold (no need for all
receipts/passbooks to be photocopied
and redistributed to the producers),
• continue to sensitize producers about the
importance of keeping
receipts/passbooks, and
• set up a regular monitoring system to
ensure internally that producers keep
their receipts/passbooks (to be included
in their procedures or traceability
manual).
13
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
In addition, the auditor must also always cross-check
the information by:
• Verifying a sample of transaction from member
and compare with data recorded at the IMS or
“section” / PC level
• Interviewing the members about their
production capacity, and the sales and record
keeping system
• Assessing if there are sales made in the name of
family members or neighboring farms.
• Observing if volumes of sales is plausible with the
data recorded for harvesting, estimates of
production and storage capacity of the
producer.
If, for a minimum of 50% of the audited producers,
there is a difference of 10% or more between the
sum of the volumes reported as sold by these
audited producers and the sum of the volumes
indicated in the purchase register for these
producers
OR
If there are very large differences between the
producers' delivery declarations and the purchase
register (even if it is for less than 50% of the producers
audited)
In both cases, the auditor must raise a non-
conformity on G.A.22 and G.A.24 / 1.2 and
1.3 as traceability is not respected and the
cocoa is most likely from a non-certified
source. If there are strong inconsistencies
which cannot be justified by the group, the
14
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
certifier must take a non-certification
decision.
1.6 e
Transactions uploaded
in traceability system
within one week
The group has a system in place to report the
information of sales transaction as required in the
Cocoa Policy.
Remote audit: the auditor checks the transactions
in GIP / MarketPlace or the transaction list sent by
the group, selects a sample of them and asks for
the corresponding bill of lading / connaissement. If
any inconsistencies are found, a non-conformity is
raised.
For the on-site audit, in addition to what can be
verified under ‘Remote audit’, the auditor must:
• check the evidence of reporting of sales and
compares with the information of sales recorded
in the IMS system
• select a sample of transaction from the
traceability platform and compare it with the
commercial document at the IMS level (and
vice-versa) to confirm their existence and that
they have indeed been reported within the
correct timeframe
• interview the responsible person at the group to
describe the processes in place to registering
purchases sales and stocks and how volumes are
registered in the system and reported
If any inconsistencies are found between the
information on the traceability platform, the
commercial documents and the interview, a non-
G.A.25 1.2 The group must upload all deliveries, and
adapt its procedure and set up a regular
monitoring system to ensure internally that
transactions are submitted on time with the
correct documentation.
Depending on the inconsistencies found by
the auditor, a non-conformity may be raised
against other control points / criteria, which
the group will have to close as well.
15
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
conformity is raised. Based on the inconsistencies
found, a non-conformity can also be raised on
G.A.22 and G.A.24 / 1.3.
1.6 f
Volumes sold as
conventional or under
other labels removed
from traceability
platform in one week
The group has a system in place to remove the
necessary volumes from the traceability platform on
time.
Remote audit: no specific instruction
For the on-site audit, the auditor must:
• Select a sample of bills of lading (or
connaissements in Ivory Coast) issued after 1
June 2020 for cocoa sold as conventional or
under other seal and compare to the
transactions performed in the traceability
platform: were the volumes sold under other seal
removed? Were they removed on time?
If the answer is no, a non-conformity must be
raised.
In case of double selling of volumes, a non-
conformity must also be raised against
G.A.22 / 1.3.
G.A.25 1.2 The group must remove all the volume sold as
conventional or under other seals from their
certified volume on the traceability platform
and sends proof to the CB.
In addition, the group must adapt its
procedure to make sure the volumes are
removed on time and set up a regular
monitoring system to ensure internally that
volumes are removed when needed (to be
included in their procedures or traceability
manual).
1.7 Premium (Sustainability Differential and Investment)
1.7a communication
on premium
The group management has a system in place to
proactively communicate with the members the
premium per kg received by the group from the sale
of RA/UTZ certified produce; The group is able to
G.A.26 1.18 Group communicates to group members the
premium per kg received by the group from
the first buyer, and adapts its reporting and
communication strategy and set up a regular
monitoring system to ensure internally that the
16
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
demonstrate that communication to group
members on the premium received has been done.
A person is appointed by the group management
that should ensure that the communication and
information is reaching its members.
Remote audit: the auditor verifies with the IMS how
communication is done to the members, and asks
about recent communication done by the IMS.
Through phone interviews, the auditor checks that
the producers have been informed.
During the on-site audit, depending on a specific
organization structure, the auditor assesses the
different forms of communication generated
(newsletter, general assembly, community meetings,
emails, etc.) and evaluates their content and if there
are conflicting information.
The auditor interviews members and cross check the
information that has been sent by the group
management and verify that it is understood.
producers have understood the
communication.
1.7b payment of
premium
The group management has sufficient means and
accounting systems in place to perform payments to
members in a transparent and administrative sound
manner. The group must deliver evidence of
premium payment to each certified producer. The
group is able to demonstrate the amounts paid to
each member.
Remote audit: the auditor interviews the IMS staff in
charge of premium payment to verify procedure
and recording of information. The auditor interviews
G.A.27 1.18 Group must pay the amounts defined in the
procedure of use of premium to the group
members. The group must also adapt its
procedure if applicable, and set up a regular
monitoring system to ensure internally that
payment of cash premium is done on time and
according to procedures.
If during the audit, the auditor has doubts
about the payment of the premium, the
auditor checks that payments have been
17
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
by phone a sample of producers to verify if they
have received their due premium according to the
procedure and volumes sold to the group.
During the on-site audit, the auditor must verify the
accounting system in place: the system is able to
demonstrate with transparency the values handled
and paid to the members.
The auditor must interview the person in charge for
accounting and payments and assess how the
process of payments takes place.
The auditor must check with the audited producers
the evidence of premium payments and check if
this information is aligned with the records of the
accounting system.
done by interviewing some producers by
phone in order to close the NC.
If any inconsistencies cannot be justified by
the group, the certifier must take a non-
certification decision
1.7 c
Use and reporting of
premium
The group management has a procedure and a
system to monitor and record the use of the premium
received from the first buyer. A person is appointed
by the group management that should ensure that
the use of the premium is documented correctly.
The group management has a system in place to
proactively communicate with the members the use
of the premium received by the group from the sale
of RA/UTZ certified produce; A person is appointed
by the group management that must ensure that
the communication and information is reaching its
members. The group is able to demonstrate that
communication to group members on the premium
received has been done.
G.A.26 1.18 The group must record the use of the premium
and communicate it to group members.
The group must adapt its reporting and
communication strategy and set up a regular
monitoring system to ensure internally that
recording is done and that producers have
understood the communication.
18
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
Remote audit: the auditor checks the premium
procedure, and for a sample of the activities
planned the previous year, asks the IMS for evidence
that they have been carried out. The auditor verifies
with the IMS how communication is done to the
members and asks about recent communication
done by the IMS. Through phone interviews, the
auditor checks that the producers have been
informed on the use of the premium.
During the on-site audit: The auditor must check
evidence that the premium uses have been
recorded and activities planned with the group
premium have been executed according to the
procedure.
The auditor must check that the IMS has
communicated to the members about the use of
the premium. The auditor must cross-check with
audited producers that they have received and
understood the information on premium use.
1.7 d use of premium -
planning
NOT APPLICABLE ANY LONGER
1.7 e
Reporting on
additional investment
by first buyers
The group management has a procedure and a
system to monitor and record all additional
investments done by the first buyer.
The group management is able to demonstrate the
execution of these investments (infrastructure,
services, etc.)
G.A.26 The group executes additional investments
received from the first buyer.
The group adapts its reporting system and sets
up a regular monitoring system to ensure
internally that recording is done on time.
19
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT,
RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
1.8 Child Labour Prevention, monitoring and Remediation
1.8 a
Introduction of CLMRS
For UTZ groups with an existing CLMRS: the auditor
checks the group’s child labor risk assessment, that
child labor liaisons have been appointed and
trained, and that prevention AND monitoring AND
remediation actions are defined, implemented and
documented.
Prevention activities must be linked to the risks
identified in the assessment (G.C.78)
For RA groups, and UTZ groups which have never
implemented a CLMRS: auditor checks that:
• the group has received a training from RA on
Assess and Address;
• the group has completed the Assess and
Address risk assessment;
• the group has planned for the mitigation
measures.
G.C.78 4.6 For UTZ groups with an existing CLMRS:
depending on the detail of the NC, child labor
liaisons are appointed and trained; prevention,
monitoring and remediation activities are
better defined, measures are taken for
activities to be implemented and
documented.
For RA groups and UTZ groups which have
never implemented a CLMRS: group is trained
by Rainforest Alliance, had completed the
Assess and Address child labor risk assessment
and has planned for the mitigation measures.
20
PRODUCER CERTIFICATION CRITERIA: NIGERIA AND CAMEROON
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT, RAISE
NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
1.A.1. Certification – Eligibility rules
1.A.1.a
Pause on new
groups
The auditor verifies that this is not a new group; in case
of doubt, the auditor gets in touch with RA.
N/A
N/A
If group is new, certification cannot be granted.
1.A.2. Geolocation Data
1.A.2.a
100% GPS
coverage of
group members
for groups with
at least 50%
coverage as of
1 February 2020
50% GPS of
group members
for groups with
less than 50%
coverage as of
1 February 2020
The CB must assess the quality of the geodata
provided by the member as part of the preparation
for the audit. This includes:
• Identifying unusual patterns for the location of the
farms/sites (e.g. perfectly squared grid in which all
points are equidistant from one another)
• Identifying geodata location in unusual locations
(e.g. in palm oil fields instead of the commodity
under the audit scope) during the audit
preparation
• Identifying potential repetition of farms/farm
units/sites within this CH and between this CH and
other RA-certified CH(s).
• Determining whether geodata was taken
following the guidelines provided by RA.
The audit team must verify at least the following
during the onsite audit in order to evaluate the
quality of the geodata provided by the CH:
• Within the sample, the CB must evaluate whether
the GPS location points/polygon provided
coincide with the actual farm location visited.
G.A.3
G.A.8
G.D.111
1.6
1.13
2.3
The group must provide a location point the
percentage request by the Cocoa Policy if there
were not all provided before the audit. Location
points provided after the audit must be checked
by the CB regarding the format and compliance
with G.D.109, G.D.110, G.D.111 / 1.6, 2.3. An
onsite verification must be done if the CB deems
that it is necessary.
Each location point which is found not credible
or not recorded well must be collected again by
the group and corrected in the registry.
If during the audit, more than 10% of the GPS
point of the audited producers are not credible,
the group must collect again the location points
for all members of the group.
If groups members are found within Protected
Areas (except enclaves or admitted farms) or to
have deforested, the group must:
- exclude those group members from the group
as well as their respective volume from the
volume estimation.
21
• The credibility of the location point/polygon
collected by the CH/member by comparing it
with the one collected by the auditor.
• If the location points of new producers have been
taken in the center of the largest farm unit (see
annex 2)
During the visit, the audit team must verify the
following signs of recent deforestation in the field.
As part of the license request process the CB must
provide:
1. Identification of all the group members’ farms
included in the audit sample.
2. To indicate the group members’ farms
included in the sample and visited during the
audit, the CB must indicate their location
points in columns AP and AQ of the Group
Member Registry.
3. Validate the Group Member Registry in the
tool provided by RA before submitting the
license in GIP or before completing the
certificate in Salesforce
Deforestation:
The audit team must include a representative sample
of farm located in risky areas with respect to the
country RA risk maps if available. During the visit, the
audit team must verify sign of recent deforestation
such as young branches on trees along the borders of
the farm, young stumps etc. The Annex 1 below is
providing further guidelines on how to audit
deforestation.
- commit to not buy products from those
members.
- communicate to those group members their
exclusion from the group
- Implement awareness raising measures or
training
- In case of deforestation, plan to collect
polygons of farms units of all producers of
medium and high risk of deforestation
For UTZ groups, if more than 5% of farms of the
audit sample have been found to have
deforested, the group cannot be certified and
the certifier must take a non-certification
decision.
For RA groups, please refer to the critical criteria
process.
22
Based on the findings of the audit, a non-conformity
can also be raised on G.D.109, G.D.110 / 2.1, 2.2.
Protected Areas:
The CB must map the location points provided by the
member against the official Protected Areas maps
provided by RA and verify if the location points are
not located inside the Protected Areas. The audit
team must include a representative sample of farm
identified close to Protected Areas through the
mapping online. The Annex 1 below is providing
further guidelines on how to audit deforestation.
AUDIT PROCESS RULES: APPLICABLE TO IVORY COAST AND GHANA
Policy measure WHAT AND HOW TO CHECK?
IF NOT COMPLIANT, RAISE
NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY
UTZ RA
3.4. Certificate Holder obligations to comply with the audit process
3.4.a Availability
of the audit
sample
By the end of the on-site audit days, if less than 75%
of the producers pre-selected by the auditor cannot
be audited, a non-conformity is raised.
G.A.8 1.13 A follow-up audit needs to take place during
which 50% of the producers which could not be
audited during the 1st audit need to be audited.
If those 50% cannot be audited during the follow
up audit, the CB must take a non-certification
decision.
If less than 75% of the producers pre-selected for
this follow up audit cannot be audited, the CB
must take a non-certification decision.
3.4.b Access to
SYDORE
Groups in Ivory Coast must provide access to the
SYDORE during the audit to the auditor.
G.A.22 1.2 Screenshots of the SYDORE for specific deliveries
selected by the auditor must be provided to the
CB.
23
In the SYDORE, the auditor checks that the
information on the relevant deliveries match the one
from GIP.
Group must implement a procedure to provide
access to the SYDORE to the auditor for the next
audit and the responsible person managing
transactions in the SYDORE is indicated in the
product flow map.
3.4.c Ability of the
audit sample to
show
government IDs
During the audit, the audit team must ask the
auditee to show the government issued ID. The audit
team must check for the auditee for which no
government IDs has been provided in the GMR that
they indeed do not have a government issued ID.
In case of discrepancy between the information
checked with the audited producers and the
information provided in the registry, a non-conformity
is raised.
G.A.8 1.13 If duplicates are found in the Government Issued
IDs provided by the group, they must be
corrected.
If any discrepancy is found between the
Government Issued IDs indicated in the registry
and the ones checked during the interview, the
discrepancy must be corrected.
The CB must ask the group to send evidence of
Government Issued IDs for a sample of
producers in the group not originally included in
the audit sample.
3.4.d Product
flow map shared
before the audit
Product flow map is shared one week before the
intended
N/A N/A No non-conformity raised but audit cannot be
conducted until all requested documents are
shared with CB.
ANNEX 1 - GUIDANCE FOR AUDITING AND REPORTING FOR DEFORESTATION AND
ENCROACHMENT INTO PROTECTED AREAS RISK
Verification of deforestation and encroachment into Protected areas in the field
1. The risk maps provided by RA for Ghana and Ivory Coast, support the auditing process by providing an overview of (1) conversion
of natural forest and ecosystems and, (2) encroachment into Protected Areas (PA). The maps are the result of overlaying
geospatial location data of the member with other layers of information (forest layer, tree cover loss, protected areas). The risk
maps for Cameroon and Nigeria will be provided at country level, without location data of the member.
2. In addition to the risk maps provided by RA, the audit team must use different factors to assess the risks to deforestation and
encroachment into PA, including but not limited to, new production areas, purchases of new land, and new infrastructure, or
large increases in production without the purchase of new land. The CB must make use of these indicators to prepare and
execute the audit, whenever available.
24
3. Audit preparation: when preparing for the on-site audit, the audit team must evaluate the quality of the geodata provided and
must also assess the available information about PA.
a. Evaluation of geodata quality: the audit team must assess the quality of the geodata provided by the member as part
of the preparation for the audit. This includes:
i. Identifying unusual patterns for the location of the farms/sites (e.g. perfectly squared grid in which all points are
equidistant from one another)
ii. Identifying geodata location in unusual locations (e.g. in palm oil fields instead of the commodity under the audit
scope) during the audit preparation
iii. Identifying potential repetition of farms/farm units/sites within this CH and between this CH and other UTZ or RA-
certified CH(s).
iv. Determining whether geodata was taken following the guidelines provided by RA.
b. Protected areas preparation: prior to the audit, the audit team must research whether there are protected areas and/or
important ecosystems in the areas under the audit, and to be knowledgeable of the rules and laws of protected areas,
including buffer zones, for the specific context of the audit. The results of such research must be recorded by the audit
team in corresponding certification file which will be made available to RA upon request.
c. It is recommended that the audit team prepares the following before going to the field:
- Transfer location points to a smartphone or device to take on the audit
- Prepare print-copies to take on the audit of farm points and polygons with relevant features that can be used for
verification (roads, towns, rivers, etc.)
- Prepare print copies of protected area maps or if possible, save them in the smartphone
- The CB could also prepare print copies with the risk maps provided by RA
4. Audit:
a. The audit team must include a representative sample of farm identified as risky in the RA risk maps of Ivory Coast and
Ghana or located in risky areas in the RA risk maps of Cameroon and Nigeria.
b. The audit team must collect the location points of all the farms visited as part of the sample.
c. The audit team must verify at least the following during the onsite audit in order to evaluate the quality of the geodata
provided by the CH:
i. Within the sample, the CB must evaluate whether the GPS location points/polygon provided coincide with the
actual farm location visited.
ii. The credibility of the location point/polygon collected by the CH/member by comparing it with the one collected
by the auditor.
iii. The CB audit team must triangulate the evidence provided by the CH with evidence provided by the farmers for
situations in which there is repetition of farms/farm units/sites within this CH and between this CH and other UTZ or
RA-certified CH(s).
25
d. The audit team must verify deforestation at different stages, i.e. in the farm, at the factory/processing unit and at IMS
level.
e. During the visit, the audit team must verify the following signs of recent deforestation in the field.
i. Evidence of recent deforestation in the field/at new areas/at borders to forests:
1. Trees confined to the borders of forest patches show signs of recent changes, e.g. when they show many
young branches growing into the open patch
2. In a new production area, estimate how old the stumps are
3. Destruction signs from felling large trees, swaths in the forest or in production sites
4. Colonization of open spaces by pioneer species
ii. The audit team must take pictures of relevant evidences and retain the picture as part of the certification file at
the CB. The CB must make such pictures available to RA upon request.
f. During visits of farms/sites with high deforestation risk or high risk of encroachment to protected areas, i.e. evidence of
recent deforestation from risk maps as described above or identified as high risk by the audit team with new information
found onsite, the audit team must exercise professional skepticism that conversion or expansion has happened and must
follow up to confirm the risk.
g. The audit team must verify at least the following indications IMS/factory/processing unit level:
i. If biomass energy, particularly wood, is used in the processing, the audit team must verify whether the volume of
wood used corresponds to the volume of wood purchased or harvested.
ii. There are new buildings/constructions that have been built from wood
iii. There are sales or storage of large quantities of wood at the premises
iv. Improvised sawmills
h. The audit team must effectively incorporate the topic of deforestation in interviews with farmers, workers and in
stakeholder consultation.
i. The audit team must collect evidence if the following situations are found during the audit: (a) a farm/farm unit has
deforested/encroached in PA, (b) a farm/farm unit was indicated as risky in the RA risk maps but field evidence proved
otherwise. The evidence could include:
i. Location point of the farm/farm units
ii. Explanation of why conversion showed up in satellite images but would not mean conversion: for example, forest
plantations that are harvested and converted to agricultural use, but would not mean conversion of natural
ecosystem
iii. (if applicable) high resolution satellite imagery showing that conversion of natural ecosystems didn’t take place
iv. Pictures, drone images or other proof of field evidence that explains risk detection (high shade coverage, timber
plantations in the surrounding etc.)
v. Farms’ age older than the cut-off date; conversion found due to harvesting shade trees, for example etc
j. In cases of evidence or suspected conversion (with or without indication of risk maps), the audit team must verify such
cases through (additional) interviews with relevant stakeholders, including but not limited to local authorities, neighboring
farms, target community members.
26
Note: For example when the audit team finds little storage huts with chainsaws, the audit team is expected to
initiate a conversation with the person(s) having access to the chainsaws; a target community member could
also be a person who has been residing for long at the community who has knowledge and is open to share or
any person who has further knowledge and insights of recent conversion in the area.
Reporting of deforestation and PA encroachment in the license request
As part of the license request process the CB must provide:
4. Identification of all the group members’ farms/farm units included in the audit sample. For CHs in Ghana and Ivory Coast, the
CB must clearly record in the Group Member Registry (column AR) the reason for choosing a specific farm in the audit sample
(i.e. Deforestation risk, Risk of encroachment in Protected Areas, Others).
5. To indicate the group members’ farms/farm units included in the sample and visited during the audit, the CB must indicate their
location points in columns AP and AQ of the Group Member Registry.
6. Regarding risk of deforestation and encroachment into PA, the CB must:
a. Indicate farms/farm units that deforested/encroached in PA, provide a summary of the evidence and audit findings
and, the location point of such farm/farm units.
b. Indicate farm/farm units indicated as risky in the RA risk maps but for which, the field evidence proved otherwise. In
addition to this, the CB must also provide a summary of the evidence and audit findings and the location point of these
farm/farm units.
27
ANNEX 2 - GEOGRAPHICAL SCOPE, FARM AND FARM UNIT