Compliance Monitoring Protocols - Timber Tracker...3) Compliance Monitoring Protocols & Checklist / Report The Philippine Due Diligence System was developed to establish documented

Document Control Doc #: Proc 003 Title: Compliance Monitoring Protocols Issue: v01 Date: 15 March 2019

Compliance Monitoring Protocols

1.0 Background & Purpose A key objective of the Philippine Timber Industry is the establishment of a due diligence system under a systematic approach that documents legality of raw material obtained from domestic supply or through imports through production and trade of finished wood products by its members. Thus, it is imperative that the Guidebook is clear and simplistic for members to understand and implement as well as sufficiently robust to provide credibility to the international market. The Philippine Due Diligence System has been established by the Philippine Timber Industry Associations (Chamber of Furniture Industry Philippines (CFIP) & Philippine Wood Producers Association (PWPA) to document industry members and potentially other companies are compliant with legal requirements of the Philippines. The Philippine Due Diligence System consists of 3 main elements:

1) Guidebook on Legal Requirements and Chain of Custody;

2) Philippine Timber Industry Associations’ Administrative Procedures;

3) Compliance Monitoring Protocols & Checklist / Report The Philippine Due Diligence System was developed to establish documented guidelines to define the requirements in respect to the Philippine legal regulations for the timber industry and chain of custody system to track material and production through the supply chain using an industry Guidebook. Administrative procedures for CFIP & PWPA to directly administer and manage the Philippine DDS; and conduct and document compliance monitoring of members to the requirements as defined in the Guidebook. The purpose of this procedure is to define the process for Philippine Timber Associations to monitor compliance of members to Philippine regulations and chain of custody system based on the Procedural Guidebook.

1.1 Scope

The scope of this procedure is limited to monitoring of the members by the timber associations & non-

members who choose to undergo a formal assessment. The procedure shall ensure work will be

completed in a controlled, consistent and effective manner.

1,2 Management Structure by the Philippine Timber Associations The main objective of Compliance Monitoring is for the Timber Associations to document member compliance to regulatory requirements and supply chain of verified legal timber supplies (Low Risk)

obtained locally in the Philippines or imported. The CFIP & PWPA will need to monitor compliance by its’ members to the requirements set out in the Guidebook as part of the Due Diligence under the Philippine’s Timber Industry Associations. The Guidebook and monitoring system of the Philippine’s Timber Industry Associations will support members to document that raw material and wood products are low risk and meet the international trade regulations that require due diligence. The Philippine Timber Industry Associations (CFIP & PWPA) are aiming to provide a structured and credible due diligence system as service to their members. The Guidebook and associated checklist will form the basis to directly monitor member compliance or through an appoint independent subcontractor. Internal monitoring directly by the Philippine Associations would be considered as a second party that would not be totally independent as the Associations work on behalf of their members. Use of independent subcontractor would provide a more independent due diligence system. The robustness of the system


and the credibility of the Associations to professionally monitoring and administer the Due Diligence System will depend on the Administrative structure and independence of the appointed monitoring teams. Figure 1. Administrative Structure

2,0 Responsibilities:

2.1 Timber Associations administration for Due Diligence Monitoring and/or appointed staff are responsible for:

• Identify and schedule wood processing mills, trading and export companies to be monitored;

• Examine audit outcomes of findings / gaps documented in the monitoring report;

• Ensure implementation of this procedure;

Timber Associations Chamber of Furniture Industries of the Philippines & Philippine Wood Producers

Association Joint Administration of Due Diligence System

Membership Requirements includes compliance to legal requirements and Guidebook Chain of Cusotdy

Timber Associations Conduct Annual Monitoring of Member Compliance to Philippine Guidebook

Members do not demonstrate compliance must be re-evaluated

Members demonstrate compliance with requirements

Member addresses issues on re-

evaluation

Member failed to mitigate issues after

re-evaluation

Member subject to membership requirements

Members are registered on the Association Website as verified

compliant to the Guidebook requirements


• Conduct reviews on the standard checklist, reporting formats, etc.

2.2 The monitoring team is responsible for:

• Implementation of monitoring activities to members in accordance to procedures;

• Document findings & objective evidence in an approved Monitoring Checklist/ Report (Appendix 1);

• Close out of non-compliance within 2 months of monitoring report.

2.3 The Company representative is responsible for:

• Rectify and address Gaps accordingly;

• Training of staffs, supervisors and workers;

3.0 Definitions

This procedure contains definitions of common terms used for monitoring compliance:

Criteria: A set of requirements that define elements of legality in respect to regulations, permits; use of documents and Chain of Custody requirements

Due Diligence System: A system to minimise risk that includes 1) information describing the timber and timber products, country of harvest, species, quantity, details of the supplier and information on compliance with national legislation. 2) Risk assessment: the risk of illegal timber in the supply chain, based on information as defined in the Philippine DDS. 3) Risk mitigation: system to mitigate risk of illegal timber in the supply chain by requiring additional information and verification from the supplier.

Gap: Defined discrepancy between current performance and activities and the requirements of a specific indicator.

Monitoring / Assessment: A documented process to obtain objective evidence and evaluating it objectively to determine the extent to which the criteria are fulfilled.

Objective evidence: Records, observations, statements or other information provided by the company in relation to indicators and criteria. Objective evidence may be qualitative or quantitative.

Organization: An organization / company or private entity being assessed / monitored

Philippine Due Diligence System: System incorporated a definition of legal timber based on an agreed

set of Principles and Criteria that refer to Philippine laws, regulations and operating procedures; control

procedures for verifying compliance with the definition of legal timber covering forest harvesting,

transportation, processing, import and export and independent monitoring

Team Leader: A person with the competence to lead a monitoring visit / assessment.

Verified Legal: Material or products that are evaluated as low risk of based on a documented risk assessment or independent verification in accordance to the Guidebook on Due Diligence for The Philippine Timber Industry

4.0 Acronyms:

BOC – Bureau of Customs

CBFM – Community Based Forest Management Agreement

CDA – Cooperative Development Authority

CFIP – Chamber of Furniture Industries of the Philippines

CITES – Convention on International Trade in Endangered Species of Wild Fauna and Flora

CLO - Certificate Lumber Origin

CMFPO – Certificate of Minor Forestry Products Origin

COC – Chain of Custody


COV – Certificate of Verification

CSC – Certificate of Stewardship Contract

CTO – Certificate of Timber Origin

CTPO – Certificate of Tree Plantation Origin

DAO – DENR Department Administrative Order

DENR – Department of Environment and Natural Resources

DMC – Department of Memorandum Circular

DR – Delivery Receipt

DTI – Department of Trade and Industry

ECC – Environmental Clearance Certificate

EMB – Export Marketing Bureau

EUTR – EU Timber Regulations

FAO/UN – Food and Agriculture Organization of the United Nations

FLEGT - Forest Law Enforcement Governance & Trade

FMB – Forest Management Bureau

IFMA – Integrated Forest Management Agreement

MAO – Ministry Administrative Order

NF – Natural Forest

NTFP – Non-Timber Forest Products (includes rattan & bamboo)

PD – Presidential Decree

PLTP – Private Land Timber Permit

PTPOC - Private Tree Plantation Ownership Certificate

PWPA – Philippine Wood Producers Association

RA – Republic Act

Re-Purposed – Wood material from waste or non-harvested sources

SEC – Securities and Exchange Commission

SIFMA – Socialized Integrated Forest Management Agreement

SI – Sales Invoice

SIFMA – Socialized Industrial Forest Management Agreement

SMF – Self-Monitoring Form

SPLTP – Special Private Land Timber Permit

TLAS – Timber Legality Assurance System

TPO – Tree Plantation Owner

Waste - Waste material from production such as sawdust; wood chips; off-cuts, etc

WIN – Wood Industry Network

WPP – Wood Processing Plant

VL – Verified Legal

5.0 Scheduling of Monitoring Visits: 5.1 The Association shall identify manufacturing, trade and export member companies to be monitored within an annual schedule to verify compliance to requirements defined in the Guidebook 5.2 The Association shall develop a monthly monitoring schedule based on logistics, activities, public holidays that may occur over the scheduling period. 5.3 The monitoring schedule shall also include subcontractors and close-out assessments for companies that have received a major non-compliance during the assessment process to verify continual compliance.


5.4 The frequency of monitoring must be at least annual. Increased frequency depends on risk, reflects the scale and impact of different operations and where sampling methods are used there needs to be a justifiable rational for selection and frequency.

6.0 Monitoring Team & Planning: 6.1 The monitoring team shall have qualifications, experience and understanding of monitoring / audit systems and the monitoring checklist and understanding of the Philippine Timber Industry and regulatory system. 6.2 The team leader shall be responsible for directing the assessment and the team members. 6.3 Preparation for monitoring should include arrangements of logistics such as air and ground travel, accommodation, to companies to be audited, etc. 6.4 The number of man-days for each assessment shall be determined based on size and extent the company. Generally, there should be 1-2 staff on each monitoring visit. 6.5 The monitoring period should be adequate to include both document review and site observations for all key activities including subcontractors, which typically takes 1-2 days, depending on the operation, use of subcontractors and travelling time.

7.0 Documents & Equipment 7.1 The monitoring team shall use the current Monitoring Checklist & Report (Appendix 6) 7.2 Annual monitoring visits shall take into account outstanding GAPs reported in the previous visit to ensure actions have been taken to improve the system. 7.3 The monitoring team shall bring equipment as needed to evaluate and record compliance as well as safety of team members as appropriate.

8.0 Conducting the Monitoring Assessment 8.1 Opening meeting shall be conducted by the lead assessor that should include the following:

• Introduce monitoring team; • Confirm the full scope of the assessment; • Explain the process and output of the monitoring visit; • Invite company to provide information on the organization, CoC & operations; • Discuss objective evidence: gaps & non-conformance; • Confirm of confidentially of assessment activities; • Arrange for use of office area; • Invite questions; • Arrange for closing meeting.

8.2 The team lead shall ensure the team is working in line with a planned schedule to cover all key activities and is communicating with team members if any problems arise. 8.3 The monitoring team shall record objective evidence of compliance against all applicable indicators and criteria and be in agreement with all findings. 8.4 The monitoring team shall obtain objective evidence through:

• Reviewing - Review of planning and operational documents such as policy, procedures, production records, sales and export data, etc.;

• Interviews & discussion - Interviews with administration and company staff as appropriate; • Inspection - Observation of company activities and factory conditions; • Measuring - measurements taken by the team and field staff; • Evaluation - compiling of data and observations of compliance to each criterion


8.5 The progress of the assessment and any concerns to the company shall be communicated, as appropriate. 8.6 All observations of compliance and non-compliance shall be supported by objective evidence and recorded in the monitoring report. A Gap is a discrepancy between current performance and activities and the requirements of a specific indicator that can be defined as Minor or Major, 8.7 The grading of level of compliance for activities under each Criterion are based on observations by the monitoring team in respect to:

• A criterion is compliant when no major gap is identified within any of the indicators that define the criterion.

Indicators: • Minor Gap: is issued against an indicator for partial compliance whereby the criterion is still

considered compliant. • Major Gap / Non-Compliance: The company does not demonstrate adequate compliance to an

indicator and subsequent criterion 8.8 The monitoring team shall conduct closing meeting with the presence of company representatives. The findings of compliance; gaps and conclusion shall be presented to the company representatives. The meeting shall include agreement on gaps and appropriate actions to address any non-compliance identified during the assessment.

9.0 Monitoring Report Preparation 9.1 The team leader shall use the current Monitoring Checklist / Report form to document all assessment findings. 9.2 The monitoring report should provide a complete, concise and clear record of findings based on objective evidence for all applicable criteria and indicators. It should include or refer to the following details:

• Summary & background information. • Highlights of findings. • List of Gaps (current, and closed). • Findings for each applicable indicator and criterion including objective evidence and evaluation of

compliance. • Attendance list at opening and closing meeting.

9.3 The monitoring report shall clearly define all Gaps and the status of gaps identified in the previous visit. The report shall clearly define recommendations and schedule for addressing major gaps identified during the monitoring visit. 9.4 The due diligence system managed by the Timber Associations can be a 2nd party system, that it is structured to document compliance but also support companies to identify and address specific problems within their system. The objective of the process is to document compliance; identify problems; and find practical solutions when non-compliance is identified. This does not mean the Standard is any lower what it does mean is that having identified a Gap the monitoring team can use its experience to provide recommendations to the Association member resolve the problem, 9.5 The monitoring report shall be completed within 5 days and maintained by the association for at least 5 years.

10.0 Monitoring Gaps & Non-conformance 10.1. The Association staff shall monitor that the company addresses all non-compliance (Major gaps) identified in the monitoring report. The Company should agree on the schedule for addressing identified major Gap / non-conformance that should be within 2 months.


10.2 A close–out visit needs to be conducted for all companies that do not demonstrate compliance. 10.3 Minor gaps should be addressed within the next scheduled monitoring visit or else the gap may be raised to a major indicating non-compliance. 10.4 Monitoring visits shall be carried out at least annually to document continual compliance of the company to regulatory requirements. Monitoring visits may also be un-announced depending on risk

ASSOCIATED DOCUMENTS & REVISIONS

The following documents are necessary for reference or use in implementation of this procedure:

RECORDS

The following records shall be maintained as a result of this procedure:

Documents / Reports (Appendix 1) Document #

Monitoring Checklist & Report SF-001 D09 - 20 Dec 2018

REVISION HISTORY

Version Details Approved Date

D08 Compliance Monitoring Protocols NA NA


Philippine Due Diligence System Monitoring Checklist & Report

SF-001 v01 / (15 March 2019)

Organization Company name (xxxx-x) Reference # doc #

Contact Person

Assessment #

Office Address

Monitoring Date dd/mm/yyyy

Mill Address

Date of Report

Date of close out

dd/mm/yyyy -

Telephone Team leader

Fax Team members

Email Approved By

Membership Information

Member #

Issuance Date dd /mm /yy

Expiration Date

Scope of Assessment

Company Type Sawmill / Wood Processing /Trading,

Scope of Assessment Company Name (office / factory ; include subcontractors)

Product Group Veneer; Plywood; Sawn Timber; Mouldings; Furniture

Sources of Material

Species Common & Scientific Names

Background Information:

Associated Organizations & Subcontractors: Description of the Supply Chain:

Supplier Material Origin Permit /

Certificate # Risk level

-


Assessment Results:

GAPs in Conformance

GAP # Type Checklist Status Description

001/year Major New

002/year Minor Closed

003/year Minor Outstanding

Close out visit (if applicable) Date

Not applicable

Recommendations

Company Name has (has not) demonstrated compliance to the requirements as no major gap (non-compliance) was identified during the assessment thus is/ (is not yet) recommended to receive a Statement of Compliance to the Philippine Guidebook on Due Diligence.

Minor Gaps identified in this assessment should be addressed before the next surveillance visit. Actions required to close the gaps include:

Gap #: Checklist #: Action

Gap #: Checklist #: Action

The next surveillance visit will be scheduled for Month / Year.

End of Summary Report


Due Diligence Requirements for the Philippines Verification Checklist

1.0 Administration of Chain of Custody The organization shall be legally registered with valid permits as required and have a policy, personnel, and documented system to manage and implement the Chain of Custody (CoC) system.

Compliance

Non-Compliance

1.1 The organization shall be registered and have valid permits required to operate the facilities that include: (Certificate of Registration; Mayor’s Business Permit; Wood Processing Plant Permit; Permit to operate; Certificate of verification clearance; Local Company registration; as applicable).

FINDINGS:

Government agency Permit type Reference # Expiry Date

Securities & Exchange Commission

Certificate of Registration

DENR: Secretary Wood Processing Plant Permit

Office of City Mayor Mayor’s Business Permit

DENR Certificate of registration local company

DENR-EMB Permit to operate

Bureau of Customs Certificate of Registration as Importer

Bureau of Customs Certificate of Registration as Exporter

Bureau of Internal Revenue


DENR-EMB Hazardous Waste Generator Registration Certificate

Department of Labor and Employment


Potential Additional Documents

Philippine Economic Zone Authority


Philippine Economic Zone Authority

Fire Safety Inspection Certificate

Foreign consulate for imported material

Authentication of supply contract

City Health Department Office

Sanitary Permit

Philippine Health Insurance Corporation


Social Security System Certificate of Registration

DENR Lumber Importation Permit

Fire Department Fire Inspection Certificate

GAP #:


1.2 The organization should have a basic policy to operate legally and obtain raw material or timber products from legal sources in line with Philippine regulatory requirements.

FINDINGS:

GAP #:

1.3 The organization shall document the CoC System that identifies all activities critical to control the production / trading system along with associated records and documents. The documented CoC system shall include purchasing (local and import), receiving, storage, identification, material allocation, processing on site and subcontracting, assembly, packaging and sales and export (as applicable).

FINDINGS:

GAP #:

1.4 The organization shall appoint a management representative to manage the Chain of Custody system.

FINDINGS:

GAP #:

1.5 The organization shall have an agreement with subcontractor organizations to ensure all activities are conducted in accordance to the company’s COC procedures.

FINDINGS:

GAP #:

1.6 All staff are trained and understand their responsibilities in relation to their job function, safety and maintaining the COC system.

FINDINGS:

GAP #:

1.7 Relevant training records are maintained.

FINDINGS:

GAP #:

1.8 The company demonstrates compliance with labour regulations, health and safety requirements in regards to operations.

FINDINGS:

GAP #:

1.9 The company provides PPE that is used during operations and training on safety.

FINDINGS:

GAP #:

1.10 The company has adequate equipment and training of staff in respect to fire or accidents.

FINDINGS:

GAP #:

1.11 The company demonstrates compliance with environmental regulations in respect to its operations.

FINDINGS:

GAP #:


2.0 Purchasing Domestic Material The organization shall have a formalized system for purchasing and receiving and recording of raw material and products that are verified legal (VL) based documented compliance with Philippine regulations.

Compliance

Non-Compliance

2.1 The organization shall have a formalized system to ensure that all raw material or products purchased within the Philippines are Low Risk that are traceable to legal sources and include documentation (harvest & transport permits) required by the DENR.

FINDINGS:

GAP #:

2.2 Records of raw material received are maintained: (logs from planted areas (CTPO / PTPOC); rattan, bamboo (CMFPO), sawn timber, plywood, etc, mill waste and re-purposed material).

FINDINGS:

GAP #:

2.3 The organization has a purchase order / payment voucher defining purchase of raw material or products.

FINDINGS:

GAP #:

2.4 Purchase Orders / Payment Vouchers, and associated documents shall contain adequate information clearly describing the quantities of material, species of timber, dimension and reference legal source of raw materials.

FINDINGS:

GAP #:

2.5 Relevant transport permits documents (Self-Monitoring Form (SMF); COV; CMFPO; DR; Transport Agreement) are available to confirm material / products purchased are transported legally.

FINDINGS:

GAP #:

2.6 Tally sheets for sawmills should contain detailed information on logs (log numbers, dimensions) or finished goods that match the associated transport permit (SMF; COV).

FINDINGS:

GAP #:

2.7 Delivery Receipts for material issued by lumber yards or timber traders should be traceable to the origin of the material through SMF, COV (as appropriate).

FINDINGS:

GAP #:

2.8 Receipt of material shall reference the Purchase Order / Purchase Voucher with clear labelling of species dimensions quantity and legal status.

FINDINGS:

GAP #:


2.9 Records of material received shall be maintained and contain reference between the Purchase Order / Payment Voucher, Production Batch Unit #, or Sales Order # as appropriate.

FINDINGS:

GAP #:

2.10 Records for purchasing, receiving, warehousing, etc., shall be summarized monthly and maintained for at least 5 years.

FINDINGS:

GAP #:

3.0 Requirements for Purchasing Imported Material The organization shall have a formalized system for legally importing timber and wood products that are evaluated as low risk based on information obtained against General Risk Categories and Risk Matrix.

Compliance

Non-Compliance

3.1 The organization needs to obtain an import permit /registration from DENR Office & Customs as required.

FINDINGS:

GAP #:

3.2 The organization shall implement a risk evaluation system for importing timber products that includes methods for defining low risk based on: 1) country of timber origin, 2) timber species and 3) operational risk for monitoring legal compliance and tracking through the supply chain.

FINDINGS:

GAP #:

3.3 The organization shall evaluate the risk of each supplier and timber product / material using the Risk Matrix and maintain records of approval.

FINDINGS:

GAP #:

3.4 Only suppliers / material that are evaluated as Low Risk through the risk assessment, can be used in manufacturing or trade of Verified Legal products under the Philippine Due Diligence System.

FINDINGS:

GAP # :

3.5 The organization shall have a valid import permit from DENR and Customs for the consignment along with phytosanitary inspections and fees paid as applicable.

FINDINGS:

GAP #:

3.6 The organization shall demonstrate the import documents correspond to the material imported: - Import approval from appropriate government agency (DENR & Customs) - Customs Declaration Forms


- Purchase Agreement / Contract - Physical Inspection report by appropriate government agency (Customs; DENR). - Records of Import (BL; Phytosanitary Certificate, Certificate of Origin) - Packing list (log list / “tally”) - Transport Permits:

FINDINGS:

GAP # :

3.7 The organisation shall provide for adequate documentation, physical identification / segregation of raw material or goods received based on certification & legal status in accordance to bonded warehousing requirements.

FINDINGS:

GAP # :

3.8 Stock of material on site match records of raw material or products received & stored in the log yard or bonded warehouse.

FINDINGS:

GAP # :

3.9 Records of raw material or products imported / received by month are available and maintained for 5 years.

FINDINGS:

GAP # :

4.0 Process Control and Manufacturing The organization shall maintain a clear system for control of production, identification and recording of verified legal material from raw material through processing and handling of finished goods.

Compliance

Non-Compliance

4.1 Manufacturing companies shall have procedures and planning to ensure raw materials are correctly issued into a defined production batch (such as work order WO#) that clearly defines the units for production, status (certified; verified legal; other) along with the production period.

FINDINGS:

4.1.1.) The company demonstrates adequate production planning and procedures that define unique production batch units (Work Order / batch #, etc.). 4.1.2) The company has system to allocate verified legal (low risk) raw material that is traceable to its origin (Local supplier, Imported) and quantity into a production batch unit (Work Order / batch #, etc.).

4.1.3) The company adequately implements planning and production controls to segregate production of Verified Legal products from Other or Certified material or products.

GAP # :


4.2 Manufacturing companies shall maintain adequate identification and documentation of Verified Legal (VL) (Low Risk) raw material used in each production batch unit to allow calculation of recovery based

on volume of raw material input and volume of products produced.

FINDINGS:

4.2.1) The company has adequate records of VL raw material stock and issuing of material into each planned and defined production batch unit (Work Order, batch, etc.) that is classified as Low Risk and / or traceable back to a SMF / COV / CMFPO as appropriate.

4.2.2) The company maintains records of input volume of VL raw material and output volume of products for production batch units (Job / Work Orders) for calculation of recovery.

4.2.3) Summary records of VL raw material allocated to production and products produced for each production batch unit are maintained by month.

GAP # :

4.3 All work in progress, components and finished goods shall be clearly identified to the appropriate production batch unit (job / work order #; batch #, etc.) to maintain traceability from raw material issued through finished products, warehousing and sales.

FINDINGS:

4.3.1 Work in progress is consistently identified to a specific unit of production (Job / Work Order # batch #) and legal status. 4.3.2) Stock material on the production floor, rework material, etc, are clearly identified as to legal status and production unit or purchase order. 4.3.3) Finished goods are consistently identified to a specific unit of production (Work Order # / batch #) and verified legal status.

GAP # :

4.4 The company shall maintain detailed production records of finished goods that should be entered into a warehouse and allocated to a sales order based on both legal & certification status and production batch # (work order #).

FINDINGS:

GAP # :

4.5 Summary production records shall be maintained monthly that identify and quantify input of VL raw material and output of VL finished goods of each production batch unit (Job Order) that can be used to

trace products to raw material and calculate recovery.

FINDINGS:

GAP # :

4.6 Records associated with production shall be maintained for 5 years

FINDINGS:

GAP # :


5.0 Sales and Exports of Verified Legal Wood Products The organisation shall maintain a clear system for identification, and traceability of verified legal products manufactured and purchased for sale and export.

Compliance Non-Compliance

5.1 The organisation shall have procedures to ensure that all products sold under a sales order are clearly identifiable according to the legal or certification status and traceable to the production batch and/or purchase order / payment voucher as appropriate.

FINDINGS:

GAP # :

5.2 The organisation shall comply with export regulations and ensure payments of exports fees and taxes are current.

FINDINGS:

5.2.1) The Organisation shall have a valid Export License from DENR & Customs

5.2.2) The Organisation shall ensure that each consignment for export has been approved and inspected by DENR & Customs as applicable.

5.2.3) The Organisation shall have required export documentation such as Export Compliance Certificate, Bill of Lading, Phytosanitary Certificate, Packing List, Sales Invoice, as applicable.

GAP # :

5.3 The organisation shall maintain adequate sales records that can be summarized to verify quantity of material and finished goods sold by verified legal status and production batch as appropriate.

FINDINGS:

5.3.1) Sales records clearly identify verified legal products sold that can be traced to defined a production batch unit and/or purchase order / purchase voucher.

5.3.2) Quantity of verified legal material / products sold to buyers is clearly defined.

GAP # :

5.4 Records of sales and exports shall be maintained for 5 years.

FINDINGS:

GAP # :