Quality Policy

1.0 SCOPE

AB Agri operates in many different countries of the world from its base in the United Kingdom. Operating practices cannot necessarily be standardised across different countries or a diversity of business types but there are key principles that always apply. This document outlines the core principles of Quality Assurance that must be interpreted and applied in each of AB Agri's operating divisions.

This policy covers all products with the potential to enter the food chain as livestock feed or to be used as pet food. Products may be:

1.1 Purchased for use as raw materials in manufacturing

1.2 Traded without ever being 'handled'

1.3 Purchased and stored for future sale

1.4 Manufactured in AB Agri factories or in those directly controlled by it

2.0 CORE PRINCIPLES

Products as defined above must be:

Compliant with current legislation in those countries where they are manufactured and/or sold; and

Demonstrably safe both to livestock and as components of livestock products in the human food chain.

Wherever possible AB Agri will participate fully in Assurance Schemes and in the United Kingdom will always be a participant in the appropriate Agricultural Industries Confederation scheme.

This means that all operating divisions must be aware of and operate to:

2.1 Relevant legislation

2.2 Appropriate industry codes of practice and assurance schemes

2.3 Customer supplied codes of practice or other documented requirements

2.4 HACCP systems based on Codex Alimentarius where this is a legal requirement or, if not, a risk based approach to food and feed safety.

Core procedures must be documented in a system that is continually reviewed and audited and all procedures, records and operating facilities must be open to inspection by customers and enforcement authorities.

3.0 PRODUCTS (including raw materials)

All products must be clearly defined by means of a product specification. The specification must be sufficiently detailed to cover the elements of safety and use required in legislation and by customers. Product labels must always be as prescribed by law and give accurate, supportable information.

4.0 SUPPLIERS

All suppliers with the potential to impact AB Agri's delivery of this policy must be approved for use and listed. Approval will include regular auditing, monitoring of Quality and Safety data and where such a scheme exists, a participant in a recognised Assurance Scheme. At the very least, the following types of businesses are encompassed by this requirement:

4.1 Processors and manufacturers

4.2 Traders and shippers

4.3 Operators of transport by road, rail, air or water

4.4 Storekeepers

In each case, approval must take account of the risks of compromise to product safety or integrity.

5.0 PREMISES AND PLANT

Buildings, plant and machinery must be designed, built, maintained and operated with consideration for product integrity. In particular this includes:

5.1 Avoiding product contamination with other things

5.2 Avoiding cross contamination between products

5.3 Maintaining full product traceability

5.4 Avoiding product spoilage and deterioration

5.5 Ensuring the accuracy of all measurements and weighments

5.6 Operating a robust pest control regime including management of bird access, and rodent and insect activity

6.0 PROCESSING

All manufacturing processes must be subject to robust controls to ensure that they perform as intended. These controls should either be built into computer systems in which appropriate access controls have been implemented or against written procedures. In the latter case, critical processes must be continually verified to ensure their correct operation and 'signed off' by responsible management.

7.0 TRACEABILITY

All products must be both identifiable and traceable through all stages in the process, including sub-processes such as in-process storage bins and routes. The level of traceability will be dependent upon the sensitivity of the product but in principle the following applies: if a material is an animal medicine or additive with a batch number then full batch traceability is required but otherwise traceability can be maintained using a combination of time, delivery information, storage location etc. The key is that the system employed must be adequate to ensure that it is always possible to link vendors with purchasers via any relevant intermediate processes, transport or storage.

8.0 TRANSPORT

Transport by road, rail, air or water must be used on the basis of the ability of the operator to avoid contamination in the same categories outlined in section 5, Premises and Plant as appropriate.

9.0 QUALITY CONTROL

Testing of products is required for the following reasons:

9.1 To demonstrate legal compliance

9.2 To assess value as a raw material and set a formulation matrix

9.3 To monitor plant performance

9.4 To evaluate supplier capability

9.5 To satisfy 'due diligence'

9.6 To give confidence to customers

The nature of testing to be carried out will range from simple physical tests to complex chemical or microbiologic analysis.

The operating business must be able to demonstrate the thought process that has led to the testing schedule (sometimes known as Quality Plan) that is in place.

10.0 MANAGING NON-CONFORMANCE

There must be a system in place that allows problems to be corrected and not repeated in the future. Problems will emerge from:

10.1 Internal or external auditing and management activity or routine observations by staff

10.2 Feedback and complaints from customers

10.3 Serious problems identified outside the business at national or international level or advised by suppliers that may affect the products purchased, used or sold by the company

It is an absolute requirement that there is a written, workable system in place for carrying out product recall in the event of a food or feed safety risk being identified.

11.0 PERSONNEL

People and their activities are the key to the success of the business. All staff must be trained in the tasks they fulfil and there must be written descriptions of their responsibilities, duties wherever there is physical involvement with products or the definition or technical management of products or product use. Training of staff must be recorded.

12.0 RECORD KEEPING

All the key processes and management activities that demonstrate compliance with this policy must be supported by records. Records may be kept in electronic media or hard copy; they must be legible and available for an appropriate period. This period must be defined after giving consideration to the sensitivity of the process, the likely shelf life of product or overriding legal requirements in place. After the appropriate retention periods old records must be disposed of in a manner that gives due consideration to the commercial sensitivity of the information held therein.

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