5 4 Internal Approval Procedures 1 The Internal

5. 4 Internal Approval Procedures 1 The Internal Audit Cycle Field extension / training Corrective measures Internal inspection Farmers Internal monitoring product flow Sanctions Internal approval decision Training Manual on Setting Up and Harmonising Internal Control Systems

5. 4 Internal Approval Procedures 2 How Much Control Do We Need? Training Manual on Setting Up and Harmonising Internal Control Systems

5. 4 Internal Approval Procedures 3 Internal Approval • screen inspection checklists • decision on approval • decide necessary corrective measures Inspection checklists and comments Internal Inspection • Sanction as required Internal Approval Manager or Internal Approval Commitee List of Approved Farmers (organic and conversion) List of Sanctioned Farmers Training Manual on Setting Up and Harmonising Internal Control Systems

5. 4 Internal Approval Procedures 4 What Should Be Done in Case of Noncompliances by Farmers ? Pesticides stored on the farm Use of herbicides Soil Erosion Coffee leaves sprayed 2 months ago Farmer used NPK fertiliser or urea Training Manual on Setting Up and Harmonising Internal Control Systems

5. 4 Internal Approval Procedures 5 What Should Be Done in Case of Mistakes Made During Processing or Buying ? Bananas mixed during packing Wrong buying records Some Bags not labeled as organic are they organic? Purchase officer has bought bananas from not certified farm because organic farmer was not at home Training Manual on Setting Up and Harmonising Internal Control Systems

5. 4 Internal Approval Procedures 6 What Needs to Be Done? Investigate • What Problem happened? • Why? • When ? • What products/lots are concerned? Note: Serious problems should always be reported immediately to ICS Coordinator. Decision • by organic approval manager /OAC • Sanctions • Corrective measures Act! Document! Training Manual on Setting Up and Harmonising Internal Control Systems

5. 4 Internal Approval Procedures 7 Example: Types of Sanctions Sanction Situation when sanction applied • Written condition • Minor deficiencies in record keeping, weak farm management. Minor violations of the standards or regulations • Penalty ICS will fine farmers $5 • Not having implemented last years conditions Major deficiencies in record keeping • Suspension for a fixed period until the farmer takes corrective actions requested (remains certified) • Repeated minor violations Clear violation of the standards but not threatening the organic integrity of the product. • De-certification of farmers --> New start of conversion period for 36 months • Clear violation of the standards threatening the organic integrity of the product. • Farmer banned from ICS membership either permanently or for a set time. • Obvious fraud Intentional obstruction of the inspection process, Refusal to respond to written requests Training Manual on Setting Up and Harmonising Internal Control Systems

5. 4 Internal Approval Procedures 8 Examples Non-compliances & Sanctions Training Manual on Setting Up and Harmonising Internal Control Systems