FOOD FRAUD VULNERABILITY ASSESSMENT Answers

Perceived
Useful information Selected answer certainty/reliability of the
Recommended answer by the assessor
Reason for Asking sources to help option (1, 2 or 3 -
# Question Indicator Answer option 1 Answer option 2 Answer option 3 expertise to fill out answering the question Expert answering the question Justification for selection of answer
the Question users answer the leave blank for (1= uncertain, 2=
the question Not Applicable)
question reasonably certain, 3=
very certain)

An adulterated food is one to which a substance has been added or

• Composition of the raw • Composition of the raw removed, deliberately and intentionally, for fraudulent purposes and has
Easy alteration of the • Composition of the
materials can be modified by materials can be modified by https://www.foodshield.org/di been modified to vary its composition, weight or volume or to cover up a
mixing with low-quality mixing with low-quality or scover-tools-links/tools/; defect. Fruits cannot be modified due to their great structure and difficult
composition of the raw materials cannot be modified
Is it simple or complex to Complexity of adulteration product-own material or foreign material (e.g. http://www.foodfraud.org/nod Raw material cannot be modified because are large objects
1
adulterate your raw materials?
materials provides
raw materials
and products can only be
foreign material, i.e. as is powders, ground meat, etc.) e?destination=node;
QA/laboratory 1 3 adulteration as they are not a homogeneous raw material. Raw material like
(fruits).
opportunities for potential replaced, i.e. it concerns powders can be modified but company supplier approval program and
feasible with ground products and by altering valuable food http://ec.europa.eu/food/safe
offenders to commit fraud large objects such as fruit
(e.g. powders, ground beef, components (e.g. protein ty/rasff/index_en.htm supplier preventive controls verify that products are received within
etc.) content) specification and the business relationships are maintened with
responsible/reputable supplier.

Fraud detection is impeded

• Detection of adulteration
when analysis of raw materials • Detection and confirmation
of raw materials is • Established on-site methods
requires advanced laboratory of adulteration of raw
How easily can adulteration of your straightforward and are available for fraud
methods and facilities or if Detectability adulteration materials requires advanced http://www.foodfraud.org/nod
2 raw materials be detected and with performed with screening (e.g. test kits) but QA/laboratory
methods are lacking, which in raw materials laboratory analysis, or e?destination=node
what kind of methods? common/simple methods confirmation of adulteration
turn provide opportunities for testing for adulteration is
(e.g. visual inspection, requires additional testing
potential offenders to commit not available at all
smelling)
fraud

Generally available technology,

• Simple/basic technologies http://www.foodfraud.org/nod
methods and knowledge to • No technologies and/or • Advanced technologies,
How available is the technology and Availability technology and and methods are available, e?destination=node;
adulterate/modify final adulteration methods are methods, facilities and
3 knowledge to enable the knowledge to adulterate and no specialist facilities http://ec.europa.eu/food/safe QA/laboratory
products provides known or available to knowledge are required to
adulteration of your final products? final products are required, to adulterate ty/rasff/index_en.htm;
opportunities for potential adulterate final products adulterate final products
final products https://www.foodshield.org/di
offenders to commit fraud
scover-tools-links/tools/

Regardless of a company's mission, strategic objectives and goals, the

main financial objective is to maximize its value for the owners. The
economic situation It is the closest expression of the proper functioning of
a company. The highest value is obtained from the future cash flows that Currently our economic situation is stable since we have
The economic situation of a • Profits are declining and the company expects to generate: the best positive balance between the presented profits, our sales have been increasing in recent
How would you describe the • There are financial losses
company can motivate Economic conditions own • The company is profitable, there is a gap between Annual reports, Company projected cash inflows and outflows, and discounted at today's value. The periods and we have efficiently managed our commitments
4 economic condition of your
employees to commit fraud for company achieving its financial goals financial targets and actual
and it is difficult to meet
financial reports
Management/finance 1 3 economic situation is also the result of commercial, operational and with suppliers.Also, the company can meet its payment
company? financial targets
economic survival performance
administrative management, which ultimately translates into operating commitments in a timely manner, since the financial
profit. Furthermore, a company is said to be in a good financial position situation is linked to liquidity conditions
when it has the ability to produce and maintain profits within a specified
period. Persevere in good results is the basic objective of management par
excellence.

When the rules and procedures are clear from the beginning, the
operational structure allows the development of employees to be adequate,
forming part of an internal culture through which a business image is
National privacy laws differ
projected. However, this is not always the case, there are often cases Our company has not broken the laws at any time of its
Companies that committed • The company has not • There is no information • The company has where for one reason or another employees do not get along well with the constitution and has not committed any criminal act. The
and may hinder answering this
Has your company been involved in criminal offences previously Criminal offences own committed criminal offences whether the company has committed criminal offences
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criminal offences previously? have a higher risk of company or broken the law in the committed criminal offences or and/or broken the law in the
question. If available: criminal Management/security 1 3 regulations or with the way of doing tasks within the company. The values ​of the company have been implemented in each
records, law enforcement regulations reformed in recent years especially emphasize the importance collaborator, avoid breaking the law and committing acts
committing future offences past broken the law in the past past
reports, media coverage
of designing internal control mechanisms within companies that prevent the that put the stability of the company in society at risk.
commission of crimes. These mechanisms can be so relevant that they can
avoid, in the event of crimes, greater evils for the company, such as its
intervention or its dissolution.

Systematic verification of
compliance to final product • Ad hoc and/or announced
• Systematic, comprehensive The monitoring system for the final product in the
monitoring tasks (sampling, verification of compliance to
(document & record analysis, Product adulteration is a serious matter, therefore, generating a food fraud
laboratory analysis, corrective monitoring tasks mainly based
observations, and actual
company is based on documentation that is generated
actions, record-keeping & • No verification of actual on analysis of records and program involves a large sequence of actions and responsibilities that lead
Are the fraud monitoring tasks of your Verification of fraud verification testing) and Internal/external audit reports from the analyzes that are carried out. This information is
documentation) based on compliance to monitoring check of presence of to constant monitoring where information is collected, analyzed and used to
6 final product control system verified
document & record analysis,
monitoring system final
tasks at final product procedures (e.g. as part of
unannounced verification by on FSMS; final product control QA/internal auditing 3 3 make decisions and have a good management system in the company. In
at the customer's disposal and present before any
in your company? product autonomous controller records; verification reports deviation that may arise at any time. The processes are
observations, and actual control auditing)
• Systematic documentation addition, which supports the guarantee of safety and quality of the final
testing by an autonomous • Ad-hoc reporting of
of verification activities and
audited and the constant monitoring needs that a
controller (no conflicting verification outcomes; mainly product.
outcomes production process can develop are evaluated.
interest) enhances discovery in case of deviations
of systematic deviations

An integrated tracking and

• Traceability system • System with clearly
tracing system including clearly
without clearly defined • System with clearly defined defined traceability resource
defined traceability resource
traceability resource units or traceability resource units; units (product level; A monitoring system is necessary to carry out rigorous control over all Our system is capable of tracking merchandise but not in
units, collection of accurate
units cannot be exactly Collection of accurate collection of accurate
and fraud-relevant information
defined (e.g. because of information but not specifically information including fraud-
areas of transport in real time. This guarantees maximum performance, the an automated way in real time. Monitoring ends the
from direct supplier up to direct reduction of errors and the improvement of the customer experience, poor moment you leave the company. The fraud inspection
continuous flow). • addressing fraud issues, only relevant issues from direct Documentation tracking and
How extensive is the tracking & customer (one up - one down), Tracking and tracing system
7
tracing system of your company? and a robust data capturing own company
Uncertainty about accuracy information on company level supplier up to direct tracing system, quality QA/logistics 2 3 process management and the lack of information technologies are some of system is functional in the company and when going out to
of information, and • Computer-based data customer management system manual the obstacles that affect logistics activities. All monitoring system must the customer, the implemented traceability system allows
and data retrieval system,
limited/no fraud relevant capturing & retrieval system • Advanced automated and
enhances tracing and
information but not systematically systematically controlled
comply with various functionalities that allow the company to plan, monitor to trace the cause that could initiate a product recall
tracking of suspicious and analyze each of the activities carried out in logistics transport. considered as a potential risk to public health.
• Data capturing and controlled (restricted robust data capturing and
products/batches, and limits
retrieval system is not fraud possibilities for fraud) data retrieval system (fraud
(safety, economic, brand)
proof proof)
damage in case of fraud

Through the Code of Ethics it is about giving effect to the values ​or ethical
• Detailed written code of principles of an organization. Ethics in companies must appeal to the
A transparent and specific
• General written code of ethical conduct or guideline
ethical code of conduct or
ethical conduct or guidelines is is available and well
processes that determine organizational decisions and behaviors. By
guidelines that is widely respecting and complying with the Codes of Ethics, corrupt practices that
Is there an ethical code of conduct available, but awareness embedded; awareness Code of conduct documents,
communicated and well Ethical code of conduct own • No written code of ethical
8 or guideline in place and embedded in
embedded in management company conduct or guideline exist
amongst all personnel is amongst all personnel is training, posters, leaflets, Human resources 1 3 destroy value and harm the economy and society can be ended. If the There isn't a ethical code in the company.
your company? limited, and or code is not stimulated (e.g. posters, company website organizational culture is stimulated and promoted, with common values
activities enhances
explicitly embedded in communication) and
prevention of unethical
management activities demonstrated in
​that serve as a guide for the individuals that make up the organizations, we
behavior could give greater ethical components to a company, generate trust, loyalty
management activities
and sustainability in the market.
 • Direct supplier(s) have a
traceability system for
• Direct supplier(s) have a Our suppliers follow an evaluation procedure where the
• Direct supplier(s) have a safety issues based on a
basic traceability system 2nd party audit reports of company ensures that they meet the necessary
Suppliers with well-designed traceability system in place for certified QA scheme(s) and
How extensive is the traceability because of legal direct supplier (2nd party
and audited traceability safety issues that is based on based on contractual Point-to-point traceability is the most widely accepted way to manage requirements to face any situation. A correctly
system of your direct supplier(s)? requirements but it not audit refers here to auditing
systems that systematically a recognized standard and requirements as set and traceability, thus controlling logistics flows, returns and product implemented traceability plan from our suppliers, in
NOTE: As an alternative to designed according to best of the supplier by your
communicate accurate and audited by a 3rd party audited (2nd part) by your
answering this question yourself, Tracking and tracing system practice nor audited by a company or by an external withdrawals. A correct traceability system allows us to prevent and detect a addition to allowing the effective removal of unsafe
9
direct suppliers can fill out the tool
fraud-relevant information to
supplier 3rd party
• Direct supplier(s) have a company; systematic,
auditor on behalf of your
QA/audit & control 3 3 food crisis, increasing the safety and benefits of companies, consumer products, allows us to have all the information about a
your company, enhances simple digital data capturing accurate and fraud relevant
themselves with respect to the • Direct supplier(s) have a company), 3rd party audit
traceability of suspicious and retrieval system, and information exchange to your confidence and greater efficiency in incident management for the product so that the final consumer is correctly informed
tracking & tracing system as defined simple data capturing and reports or relevant documents
products/batches and limits information about suspicious company Administration. about the ingredients and processes to which it has been
by the company retrieval system and there is from direct supplier(s) if
damage in case of fraud materials is communicated • Direct supplier(s) have
no communication about available subjected. , something of vital importance in the event of a
improvised advanced digital robust data
deviations food crisis, return and / or withdrawal.
capturing system; fraud
proof

An effective traceability system provides access to all the information that

• The supply chain has a • The supply chain self- is being generated in the supply chain in an immediate and integrated way,
certain degree of self- regulates and communication
• No self-regulation and poor
regulation but communication between companies is very
helping to detect, isolate and prevent problems throughout the distribution.
Extensive self-regulation and communication between One of the most critical factors that have driven transparency in supply Communication and collaboration between the different
depends on individual active
social control across the supply companies across the supply
chain and transparent chain
companies (i.e. not • Self-regulating tools (e.g. chains is increased consumer demand to know more about the products parts of the logistics chain have allowed the successful
systematic) • Self-regulating code of conduct, they are buying, especially in the e-commerce industry when it comes to implementation of a strategy to increase logistics visibility,
How would you describe the social feedback/actions on criminal • Limited/no self-regulating
tools (e.g. code of conduct, certification scheme) are
10 control and transparency of actions offences reduces opportunities Social control chain network tools (e.g. code of conduct,
certification scheme) exist but widely implemented and
QA/procurement 3 3 being informed about delivery. their products. Moving towards a demand- and it is only through open communication that they can
across your supply chain? and motives for potential certification scheme) exist, driven supply chain is one of the most important steps a retailer must take meet these objectives. For this, the construction of good
are not widely implemented compliance is monitored
offenders and enhances limited/no monitoring on
detectability of fraudulent compliance
and compliance is not systematically • All today. relationships with our suppliers is essential for the
monitored systematically unethical conduct is Visibility from start to finish in the supply chain results in reduced fulfillment of our business goals.
behavior • Unethical conduct is rarely
• Only serious/obvious systematically communicated
communicated
unethical conduct and/or across the supply chain and
administrative costs, shipping and maintenance costs of inventory,
incident are communicated information is widely shared optimization of inventories, improvements in transport processes, in the
customer experience and their satisfaction levels.

The prevention of food fraud through the logistics chain is the cornerstone
of good relationships with customers and suppliers. The common factor in
many cases of food fraud is that adulterant is not a danger to the food
• Specific guidelines and security, nor easily identifiable (since this would go against the objective of
Active communication of fraud A basic knowledge guide on food fraud throughout the
How well established is guidance for incidents as well as guidelines,
• General guidelines (mainly via examples of best practices
Industry-wide organization
scammers). Common adulterants include water and sugar, or ingredients
• No specific guidelines for websites) for fraud mitigation for fraud monitoring & supply line on a regular basis allows the identification of
fraud prevention and control best practices and fraud and association websites: e.g. that can be used from in a legitimate and declared way, but whose
Fraud control system fraud mitigation exist or measures are available, but mitigation are provided vulnerabilities which ensure the effectiveness of the
11 across your sector of the food supply monitoring and mitigation
supplier aren't shared; guidelines there are no examples of best actively via website,
https://gmpplus.org/pagina/75 QA/procurement 3 3 improper use constitutes fraud. Food fraud cheats consumers by providing
process. Likewise, the security system establishes the
chain? (i.e. your company and your activates by companies 01/cheap-is-too-good-to-be- lower quality food, against their knowledge and Will. The economically
focus on safety only practices of mitigation training, information
direct competitors) supports the effectiveness of true.aspx procedure for ensuring the safety of raw materials and
fraud monitoring systems
measures brochures and other motivated adulteration deprived consumers of the quality products that
mediums therefore final products.
they intend to buy. It can also have serious security consequences food and
consumer health. The prevention of food fraud is of the utmost importance
to protect the trust of our consumers and to maintain, practices of
reasonable sustainable business.

An integrated risk/contingency • An integrated We have a bioterrorism and product recall procedure.

An entire contingency system is based on an analysis of vulnerabilities
plan for both fraud and food • A documented risk/contingency plan for The HACCP program contains an analysis of risks and
safety issues that is science- risk/contingency plan is in both fraud and safety issues against food fraud in raw materials and in the production process.
• No documented FSMS documents, business vulnerabilities from the raw material to the dispatch of the
Does your company have fraud based, well documented and place with communication is in place, with detailed Therefore, the first analysis consists of knowing if you have implemented a
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contingency measures in place? updated regularly can diminish
risk/contingency plan for
principles and tools for safety communication principles and
continuity plans, risk QA/risk/public relations 2 3 procedure against food fraud that analyzes a mitigation plan against food
final products. Each party involved in the entire supply
fraud issues is in place communication plans chain plays a fundamental role in the integrity of our
the impact and consequences issues and recalls, but fraud tools that are well
fraud of your raw materials and packaging materials in contact with the
of fraud issues (internal or issues not explicitly addressed documented and updated products, with this constant monitoring and analysis of the
external) regularly product.
needs that may arise according to the risk analysis is basic
to maintain our mitigation plan against frauds.