Report on food fraud vulnerability self-assessment

Insert Company Name

5/16/2018
 Information and scoping sheet
Company details
Company Insert Company Name
Business Unit Insert Business Unit
Location Insert Location of Business Unit
Date: Day Month Year

Food fraud vulnerability assessment team

Name Job Title

Team leader:
Team member:
Team member:
Team member:
Team member:
Team member:
Team member:
Team member:

Ingredient, Product, Brand,

Site, Country or Division
being assessed:
Justification for selection Result from Decision Tree…
based on impact analysis /
decision tree:

Suppliers involved in the Insert supplier(s) company name

assessment (if any):

Customers involved in the Insert customer(s) company name

assessment (if any)

Part(s) of the food supply

chain being assessed (e.g.
manufacturing, primary
production, retail, catering,
etc):

Countries / Geographical Insert region

Regions involved in the
assessment:
 Main questions Answers

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

https://www.foodshield.org/discover-
• Composition of the raw materials can be • Composition of the raw materials can
• Composition of the materials cannot tools-links/tools/;
Easy alteration of the composition of the raw materials modified by mixing with low-quality be modified by mixing with low-quality or
Is it simple or complex to adulterate your raw be modified and products can only be http://www.foodfraud.org/node?
1 provides opportunities for potential offenders to product-own material or foreign material, foreign material (e.g. powders, ground QA/laboratory
materials? replaced, i.e. it concerns large objects destination=node;
commit fraud i.e. as is feasible with ground products meat, etc.) and by altering valuable food
such as fruit http://ec.europa.eu/food/safety/rasff/in
(e.g. powders, ground beef, etc.) components (e.g. protein content)
dex_en.htm

• Simple/basic technologies and methods

Is the technology and knowledge to adulterate
2 adulterate the raw materials are neither facilities and knowledge are required to
your raw materials generally available?
http://www.foodfraud.org/node?
are available, and no specialist facilities
Technology, methods and knowledge to destination=node
• Technologies and/or methods to • Advanced technologies, methods, are required, to adulterate the raw
adulterate/modify a certain type of raw materials http://ec.europa.eu/food/safety/rasff/in
materials QA/laboratory
provides opportunities for potential offenders to dex_en.htm;
available, known, or reported adulterate the raw materials
commit fraud https://www.foodshield.org/discover-
• The knowledge required for tools-links/tools/
adulteration is generally available

• Detection of adulteration of raw

Fraud detection is impeded when analysis of raw • Established on-site methods are • Detection and confirmation of
materials is straightforward and
How easily can adulteration of your raw materials be materials requires advanced laboratory methods and available for fraud screening (e.g. test adulteration of raw materials requires
3 performed with common/simple QA/laboratory
http://www.foodfraud.org/node?destination=node
detected and with what kind of methods? facilities or if methods are lacking, which in turn provide kits) but confirmation of adulteration advanced laboratory analysis, or testing
methods (e.g. visual inspection,
opportunities for potential offenders to commit fraud requires additional testing for adulteration is not available at all
smelling)
• Simple/basic technologies and methods http://www.foodfraud.org/node?
are available, and no specialist facilities destination=node; QA/laboratory
Generally available technology, methods and knowledge • No technologies and/or adulteration • Advanced technologies, methods,
How available is the technology and knowledge to are required, to adulterate final products http://ec.europa.eu/food/safety/rasff/in
4 to adulterate/modify final products provides methods are known or available to facilities and knowledge are required to • The knowledge required for
enable the adulteration of your final products? dex_en.htm;
opportunities for potential offenders to commit fraud adulterate final products adulterate final products adulteration is generally available https://www.foodshield.org/discover-

Fraud detection is impeded when analysis of final

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

http://www.foodfraud.org/node?
The ease of counterfeiting of a product and general • It is complex to counterfeit the destination=node;
• The product can be counterfeited but • The product can easily be counterfeited
How simple or complex is counterfeiting of your availability of technology/methods/facilities/knowledge product and technologies, methods, http://ec.europa.eu/food/safety/rasff/in
6 this requires advanced technologies, and technologies, methods, facilities and QA/laboratory
final product? to do so provides opportunities for potential offenders facilities and knowledge are not dex_en.htm;
methods, facilities and/or knowledge knowledge are generally available
to counterfeit generally available https://www.foodshield.org/discover-
tools-links/tools/

Detection of counterfeit products is impeded when

• Detection of counterfeit products is • Established and on-site methods are • Detection and confirmation of
analysis requires advanced laboratory methods and
How easily can counterfeiting of your final product be easy and performed with available for counterfeit screening (e.g. counterfeiting requires advanced
7 facilities or if methods are lacking, which in turn http://www.foodfraud.org/node?destination=node
QA/laboratory
detected and what kind of methods are available? common/simple methods such as by test kits) but confirmation of laboratory analyses, or testing for
provides opportunities for potential offenders to commit
visual inspection or smelling counterfeiting requires additional testing counterfeiting is not available at all
fraud
frequent modification and allow easy interference, or
How would you describe the production lines / continuous flow processes and minor minor equipment modifications between small batches with major modifications Process flowcharts in documentation in
8 include shifts without strict control and unauthorized QA/processing
processing activities of your company? equipment
• The Supplymodifications between with
chain is transparent, batches
• (repetitive
The supply flow),
chain is with the
not fully between
• batches
The supply (intermittent
chain is complex andflow), and
lacks HACCP/FSMS manual
access of personnel provide opportunities for potential
good insight into suppliers and transparent; only direct suppliers and transparency; typically customers and
A complex supply chain that lacks transparency, with • Business relationships are variable; • Business relationships are ad-hoc and Documents of branch organization or
How would you describe your part of the food supply customers
• Business relationships are long-term customer are known suppliers are geographically disbursed Procurement/audit &
9 short-term/ad-hoc relationships, and no/limited some relationships are long-term, others price is the main driver for selecting from industry organizations. For
chain? relationships and characterized by trust control
information exchange provides opportunities for fraud coordinated, with comprehensive short-term
the supply chain; information exchange suppliers
• No information exchange occurs example: http://www.coceral.com/
information exchange across the supply occurs mainly with direct suppliers and between direct suppliers and customers destination=node;
Reported fraudulent incidents with similar raw material, • No fraudulent incidents related to raw • A few fraudulent incidents have occurred • Many fraudulent incidents have
Have fraudulent incidents of similar raw materials materials are known with specific raw materials occurred
• Incidentswith
arespecific raw materials
well known and http://ec.europa.eu/food/safety/rasff/in
10 often accompanied by media attention, indicate • No documented evidence/information • Limited documentation and few/no QA
been reported? documented, and have received dex_en.htm;
opportunities for fraud of fraud is available media reports are available
substantial media attention https://www.foodshield.org/discover-
destination=node;
Reported fraudulent incidents with similar final products, • No fraudulent incidents related to any • A few fraudulent incidents have occurred • Many fraudulent incidents have
Have fraudulent incidents of similar final products final products are known with specific final products occurred
• Incidentswith
arespecific final products
well known and http://ec.europa.eu/food/safety/rasff/in
11 often accompanied by media attention, indicate • No documented evidence/information • Limited documentation and few/no QA
been reported? documented, and have received dex_en.htm;
opportunities for fraud of fraud is available media reports are available
substantial
• media
Tight global attention
supplies of raw materials https://www.foodshield.org/discover-
• Raw materials are readily available • Stable prices but the supply of raw and/or shortages exist
• Export bans on raw materials exist in
• No export bans on raw materials exist materials is not readily available
many countries e.g.
How would you define the supply and pricing of your Economic pressures on raw materials can motivate • Price spikes of raw materials are Procurement/audit &
12 • Prices for raw materials are stable • Export bans on raw materials exist in a http://www.indexmundi.com/commoditi
raw materials? offenders to commit fraud common control
• Pricing of raw materials is independent few countries • Large differences in prices of materials es/?commodity=cocoa-beans
of geographical origin from different geographical regions
• Prices of substitute raw materials are • Prices of substitute raw materials vary
Value added by the composition of raw materials (e.g. equivalent greatly
• The value of raw materials is not • The value of raw materials is influenced • Value of raw materials is greatly
Do special attributes or components determine the protein content), production methods (e.g. organic)
13 determined by its composition, way of by its composition (e.g. protein or fat determined by its composition, way of Procurement
value of your raw materials? and/or geographical origin can motivate offenders to • Profits are declining and there is a gap
How would you describe the economic condition of The economic production or origin content) production
There areand/or origin
14 commit fraud situation of a company can motivate • The company is profitable, achieving
between financial targets and actual
• financial losses and it is Annual reports, Company financial
Management/finance
your company? employees to commit fraud for economic survival its financial goals difficult to meet financial targets reports
Short-term financial goals, with strong emphasis to • Long term financial targets, coupled performance
• Financial targets and food quality and • There is a strong emphasis to achieve
What are the characteristics of the business strategy achieve such goals and without specifying the with food quality and safety goals, and safety goals are ambiguous (short-term) financial goals, while the Mission statement of company,
15 • There's a lack of clarity about the means Management
of your company? (legitimate) means by which to achieve them can the means by which the objectives means to achieve them legitimately is Company Code of Conduct
motivate employees to commit fraud • Mutual
should betrust, interest
achieved, are&well
respect
specified toMutual
• achieve these
trust, objectives
interest and respect not specified
• There's a lack of mutual trust, interest
between all employees across the generally exists among employees but not
& respect among employees
company
• Standards, codes and requirements across
• the
Not all entire company
employees take standards, codes • Standards, codes and requirements are
are taken seriously by all employees and requirements
• Discussions seriouslyconduct
on unethical but many & do not taken seriously across the company
How would you describe the ethical business culture A poor ethical business culture can motivate employees • Discussions on unethical conduct & • There are no discussions on unethical
16 • Reports on unethical conduct are moral
• issues/dilemmas
Reports is limited
on unethical conduct to not
are major • Reports& on unethical conduct are Ethical culture assessments Management
of your company? to commit fraud moral issues/dilemmas are common conduct moral issues/dilemmas
always taken seriously, and corrections incidents
taken only (i.e.
seriously ad employees,
by all hoc) and usually ignored, and corrections of
of unethical activities are encouraged corrections of unethical conduct are not unethical activities are neither
• Ethical conduct
and acknowledged is highly valued and • Ethical conduct
broadly acknowledgedis not equally valued, • Ethical conduct is neither
encouraged nor acknowledged valued nor
rewarded by senior management nor rewarded by senior management rewarded by senior management
National privacy laws differ and may
• The company has not committed • There is no information whether the • The company has committed criminal
Has your company been involved in criminal offences Companies that committed criminal offences previously hinder answering this question. If
17 criminal offences or broken the law in company has committed criminal offences offences and/or broken the law in the Management/security
previously? have a higher risk of committing future offences available: criminal records, law
the past or broken the law in the past past
enforcement reports, media coverage

How would you rate the corruption level (according

• The company is active in countries • The company is active in countries with • The company is active in countries
to the Transparency International Corruption High levels of corruption in a country increases the
18
Perception Index) in the countries where your risk of fraud
with low levels of corruption (rated 1-25 medium levels of corruption (rated 26-75 with high levels of corruption (rated 76 http://www.transparency.org Security
on the Index) on the Index) and above on the Index)
company is active?
• The company sets fixed prices for • The company typically buys from • The company always buys from
How would you describe the financial strains Financial strains imposed by companies on their direct direct supplier(s) in line with market suppliers that offer the lowest price and suppliers that offer the lowest prices and Annual reports of suppliers, company Management/
19
imposed by your company on your direct supplier(s) ? supplier(s) can motivate the supplier to commit fraud prices, and supplier(s) have other suppliers
• are somewhat
The supplier(s) profits dependent on and
are declining, the suppliers are completely dependent on financial Reports procurement
How would you describe the economic health of your The economic situation of the company can motivate • The supplier(s) is profitable and
customers company • There are financial
for theirlosses andsurvival
it is Annual reports of suppliers, company Management/
20 there is a for
gaptheir financial
between theirsurvival
financial the company financial
direct supplier(s)? the supplier(s) to commit fraud for economic survival achieving its financial targets difficult to meet financial targets financial Reports procurement
targets and actual performance

Short-term financial goals, with strong emphasis to • Long term financial targets, coupled • Financial targets and food quality and • There is a strong emphasis to achieve
What are the characteristics of the business strategy achieve such goals and without specifying the with food quality and safety goals, and safety goals are ambiguous, and there's a (short-term) financial goals, while the Suppliers' mission statement and Code Management/
21
of your direct supplier(s) ? (legitimate) means by which to achieve them can the means by which the objectives lack of clarity about the means to achieve means to achieve them legitimately is of Conduct procurement
motivate suppliers to commit fraud should be achieved, are well specified these objectives not specified

• Mutual trust, interest & respect • Mutual trust, interest and respect
• There's a lack of mutual trust, interest
between all employees across the generally exists among employees but not
& respect among employees If available: ethical culture assessment.
company
• Standards, codes and requirements across
• the
Not all entire company
employees take standards, codes • Standards, codes and requirements are
are taken seriously by all employees and
• requirements
Discussions seriouslyconduct
on unethical but many & do not taken seriously across the company Procurement/
How would you describe the ethical business culture Poor ethical business culture of companies can • Discussions on unethical conduct & • There are no discussions on unethical If not: employees' perception of
22 • Reports on unethical conduct are moral
• issues/dilemmas
Reports is limited
on unethical conduct to not
are major • Reports& on unethical conduct are information provided by
of your direct supplier(s) ? motivate potential offenders to commit fraud moral issues/dilemmas are common conduct moral issues/dilemmas supplier's ethical culture
always taken seriously, and corrections incidents
taken only (i.e.
seriously ad employees,
by all hoc) and usually ignored, and corrections of supplier
of unethical activities are encouraged corrections of unethical conduct are not unethical activities are neither
• Ethical conduct
and acknowledged is highly valued and • Ethical conduct
broadly acknowledgedis not equally valued, • Ethical conduct is neither
encouraged nor acknowledged valued nor
rewarded by senior management nor
• rewarded
There by senior management
is no information whether the rewarded by senior management
National privacy laws differs and may
• The supplier has not committed supplier has committed criminal offences • The supplier has committed criminal
Has your direct supplier(s) been involved in criminal Companies that committed criminal offences previously hinder answering this question. If
23 criminal offences or broken the law in or broken the law in the past offences and/or broken the law in the Security/procurement
offences previously ? have a higher risk of committing future offences available: criminal records, law
the past past
enforcement reports, media coverage
 National privacy laws differs and may
• The supplier has not committed • The supplier has committed criminal
Has your direct supplier(s) been involved in criminal Companies that committed criminal offences previously • The supplier may have been committed hinder answering this question. If
23 criminal offences or broken the law in offences and/or broken the law in the Security/procurement
offences previously ? have a higher risk of committing future offences criminal offences or broken the law in the available: criminal records, law
the past past National privacy laws differs and may
Has your direct supplier(s) been a victim of food fraud There
past is no information available as to enforcement reports, media coverage
When a direct supplier has been a victim of food fraud • The supplier has not been a victim of The supplier has been a victim of food hinder answering this question. If
24 committed
How would by
youtheir
ratesuppliers, customers
the corruption levelor(according
other whether the supplier has been a victim of Security/procurement
there is a higher risk to your company food fraud in the past fraud in the past available: criminal records, law
parties?
to the Transparency International Corruption High levels of corruption in a country increases the • Suppliers and customers are active in food
• fraud in
Suppliers thecustomers
and past are active in • Suppliers and customers are active in
25
Perception Index) in the countries where your direct risk of fraud countries with low levels of corruption countries with medium levels of corruption countries with high levels of corruption
http://www.transparency.org
enforcement reports, media coverage Security
supplier(s) and customers are active? • The company operates in a stable
How would you describe the economic health across market
The economic situation across your sector can motivate • The company operates in a growing • The company operates in a declining Management/
26 your sector of the food supply chain (i.e. your Company data
offenders to commit fraud market(s) market(s) procurement
company and your direct competitors)? • The company operates in growing and
declining markets
• There is no information whether the National privacy laws differs and may
• The supplier has not committed customer has committed criminal offences • The customer has committed criminal
Has your customer(s) been involved in criminal Customers that committed criminal offences previously • The customer may have been committed hinder answering this question. If
27 criminal offences or broken the law in orBranch
broken the law in the past offences and/or broken the law in the Security/procurement
offences previously ? have a higher risk of committing future offences • Branch of industry culture is • of industry
criminal offences culture
or broken is law in the
the • Branch of industry culture is available: criminal records, law
How would you describe the ethical business culture the past past
characterized by a high level of mutual characterized
past by overall mutual trust, characterized by lack of mutual trust & Policy documents
enforcement on ethics
reports, mediaby branch or
coverage
Poor ethical business culture in a branch of industry can
28 across your sector of the food supply chain (i.e. your trust and respect, ethical discussions limited and ad hoc ethical discussions and interests, restricted/no moral/ethical industry organization.
National Ethics and
privacy laws differs being a
may Management
How common are criminal offences across your motivateoffences
Criminal potential offenders
that to commit
have occurred fraud across
previously • There is no evidence of fraudulent • Thereconduct
may have been incidences of • There is well-known
company and your direct competitors)? and ethical conduct is highly valued ethical is moderately valued discussions and ethicaland documented
conduct is not topic ofanswering
hinder industry meetings.
this question. If
29 sector of the food supply chain? (i.e. your company the sector have a higher risk of reoccurring and activity
betweenorcompanies
other forms of law breaking in fraud across
between the sector but there is no
companies evidence of fraudulent
valued between activity across our
companies available: criminal records, law
Security
and your direct competitors)? impacting your company our sector specific information available sector of the food industry
enforcement reports, media coverage
A high level of competition in a sector of the food
How would you rate the level of competition across Competitive intensity can be determined
industry may result in difficulties to reach financial goals • Low levels of competition across the • Medium levels of competition across the • Highly competitive sector of the food Management/
30 your sector of the food supply chain (i.e. your by legitimate means, which can motivate potential sector sector industry
by the number of competitors in the
procurement/sales
company and your direct competitors)? sector
offenders to commit fraud
Price differences as a result of different regulation • The price policy of food ingredients • The price policy of food ingredients and • The price policy of food ingredients and
Are there price differences as a result of regulatory Procurement / legal /
31 across countries can motivate potential offenders to and food products is similar for all food products is different in some food products varies considerably across
differences across countries? regulatory
commit fraud countries countries different countries

Detectability of adulterated and/or suspicious raw • Systematic, evidence-based (using

• Sampling plan only for safety and • No systematic ad-hoc sampling for fraud • Specific fraudand
screening methods
materials is enhanced when companies have a both historical scientific data) and
quality
• analysesfor
No methods but not detection
fraud for fraud check
in analysis
• General screening (quick) methods in systematic usefor
of fraud-related
fit-for-purposeanalyses
structured incoming material control system that sampling plan
place; external fraud analysis only in place but no (external) confirmatory fraudconfirmatory techniques (in house or in Documented FSMS plan; incoming
How would you rate your company's raw material includes: an evidence-based sampling plan for fraud • General procedure for sampling and • Customized with
procedures for fraud
32 case
• Noof inspectionfor
procedures demands/fraud issues
fraud monitoring testing collaboration accredited material control program/plan; QA / laboratory
monitoring control systems' ability to detect fraud? detection; accurate and specific fraud detection screening for monitoring of ingredient/rawmonitoring and handling of non-
tasks laboratories) procedure for incoming material control
methods; specific fraud monitoring procedures; and • No record keeping on adulterated or • Record-keeping
material in case of deviations;
fraud issues • Systematic record keeping and detailed
conformities
systematic record-keeping and documentation as an suspicious raw materials, and no limited documentation on fraud documentation of fraud monitoring
integral part of their FSMS documentation of fraud procedures monitoring procedures/systems procedures & systems
• Systematic and comprehensive
Systematic verification of fraud monitoring tasks at • Ad-hoc and or announced verification of verification (document & record analysis,
incoming material control, i.e. based on document & fraud monitoring tasks; mainly based on observations, and actual testing), Internal/external audit reports on FSMS;
Are the fraud monitoring tasks of your raw material record analysis, observations, and actual testing by an • No verification of fraud monitoring analysis of records and check of presence unannounced and performed by
33 incoming material control records; QA/internal auditing
control system verified in your company? autonomous controller enhances discovery of non- tasks at incoming material control of procedures (e.g. as part of auditing) autonomous controller of fraud verification reports
compliance practices is enhanced and assures adequate monitoring tasks
performance of the fraud monitoring tasks
• Ad-hoc reporting of verification • Systematic documentation of
• Sampling plan only for safety and outcomes; mainly in case of deviations verification
• Systematic,activities and outcomes
evidence-based (using
• No systematic, ad-hoc sampling for
quality analysesfor
• No methods but not detection
fraud for authenticity
in both historical
• Specific fraudand scientific
screening data) and
methods
A structured monitoring system for fraud detection in fraud
• analysis
General screening (quick) methods in
check external authenticity analysis
place; sampling plan
systematic usefor
of fraud-related
fit-for-purpose analyses
final products with an evidence based sampling plan for place but no or ad-hoc (external)
only in case of inspection • General procedure for sampling and confirmatory
• Customizedtechniques
procedures(in forhouse
fraud or in
How would you describe the fraud related parts of fraud detection, accurate and specific fraud detection • No procedures for fraud monitoring confirmatory fraud testing Documented FSMS plan; final product
demands/fraud issues screening for ad-hoc monitoring of collaboration
monitoring and with accredited
handling laboratory)
of non-
34 your final product monitoring control system of your methods, and fraud specific procedures and systematic tasks control program/ plan; procedure(s) QA/ laboratory
products for fraud issues conformities
company? record-keeping and documentation as integral part of • Systematic-record keeping and detailed final product control/analysis
• No record keeping on adulterated or • Mainly record-keeping in case of
their FSMS enhances detectability of internal documentation of fraud monitoring
suspicious raw materials and no deviations; limited documentation on
fraudulent practices procedures & fraud monitoring system
documentation of fraud procedures fraud
• monitoring
Ad hoc procedures/system
and/or announced verification of • Systematic, comprehensive (document
design
compliance to monitoring tasks mainly & record analysis, observations, and
Systematic verification of compliance to final product based on analysis of records and check of actual verification testing) and
monitoring tasks (sampling, laboratory analysis, presence of procedures (e.g. as part of unannounced verification by
corrective actions, record-keeping & documentation) auditing) autonomous controller Internal/external audit reports on FSMS;
Are the fraud monitoring tasks of your final product • No verification of actual compliance to
35 based on document & record analysis, observations, and final product control records; verification QA/internal auditing
control system verified in your company? monitoring tasks at final product control • Ad-hoc reporting of verification • Systematic documentation of
actual testing by an autonomous controller (no outcomes; mainly in case of deviations verification activities and outcomes reports
conflicting interest) enhances discovery of systematic • Established and comprehensive
deviations
Systematically collected, accurate information on mass • Basic administrative system with (accurate mass balance data, of all
balance flows of all raw materials, ingredients, and final • Process monitoring information system
limited information or no specific crucial ingredients, materials, & final
How extensive is the information system for internal products throughout the company (including internal with accurate information on mass • Structured record keeping of mass flow
36 information on mass balances of • No integral analysis of ingredients
mass flow data product flows) process monitoring information and documentation system Finance
• Data only analyzed in final
case of balances
• System of mainly
with bulk information and systematic analysis of
control of mass balance flows in your company? suppliers) and systematically analysis of the integral incoming
• materials
Traceability systemand
withoutproducts
clearly throughout theclearly
companydefined traceability information
(including • System with clearly
system defined
dedicated traceability
for control
dataset, enhances discovery of flaws in mass balances, inspection requirements resource units; Collection of accurate integral
of mass data
resource unitsof(product
balance whole
flows company
level; collection
defined traceability resource units or internal suppliers)
and provides evidence of fraud control (assurance) (including internal suppliers)
information but not specifically addressing of accurate information including fraud-
An integrated tracking and tracing system including units cannot be exactly defined (e.g.
fraud issues, only information on company relevant issues from direct supplier up to
clearly defined traceability resource units, collection of because of continuous flow).
• Computer-based data capturing &
level • Advanced
direct customerautomated and
accurate and fraud-relevant information from direct • Uncertainty about accuracy of
retrieval system but not systematically systematically controlled robust data Documentation tracking and tracing
How extensive is the tracking & tracing system of supplier up to direct customer (one up - one down), and information, and limited/no fraud
37 controlled (restricted possibilities for capturing and data retrieval system system, quality management system QA/logistics
your company? a robust data capturing and data retrieval system, relevant information
fraud) (fraud proof) manual
enhances tracing and tracking of suspicious
products/batches, and limits (safety, economic, brand)
• Data capturing and retrieval system is
damage in case of fraud
Application of acknowledged integrity screening not fraud proof
Use of established
• Detailed written codeintegrity screening
of ethical conduct Personnel documents, protocols or
Is integrity screening of employees common methods for employment of personnel enhances • Use of established
General written code integrity screening
of ethical conduct
38 A transparent and specific ethical code of conduct or • No integrity screening of employees methods
or is standard
guideline for and
is available employment
well of Human resources
procedure in your company? identification of future employees prone to unethical methods
or for employees
guidelines is available, atbut
keyawareness
positions • Whistle blowing system is well-all guidelines for personnel employment
Is there an ethical code of conduct or guideline in guidelines that is widely communicated and well • No written code of ethical conduct or • Whistle allblowing system is available, but all personnel
embedded; awareness amongst Code of conduct documents, training,
39 behavior
A well-designed and implemented whistle blowing amongst personnel is limited, and or established and well-known among Human resources
place
Is and
there a embedded in your system
whistle blowing company?(system for embedded in management activities enhances guideline exist no clear protection personnel is stimulated (e.g. posters, posters, leaflets, company website
system, including an independent code is not explicitlysystem
embedded for the
in whistle
40 reporting assumed fraudulent activities) in place in prevention of unethical behavior officer and protection • No whistle blowing system exists blower is in place, and reporting of
personnel, fraudulent
communication) practices can in
and demonstrated be Policy document of company, procedure
Human resources
system for whistle blowing, enhances discovery of management activities reported to anactivities
independent officer, and for fraud reporting
your company? fraudulent activity goes to supervisor (no management
fraudulent activities anonymity of the whistle blower is strictly
independent officer) • Comprehensive contractual
protected
requirements established in close
• Contractual requirements for direct • Contractual requirements are
Do contractual requirements with your direct Established, comprehensive contractual requirements collaboration with direct supplier(s)
suppliers are mainly set on logistic established together with direct Purchase documentation system,
41 suppliers include elements that limit opportunities for explicitly addressing fraud prevention enhance the addressing logistics, safety and quality, Procurement
parameters: cost, amount and supplier(s) for both logistic and safety & purchase contracts
fraud? prevention of fraudulent practices but also requirements on adoption of
availability quality parameters
ethical code/guidelines, and adoption of
similar technical fraud control measures
Suppliers with well-designed and systematically audited • Direct supplier(s) has a well established
What best describes the fraud control system of • Direct supplier(s) has a well established
NOTE: As an alternative to answering this question Food Safety Management Systems that include • Direct supplier(s) don’t have a FSMS FSMS in place that is regularly audited by
your direct supplier(s)? FSMS in place that is regularly audited by Audit reports; relevant documents from
42 yourself, direct suppliers can fill out the tool dedicated fraud control measures enhances or the FSMS is limited (not audited •
a An
3rdestablished and comprehensive
party and systematically uses fraud QA/audit & control
a 3rd party and uses basic fraud screening direct supplier(s) if available
themselves with respect to the control measures as detectability of fraudulent products supplied to your • A basic administrative
externally, systeminexists
no fraud measures place) • A process monitoring information process
screening monitoring
methods and information system
confirmatory
methods
How extensive is the information system for control
defined by the company company with limited/no specific information on system exists with accurate information exists
tests todedicated to the control
identify suspicious of mass
materials
of mass balance flows of your direct supplier(s)? An advanced information system to control mass mass balance flows of incoming on mass balance flows of bulk ingredients balance flows (accurate mass balance
balance flows in the supplying company enhances materials and final products only data,
• of all crucial
Structured recordingredients,
keeping of materials,
mass data
43 discovery of problems in their mass balances and • No integral analysis of mass data flow & final product flows)analysis of integral Information and documentation system Supplier/audit & control
NOTE: This question can be only asked directly of the • Data only analyzed in case of flow and systematic
provide evidence of fraud control (assurance) to across the company (including internal • Direct supplier(s) have a(including
traceability
supplier(s) inspection requirements data across the company
your company • Direct supplier(s) have a basic suppliers) system 2nd party audit reports of direct supplier
• Direct supplier(s) have a traceability internal for safety issues based on a
suppliers)
Suppliers with well-designed and audited traceability traceability system because of legal certified QA scheme(s) and based on (2nd party audit refers here to auditing
How extensive is the traceability system of your systems that systematically communicate accurate and system in place for safety issues that is of the supplier by your company or by
NOTE: As an alternative to answering this question requirements
• but it have
Direct supplier(s) not designed
a simple data • Direct contractual requirements as set and
44 direct supplier(s)? fraud-relevant information to your company, enhances based onsupplier(s)
a recognizedhave a simple
standard digital
and • Direct supplier(s) have advanced digital
an external auditor on behalf of your QA/audit & control
yourself, direct suppliers can fill out the tool according and
capturing to best practice
retrieval nor audited
system and data capturing and retrieval system, and audited (2nd part) by your company;
audited by a 3rd party robust data capturingand system;
themselves with respect to the tracking & tracing traceability of suspicious products/batches and limits byNo
a 3rd
there
• party
is no communication
self-regulation and poorabout • The supply
information chain
about has a certain
suspicious degreeisof
materials systematic,
• The supplyaccurate fraud fraud
chain self-regulates and
company), 3rd party audit reports or
relevant
damage inself-regulation
Extensive case of fraud and social control across the self-regulation
• Self-regulatingbut communication proof relevant documents from direct
system as defined by the company deviations
communication between companies
• Limited/no self-regulating tools (e.g. communicated adtools
hoc (e.g. code of information
communication exchange to your company
• Self-regulating tools (e.g. code of is
between companies
supply chain and transparent feedback/actions on depends on
conduct, individualscheme)
certification companies (i.e.
exist butnot supplier(s) if available
How would you describe the social control and acrossofthe
code supplycertification
conduct, chain scheme) very active
conduct, certification scheme) are widely
45 criminal offences reduces opportunities and motives for systematic)
are not widely implemented and QA/procurement
transparency of actions across your supply chain? exist, limited/no monitoring on implemented
• All unethicaland compliance
conduct is
is systematically
potential offenders and enhances detectability of • Unethical conduct is rarely compliance
• is not monitored
Only serious/obvious unethical conduct
compliance monitored systematically
communicated across the supply chain
fraudulent behavior communicated systematically
and/or incident are communicated
and information is widely shared
• Specific guidelines and examples of
Active communication of fraud incidents as well as • General guidelines (mainly via websites) Industry-wide organization and
How well established is guidance for fraud prevention • No specific guidelines for fraud best practices for fraud monitoring &
guidelines, best practices and fraud monitoring and for fraud mitigation measures are association websites: e.g.
46 and control across your sector of the food supply mitigation exist or aren't shared; mitigation are provided actively via QA/procurement
mitigation activates by companies supports the available, but there are no examples of https://gmpplus.org/pagina/7501/cheap
chain? (i.e. your company and your direct competitors) guidelines focus on safety only website, training, information brochures
effectiveness of fraud monitoring systems best practices of mitigation measures -is-too-good-to-be-true.aspx
and other mediums

• National food policy with generally • Well established national food policy
National food policy is the basis for legal controls. Websites of policy makers. For example:
defined legislation for food fraud with detailed specifically defined
National food policy specifically addressing fraud and • Only a general national food policy https://www.food.gov.uk/enforcement/f
How would you describe your national food policy? mitigation but it is not harmonized with legislation to ,mitigate against food fraud
47 harmonized with internationally recognized exists without specific legislative oodfraud Legal / regulatory
(i.e. country-level) internationally recognized that is harmonized with internationally
recommendations enables systematic and consistent requirements for food fraud mitigation http://ec.europa.eu/food/food/horsemea
recommendations for food fraud recognized recommendations for food
controls for food fraud mitigation t/index_en.htm
mitigation fraud mitigation

• Systematic fraud-related enforcement

• Fraud-related enforcement practices
• No national fraud related enforcement practices with risk-based frequency of
National enforcement practices specifically aimed at exist but with low frequency of inspections
practices exist inspections by regulatory/law
How well are fraud prevention laws enforced food fraud and systematically supported by by regulatory/law enforcement agencies
48 enforcement agencies Websites of national food authorities Legal / regulatory
locally? fines/sanctions helps to expand control measures and
enhances fraud detection and prevention
• Low level of fines/sanctions with little • High level of fines/sanctions with
• Very limited or no fines/sanctions
financial impact substantial financial impact
National enforcement practices aimed at food fraud
aligned across links of the international supply chain, • Fraud related enforcement practices • Fraud related enforcement practices • Fraud related enforcement practices
How well are fraud related laws enforced across Websites of all national food authorities
49 supported by fines/sanctions, increases the are lacking at most stages across the exist across parts of the international are aligned across all stages of the Legal / regulatory
your international supply chain? • Little or no supply
fines/sanctions and the• Fines/sanctions vary considerably involved in the international supply chain
effectiveness of control measures and enhances fraud international chain supply chain but the frequency of across • High level ofsupply
international fines/sanctions
chain withwith
risk-based
financial impact is minimal the international
inspections supply chain enforcement
by regulatory/law substantial
frequency offinancial impact
inspections by
detection
An integrated risk/contingency plan for both fraud and agencies varies regulatory/law
• An integratedenforcement agencies
risk/contingency plan for
• A documented risk/contingency plan is
food safety issues that is science-based, well both fraud and safety issues is in place,
Does your company have fraud contingency • No documented risk/contingency plan in place with communication principles FSMS documents, business continuity
50 documented and updated regularly can diminish the with detailed communication principles QA/risk/public relations
measures in place? for fraud issues is in place and tools for safety issues and recalls, but plans, risk communication plans
impact and consequences of fraud issues (internal or and tools that are well documented and
fraud issues not explicitly addressed
external) updated regularly
 Answer
Certainty
Question nr

9. Transparency chain network

10. Historical evidence fraud raw materials
1. Complexity of adulteration raw materials

8. Interference processing lines

0
0
1

11. Historical evidence fraud final products

2. Availability technology and knowledge to adulterate raw materials

7. Detectability
0
0
2
3. Detectability adulteration raw materials

6. Complexity
0
1
0
0
3

0.5
4. Availability technology and knowledge to adulterate final products

of counferfeiting
0
0
4
5. Detectability adulteration final products

0
0
5

of counterfeiting
1. Complexity of adulteration raw materials
6. Complexity of counterfeiting

0
0
6
7. Detectability of counferfeiting
Opportunities

0
0
7
8. Interference processing lines

0
0
8
9. Transparency chain network

0
0
9 10. Historical evidence fraud raw materials

5. Detectability adulteration final products

3. Detectability adulteration raw materials
10

0
0 11. Historical evidence fraud final products
11

0
0

12. Supply and pricing raw materials

12

0
0

2. Availability technology and knowledge to adulterate raw materials

13. Valuable components or attributes raw materials
13

0
0

14. Economic conditions own company

4. Availability technology and knowledge to adulterate final products

0
0
14

15. Organizational strategy own company

16. Ethical business culture own company

15 16

0 0
0 0

28. Ethical business

29. Historica
30. Level o

25. Corr
26. Economic con
27. Cr
 25. Corr
8. Interference processing lines 5. Detectability adulteration final products

7. Detectability
6. Complexity
of counferfeiting
of counterfeiting

12 35
Certainty score (1=un certain,

Certainty score (1=un certain,

10 30
8 25
6 20
15
4
10
2 5
0 0
1 2 3 4 5 6 7 8 9 10 11 1
Question number
 Motivations Control mea

35. Verification of fraud monitoring system final products

33. Verification of fraud mon. system raw materials

37. Tracking and tracing system own company

28. Ethical business culture branch of industry

32. Fraud monitoring system raw materials

34. Fraud monitoring system final products

26. Economic conditions branch of industry

30. Level of competition branch of industry

18. Corruption level country own company

29. Historical evidence branch of industry

36. Information system own company

25. Corruption level country supplier
22. Ethical business culture supplier
21. Organizational strategy supplier
17. Criminal offences own company

27. Criminal offences customer

23. Criminal offences supplier
20. Econ. conditions supplier
19. Financial strains supplier

24. Victimization of supplier

31. Price asymmetries

17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

49. Law enforcement ch

13.12. Supply
Valuable
31. and pricing raw
Pricecomponents
asymmetries materialsraw materials
or attributes 48. Law enforcement loca
30. Level of competition branch of industry 14. Economic conditions own company
29. Historical evidence branch of industry 1 15. Organizational strategy own company
47. National food pol
28. Ethical business culture branch of industry 0.5 16. Ethical business culture own company

27. Criminal offences customer 17.0Criminal offences own company 46. Fraud control indust

26. Economic conditions branch of industry 18. Corruption level country own company
45. Social control chain netw
25. Corruption level country supplier 19. Financial strains supplier
24. Victimization of supplier 20. Econ. conditions supplier 44. Tracking and tracing system
23.22.
Criminal
21. Organizational
Ethicaloffences
businesssupplier
strategy
culture supplier
supplier 43. Mass bal.
 45. Social control chain netw
25. Corruption level country supplier 19. Financial strains supplier
24. Victimization of supplier 20. Econ. conditions supplier 44. Tracking and tracing system
23.22.
Criminal
21. Organizational
Ethicaloffences
businesssupplier
strategy
culture supplier
supplier 43. Mass bal.

60

Certainty score (1=un certain,

35
Certainty score (1=un certain,

30 50
25 40
20 30
15
20
10
5 10
0 0
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 1 2 3
Question number
 Control measures
39. Ethical code of conduct own company

44. Tracking and tracing system supplier

38. Integrity screening own employees

49. Law enforcement chain network

40. Whistle blowing own company

42. Fraud control system supplier

41. Contractual requir. suppliers

48. Law enforcement local chain

45. Social control chain network
43. Mass bal. contr. supplier

46. Fraud control industry

47. National food policy

50. Contingency

38 39 40 41 42 43 44 45 46 47 48 49 50
0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0

32. Fraud monitoring system raw materials

33.
50. Verification
Contingency of fraud mon. system raw materials
49. Law enforcement chain network 34. Fraud monitoring system final products
1
48. Law enforcement local chain 35. Verification of fraud monitoring system final products

0.5
47. National food policy 36. Information system own company

0
46. Fraud control industry 37. Tracking and tracing system own company

45. Social control chain network 38. Integrity screening own employees

44. Tracking and tracing system supplier 39. Ethical code of conduct own company

43. Mass bal. contr. supplier 40. Whistle blowing own company
42. Fraud41.
control
Contractual
systemrequir.
supplier
suppliers
 45. Social control chain network 38. Integrity screening own employees

44. Tracking and tracing system supplier 39. Ethical code of conduct own company

43. Mass bal. contr. supplier 40. Whistle blowing own company
42. Fraud41.
control
Contractual
systemrequir.
supplier
suppliers

60
Certainty score (1=un certain,

50
40
30
20
10
0
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Question number
Answer
Certainty
Question nr
1. Complexity of adulteration raw materials

0
0
1
2. Availability technol/knowl. to adult. raw materials

0
0
2
3. Detectability adulteration raw materials

0
0
3
4. Availability technology and knowledge to adulterate final products

0
0
4
5. Detectability adulteration final products

0
0
5
6. Complexity of counterfeiting

0
0
6
7. Detectability of counferfeiting
Opportunities

0
0
7
8. Interference processing lines

0
0
8
9. Transparency chain network

0
0
9
10 10. Historical evidence fraud raw materials

0
0 11. Historical evidence fraud final products
11

0
0

12. Supply and pricing raw materials

12

0
0

13. Valuable components or attributes raw materials

13

0
0

14. Economic conditions own company

0
0
14

15. Organizational strategy own company

16. Ethical business culture own company

15 16

0 0
0 0

17. Criminal offences own company

18. Corruption level country own company

19. Financial strains supplier

20. Econ. conditions supplier

21. Organizational strategy supplier

22. Ethical business culture supplier

Motivations

23. Criminal offences supplier

24. Victimization of supplier

25. Corruption level country supplier

26. Economic conditions branch of industry

27. Criminal offences customer

17 18 19 20 21 22 23 24 25 26 27

0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0
 32. Fraud monitoring system raw materials

1. Complexity of adulteration raw materials 1

13. Valuable components or attributes raw materials 2. Availability technol/knowl. to adult. raw materials 37. Tracking and tracing system own company 33. Ver
12. Supply and pricing raw materials 1 3. Detectability adulteration raw materials 0.5
0.5
11. Historical evidence fraud final products 4. Availability technology and knowledge to adulterate final products 0
0
10. Historical evidence fraud raw materials 5. Detectability adulteration final products
36. Information system own company 34. Fra
9. Transparency chain network 6. Complexity of counterfeiting
8. Interference
7. Detectability
processing
of counferfeiting
lines
35. Verification of fraud monitoring system final produ
 38. Integrity screening own employees

14. Economic conditions own company

1
1
0.5
18. Corruption level country own company 0.5 15. Organizational strategy own company

0 0

40. Whistle blowing own company 39. E

17. Criminal offences own company 16. Ethical business culture own company
 41. Contractual requ

1
19. Financial strains supplier

25. Corruption level country supplier 1 20. Econ. conditions supplier 0.

0.5
44. Tracking and tracing system supplier 042
0
24. Victimization of supplier 21. Organizational strategy supplier

23. Criminal offences supplier 22. Ethical business culture supplier

43. Mass bal. cont
 45. Social control chain netw

26. Economic conditions branch of industry

1

31. Price asymmetries 1 27. Criminal offences customer

49. Law enforcement chain network 0.5
0.5
0 0

30. Level of competition branch of industry 28. Ethical business culture branch of industry

29. Historical evidence branch of industry 48. Law enforcement local chain 4
 28. Ethical business culture branch of industry

0
0
28
29. Historical evidence branch of industry

29

0
0
30. Level of competition branch of industry

31. Price asymmetries

0 0
0 0
30 31
32. Fraud monitoring system raw materials

33. Verification of fraud mon. system raw materials

34. Fraud monitoring system final products

35. Verification of fraud monitoring system final products

36. Information system own company

37. Tracking and tracing system own company

38. Integrity screening own employees

39. Ethical code of conduct own company

40. Whistle blowing own company

41. Contractual requir. suppliers

42. Fraud control system supplier

Control measures

43. Mass bal. contr. supplier

44. Tracking and tracing system supplier

32 33 34 35 36 37 38 39 40 41 42 43 44

0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0

45. Social control chain network

45

0
0

46. Fraud control industry

46

0
0

47. National food policy

47

0
0

48. Law enforcement local chain

48

0
0

49. Law enforcement chain network

49

0
0

50. Contingency
50

0
0
 32. Fraud monitoring system raw materials

1
mpany 33. Verification of fraud mon. system raw materials
0.5

mpany 34. Fraud monitoring system final products

erification of fraud monitoring system final products

8. Integrity screening own employees

0.5

39. Ethical code of conduct own company

 41. Contractual requir. suppliers

0.5

em supplier 042. Fraud control system supplier

43. Mass bal. contr. supplier

 45. Social control chain network

work 0.5 46. Fraud control industry

t local chain 47. National food policy

Assessment: Risks Risk level Control measures Level of adequacy
evaluation results (high/low) (high/low)
Opportunities high Internal hard controls low
Motivations own company high Internal soft controls low
Motivations direct supplier(s) high External supplier(s) controls low
Motivations chain/industry/int. high External chain/industry/int. controls low
Conclusions Abcdefg

Proposed mitigation Abcdefg

Company Report Name: Report Y Company X-1

5/16/2018

End of Fraud Vulnerability Self-Assessment Report

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