MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 1 of 18 Issue Date

06.04.2008 Issued by M Clegg Doc.No. QAM CONTENTS PAGE CONTENTS AND SCOPE 1 INTRODUCTIONS (TECHNICAL MANAGEMENT SYSTEM) 2 10 QUALITY POLICY 11 HYGIENE POLICY 12 ENVIRONMENTAL POLICY 13 ALLERGEN DECLARATION 14 MANAGEMENT RESPONSIBILITIES 15 18 RELATIONSHIP BETWEEN THE STANDARD & QUALITY SYSTEM 1920 ORGANISATIONAL CHART 21 HACCP SYSTEM (See HACCP Manual & Risk Assessments) QAHM ALLERGEN STATEMENT SCOPE: Importers and distributors of quality chilled foods and dry /ambient product.
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 2 of 18 Issue Date

06.04.2008 Issued by M Clegg Doc.No. QAM 1.0 Technical Management System/Management Review: Senior Management Commitment and Continual Improvement This shall include all quality and hygiene systems required to address 'THE GLOBAL FOOD STANDARD FOR FOOD SAFETY' and found throughout MARK CLEGG & CO The Directors and managers have been identified and are responsible for the daytoday management of, hygiene and product safety management system. A deputy has been appointed for those times when the Directors are unavailable. A BRC . (British Retail Consortium) Committee is in place and is responsible for the review of the hygiene and product safety systems. Ultimate responsibility rests with the Directors. The Directors shall ensure that there is provision of resource and investment to meet safety, legal and customer requirements. Hazard Analysis (HACCP) will form the basis of the scheme identifying all hygiene risks to the product and will be a prerequisite for the development of the system. A Management Review Team consisting of the BRC Committee has been formed. Minuted meetings take place at regular intervals and are appropriately documented. 1.1 Document Control:3.7(BRC standard ref No) The manuals shall be controlled as an essential element of demonstrating compliance. The organisation has established and maintained documenting procedures to control all documents and data relating to the requirements of this standard. A master file of all related documents is kept. Records of all the documents will be maintained and archived for a minimum of two years.
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 3 of 18 Issue Date 06.04.2008 Issued by

M Clegg Doc.No. QAM 1.2 Purchasing:3.6 MARK CLEGG & CO shall control all its purchasing processes, which are critical to product safety, legality and quality to ensure product procured conforms to defined requirements. MARK CLEGG & CO has a documented Approved Supplier procedure in place based upon HACCP principles. 1.3 Specifications:3.7.2 MARK CLEGG & CO shall ensure that appropriate specifications exist for raw materials (including product packaging) through to finished goods. Specifications will be adequate, accurate and shall ensure compliance with relevant safety and legislation requirements. All specifications will be reviewed intermittently within the management review procedure. 1.4 Management of Incidents and Product Recall:3.11 MARK CLEGG & CO will provide written guidance to relevant staff regarding the type of event that would constitute an 'incident'. A documented incident reporting procedure is in place. 1.5 Traceability:3.9 MARK CLEGG & CO has implemented a system to trace finished products from source to finished good at any given time and has established a system so a customer can
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 4 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM identify a product should traceability be required based on the quality system. 1.6 Internal Audits:3.5 An established full audit procedure to include both the quality

manual and hygiene and HACCP systems has been implemented. All audits are fed through to a management review. 1.7 Corrective Action & preventive action:3.8 MARK CLEGG & CO shall ensure that procedures are in place to investigate the cause of significant nonconformity against standards, audits, working practices customer complaints etc. Corrective action shall always be seen as an opportunity to improve and a tool to carry the company towards Total Quality Management. 1.8 Complaints/Complaint Handling:3.10 All complaints are monitored and reviewed. MARK CLEGG & CO considers all complaints to be an opportunity to improve via thorough investigation. 1.9 Supplier Monitoring:3.6 MARK CLEGG & CO operates a procedure for approval and monitoring of all its suppliers. The approved supplier list has been collated on a historical and questionnaire basis. Supplier visits are carried out via marketing/purchasing and recorded.
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 5 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM 1.10 Process Control/ HACCP:6.1 The company shall be able to demonstrate effective controls of all operations undertaken. The Critical Control Points (CCP's) for the processes and tolerances shall be defined in the HACCP study. Where particular processes are specified in legislation these must be achieved as a minimum. Ie all prerequisites must be met prior to HACCP being implemented. (See list of prerequisites). 1.11 Product Control: Design and development:5.1 MARK CLEGG & CO ensures quality checks are carried out to demonstrate that products are within tolerances laid down

in the agreed product specification. A HACCP study is undertaken during any product design or development to identify and assess all potential safety hazards and associated risks. Procedures shall be in place to prevent the cross contamination of all raw materials, packaging and finished product. 1.12 Product Inspection & Laboratory Testing:5.5 Where MARK CLEGG & CO undertakes product analyses critical to confirm product/food safety then the laboratory will be UKAS accredited? 1.13 Product Release:5.7 Product release will be addressed via the company HACCP procedures and appropriate checks will be made against Critical Control Points to ensure that the process was within
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 6 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM specification before product is released from the company's control. The company shall ensure that all out of specification product is clearly identified, labelled or quarantined. 1.14 Metal detection/Foreign body detection:5.3 MARK CLEGG & CO shall ensure that all necessary steps are taken to identify, avoid, control, eliminate or minimise the risk of metal or any other foreign body entering the product. 1.15 Factory Standards Including Perimeters & Grounds:4.0 MARK CLEGG & CO fully understands its responsibilities in maintaining to a high standard both the factory integrity and its adjoining perimeter and grounds. Monies are setaside in the budget annually to address the above. Both the factory and surrounding areas are covered by procedures and include, cleaning and scheduled maintenance. 1.16 Layout & Production Flow:4.0 The Premises and plant shall be designed, constructed and maintained to control the risk of product contamination and

comply with current and relevant legislation. See Work Instruction/HACCP Manual. 1.17 Maintenance of Equipment:4.6 All equipment will be maintained in relation to the avoidance of product contamination. All completed work will be followed by a hygiene inspection. All maintenance personnel will comply with personal hygiene requirements and safe system of work. 1.18 Equipment and process validation:4.5
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 7 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM The effective control of equipment critical to product/process safely as identified in the HACCP study shall be checked eg packaging seals, clips etc. 1.19 Calibration and the control of measuring devices:6.3 The company will identify measuring equipment used to monitor Critical Control Points and product safety and legality. The identified equipment will be calibrated to a national standard NAMAS. With full records kept. 1.20 Housekeeping & Hygiene:4.9 MARK CLEGG & CO is responsible for identifying of suitable and safe cleaning methods and materials. Thus ensuring the premises and machinery are kept clean at all times and standards and procedures of hygiene and housekeeping are maintained at all times. Accredited chemical suppliers are sought and used. 1.21 Waste & Waste Disposal:4.10 Systems for dealing with internal and external waste storage are in place. Particular attention will be paid to formulating a disposal procedure for contaminated/quarantined products. This will take into account any risk of contamination. 1.22 Contamination Control: Physical, chemical:4.8 All practicable steps will be taken to identify, avoid, eliminate

or minimise the risk of foreign body contamination ie physical, chemical and microbial. 1.23 Pest Controls:4.11 Controls are in place to prevent actual or potential infestation and the resulting contamination from rodents, flying and
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 8 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM crawling insects, birds and other pests. Accredited suppliers are sought and used, data is analysed following visits and reports are fed through management review. 1.24 Product Packaging:5.4 Product Packaging (shrinkwrap, trays, clips, netting etc) shall be for the intended use and stored under conditions so as to minimise the risk of contamination and deterioration. 1.25 Transport, Storage & Distribution:4.12 The transport, storage and distribution of raw materials and finished products are undertaken as to minimise the risk of contamination. Full temperature records kept at receipt, storage and delivery to ensure due diligence/chill chain. 1.26 Personal Hygiene:7.3 MARK CLEGG & CO understands its responsibilities towards addressing the needs of the Management of Health & Safety Regulations 1994, the Food Safety (General Food Hygiene) Regulations 1995. There will be an effective procedure for the control of jewellery and personal items. Appropriate protective clothing will be worn to minimise the risk of product contamination. Sufficient hygiene training will be given to relevant staff with full records kept. 1.27 Access & Movement of Personnel:7.2 All access and movement of personnel will be on a managed basis to minimise cross contamination in all areas. 1.28 Staff/Welfare Facilities:4.7 Staff facilities shall be designed and operated so as to

minimise the risk of product contamination. Toilets and hand

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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 9 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM washing facilities shall be adequate and be maintained in a clean and hygienic condition. Rest and break facilities shall be of a suitable standard to promote good hygiene practices. 1.29 Medical screening:7.4 The company will ensure that full medical screening is in place with a return to work policy fully documented along with preemployment medical questionnaires. Considerations will be given to those returning from foreign holiday and may be deemed as convalescent carriers, or those with sickness in the family. 1.30 Personal Health:7.4 Illnesses likely to adversely effect product safety shall be monitored and controlled. 1.31 Categorisation/Risk Determination:2.0 MARK CLEGG & CO has a policy that all products are rated in accordance with BRC global standard across its entire operation. Its designated BRC team, using the appointed risk rating procedure used for risk assessment will carry out hazard analysis. (See Technical Standardguidance notes ratings [issue 5]) 1.32 Quantity control:6.2 Checks shall be carried out to demonstrate that pack contents conform to the legal requirements where the product is available to the ultimate consumer/customer. Records of weights, shall be adequate to demonstrate compliances with legal requirements. 1.33 Contract Review & customer focus:3.4
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MARK CLEGG & CO Quality Manual

GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 10 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM Meeting customer requirements and attaining complete customer satisfaction is part of MARK CLEGG & CO's strive towards continuous improvement. Customer feedback is a valuable tool in achieving this goal. (See customer focus) 1.34 Personal Protective equipment:7.5 Full PPE shall be issued to all members of staff and shall be designed to reduce the risk of product contamination. Full PPE shall also be made available to all visitors, contractors working or entering food areas. 1.35 Training:7.1 All members of staff shall receive training commensurate to duties with full training records in place. 1.36 Control of Non Conforming Product:5.6 The Company shall ensure all out of specification product is clearly labelled and quarantined 1.37 Handling requirements for specific materials Materials containing allergens and identity preserved materials:5.2 Where raw materials and finished product require special procedures for handling specific materials (allergens) or preserved status (GM) then these shall be in place to ensure product safety, legality and quality are maintained
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 11 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM

Quality Policy The company shall at all times ensure it meets its obligation to supply safe and legal products and understand its responsibilities to its customers It is the aim of MARK CLEGG & CO to ensure that all food handling staff is trained in basic food handling and hygiene techniques. The company's senior management will ensure communication to its management and supervisory staff of the importance of meeting statutory, legal and customer requirements. MARK CLEGG & CO will only use fresh product that conforms to customer standards and specifications (unless otherwise specified) MARK CLEGG & CO aims to operate an Efficient and Hygienic Company at all times. We will maintain a close monitoring procedure made up of daily and weekly checks, overseen by an internal monthly audit system. Any product not conforming to our company standards will be rejected. It is the aim of the Company to strive for continuous improvement across all areas in everything that we do. Mark Clegg MANAGING DIRECTOR
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 12 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM HYGIENE POLICY MARK CLEGG & CO identifies its duties as laid out under the Food Safety (General Food Hygiene) Regulations 1995. It is the policy of this company to show due diligence as suppliers to the food industry. MARK CLEGG & CO will take all reasonable care to prevent contamination of products through physical, chemical and microbiological cross contamination. This documented Quality/ HACCP system is in line with the requirements of the Technical Standard devised by the British Retail Consortium Global Standard, and designed for suppliers to the food industry. This documentation is our statement of intent. The senior management team acknowledges its duties for achieving the hygiene standard and has assigned appropriate resources and priority

to ensure continued compliance. The Food Safety (General Food Hygiene) Regulations 1995 outlines legislation based on EU directives. A requirement of this being due diligence be proven at all stages in the production and sale of the final product. M Clegg
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 13 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM MANAGING DIRECTOR Environmental Policy As part of our continuing drive for improvement, we have developed this environmental policy statement. It sets out our commitment to reducing our environmental impact and, where possible, improving the local environmental conditions. At MARK CLEGG & CO we are committed to continually looking at all areas of operation to encourage environmental protection. We will strive to build on our existing activities, such as sourcing of suppliers with their own environmental statements and policies, seeking advice from environment consultant agencies and acting on this advice by investigating to become more efficient. In particular our company will: Minimise energy consumption by using energy efficient equipment, and maintaining equipment on a regular basis to maintain high levels of efficiency. Recycle wherever appropriate Ensure levels of waste are minimised and waste created is disposed of in an environmentally friendly manner. Use transport in an environmentally friendly manner by ensuring vehicles are fully maintained, routed to reduce mileage and driven carefully to reduce fuel consumption and emission. Look into the use of alternative fuels for use in transport Promote environmental awareness across the company M Clegg

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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 14 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM MANAGING DIRECTOR Allergen Declaration In keeping with other food distributors, we are now being asked by our customers to confirm where applicable that our products do not contain any unknown allergens. We believe that these worries are being raised by the recent EU regulations, which require that products containing allergens eg Soya should be clearly labelled. With regard to absolute assurances, ie to claim that our products are 100% allergen free, this is an extremely complex field, and there is current information available via the current allergen list that the company will constantly monitor. We believe that in general , our entire product that is processed on the premise ie 'cheese' is clearly labelled for allergen content, and we will continue to monitor for allergen content and will label accordingly. Mark Clegg MANAGING DIRECTOR
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 15 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM RESPONSIBILITIES MANAGING DIRECTOR

 Ensure the smooth running of the company Negotiate and purchase nonedibles (ie vehicles, warehouse equipment, fuel etc.) Play an active role in all parts of the business and help to motivate staff and maintain a high level of morale Selection and recruitment of new members of management Overall responsibility for company Health & Safety To provide advice on product availability & pricing To help with the company's growth & profitability Oversee new accounts Oversee the accounts & credit control. To ensure resource made available to maintain GLOBAL FOOD STANDARD AUDIT TEAM (Comprise of members from various departments) Conduct internal audits of the Quality system & working procedures Report to the Managing Director
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 16 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM Relationship between the standard and procedures Issue level one STANDARD/ELEMENT NUMBER PROCEDURE NUMBER 1 HACCP System HACCP Flowcharts 2 QUALITY MANAGEMENT SYSTEMS Inc Procedure/Quality Manual To Include : 2.1 General Requirements Quality Manual 2.2 Policy Statement Quality Policy, Hygiene Policy, Environmental

Policy, Gm statement 2.3 Quality Manual Quality Manual 2.4 Organisational Charts, Responsibility & Management Authority Quality Manual 2.5 Management Commitment 2.6 Customer Focus 2.7 Management Review 2.8 Resource Management Quality Manual 2.9 Internal Audit 2.10 Purchasing, Approved Supplier 2.11 General Documentation Requirements 2.11.1 Documentation Control 2.11.2 Specification 2.11.3 Procedures Procedure Manual (See Records) 2.11.4 Record Keeping All Sections 2.12 Corrective Actions 2.13 Traceability 2.14 Product Recall 2.15 Complaint Handling 3.0 FACTORY ENVIRONMENT 3.1 External Environment Standards 3.1.1 Location 3.1.2 Perimeter & Grounds 3.2 Internal Environment Standards
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level 1 Sheet 17 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM 3.2.1 Layout and Product Flow

3.2.2 Fabrication, Raw Materials, Handling, Prep, Process, Packing, Storage Areas 3.2.2.1 Walls 3.2.2.2 Floors 3.2.2.3 Ceiling & Overheads 3.2.2.4 Windows 3.2.2.5 Doors 3.2.2.6 Lighting 3.2.2.7 Air Conditioning 3.3 Services 3.4 Equipment 3.5 Maintenance 3.6 Staff Facilities 3.7 Physical & Chemical Product Contamination 3.8 House Keeping & Hygiene 3.9 Waste & Waste Disposal 3.10 Pest Control 3.11 Transport 4.0 PRODUCT CONTROL 4.1 Product Design & Development 4.2 Specific Handling Requirements 4.3 Metal, Foreign Body Detection 4.4 Product Packaging 4.5 Product Analysis 4.6 Stock Rotation 4.7 Product Release 4.8 Control of NonConfirming Product 5.0 PROCESS CONTROL 5.1 Control of Operations 5.2 Quantity Control 5.3 Calibration 6.0 PERSONNEL 6.1 Training 6.2 Personal Hygiene, Raw Materials, Handling, Prep, Process, Packing & Storage. 6.3 Medical Screening 6.4 PPE, Handlers, Others, Visitors, etc
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MARK CLEGG & CO Quality Manual GLOBAL STANDARD FOR FOOD SAFETY Issue Level

1 Sheet 18 of 18 Issue Date 06.04.2008 Issued by M Clegg Doc.No. QAM