SGS SA (SGSN) Earnings Call Transcript & Summary

Hello, and welcome to our presentation on BRC Global Standard Packaging Materials Issue 6, the learnings from the first 12 months of this standard going live. My name is Emma Hosking, and I'm the global product manager for SGS, and my colleague, Dorota Zulawnik, who is our Nonfood Compliance Manager. We will be presenting a subject to you with some time at the end for any Q&A. We will be taking you through areas highlighting what has been performed well over the last 12 months, areas that sites have implemented successfully, but we will also be providing an insight to the areas where more attention is required in order to comply successfully with the standard. I hope you enjoy our presentation. So just SGS at a glance, certification body, we're the #1 world leader, over 89,000 employees. Just under 3,000 offices and laboratories, 11 global industries, and we offer local expertise globally. We offer solutions, a longer value chain. Again, not lasting too long on this slide, but covering primary production, transport, logistics and trade, processes, manufacturers, suppliers, retail and foodservice through all forms of testing, welfare and auditing training programs. So just a brief introduction, as I'm sure most of you on this call will be familiar with the standard, so just aligning to the benchmarking requirements of the GFSI. The Global Standard for Packaging Materials Issue 6 was published in August 2019, with the first day of audits taking place to this standard, the first of February 2020. So just going to discuss very, very briefly, the -- some of the new issue changes. So again, just a few of the issues where attention is sort of highlighted. And one key area that aligns with the GFSI benchmarking is the development of a product safety culture. This is to drive and promote quality culture within a business in a sort of a positive direction. Another area that has been given focus is reducing the risk of exposure to fraud. There was a key emphasis on continual improvement within this new issue, and this is by emphasizing effective root cause analysis and a robust internal audit program. There is a new section, the Microbiological Environmental Monitoring Program, which has been introduced and is based on risk. It touches on product authenticity, claims and chain of custody. And another element is the inclusion of traded goods into the core standard. Touching back to the product safety culture, SGS has created a product safety culture assessment realized, which has been customized specifically towards the industry. This new SGS realized program has been specifically designed to address the culture requirements by providing an effective means of measuring culture and actionable intelligence that can be used to implement improvements. Should anyone be interested in this, please contact your local SGS office. So just a couple of more slides before I hand you over to Dorota. So just as a brief sort of introduction and oversight to the data that Dorota will be presenting. SGS has issued over 800 packaging material certificates against the Issue 6 standard in a 12-month period. So this is the data that we've analyzed. And as I say, come up with some sort of trend analysis for you. And this is using all the 3 main order options. So we have the on-site audit, which is the full-on site visit, as it suggests. We have the remote audit, which is, again, as it suggests 100% remote and it's a COVID-19 solution, or we have the relatively new the blended audit, which is up to 50% remote and a minimum of 50% on-site. So just very quickly before I hand over to Dorota. We just have a very simple poll question, which, if you could just take a couple of seconds to answer, that would be very much appreciated. The question being, are you currently certificated to the BRC, Global Standards Packaging Materials Issue 6 with SGS, if you could simply select yes or no and then press submit, that would be great. So without any further ado, I will now hand you over to Dorota. So thank you very much, Dorota.

Thank you, Emma. I would like to share our observations from the audits we conducted with that here. This is the list of 20 closures where nonconformities were raised driven by our audience, starting from the highest number. The vast majority concerns new or change requirements, which, as it turn out, were not successfully implemented in the audited companies. As you can see, #1 is product of authenticity claims and chain of custody, which is a brand-new class; then pest management, which was slightly changed; next, hazard analysis and risk assessment with minor changes; supplier approval and performance monitoring. This is one of the biggest changes in the usual standard, maintenance, especially temporary and personal modifications, which hasn't changed, but this is always a clause causing problems. Housekeeping and clinic. This is the rules how to keep good hygiene standard. It also includes microbiological environmental monitoring program, which is new. Chemical and biological control. Again, with minor changes, however, always causes problems. Traceability requirements concerning this point, extend significantly, covering suppliers feasibility system, which is the most problematic. And so on, I will discuss the points in detail later in the presentation. And now a few words about what is being done well. New requirements have been introduced regarding control of the commandant records that are in electronic form. At present, in most companies, documents are in electronic form, and it does not pose a problem as they are well maintained. We're packaging for food or other hygiene-sensitive product is produced as statement of compliance shall be maintained. Such a document, which in Europe is caused the declaration of compliance, has been used for a long time. So this is not a novelty. It is not a problem. Correct defense preventive actions, new fundamental close. Again, it is not a novelty because it was required earlier, but not as a fundamental close. Management of product withdraws incident and product recalls, implementation of the written guidance and training for relevant stuff regarding the type of even that would constitute an that is required now. The requirement has only been extended with elements, which should be included in the written guidance. Both marginal elements were implemented correctly that we didn't register many nonconformities. Generally, the requirements regarding site standard hasn't changed much. Several clauses have been added, which really don't cause problems for the company. However, the requirement, additional contamination control to evaluate its walkways has often been omitted in implementation and nonconformities with that particular growth happened. So we must remember that any places were evaluated walkways exist. Companies must provide effective methods to prevent contamination of the product due to people moving above production lines. Other new clauses in this point of the standard didn't cause such problems. Among them are site security and documented product defense plan, what is required now a map or plan of the site with traveled routes for personal raw materials and intermediate and finished products as well as routes for the removal of waste. Lubrication points and application methods of any lubrication must be clearly defined. It is very important clause and requirement because properly implemented, it can prevent contamination, which may be hard to detect. I must admit that the this clause also still causes problems. Although generally evaluations are quite positive. As for maintenance, maintenance locks shall be maintained for all off-line testing equipment. In most companies, it was forced before the requirements appeared. So it is not a big problem. As for housekeeping and cleaning, only the requirement was added that housekeeping and cleaning shall be based on risk, what is generally fulfilled. Although housekeeping and cleaning is not new. It always generates a large number of nonconformity during the audit. Areas and services that are not clean enough are found often to say that they do not cause product contamination risk. Additionally, Point 848 requires defining microbiological environmental monitoring program. This requirement generates very big problems. But I will talk about it when I discuss most commonly awarded nonconformities. As for waste and waste disposal, usually in most companies, external areas are cleaned twice does not pose any problem. As for incoming goals, new requirements regarding this clause did not cause problems. Procedure for inspection of loads on arrivals and procedure for the acceptance of raw materials were usually available. As far as the system to validate raw materials and intermediate products prior to the introduction to the process. The same as for storage of materials and intermediate and finished products. And again, the requirements regarding storage of materials and finished products, did not pose problems. Procedures to maintain product safety and quality during firm storage by on risk were available. Companies most often have first in, first out, FIFO, system used for control of stock. In this case, the biggest problem was probably safe pallet storage when they were placed outside. So just as a reminder, pallets shall be properly protected from the outside and inspected for signals of damage or contamination prior to use. Procedure for the dispatch and transport of products were well implemented, restrictions on the use of combined load and requirements for the security of products during transit were identified and preventive actions were usually implemented. Changes in the clause regarding training and competence did not pose problems either and were properly implemented. These changes concerned defining and documenting how new or changed procedures, working methods or practices related to product safety or quality are communicated to relevant personnel. Communication is usually done in the form of trainings and reviewing the effectiveness of training and trainers is required now. And now I would like to talk about the most common problems and nonconformity. A food safety and quality culture has been introduced following the food standard. These particular requirements came into force on the first of February 2021. So the company should take steps to involve all employees to ensure product safety. Starting from the sales department, for example, they must obtain from the customers, the relevant information, which allows to design safe packaging, safe product. The information such as usage, what is to be packed shelf life, freezing, capping, distribution, storage and processing to which packaging can be exposed, such as processing in high-temperature heating or cooling and legal requirements in sales countries. All these information is necessary to select proper raw materials, including inks, gloss, varnishes and design safe packaging which meet legal requirements, what is also very important. Design packaging is sent to the production department, where it is made and where many has that occurred, which can make the packaging unsafe. This is why all employees must be aware of these hazards and work in a way which will eliminate them. Therefore, it is vital to make the employees in all department aware of the influence on the production of safe packaging and to engage them in obeying the work standards, which allow to produce such safe packaging. This can be done step by step. First of all, you have to engage all employees and make them aware of the impact on product -- production of safe packaging then identify trends and weaknesses in your company. For example, based on the information from employees but also from audits, both internal and external hygiene inspections, some signals of non-keeping GMP roles, customer compliance, nonconforming product found during the production, et cetera. Based on the information, you should plan activities to implement the culture within timescale, implementing the activities and reviewing the effectiveness of the activities. But once again, the most important and crucial is to involve all employees to ensure product safety and make them aware of any safety hazards and to instruct them how to work to eliminate these hazards. And consequently produce safe product. It is a requirement, which came into force only 2 months ago, but it seems that it will cost many problems. Another new requirement, which still causes problems, to my surprise, is the correct use of the proper logo. The most frequent nonconformity is the use of incorrect logo or the use of logo in a wrong way. So just to remind you, the most important rules for using the logo as are follows: Companies that achieve certification and have no exclusion from the scope are qualified to use the BRCGS logo on marketing materials, for example; the BRCGS logo may not be used by companies that do not include all produced products within the audit scope; the only exemption is exclusion of traded books. In that case, the logo can be used; generally, the logo shall not be used on products or product's packaging; if the site is not longer certified because of certificates expiry withdrawal or suspension, the logo shall not longer be used. More information is available at BRCGS website. It is very important that all certified companies become familiar with the requirements concerning the use of logo. Some additional requirements have been added regarding the content of the management review, such as the effectiveness of the HARM system and the effectiveness of the product defense and product fraud prevention plans. The impact of any applicable legislation and certification schemes changes. There's an evaluation of any objective that have not been met. The above management elements are often missing from the management review reports. I would like to draw your attention to additional documents published by BRCGS called Position Statements. They often includes additional requirements. These documents can be found on the BRCGS website. So it is very important to check what is published on it. There were several such documents in the past, but now we have only one. That includes all the ones published areas. It is P618. It was published in March 2021. So it is very new. The document contains clarification of food Defense And Food Fraud in the packaging materials standard; disposable food contact packaging versus consumer items; additional requirements for functional packaging claims; and allergen management control. Each certified company must get familiar with this document and implement its requirements. But please note that implementation date are different for different requirements. The last 2 came into force on the first of July 2021. The non conformity that occurs very often is the lack of knowledge about these requirements and therefore, no implementation. As for hazard and risk management, quality-related hazards have been excluded from Point 22 and analysis of these hazards have been moved to Clause 54, Process Control. However, the rules haven't changed, the whole analysis can be one document, and therefore, it does not cause problems. Two additional points, foreseeable misuse by consumer and potential for raw materials fraud have been added and should be considered when identifying hazards. And this caused a lot of problems. In the new version of the standard, verification of compliance with the whole standard is required as well as with any applicable modules. There is only one additional module available now, plastic pilot loss prevention. Generally, the frequency of internal audits shall be based on risk associated with the activity and previous audit performance, but all processes shall be audited at least annually. The scope of internal audit program must include higher our product safety and quality plan, including the activities to implement it, prerequisite programs, product defense and product fraud prevention plans procedures implemented to achieve the standard and modules. The most frequent nonconformities concern the fact that not all processes are audited or there are objections to the frequency of the audit. In addition to internal audit, now separate program of documented inspection is required, but only for sites, manufacturing materials intended to be in contact with fraud or other hygiene sensitive products. Inspections must focus on hygiene inspections mostly and shall be conducted as site visit. The frequency of these inspections shall be based on risk. Most common solution is an inspection once a month, but the frequency may be different. For example, once in 2 or 3 months, but it must be justified by risk assessment. From our observations, it is evident that the companies do not always have a separate program for such inspections, and the frequency is often not based on risk. Supplier approval and performance monitoring is one of the biggest changes in the new issue of the standard. Currently, supplier approval methods should be based on risk and include either one or a combination of criteria. The first is valid certification to the applicable global standard or GFSI recognized standard; and/or the second is supplier audit. And all the last one is the supplier questioner. But this -- my thought must be justified by risk assessment. Suppliers of raw materials for packaging companies seldom have the certificates mentioned earlier. So we are left with either the audit or the questionnaire. It is not always possible to conduct the audit, for example, because of the location of the supplier in the different countries or even in defense continent. So the questioner might be the only choice and that is why it is the most often used option. But we must remember that if questioners were used during the initial approval, they must be a issue at a great intervals based on risk. Most nonconformities are connected with disclose. If the companies approve its suppliers based on a questioner, it is often not justified. Another big challenge is the requirement that the supplier must implement the effective traceability system additionally, it shall be ensured that the suppliers have the system, the verification of the supply disability system causes the biggest problems. If the supplier is GFSI recognized standard certified, traceability is required by the standard, and it is verified during the external audit. If the company is not certified but agrees to the audit, it can be verified on site. However, the questioner is the most popular method, as I mentioned before, yet not the best, because traceability system questions must be additionally included in it, and the answer must be obtained. Where the supplier has been approved based on the questioner instead of certification or audit verification, the supplier traceability system shall be carried out on the first approval and then at least every 3 years. This may be achieved by the traceability test. But please note that the traceability test may be one of the methods used. There is a lot of additional information in the interpretation guidance, I highly recommend you to have a look at the document. The next big issue is supplier approval and performance monitoring, where raw materials are purchased from agent, broker or wholesaler. In this case, this site shall know the identity of the last manufacturer packer unless the agent, broker is certified to the global -- relevant global standard or relevant standard benchmarked by GFSI. And again, because the agent, broker or wholesaler are still uncertified by both standards, additional actions must be taken to obtain information about the last manufacturer or packer. System to minimize the risk of purchasing fraudulent raw materials is required. Different sources of information may be used that allow to identify threats to the supply chain to assess the potential risks of substitution of the raw materials. This can be any trade associations or government sources or any private source centers. Examples of materials that are identified as being at risk. This may be any premium or high-volume materials like [indiscernible], special materials for the creation or virgin materials or biodegrade materials or raw materials with FSC marks or any other materials that can be easily substituted. In case of such materials, appropriate control measures shall be established, like assessment perform at suppliers approval based on history or required certificate of analysis with every delivery or on-site testing, whatever. Whichever control it would be, it must be reviewed anyway. First of all, [indiscernible] assessment for all raw materials or groups of raw materials has to be prepared to assess the potential risk of substitution based on available information, then find the material that are identified as being at risk. Then established proper control measure and review them annually. Because it is a completely new requirement, it often causes problems. There are many nonconformities connected with the fact that not all raw materials were assessed. The key change related to traceability is that where rework or any reworking operation is performed or outsource or subcontracted activities are carried out, traceability shall be maintained. And traceability of test data and samples to production lot shall be maintained. And the generally suppliers for materials shall have an effective treatability system as well, as I told you before. And the verification of the suppliers disability system causes the biggest problem. Taking into account the company internal traceability system, the most common problems are connected with the fact that not all raw materials are included in the system or batch numbers are wrongly recorded. Each time during the audit, the auditor is obliged to perform traceability test on a randomly taken sample. And during that test, system in perfection are often discovered. That's where nonconformities are raised. Problems are also caused by the microbiological environment and monitoring program. The program shall be in place to ensure that clinic operation are effective in minimizing the risk of product contamination. The program shall consider the likelihood of the microorganism survival on packaging materials and the use. The potential products that we may consider as good environment for survival of microorganism are, for example, sausage casings as they are produced wet; or product made of natural materials, such as wood, cork or cotton, but also paper and paper products. So microbiological current biodata monitoring program shall be based on risk. Appropriate control limit shall be defined and program shall be reviewed. The most recurring nonconformities concern the fact that there is no program at all or it is incomplete and can miss some required elements such as sampling protocol or the identification of sample location, frequency of tests, target organisms or test methods or results and valuation. There are a few new requirements for Pest Management that caused a lot of problems. Pest activity throughout different seasons should be analyzed because it can change during the year. In Europe, for example, we can observe increased pest activity in autumn and the decrease in winter. The number and frequency of inspections should be justified to it. And additional measures to prevent birds and [indiscernible] should be implemented and have often been omitted in the implementation. As regards to Clause 54, Process Control, the most frequent nonconformities concerned the lack of control over equipment settings that means that the changes to the equipment settings must be completed by trained and authorized staff and to pass for protected or otherwise restricted if there is a high-risk of such an authorized interference. Another problem is dry clearance procedure. More stringent requirements have been established because during all changeover or changes of the products, the risk of mixing is the highest. That's why raw materials, packaging materials, all documents, work orders and description of the products must be strictly controlled. Before starting a new order, the line must be cleared and this fact should be recorded. There are often problems because the line is not fully cleared and some materials of documents remain and they can cause mistakes or confusion of artwork or products. Another big challenge is a new requirement connected with the validation of test methods used for product inspection. We must remember that the test methods used by the site in both online and off-line testing shall be validated to ensure their sensitivity, reproducibility and range. It especially concerns company methods, which were defined internally based on the company experience or are required by the customer but not based on commonly approved international standards. In such cases, validation of metals must be performed and recorded. Additionally, where testing shows out of specification results, a documented procedure for investigating these results shall be established and followed to determine whether the cost is not conforming product or testing failure. Another problem is automated inspection equipment. For example, vision systems installed in the printing machines. It is necessary to ensure that it is collectively set up and capable of selecting or rejecting the packaging, when it is out of specification. As a minimum testing of the equipment shall be completed at the start of the production arm, at the end of the production arm and during production, if necessary. Procedure for inspection of such equipment are required as well as procedure in the event of failure in the equipment. Generally, companies which have such equipment perform tests, but do not have clearly defined procedures, which may result in raising nonconformities during the audit. The last month lottery's clause in the standard concerned personnel. In Issue 6, there weren't many changes. However, auditors identify many nonconformities connected mainly with the lack of required records from trainings or insufficient level of hygiene, for example, wearing jewelry, carrying personal items in production area, bringing in food or prohibited drinks and inappropriate clothing. I must admit that such nonconformities happened often and are difficult to eliminate because they are part of the personal behavior. The implementation of safety culture can help a lot. And, of course, promotion of safe behavior among all employees. Clause 7 concerning traded products is not mandatory. It is still an entry requirement, but not additional voluntary model any longer. If the company conducts activity in traded products, they have 2 options: To apply requirements included in this Clause and certify the whole activity; or not cover traded products within certification, but then it must be recorded as an exclusion from this Clause. As you probably remember in this case, the company can still use BRCGS logo. That's all from me. Thank you very much for your attention. If you have any questions, you can enter them now into Q&A box.

Lovely. Thank you very much, Dorota. That was a great insight into the impact the changes of Issue 6 over the last 12 months. With some really interesting data. So just before we go into the Q&A session, just a quick reminder for everybody. Please, could you look out for the request and answer our post-event survey, that will be very much appreciated.

So now going into the Q&A, I can see there are some very interesting questions coming in. If you have any, obviously, please feel free to submit them. We will do our best to answer all of them. And any that we don't get to, we will certainly respond to after the event. If I just have a look. So the first one, regarding supplier approval criteria, what certificates are recognized by the GFSI?

Okay. Yes. So currently, as for packaging, we have a choice of BRCGS or FFSC 22,000 or IFRS or SQF, so this for. And of course, more information you can find on the GFSI website. So please have a look at the website, there are quite interesting information on it.

Okay. Fantastic. Another one, how can we verify the suppliers traceability system?

Oh yes. The traceability system, it is a challenge, I have to say, especially where the supplier has been approved based on questioner instead of certification or an audit. So we can do it based on traceability test. But in fact, the test is not the only method. As I told you during the presentation, there is a really very good interpretation guidance. And you can find there quite, again, good information. And you can find there that there are other methods can be used for traceability test system for suppliers. One of them is work examples from the raw material supplier, which clearly explained the process, the traceability process. The other is a detailed description of the traceability system provided by the material supplier. And I think the last one, so this detailed description of the traceability system is the easier -- easiest to achieve. So probably, again, it will be the most popular method. So again, I highly recommend you to have a look at the interpretation guidelines, you can find the information about that.

Okay, fantastic. Thank you very much. I hope that helped answer that question. Next goes, can you please differentiate between the subcontractor and outsourcing?

Yes. Subcontractor and outsource processes. So subcontracted activities, it is a process that is carried out at another side on behalf of the certificated side. But the material cost of site to be processed and stay off-site. However, the outsourced process, this is a step in the process, which is completed somewhere also in the other company. And where the intermediate production process or step in the manufacture of the product, is carried out of another company and to return to the original side. So this is the difference. So subcontracted activities that -- well, this is one of the materials go off-site and stay off-site, outsourced processes, it's go off-site and return to the original site to be completed, okay?

Yes, no, perfect. That does sometimes cause quite a lot of confusion. Isn't it?

Yes. Yes. It is. Yes, absolutely, I agree.

There's a question here that I can take on to do is the effective implementation of the quality and safety culture. So just on that one, there's lots of things that can be done to implement a product safety culture. And so many ideas, including team events, social gatherings, involving the team in writing new procedures, idea gathering, team meetings, regular consultations, keeping the team regardless of the sort of the departments or the areas that they work and keeping them updated and involved in trend analysis so they can actively participate with solutions. Even friendly competitiveness between sites or departments can have a very positive impact on team spirit motivation. And it also goes a really long way to positive product safety culture. It is important to achieve the standard to have a documented plan in place, which is reviewed on a regular basis, what works well and what doesn't work well with time lines and any sort of future improvements. Just as a note, I briefly touched on it earlier, but SGS have a product SGS realized, which is a new culture safety module, this can take place without auditor interaction and is separate during the audit. So it helps you assess the culture in your business and can be measured year-on-year. So this brochure is actually now available to download from the SGS website. So hopefully, that has answered that question. Another one for you Dorota, if a supplier is certified to a third-party ISO standard, and we approve using a questionnaire, does traceability still need to be confirmed at first approval?

Yes, okay. So yes, the traceability systems still must be confirmed of the first approval. However, it can be quite easy, much more easier than if that the company is not certified at all. So in fact, if there is a certificate, even if this is ISO 9000 certificate, it will be much easier. So probably we can ask the supplier just to describe the traceability system that is on site. Yes, that's okay.

Okay, fantastic. And hopefully, a fairly straightforward one. Can you please give examples of traded products?

Traded products.

So I mean I can jump in. Not necessarily specific examples of a traded product. Sorry to interrupt you, Dorota. Did you want -- yes, I can jump in, not necessarily specific example of a traded product, but a traded product is a product that you don't manufacture yourselves on site. So you buy the products in. It supplements...

Yes. So it can be any different -- any products, but it must be packaging. Yes. So any kind of packaging that is bought by the company, sell by the company as well. So it can be everything, but it must be packaging. Yes.

Perfect. Yes. No, perfect. Packaging is -- no, I'm not sure if I understand correctly, packaging supply assessments and audit guideline is probably something we just have to look into a little bit on that one. It's asking if we can share. So why has the hazard and risk management being split into 2 different points?

Okay. So yes, in this new version of the standard, we have, in fact, risk assessment in 2 different places, 2 different clauses. One is in point to 2. And in this particular clause, we evaluate results related to product safety and legality. And in fact, we should also identify control measures that should be implemented. It can be also a critical control points, including in the control measures. However, in the Point 54, yes, Process Control, we have to evaluate hazards related to quality only. And control measures should be based on GMP and prerequisite programs. So then the difference between the product safety and legality issues and versus quality issues, let's say. So it is to help the companies to understand the difference between this product, safety and legality issues versus the quality issues. So I think...

Perfect.

Okay. Thank you.

Very comprehensive. So for those of us not yet certificated to the BRC Global standards, how can we access the guidance documents.

It is in fact free, free guidance, you can find it on the BRCGS website. So if you open the BRCGS website, you can choose the packaging material standard. And there are probably some information in some -- for sure there is a checklist; for sure, there are additional position statements. So it's quite many additional documents available there.

Fantastic. Yes. Just a confirmation actually on one of your last answers. So just to confirm, products that are not packaging materials, but stores in our warehouse for distribution elsewhere do not count as traded goods?

No, no. If this is -- if the company trade, some products, what is not packaging materials, should not -- it should not be mentioned in the scope. So this is constantly different. So only products that are packaging materials should be taken into account when implementing and certified BRCGS packaging material standard.

Yes, fantastic. And just to add to that one, it may be that another BRCGS standard will cover those products.

Yes, sure.

Yes. No, no, it's fine. So it's not covered by packaging, but should it be something that you wanted to be covered by BRCGS? Then if you sort of contacted SGS, we could kind of give you -- we could give you the advice as to which standard is the most appropriate. So another question. If we make a product for a customer and use their packaging with their brand name, what are the requirements or controls required for that packaging?

Under the brand name, yes?

Yes.

Okay. So in...

If you would like, we can come back to it. But if...

Yes, yes. We can come back maybe in detail later. But generally, if there is a brand name on the packaging so there is a requirement to control this branch and have an agreement with companies who is owner of this brand name. And in the agreement, there should be some information how to control the the brand name. So this is quite important. Especially during, of course, printing process, and if we have some products printed -- already printed and where our waste, for example, because of some problems, quality problems, what's to do with this particular waste with branded name on it? So this is quite important. But of course, I can put maybe more information, maybe in the e-mail and send.

Okay. Fantastic. So another question, history on fraud in packaging. What other public sources are there, which are similar to the [indiscernible] sort of guideline? Are there any sort of other well-known sources where we can get this information from?

Okay. So again, I would like to ask you to have a look at the position statement. As I told you during the presentation, there is 1 position statement, now including all the information, this is position statement P618, and you can find the really very helpful information about food defense and food fraud. So please have a look at the document. The is quite many sources of information about the -- about that. Usually, it is some government information different in different countries. So we have to again have a look at the -- some government pages, websites and try to find some information, but please have a look at the position statement.

Okay. Thank you.

Yes, okay.

And do customers still have to audit their suppliers, that's BRCGS certified?

Do customers still have to audit suppliers? No, in fact, it is one of the criteria that can be applied. It is not their only one. So you can evaluate -- let's say, evaluate your supplier based on certification, but based on certificate or based on the audit or based on the questionnaire. So we have, in fact, 3 methods to apply. So the audit is not the only one method. So it is not necessary to do always the audits.

Perfect. Thank you very much. BRCGS certification is specific to a particular manufacturing site, whether there is a multi cycle or detection available wherein if the scope is the same for a company with multiple locations. So can a BRCGS audit be done on a sample basis for certification purposes? That's quite a lengthy one. So it's about multi sites. And if we can sample more locations?

In fact, sampling of the location, it's not possible in BRC. So if we want to certify a multisite, so every site must be visited. But it must be very clearly stated in the report and in the scope, what exactly processes are run in each location. So it is not like in quality standards. And unfortunately, not, we have to be sure that every -- in every location and in every site, the processes are correct and the products are safe for the consumer for the next user.

Yes. Yes, 100%. And the rules for multi sites can be the specific rules in the details of multisites decides can be seen in the standards but...

Yes.

Yes. No, that's fantastic. And I think we've probably got time for one more question. So if the agent and broker are online traders and doesn't have a certificate that the manufacturing company does is sufficient maybe?

If the agent and broker are online traders. So in fact, we have to know that the requirement is that we have to know the last manufacturer or packer, if the raw materials are purchased from agent or broker. So in fact, it is important for us to know -- just to know the name of the last manufacturer or packer. Yes. This is what the standard requires.

Okay. Fantastic. A couple more questions, but I think we're coming to the end of the hour. So okay. What we'll do -- any questions that we haven't had an opportunity to answer, we will certainly get back to everybody. So yes, thank you very much, Dorota. And drawing this webinar to an end. Many thanks to you all for listening and for the questions that have been submitted. And as I say, if we haven't managed to answer, then we'll get back to you after the event is closed. I hope this event and webinar has given you some valuable information and learnings over the last 12 months, effectively the first year for packaging Issue 6. And yes, thank you again for listening.

Thank you very much. Once again, thank you very much.