Annex

Organic System Plan

OSP

for

Fraud Prevention Plan (FPP)

Certification according to …

| NOP |

Organic Fraud Prevention Plan Overview

In addition to the information in your Organic System Plan, the National Organic Program (NOP) now requires all operations to develop an Organic Fraud Prevention Plan (FPP). This plan is substantial for protecting supply chains around the world from organic fraud and minimizing related risks. If effective, a FPP can detect and prevent fraud already at an early stage and therefore enhancing the overall integrity of organic supply chains.

Tailoring Your Fraud Prevention Plan

Your Fraud Prevention Plan should be tailored to match your operation's specific practices. It must

outline the measures you take to ensure that only compliant suppliers and products are used.

Examples include but are not limited to:

Producers dealing with both organic and non-organic crops:

These operations need not only a plan to prevent non-organic items from being misrepresented as organic but also to prevent them from commingling.

Processors handling a wide range of organic ingredients:

These operations must address fraud in complex supply chains in their plan.

Confirming the Organic Status

Your plan has to verify the organic status of suppliers and products, ensuring traceability back

through the supply chain. As you set up your FPP, take into account your methods for sourcing and

distributing organic products. This might include transport of products as well. Reference pertinent parts of your Organic System Plan as needed.

Instructions for Developing Your Fraud Prevention Plan

Your Fraud Prevention Plan has to detail practices that eliminate vulnerabilities and minimize risk.

By completing this module and thoroughly considering the risks, vulnerabilities, and actions taken

by your operation, you can ensure the reliability of your supply chains and protect the integrity of

your organic products.

Examples of Vulnerability Points

For Producers/Farms:

Organic seed, feed, and bedding sources: Ensure that your raw agricultural feed supplier is certified for that feed.

For Handlers (including brokers and traders):

Supply chain verification: Verify the supply chain for each ingredient up until the last certified handler. This may include transporters and exempt operations. Some previously exempt operations may now require certification. Encourage your suppliers to get certified for full-chain traceability and reduced risk.

For Producer/Handlers:

Fraud prevention strategies: Outline strategies for preventing fraud in both production and handling.

By thoroughly considering these points, you can develop a comprehensive and effective FPP that supports the integrity and trustworthiness of your organic operations.

If you already have described elements of the fraud prevention plan as indicated below in your quality manual, please name and attach the relevant internal procedure and highlight the pertinent section.

Organic Fraud Prevention Plan

Team Members Responsible

Name	Role
• Responsibilities: Approving, implementing, training, and monitoring the Organic Fraud Prevention Plan.

Existing Plan Status

Does your operation have an existing Organic Fraud Prevention Plan?
No; Complete this module	Yes; Attached. Skip the remainder of this module if your existing Organic Fraud Prevention Plan includes all aspects outlined and fill out the following table. If any aspects are missing in your internal procedures, complete those sections in the Kiwa BCS template. Be sure to include missing sections in your internal procedure.

Elements of the Fraud Prevention Plan	Reference in your internal procedure
Team Members Responsible
Supply Chain Map
Supplier Identification
Critical Control Points Identification
Vulnerability Assessment – Assessment process
Vulnerability Assessment Table
Monitoring practices

Supply Chain Map “Flowchart” & Critical Control Points

Supply Chain Map:

Provide a flow chart illustrating all received/incoming organic ingredients and/or products in your supply chain. This should include:

Ingredient groups (such as organic seed)

Certification status of each entity involved

Location of suppliers

Transportation events

Storage events

All other handling activities

Highlight Critical Control Points

Suply chain map attached	Annex No.

Supplier Identification:

Describe how and where you identify suppliers of organic products in your operations recordkeeping system.
• Example: Suppliers are tracked through a supplier list.

Critical Control Points Identification:

Identify and describe critical control points in your supply chain where organic fraud or loss of organic status are most likely to occur. Please be sure to include these points in the flow chart attached under point 1 of this chapter.

Vulnerability Assessment

Assessment Process:

Describe your process for performing a vulnerability assessment, including actions taken and factors considered.
Factors may include: Supplier's certification status, Location (imported or domestic), Economic aspects (ingredient scarcity or high demand), Agronomic factors (vulnerability to pests or diseases), Supply chain details (handling of organic and conventional products, Nature of your relationship with the supplier

Vulnerability Assessment Table

Critical Control Point	Mitigation or Prevention Strategies	Monitoring Practices

Training and Reporting

Describe how employees will be trained on the Organic Fraud Prevention Plan and any updates that are made.

Describe the process that will be taken for reporting suspected organic fraud to both Kiwa BCS and the National Organic Program (NOP).

Monitoring

Monitoring Practices:

Describe the monitoring practices and verification tools used to assess the effectiveness of the Organic Fraud Prevention Plan, including:
Frequency of plan reviews and updates:
Methods for determining the adequacy and effectiveness of the plan in mitigating and preventing organic fraud
Factors may include: Supplier's certification status, Location (imported or domestic), Economic aspects (ingredient scarcity or high demand), Agronomic factors (vulnerability to pests or diseases), Supply chain details (handling of organic and conventional products, Nature of your relationship with the supplier

Place: Date: Signature of the farm’s/company’s representative: Name (in block letters) of the farm’s/ company’s representative: