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AUDITING INSTRUCTIONS RELATED TO

THE COCOA POLICY May 2020 (last update 5th of June 2020)

2

INTRODUCTION

As part of the Cocoa Policy, Rainforest Alliance is publishing specific auditing instructions for the measures in the Cocoa Policy. The

auditing instructions in this document concern the audits against the UTZ Code of Conduct and Rainforest Alliance Sustainable

Agriculture Network, in Ivory Coast, Ghana, Nigeria and Cameroon. Specific auditing instructions on the Chain of Custody measures in

the Cocoa Policy document will be published separately.

In addition to those auditing instructions, Rainforest Alliance has also published instructions and clarifications for certified groups on

implementing the Cocoa Policy in Ivory Coast and Ghana as well as in Cameroon and Nigeria.

In case of a partial remote audit (see Audit Exception Policy for COVID-19), specific instructions for the remote part of the audit have

been indicated where applicable in the table below.

For the column on how to close the non-conformity, in addition to what is indicated there, the group must analyze and tackle the root

cause of the non-conformity. In addition to what it is specified below, the CB can conduct a follow up audit if deemed necessary.

PRODUCER CERTIFICATION CRITERIA IVORY COAST AND GHANA

Policy measure WHAT AND HOW TO CHECK?

IF NOT COMPLIANT,

RAISE NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY

UTZ RA

1.1. Certification – Eligibility rules

1.1 a

no dual certification

RA/UTZ

This will be checked by RA during audit application

of the group.

N/A N/A

1.1 b

Pause on new groups


of the group.

N/A N/A

1.1 c

No change of utz

certification cycle


of the group.

N/A N/A

1.1 d

government

registration of certified

groups

Groups must be legally registered to trade cocoa. If

groups are not able to show legal registration, there

are not compliant with the law - the CB must take a

non-certification decision.

https://www.rainforest-alliance.org/business/resource-item/policy-for-farm-and-chain-of-custody-certification-in-cocoa/

https://www.rainforest-alliance.org/business/resource-item/instructions-and-clarifications-for-certified-groups-in-ghana-and-cote-divoire-on-implementing-the-cocoa-policy/?utm_campaign=cy20estwd&utm_source=20vvaestwd&utm_medium=email&s_src=ADN20VX&s_subsrc=20vvaestwd&autologin=true

https://www.rainforest-alliance.org/business/resource-item/instructions-and-clarifications-for-certified-groups-in-cameroon-and-nigeria-implementing-the-cocoa-policy/

https://www.rainforest-alliance.org/business/resource-item/audit-exception-policy-for-covid-19/

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IF NOT COMPLIANT,


UTZ RA

1.1 e

No membership of

multiple groups

The CB must verify this with the Data Validator Tool. N/A N/A If the certification body finds that a farmer is

part of several certified groups, this farmer as

well as his or her estimated volume must be

removed from all certified groups. If such a

case is found after the certificate is delivered,

the Rainforest Alliance reserves the right to

require the certificate holder to do so.

1.1 f

Waiting period for

recertification

This will be checked by RA during the audit

application of the group.

N/A N/A

1.1 g

use of RA/UTZ logo for

groups not certified

Not applicable – this concerns groups which are not

part of the certification program anymore.

N/A N/A

1.2. Growth in Group Membership

1.2 a

Limit in group

membership growth

The auditor checks the group registry and compares

the total number of group members with the one

from the previous certification year (the CB must

verify this with the Data Validator Tool). If the growth

is more than 10%, a non-conformity is raised.

If the group requests a group extension after the

certificate is issued, the auditor verifies that the total

growth is not more than 10% in comparison to the

previous certification year. If it is more than 10%, the

group extension is not issued.

G.A.8

1.13

The group must remove group members to be

compliant with the 10% maximum growth in

group membership.

1.2 b

Minimum compliance

standard for new

members

All new group members must be at the same

compliance level than the existing group members.

If auditor finds that new group members are not at

the same compliance level than existing group

G.A.11 1.14 Group must re-evaluate the compliance of all

new group members against the compliance

level of the existing ones and update their risk

assessment and group management plan

accordingly (G.A.16 and G.A.17 / 1.7.

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IF NOT COMPLIANT,


UTZ RA

members, the auditor must raise an NC on internal

inspections (G.A.11 / 1.14)

1.3 Group Member Registry

1.3 a

inclusion of

government issued ID

Prior the audit, the CB must check if the types of

government issued ID provided in the Group

Member Registry are part of the approved

government issued IDs mentioned in the document

“Instructions and Clarifications for certified groups in

Ghana and Côte d’Ivoire on Implementing the

Cocoa Policy”.

The CB must also check if the government issued ID

have been recorded in the format instructed by the

same document.

The CB must check if there are no duplicates of

government issued IDs within the group.

During the audit, the audit team must ask the

auditee to show the government issued ID, compare

with the information provided in the registry and

check for any discrepancy.

G.A.8 1.13 If duplicates are found in the Government

Issued IDs provided by the group, they must be

corrected.

If any discrepancy is found between the

Government Issued IDs indicated in the registry

and the ones checked during the interview,

the discrepancy must be corrected.

The CB must ask the group to send evidence

of Government Issued IDs for a sample of

producers in the group not originally included

in the audit sample.

1.4 Geolocation Data

1.4 a

100% GPS coverage for

group members

Quality of the geodata:

The CB must assess the quality of the geodata

provided by the member as part of the preparation

for the audit. This includes:

- Identifying unusual patterns for the location of the

farms/sites (e.g. perfectly squared grid in which all

points are equidistant from one another)

- Identifying geodata location in unusual locations

(e.g. in palm oil fields instead of the cocoa fields)

during the audit preparation

G.A.3

G.A.8

G.D.111

1.6

1.13

2.3

The group must provide a location point for

each of the group members if there were not

all provided before the audit. Each location

point which is found not credible or not

collected according to RA instructions must

be collected again by the group and

corrected in the registry.

Location points provided after the audit must

be checked by the CB regarding the format

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IF NOT COMPLIANT,


UTZ RA

- Identifying potential repetition of farms/farm

units/sites within this Certificate Holder (CH) and

between this CH and other UTZ or RA-certified CH(s).

- Determining whether geodata was taken following

the guidelines provided by RA.

The audit team must verify at least the following

during the onsite audit in order to evaluate the

quality of the geodata provided by the CH:

- Within the sample, the audit team must evaluate

whether the GPS location points/polygon provided

coincide with the actual farm location visited.

- The credibility of the location point/polygon

collected by the CH by comparing it with the one

collected by the auditor.

Deforestation:

The audit team must include a representative

sample of farms identified as risky with respect to

deforestation as per indicated in the RA risk maps.

During the visit, the audit team must verify sign of

deforestation. The Annex 1 below is providing

further guidelines on how to audit deforestation.

The audit team must verify that the activities of the

management plan have been correctly

implemented as defined in the management plan

timelines, including those of previous years if group

had members in buffer zones.

Based on the findings of the audit, a non-

conformity can also be raised on G.D.109, G.D.110 /

2.1, 2.2 .

and compliance with G.D.109, G.D.110,

G.D.111 / 1.6, 2.3. An onsite verification must

be done if the CB deems that it is necessary.

If during the audit, more than 10% of the GPS

point of the audited producers are not

credible, the group must collect again the

location points for all members of the group.

If deforestation is confirmed, the group must:

- exclude those group members from the

group as well as their respective volume from

the volume estimation.

- commit to not buy products from those

members.

- communicate to those group members their

exclusion from the group

- Implement awareness raising measures or

training

- Plan to collect polygons of farms units of all

producers of medium and high risk of

deforestation

For UTZ groups, if more than 5% of farms of the

audit sample have been found to have

deforested, the group cannot be certified

and the certifier must take a non-certification

decision.

For RA groups, please refer to the critical

criteria process.

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IF NOT COMPLIANT,


UTZ RA

As part of the license request process the CB must

provide:

1. Identification of all the group members’

farms included in the audit sample. The CB

must clearly record in the Group Member

Registry (column AR) the reason for choosing

a specific farm in the audit sample (i.e.

Deforestation risk, Risk of encroachment in

Protected Areas, Others).

2. To indicate the group members’ farms

included in the sample and visited during the

audit, the CB must indicate their location

points in columns AP and AQ of the Group

Member Registry.

3. Validate the Group Member Registry in the

tool provided by RA before submitting the

license in GIP or before completing the

certificate in Salesforce

1.4 b

non-certification of

groups in protected

areas

The CB must map the location points provided by

the member against the official Protected Areas

maps provided by RA and verify if the location points

are not located inside the Protected Areas unless

allowed by applicable law. In Ivory Coast,

applicable law refers to enclaves approved by

MINEF and in Ghana, to admitted farms with

polygons provided by the Forestry Commission of

Ghana.

G.A.3

G.D.111

1.6

2.3

If groups members are found within Protected

Areas (except enclaves or admitted farms),

the group must:

- exclude those group members from the

group as well as their respective volume from

the volume estimation.

- commit not to buy products from those

members.



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IF NOT COMPLIANT,


UTZ RA

The audit team must include a representative

sample of farm identified as risky with respect to

encroachment in Protected Areas in the RA risk

maps.

In case of admitted farms in Ghana, the CB must

map the polygon of the admitted farm and verify its

credibility on site.

The audit team must get in contact with the

excluded group members to verify that they

have been removed from the group.

1.5 Yield Estimates

1.5 a

GPS mapping required

to determine certified

Area

If group is in compliance year 3 or more, the group

has determined the certified area with a GPS tool.

Remote audit: the auditor checks the data in the

group registry – round numbers are a sign that the

area was not determined with a GPS tool. Based on

the contact information in the registry, the auditor

contacts a few producers and confirms whether or

not the certified area of their farm has been

determined with the use of a GPS tool by going over

the cocoa farm boundaries. If not, a non-conformity

is raised.

During the on-site audit, the auditor must confirm

with audited producers whether or not the certified

area of their farm has been determined with a GPS

tool. If not, a non-conformity is raised.

To verify the reliability of the information in the group

registry, the auditor checks the certified area by

going over the perimeter of the area with a GPS tool

for at least 15% of the audited producers (rounded

up to the next whole number and with a minimum of

5, including a large farm if existent in the group). If on

G.A.2 N/A To close this non-conformity, the group must

determine with a GPS tool the certified area

of all the certified producers in order to have

a credible certified area.

The group must also put in place a system

whereby the group collects the data on the

certified area with a GPS tool for any new

producers for their approval into the group.

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IF NOT COMPLIANT,


UTZ RA

average, a difference in area of more than 10% is

found, a non-conformity is raised.

1.6 Traceability

1.6 a

annual calibration of

weight/volume

equipment

A system is in place to ensure the calibration of

weight stations, records and calibration certificates

(in case applicable) are in place.

Remote audit: the auditor asks the IMS about the

existing weighing stations officially used to determine

the weight of the certified product and asks for the

group to send the proof of the latest calibration of

the weighing equipment. If not available, a non-

conformity is raised.

For the on-site audit, the auditor must:

• Ask the IMS about the existing weighing stations

officially used to determine the weight of the

certified product and for proof of their latest

calibration

• Interview responsible staff for weighing – staff

should demonstrate how the process of weighing

products and recording information takes place

• If applicable, ask the staff in charge of

calibrating to show how they do it

• If possible, the auditor can weigh him/herself to

detect important inaccuracy of calibration.

If group cannot show proof of the latest calibration,

if staff cannot properly demonstrate the process of

weighing or recording, or if important inaccuracies

are found, a non-conformity is raised.

G.A.29 1.2 The group must calibrate the weighing

equipment and send the documented

evidence to the CB.

If any important inaccuracy in weight is found

by the auditor (10% or more), the group also

sets up a regular monitoring system to ensure

internally that the weighing equipment is

calibrated (to be included in their procedures

or traceability manual).

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UTZ RA

1.6 b

product flow map

required

The explanations / instructions below explain not

only the product flow map, but other traceability

aspects as well:

The group has systems and procedures in place to

ensure that certified products are segregated and

traceable.

There is documented proof that products that the

group sells as certified can be traced back to the

certified farm(s) where these were produced

The map of the product flow is complete, and all

intermediaries are mentioned.

Remote audit: the auditor verifies the product flow

map shared by the group and compares it to the

information available in the registry. If information is

incomplete or incorrect, a non-conformity is raised.

Based on the contact information in the registry, the

auditor contacts a sample of producers (at least 10)

to ask them about their previous year delivery to the

group and estimated production, and compares it

with the information in the registry. If inconsistencies

are found, a non-conformity is raised.


• Check that the map of the product flow

exists and corresponds to reality

• Verify that the system and procedures in place

ensure visual and physical segregation of

certified products

• Check purchase and sales documents linked to

physical deliveries of the group

management, from the certified, multi-certified

G.A.22 1.2 / 1.3 Depending on the inconsistencies found by the

auditor, the group must:

• provide the missing documentation,

and/or

• train the relevant intermediaries and

IMS staff, and/or

• amend the relevant procedure and

product flow map, and

• set up a regular monitoring system to

ensure that traceability is respected

throughout the year

• formally agree that the CB could do a

remote verification at a later stage

during the harvest period.

If inconsistencies cannot be justified by the

group and the checks on recent purchases by

the IMS show that the purchasing system is not

guaranteeing traceability, the certifier must

take a non-certification decision.

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IF NOT COMPLIANT,


UTZ RA

and non-certified products + Overall calculation

of input and output at group level

• Interview the IMS on their knowledge and

capacity to implement correctly their traceability

procedure

• Interview the producers on their production,

sales, estimated production and compare it with

the information available at the IMS/PC level (see

below under 1.6 d)

• Trace back up or down the traceability flow to

see if uninterrupted or lost at any point, starting

either from a recent transaction in the

traceability system, or starting from audited

producers up until the IMS (the auditor must

check on the most recent sales done by the

producers).

If there is missing information, lack of understanding

or poor implementation of traceability procedures,

inconsistencies in volumes, or if traceability is lost, a

non-conformity is raised.

If any of those inconsistencies cannot be justified by

the group, the certifier must take a non-certification

decision.

1.6 c

Intermediaries maintain

the traceability of

products purchased

from the group

members and sold to

the Group

There is documented proof that products that the

group sells as certified can be traced back to the

certified farm(s) where these were produced

The map of the product flow is complete, and all

intermediaries are mentioned.

Intermediaries keep certified products segregated

and traceable.

G.A.24 1.2 If any of those inconsistencies cannot be

justified by the group, the certifier must take a

non-certification decision.

Depending on the inconsistencies found by the

auditor, the group must:

• provide the missing documentation,

and/or

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IF NOT COMPLIANT,


UTZ RA

Remote audit: the auditor asks the IMS for their

traceability procedure and verifies that it is coherent.

The auditor interviews by phone a sample of

intermediaries to verify that:

• Intermediaries have been trained or

instructed by the IMS,

• are knowledgeable on the traceability

procedure and

• follow the system or procedure to

appropriately record traceability

information.

If inconsistencies are found or traceability procedure

not followed, a non-conformity is raised.

For the on-site audit, in addition to what can be

verified under ‘Remote audit’, the auditor must:

• Calculate on a sample basis the input and

output for intermediaries indicated on the map

of the product flow (balance exercise).

• Interview a sample of intermediaries (at minimum

the square root of the total number of

intermediaries) mentioned in the map of the

product flow: is the map complete? are they

aware of the traceability requirements? do they

have purchase and sales documents linked to

physical deliveries?

If there is missing documentation or missing

information, lack of understanding or poor

implementation of traceability procedures,

inconsistencies in volumes, or if traceability is lost, a

non-conformity is raised.

• train the relevant intermediaries and

IMS staff, and/or

• amend the relevant procedure and

product flow map, and


ensure that traceability is respected

throughout the year

• formally agree that the CB could do a

remote verification at a later stage

during the harvest period.

If inconsistencies cannot be justified by the

group and the checks on recent purchases by

the IMS show that the purchasing system is not

guaranteeing traceability, the certifier must

take a non-certification decision.

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IF NOT COMPLIANT,


UTZ RA

If any of those inconsistencies cannot be justified by

the group, the certifier must take a non-certification

decision.

1.6 d

Group members keep

proofs of payment

(receipts or passbooks)

for each sale

The group management has a procedure to ensure

that group members receive a proof of payment

(receipt or passbook) for each delivery. Group

members have their sales receipts/passbooks.

Remote audit: the auditor asks the IMS for their

traceability procedure and verifies that it is coherent.

the auditor interviews by phone a sample of IMS staff

to verify that:

• relevant staff has been trained or instructed

by the IMS,

• are knowledgeable on the traceability

procedure and

• follow the system or procedure to

appropriately record traceability

information.

If inconsistencies are found or traceability procedure

not followed, a non-conformity is raised.



• Verify the receipt/passbook kept by the audited

producers

If 50% or more of the audited producers do

not have all their receipts/passbooks, a non-

conformity is raised against G.A.24 and 1.3.

G.A.24 1.3 If there is no inconsistency after auditors have

checked the volumes and dates but receipts

are missing at producer level, in order to close

the non-conformity, the group must:

• report back to the producers on its total

volume sold (no need for all

receipts/passbooks to be photocopied

and redistributed to the producers),

• continue to sensitize producers about the

importance of keeping

receipts/passbooks, and


ensure internally that producers keep

their receipts/passbooks (to be included

in their procedures or traceability

manual).

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UTZ RA

In addition, the auditor must also always cross-check

the information by:

• Verifying a sample of transaction from member

and compare with data recorded at the IMS or

“section” / PC level

• Interviewing the members about their

production capacity, and the sales and record

keeping system

• Assessing if there are sales made in the name of

family members or neighboring farms.

• Observing if volumes of sales is plausible with the

data recorded for harvesting, estimates of

production and storage capacity of the

producer.

If, for a minimum of 50% of the audited producers,

there is a difference of 10% or more between the

sum of the volumes reported as sold by these

audited producers and the sum of the volumes

indicated in the purchase register for these

producers

OR

If there are very large differences between the

producers' delivery declarations and the purchase

register (even if it is for less than 50% of the producers

audited)

In both cases, the auditor must raise a non-

conformity on G.A.22 and G.A.24 / 1.2 and

1.3 as traceability is not respected and the

cocoa is most likely from a non-certified

source. If there are strong inconsistencies

which cannot be justified by the group, the

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UTZ RA

certifier must take a non-certification

decision.

1.6 e

Transactions uploaded

in traceability system

within one week

The group has a system in place to report the

information of sales transaction as required in the

Cocoa Policy.

Remote audit: the auditor checks the transactions

in GIP / MarketPlace or the transaction list sent by

the group, selects a sample of them and asks for

the corresponding bill of lading / connaissement. If

any inconsistencies are found, a non-conformity is

raised.



• check the evidence of reporting of sales and

compares with the information of sales recorded

in the IMS system

• select a sample of transaction from the

traceability platform and compare it with the

commercial document at the IMS level (and

vice-versa) to confirm their existence and that

they have indeed been reported within the

correct timeframe

• interview the responsible person at the group to

describe the processes in place to registering

purchases sales and stocks and how volumes are

registered in the system and reported

If any inconsistencies are found between the

information on the traceability platform, the

commercial documents and the interview, a non-

G.A.25 1.2 The group must upload all deliveries, and

adapt its procedure and set up a regular

monitoring system to ensure internally that

transactions are submitted on time with the

correct documentation.

Depending on the inconsistencies found by

the auditor, a non-conformity may be raised

against other control points / criteria, which

the group will have to close as well.

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IF NOT COMPLIANT,


UTZ RA

conformity is raised. Based on the inconsistencies

found, a non-conformity can also be raised on

G.A.22 and G.A.24 / 1.3.

1.6 f

Volumes sold as

conventional or under

other labels removed

from traceability

platform in one week

The group has a system in place to remove the

necessary volumes from the traceability platform on

time.

Remote audit: no specific instruction


• Select a sample of bills of lading (or

connaissements in Ivory Coast) issued after 1

June 2020 for cocoa sold as conventional or

under other seal and compare to the

transactions performed in the traceability

platform: were the volumes sold under other seal

removed? Were they removed on time?

If the answer is no, a non-conformity must be

raised.

In case of double selling of volumes, a non-

conformity must also be raised against

G.A.22 / 1.3.

G.A.25 1.2 The group must remove all the volume sold as

conventional or under other seals from their

certified volume on the traceability platform

and sends proof to the CB.

In addition, the group must adapt its

procedure to make sure the volumes are

removed on time and set up a regular


volumes are removed when needed (to be

included in their procedures or traceability

manual).

1.7 Premium (Sustainability Differential and Investment)

1.7a communication

on premium

The group management has a system in place to

proactively communicate with the members the

premium per kg received by the group from the sale

of RA/UTZ certified produce; The group is able to

G.A.26 1.18 Group communicates to group members the

premium per kg received by the group from

the first buyer, and adapts its reporting and

communication strategy and set up a regular

monitoring system to ensure internally that the

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IF NOT COMPLIANT,


UTZ RA

demonstrate that communication to group

members on the premium received has been done.

A person is appointed by the group management

that should ensure that the communication and

information is reaching its members.

Remote audit: the auditor verifies with the IMS how

communication is done to the members, and asks

about recent communication done by the IMS.

Through phone interviews, the auditor checks that

the producers have been informed.

During the on-site audit, depending on a specific

organization structure, the auditor assesses the

different forms of communication generated

(newsletter, general assembly, community meetings,

emails, etc.) and evaluates their content and if there

are conflicting information.

The auditor interviews members and cross check the

information that has been sent by the group

management and verify that it is understood.

producers have understood the

communication.

1.7b payment of

premium

The group management has sufficient means and

accounting systems in place to perform payments to

members in a transparent and administrative sound

manner. The group must deliver evidence of

premium payment to each certified producer. The

group is able to demonstrate the amounts paid to

each member.

Remote audit: the auditor interviews the IMS staff in

charge of premium payment to verify procedure

and recording of information. The auditor interviews

G.A.27 1.18 Group must pay the amounts defined in the

procedure of use of premium to the group

members. The group must also adapt its

procedure if applicable, and set up a regular


payment of cash premium is done on time and

according to procedures.

If during the audit, the auditor has doubts

about the payment of the premium, the

auditor checks that payments have been

17


IF NOT COMPLIANT,


UTZ RA

by phone a sample of producers to verify if they

have received their due premium according to the

procedure and volumes sold to the group.

During the on-site audit, the auditor must verify the

accounting system in place: the system is able to

demonstrate with transparency the values handled

and paid to the members.

The auditor must interview the person in charge for

accounting and payments and assess how the

process of payments takes place.

The auditor must check with the audited producers

the evidence of premium payments and check if

this information is aligned with the records of the

accounting system.

done by interviewing some producers by

phone in order to close the NC.

If any inconsistencies cannot be justified by

the group, the certifier must take a non-

certification decision

1.7 c

Use and reporting of

premium

The group management has a procedure and a

system to monitor and record the use of the premium

received from the first buyer. A person is appointed

by the group management that should ensure that

the use of the premium is documented correctly.

The group management has a system in place to

proactively communicate with the members the use

of the premium received by the group from the sale

of RA/UTZ certified produce; A person is appointed

by the group management that must ensure that

the communication and information is reaching its

members. The group is able to demonstrate that

communication to group members on the premium

received has been done.

G.A.26 1.18 The group must record the use of the premium

and communicate it to group members.

The group must adapt its reporting and

communication strategy and set up a regular


recording is done and that producers have

understood the communication.

18


IF NOT COMPLIANT,


UTZ RA

Remote audit: the auditor checks the premium

procedure, and for a sample of the activities

planned the previous year, asks the IMS for evidence

that they have been carried out. The auditor verifies

with the IMS how communication is done to the

members and asks about recent communication

done by the IMS. Through phone interviews, the

auditor checks that the producers have been

informed on the use of the premium.

During the on-site audit: The auditor must check

evidence that the premium uses have been

recorded and activities planned with the group

premium have been executed according to the

procedure.

The auditor must check that the IMS has

communicated to the members about the use of

the premium. The auditor must cross-check with

audited producers that they have received and

understood the information on premium use.

1.7 d use of premium -

planning

NOT APPLICABLE ANY LONGER

1.7 e

Reporting on

additional investment

by first buyers

The group management has a procedure and a

system to monitor and record all additional

investments done by the first buyer.

The group management is able to demonstrate the

execution of these investments (infrastructure,

services, etc.)

G.A.26 The group executes additional investments

received from the first buyer.

The group adapts its reporting system and sets

up a regular monitoring system to ensure

internally that recording is done on time.

19


IF NOT COMPLIANT,


UTZ RA

1.8 Child Labour Prevention, monitoring and Remediation

1.8 a

Introduction of CLMRS

For UTZ groups with an existing CLMRS: the auditor

checks the group’s child labor risk assessment, that

child labor liaisons have been appointed and

trained, and that prevention AND monitoring AND

remediation actions are defined, implemented and

documented.

Prevention activities must be linked to the risks

identified in the assessment (G.C.78)

For RA groups, and UTZ groups which have never

implemented a CLMRS: auditor checks that:

• the group has received a training from RA on

Assess and Address;

• the group has completed the Assess and

Address risk assessment;

• the group has planned for the mitigation

measures.

G.C.78 4.6 For UTZ groups with an existing CLMRS:

depending on the detail of the NC, child labor

liaisons are appointed and trained; prevention,

monitoring and remediation activities are

better defined, measures are taken for

activities to be implemented and

documented.

For RA groups and UTZ groups which have

never implemented a CLMRS: group is trained

by Rainforest Alliance, had completed the

Assess and Address child labor risk assessment

and has planned for the mitigation measures.

20

PRODUCER CERTIFICATION CRITERIA: NIGERIA AND CAMEROON


IF NOT COMPLIANT, RAISE

NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY

UTZ RA

1.A.1. Certification – Eligibility rules

1.A.1.a

Pause on new

groups

The auditor verifies that this is not a new group; in case

of doubt, the auditor gets in touch with RA.

N/A

N/A

If group is new, certification cannot be granted.

1.A.2. Geolocation Data

1.A.2.a

100% GPS

coverage of

group members

for groups with

at least 50%

coverage as of

1 February 2020

50% GPS of

group members

for groups with

less than 50%

coverage as of

1 February 2020

The CB must assess the quality of the geodata

provided by the member as part of the preparation

for the audit. This includes:

• Identifying unusual patterns for the location of the

farms/sites (e.g. perfectly squared grid in which all

points are equidistant from one another)

• Identifying geodata location in unusual locations

(e.g. in palm oil fields instead of the commodity

under the audit scope) during the audit

preparation

• Identifying potential repetition of farms/farm

units/sites within this CH and between this CH and

other RA-certified CH(s).

• Determining whether geodata was taken

following the guidelines provided by RA.

The audit team must verify at least the following

during the onsite audit in order to evaluate the

quality of the geodata provided by the CH:

• Within the sample, the CB must evaluate whether

the GPS location points/polygon provided

coincide with the actual farm location visited.

G.A.3

G.A.8

G.D.111

1.6

1.13

2.3

The group must provide a location point the

percentage request by the Cocoa Policy if there

were not all provided before the audit. Location

points provided after the audit must be checked

by the CB regarding the format and compliance

with G.D.109, G.D.110, G.D.111 / 1.6, 2.3. An

onsite verification must be done if the CB deems

that it is necessary.

Each location point which is found not credible

or not recorded well must be collected again by

the group and corrected in the registry.

If during the audit, more than 10% of the GPS

point of the audited producers are not credible,

the group must collect again the location points

for all members of the group.

If groups members are found within Protected

Areas (except enclaves or admitted farms) or to

have deforested, the group must:

- exclude those group members from the group

as well as their respective volume from the

volume estimation.

21

• The credibility of the location point/polygon

collected by the CH/member by comparing it

with the one collected by the auditor.

• If the location points of new producers have been

taken in the center of the largest farm unit (see

annex 2)

During the visit, the audit team must verify the

following signs of recent deforestation in the field.

As part of the license request process the CB must

provide:

1. Identification of all the group members’ farms

included in the audit sample.

2. To indicate the group members’ farms

included in the sample and visited during the

audit, the CB must indicate their location

points in columns AP and AQ of the Group

Member Registry.

3. Validate the Group Member Registry in the

tool provided by RA before submitting the

license in GIP or before completing the

certificate in Salesforce

Deforestation:

The audit team must include a representative sample

of farm located in risky areas with respect to the

country RA risk maps if available. During the visit, the

audit team must verify sign of recent deforestation

such as young branches on trees along the borders of

the farm, young stumps etc. The Annex 1 below is

providing further guidelines on how to audit

deforestation.

- commit to not buy products from those

members.



- Implement awareness raising measures or

training

- In case of deforestation, plan to collect

polygons of farms units of all producers of

medium and high risk of deforestation

For UTZ groups, if more than 5% of farms of the

audit sample have been found to have

deforested, the group cannot be certified and

the certifier must take a non-certification

decision.

For RA groups, please refer to the critical criteria

process.

22

Based on the findings of the audit, a non-conformity

can also be raised on G.D.109, G.D.110 / 2.1, 2.2.

Protected Areas:

The CB must map the location points provided by the

member against the official Protected Areas maps

provided by RA and verify if the location points are

not located inside the Protected Areas. The audit

team must include a representative sample of farm

identified close to Protected Areas through the

mapping online. The Annex 1 below is providing

further guidelines on how to audit deforestation.

AUDIT PROCESS RULES: APPLICABLE TO IVORY COAST AND GHANA


IF NOT COMPLIANT, RAISE

NC AGAINST: HOW TO CLOSE THE NON-CONFORMITY

UTZ RA

3.4. Certificate Holder obligations to comply with the audit process

3.4.a Availability

of the audit

sample

By the end of the on-site audit days, if less than 75%

of the producers pre-selected by the auditor cannot

be audited, a non-conformity is raised.

G.A.8 1.13 A follow-up audit needs to take place during

which 50% of the producers which could not be

audited during the 1st audit need to be audited.

If those 50% cannot be audited during the follow

up audit, the CB must take a non-certification

decision.

If less than 75% of the producers pre-selected for

this follow up audit cannot be audited, the CB

must take a non-certification decision.

3.4.b Access to

SYDORE

Groups in Ivory Coast must provide access to the

SYDORE during the audit to the auditor.

G.A.22 1.2 Screenshots of the SYDORE for specific deliveries

selected by the auditor must be provided to the

CB.

23

In the SYDORE, the auditor checks that the

information on the relevant deliveries match the one

from GIP.

Group must implement a procedure to provide

access to the SYDORE to the auditor for the next

audit and the responsible person managing

transactions in the SYDORE is indicated in the

product flow map.

3.4.c Ability of the

audit sample to

show

government IDs

During the audit, the audit team must ask the

auditee to show the government issued ID. The audit

team must check for the auditee for which no

government IDs has been provided in the GMR that

they indeed do not have a government issued ID.

In case of discrepancy between the information

checked with the audited producers and the

information provided in the registry, a non-conformity

is raised.

G.A.8 1.13 If duplicates are found in the Government Issued

IDs provided by the group, they must be

corrected.

If any discrepancy is found between the

Government Issued IDs indicated in the registry

and the ones checked during the interview, the

discrepancy must be corrected.

The CB must ask the group to send evidence of

Government Issued IDs for a sample of

producers in the group not originally included in

the audit sample.

3.4.d Product

flow map shared

before the audit

Product flow map is shared one week before the

intended

N/A N/A No non-conformity raised but audit cannot be

conducted until all requested documents are

shared with CB.

ANNEX 1 - GUIDANCE FOR AUDITING AND REPORTING FOR DEFORESTATION AND

ENCROACHMENT INTO PROTECTED AREAS RISK

Verification of deforestation and encroachment into Protected areas in the field

1. The risk maps provided by RA for Ghana and Ivory Coast, support the auditing process by providing an overview of (1) conversion

of natural forest and ecosystems and, (2) encroachment into Protected Areas (PA). The maps are the result of overlaying

geospatial location data of the member with other layers of information (forest layer, tree cover loss, protected areas). The risk

maps for Cameroon and Nigeria will be provided at country level, without location data of the member.

2. In addition to the risk maps provided by RA, the audit team must use different factors to assess the risks to deforestation and

encroachment into PA, including but not limited to, new production areas, purchases of new land, and new infrastructure, or

large increases in production without the purchase of new land. The CB must make use of these indicators to prepare and

execute the audit, whenever available.

24

3. Audit preparation: when preparing for the on-site audit, the audit team must evaluate the quality of the geodata provided and

must also assess the available information about PA.

a. Evaluation of geodata quality: the audit team must assess the quality of the geodata provided by the member as part

of the preparation for the audit. This includes:

i. Identifying unusual patterns for the location of the farms/sites (e.g. perfectly squared grid in which all points are

equidistant from one another)

ii. Identifying geodata location in unusual locations (e.g. in palm oil fields instead of the commodity under the audit

scope) during the audit preparation

iii. Identifying potential repetition of farms/farm units/sites within this CH and between this CH and other UTZ or RA-

certified CH(s).

iv. Determining whether geodata was taken following the guidelines provided by RA.

b. Protected areas preparation: prior to the audit, the audit team must research whether there are protected areas and/or

important ecosystems in the areas under the audit, and to be knowledgeable of the rules and laws of protected areas,

including buffer zones, for the specific context of the audit. The results of such research must be recorded by the audit

team in corresponding certification file which will be made available to RA upon request.

c. It is recommended that the audit team prepares the following before going to the field:

- Transfer location points to a smartphone or device to take on the audit

- Prepare print-copies to take on the audit of farm points and polygons with relevant features that can be used for

verification (roads, towns, rivers, etc.)

- Prepare print copies of protected area maps or if possible, save them in the smartphone

- The CB could also prepare print copies with the risk maps provided by RA

4. Audit:

a. The audit team must include a representative sample of farm identified as risky in the RA risk maps of Ivory Coast and

Ghana or located in risky areas in the RA risk maps of Cameroon and Nigeria.

b. The audit team must collect the location points of all the farms visited as part of the sample.

c. The audit team must verify at least the following during the onsite audit in order to evaluate the quality of the geodata

provided by the CH:

i. Within the sample, the CB must evaluate whether the GPS location points/polygon provided coincide with the

actual farm location visited.

ii. The credibility of the location point/polygon collected by the CH/member by comparing it with the one collected

by the auditor.

iii. The CB audit team must triangulate the evidence provided by the CH with evidence provided by the farmers for

situations in which there is repetition of farms/farm units/sites within this CH and between this CH and other UTZ or

RA-certified CH(s).

25

d. The audit team must verify deforestation at different stages, i.e. in the farm, at the factory/processing unit and at IMS

level.

e. During the visit, the audit team must verify the following signs of recent deforestation in the field.

i. Evidence of recent deforestation in the field/at new areas/at borders to forests:

1. Trees confined to the borders of forest patches show signs of recent changes, e.g. when they show many

young branches growing into the open patch

2. In a new production area, estimate how old the stumps are

3. Destruction signs from felling large trees, swaths in the forest or in production sites

4. Colonization of open spaces by pioneer species

ii. The audit team must take pictures of relevant evidences and retain the picture as part of the certification file at

the CB. The CB must make such pictures available to RA upon request.

f. During visits of farms/sites with high deforestation risk or high risk of encroachment to protected areas, i.e. evidence of

recent deforestation from risk maps as described above or identified as high risk by the audit team with new information

found onsite, the audit team must exercise professional skepticism that conversion or expansion has happened and must

follow up to confirm the risk.

g. The audit team must verify at least the following indications IMS/factory/processing unit level:

i. If biomass energy, particularly wood, is used in the processing, the audit team must verify whether the volume of

wood used corresponds to the volume of wood purchased or harvested.

ii. There are new buildings/constructions that have been built from wood

iii. There are sales or storage of large quantities of wood at the premises

iv. Improvised sawmills

h. The audit team must effectively incorporate the topic of deforestation in interviews with farmers, workers and in

stakeholder consultation.

i. The audit team must collect evidence if the following situations are found during the audit: (a) a farm/farm unit has

deforested/encroached in PA, (b) a farm/farm unit was indicated as risky in the RA risk maps but field evidence proved

otherwise. The evidence could include:

i. Location point of the farm/farm units

ii. Explanation of why conversion showed up in satellite images but would not mean conversion: for example, forest

plantations that are harvested and converted to agricultural use, but would not mean conversion of natural

ecosystem

iii. (if applicable) high resolution satellite imagery showing that conversion of natural ecosystems didn’t take place

iv. Pictures, drone images or other proof of field evidence that explains risk detection (high shade coverage, timber

plantations in the surrounding etc.)

v. Farms’ age older than the cut-off date; conversion found due to harvesting shade trees, for example etc

j. In cases of evidence or suspected conversion (with or without indication of risk maps), the audit team must verify such

cases through (additional) interviews with relevant stakeholders, including but not limited to local authorities, neighboring

farms, target community members.

26

Note: For example when the audit team finds little storage huts with chainsaws, the audit team is expected to

initiate a conversation with the person(s) having access to the chainsaws; a target community member could

also be a person who has been residing for long at the community who has knowledge and is open to share or

any person who has further knowledge and insights of recent conversion in the area.

Reporting of deforestation and PA encroachment in the license request

As part of the license request process the CB must provide:

4. Identification of all the group members’ farms/farm units included in the audit sample. For CHs in Ghana and Ivory Coast, the

CB must clearly record in the Group Member Registry (column AR) the reason for choosing a specific farm in the audit sample

(i.e. Deforestation risk, Risk of encroachment in Protected Areas, Others).

5. To indicate the group members’ farms/farm units included in the sample and visited during the audit, the CB must indicate their

location points in columns AP and AQ of the Group Member Registry.

6. Regarding risk of deforestation and encroachment into PA, the CB must:

a. Indicate farms/farm units that deforested/encroached in PA, provide a summary of the evidence and audit findings

and, the location point of such farm/farm units.

b. Indicate farm/farm units indicated as risky in the RA risk maps but for which, the field evidence proved otherwise. In

addition to this, the CB must also provide a summary of the evidence and audit findings and the location point of these

farm/farm units.

27

ANNEX 2 - GEOGRAPHICAL SCOPE, FARM AND FARM UNIT

auditing instructions related to the cocoa policy€¦ · the audit team must verify at least the...

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