2 TABLE OF CONTENT 1. COMPANY INFORMATION 3 2. Production of White Sugar Sugar Beet: Raw cane sugar: Processing aids: 5 3. General Information ON Food Law Provisions 6 4. PackAGing Materials

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2 TABLE OF CONTENT 1. COMPANY INFORMATION 3 2. Production of White Sugar Sugar Beet: Raw cane sugar: Processing aids: 5 3. General Information ON Food Law Provisions 6 4. PackAGing Materials 6 5. TRACEABILITY 6 6. FOOD HYGIENE Personal Hygiene Cleaning Pest Control Waste management Storage and transportation Training Maintenance Foreign Bodies Glass Policy 8 7. HAZARD ANALYSIS CRITICAL CONTROL POINT (HACCP) 8 8. QUALITY OF SUGAR Regulatory status in the EU EU Regulated Parameters Methods Sampling and Testing Plans Microbiology Monitoring Plan 9 9. Nonconforming Products Complaint Management Recall Procedure Crisis Management Food Defense Product General Information Allergens Genetically Modified Organisms (GMO) Irradiation/Treatment with Ionising Radiation HALAL Status Kosher Status Vegan, Vegetarian Status Best Before Date (BBD) MATERIAL SAFETY DATA SHEET (MSDS) REACH CORPORATE SOCIAL RESPONSIBILITY (CSR) 12 3 1. COMPANY INFORMATION Südzucker Group Südzucker Group is the market leader in the EU Sugar Market and is active in 10 European countries with over 30 production sites. Members of Südzucker Group are Raffinerie Tirlemontoise S.A., Saint Louis Sucre S.A., Südzucker AG, Südzucker Polska S.A. as well as AGRANA Zucker GmbH. The annual sugar production is around 5,5 Mio. tons. All production sites of Südzucker Group are certified according to a GFSI equivalent standard. All certificates are available at the Südzucker website. 2. Production of White Sugar Sugar is formed naturally in plants and fruits. For the production of White Sugar especially sugar cane and sugar beet are cultivated. The aim of the sugar manufacturing process is to extract the sucrose from the sugar cane or sugar beet to obtain white sugar, a product with a high level of purity. The sugar manufacturing processes are characterized by handling of big volumes, by a continuous process and by products of high purity and homogeneity. From extraction/remelting to crystallization the processes are fully automatic and to a great extent take place in closed systems. 2.1 Sugar Beet: In Europe sugar beet is the main raw material for the production of sugar. Sugar beets are harvested and processed in a so-called campaign starting in September until about the end of the year. The manufacturing of sugar in all Südzucker Group factories is comparable and characterized by the following steps: Beet reception and storage: After reception the sugar beets are stored shortly in the sugar factories in the beet yard. After cleaning the beets are cut into small pieces ( cossettes ) by slicing machines. Extraction / Diffusion: In a continuous counter-current extraction process using water the cossettes are heated to around 70 C and desugarized. The obtained raw juice contains approx. 15 % sugar. Purification: Besides sugar the raw juice still contains other natural components of the sugar beet. Most of these components are removed during the purification process which starts by mixing the raw juice with lime milk. Precipitation is accomplished by adding carbon dioxide. The generated calcium carbonate surrounds the precipitated non-sugar components that can be separated by filtering. After removal of the precipitants a light yellow liquid remains the thin juice. Evaporation: The thin juice is concentrated in a multi-stage evaporation station under pressure and at high temperatures until the dry matter content of the resulting juice is about 70 % (thick juice). The thick juice is highly viscous, clear and light-gold in colour. 4 Crystallisation, drying, sieving, storage: The crystalline sucrose is obtained by concentrating the thick juice at reduced temperature and under vacuum. The suspension of crystals and syrup is passed via intermediate tanks into the centrifuges where crystals and syrup are separated. The obtained White Sugar is dried, cooled and pre-sieved, followed by storage. The sugar is distributed either as bulk or packaged. Besides sugar other products are obtained from sugar beet processing which are used for non-food purposes, like animal feed and fertilizer for agriculture. Fig. 1 White Sugar from Sugar Beet Beet reception and storage Preparation of beets (cleaning and separation) Beet slicing Extraction/Diffusion Juice purifi cation Evaporation Thick juice storage and transportation Filtration Crystallisation and Centrifugation Sugar drying Pre-Sieving Storage (silo) Sieving (attainment of particle size) Buffer silo Loading of bulk products Packaging Further Processing 5 2.2 Raw cane sugar: After harvesting the sugar cane is transported to sugar mills for processing to raw cane sugar. For the refi ning process in Europe the raw cane sugar is purchased from overseas. The White Sugar is obtained through the following process steps outlined in the scheme: Fig. 2 White sugar from raw cane sugar Raw Cane Sugar storage and reception Pre-cleaning of Raw Cane Sugar Remelting of Raw Cane Sugar and affi nation Purifi cation Filtration Evaporation Crystallisation and Centrifugation Sugar drying Pre-Sieving Storage (silo) Sieving (attainment of particle size) Buffer silo Loading of bulk products Packaging Further Processing 2.3 Processing aids: Processing aids are necessary during sugar beet processing and raw cane sugar refi ning for various technological functions. The Südzucker Group uses processing aids in accordance with applicable legal provisions in Europe. Companies have implemented procedures in their quality assurance systems to ensure that appropriate materials in adequate qualities are used. 6 3. General Information ON Food Law Provisions The White Sugar produced and delivered by Südzucker Group complies with the applicable national and European food law provisions. In particular: Regulation (EC) Nr. 178/2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety Regulation (EC) Nr. 852/2004 on the hygiene of foodstuffs Directive 2001/111/EC relating to certain sugars intended for human consumption Regulation (EC) Nr. 1881/2006 setting maximum levels for certain contaminants in foodstuffs Regulation (EC) Nr. 1935/2004 on materials and articles intended to come into contact with food 4. PackAGing Materials Food contact materials like packaging comply with applicable European legislation and are suitable for the intended use. Respective quality assurance as well as traceability measures as required by Regulation (EC) No 1935/2004 are installed. 5. TRACEABILITY In accordance with Article 18 of EU Regulation 178/2002/EC, Südzucker Group has installed a system to assure the traceability of products. All products placed on the market can be traced back on basis of the lot number. Example of the Lot Number (10 digits) for packed goods L plant number - last digit of the year - day in the year - no general definition for SZ group 6. FOOD HYGIENE Südzucker Group has implemented measures of Good Manufacturing Practices according to Annex II of EU Regulation (EC) No 852/2004 on the hygiene of foodstuffs. 6.1 Personal Hygiene All persons entering production areas (plant personnel, visitors and external contractors) shall comply with hygiene rules. The requirements of personal hygiene are determined by the needs of the individual areas, with special requirements in the areas starting from centrifuges. Specific requirements on personal hygiene can include (but are not limited to): protective clothing as well as hair net, regular laundry of protective clothing, clean footwear, prohibition of wearing jewellery, use of coloured metal detectable plaster. All employees, including temporary personnel and external contractors are regularly instructed in matters of food hygiene. 7 6.2 Cleaning There is a cleaning program that ensures cleanliness of the food processing areas. Cleaning is carried out with the appropriate equipment in different ways and with varying degrees of frequency in the individual areas. The type of cleaning is stipulated in cleaning plans. Checks are carried out to determine whether cleaning plans are being observed. 6.3 Pest Control Pest management programs to monitor and control pest activity in the facilities and the surrounding area are implemented. For the implementation of pest management activities the companies have contracts with specialist firms. The pest management program includes but is not limited to: Pest management plans and methods A plan showing the location of pest control devices Inspection procedures and frequencies and documentation of pest control activities. 6.4 Waste management There is no food waste resulting from the sugar manufacturing process itself. In the beet processing, the remaining of beets (leaves, small fragments of beets, pulps) are intended for animal feed. Other waste is collected in special containers and disposed of according to legal requirements. 6.5 Storage and transportation The Südzucker Group has defined requirements for managing warehousing and transportation to maintain the quality and ensure the safety of products delivered to customers. If subcontractor are used the corresponding requirements are part of the contract. Regular inspections by the Südzucker Group ensure that these requirements are followed. 6.6 Training Training is organized to ensure that all employees receive appropriate training for their tasks including regular refresher training. Training is provided to new employees before starting work in production. 6.7 Maintenance Maintenance ensures that equipment used for the sugar manufacturing process is suitable for the purpose intended and in good repair. For this purpose there is a program for preventive and corrective maintenance which considers: Measures to ensure that, after maintenance activities, the equipment is clean, sanitized, and in good repair prior to resuming production. Appropriate measures to protect products during repair or maintenance activities. Rules for isolating maintenance work areas from operating production lines. 6.8 Foreign Bodies The Südzucker Group has implemented programs to prevent, detect, and control foreign bodies in the produced food stuffs. Within the scope of the HACCP concept, the appearance of foreign bodies (e.g. glass, wood, metal) is subjected to risk assessment. While the process as such includes different barriers (filter, sieves) further measures are taken to avoid the occurrence of foreign bodies. 8 6.9 Glass Policy The aforementioned includes the defined use of glass and hard plastic items in production and storage areas. As a general rule it is prohibited to take glass and hard plastic items into these areas. The allowed items made of glass and hard plastic are registered. This register is regularly updated and checked, based on a risk categorization. 7. HAZARD ANALYSIS CRITICAL CONTROL POINT (HACCP) The HACCP-system is a preventive approach for food safety. With respect to article 5 of Regulation (EC) No 852/2004 on the hygiene of foodstuffs, the materials used, the processes and products are analyzed and evaluated in HACCP-studies according to the principles of Codex Alimentarius and the definitions of ISO The implementation is done within the Quality Management System. 8. QUALITY OF SUGAR 8.1 Regulatory status in the EU White Sugar or Sugar is a foodstuff and compliant with the definition as laid down in Directive 2001/111/EC relating to certain sugar intended for human consumption. 8.2 EU Regulated Parameters White Sugar and Extra-White Sugar comply with the quality requirements as laid down in Directive 2001/111/EC and Regulation (EU) No 1308/2013 respectively. Those are: Sugar Quality Polarization Moisture Invert sugar EEC total points : colour type colour in solution ash content Extra-white Sugar Sugar Grade. 1 99,7 Z 0,06 % 0,04 % 8 points 4 points 3 points 6 points White Sugar Sugar Grade 2 99,7 Z 0,06 % 0,04 % 22 points 9 points 6 points 15 points 8.3 Methods To test the EU regulated parameters ICUMSA methods (International Commission for Uniform Methods of Sugar Analysis) are used. ICUMSA is a world-wide body which brings together the activities of the National Committees for Sugar Analysis in more than thirty member countries. 8.4 Sampling and Testing Plans The quality of the produced sugar is controlled by the factory laboratories according to agreed sampling and testing plans. These plans specifies kinds of samples to be analyzed (end-products and intermediates), test parameters, frequency and applied methods. The comparability and proficiency of the factory laboratories is ensured by regularly participations in collaborative studies. 9 8.5 Microbiology White Sugar is a dry product with very low water content. The aw (water activity) values of dry sugar lies below the limit at which food pathogenic bacteria can grow or produce toxins. White sugar is thus microbiologically stable and does not require further precautions than Good Manufacturing Practices when stored under appropriate hygienic and dry conditions. Due to these facts, there has been no need to establish microbiological limits for sugar in the European and international legislation. 8.6 Monitoring Plan Companies of the Südzucker Group have a common monitoring plan in place which includes parameters, methods and limits in order to verify that the products supplied comply with regulatory provisions and the product specifications. The monitoring plan covers for example pesticides and heavy metals. Pesticides: The results are in general below the respective detection limits and confirm that pesticides do not play a role in sugar. Heavy metals: For sugar previously existing limits have been officially withdrawn as they were unwarranted due the low detected traces, if any. The monitoring confirms that a risk through heavy metals for sugar can be excluded. Radionuclides: Monitoring of radionuclides confirms that nuclear incidences of the past are without consequence on white sugar produced or refined in Europe. 9. Nonconforming Products There are documented procedures in place to prevent the unintended use or delivery of final products which do not meet requirements. These documented procedures define by one or more the following actions: identification, segregation, risk assessment, determination and execution of the final disposition of nonconforming products. 10. Complaint Management The complaint management system takes care of the complaints receipt, registration, forwarding, intermediate handling as well as the potential product recall and the final settlement of complaints. The installed complaint management that guarantees that complaints are handled in a proper and efficient manner. If necessary corrective actions are induced in order to prevent recurrence. 11. Recall Procedure The recall procedure defines activities required for product recall: like containment of materials, batches, collection of all possible data, materials employed in the production, decision on the type of product recall or notification of the departments affected. The procedure is tested at least annually. Crisis Management To overcome a crisis situation effectively a crisis management procedures are in place. The crisis management includes definition of a crisis team, its competences and a defined flow of information. In a crisis situation all actions are taken by the crisis management team whose decisions take into consideration regulatory provisions, scientific data, authorities expectations, customer views as well as costs. 13. Food Defense The Südzucker Group has implemented a Food Defense concept in their production sites. This concept includes the following: Access control to the production sites Performance of hazard analysis and assessment of associated risks Training of employees To take measures to prevent tampering Consideration of aspects of personnel security 14. Product General Information 14.1 Allergens Substances that may cause allergies or intolerances in some people ( allergens ) are listed in Annex II of Regulation (EU) No 1169/2011 on the provision of food information to consumers. White Sugar does not require allergen labelling according to Regulation (EU) No 1169/2011. Except for SO2 the substances listed in Annex II are not used in the sugar production process. The SO2 content is below 10 mg/kg. Substances or products causing allergies or intolerances (Annex II) Use in the sugar manufacturing process Cereals containing gluten and products thereof (i.e. wheat, rye, barley, oats, spelt, kamut or their hybridised strains) Crustaceans and products thereof. NO NO Eggs and products thereof. NO NO Fish and products thereof. NO NO Peanuts and products thereof. NO NO Soybean and products thereof. NO NO Milk and products thereof. NO NO Nuts and products thereof. NO NO Celery and products thereof. NO NO Mustard and products thereof. NO NO Sesame seeds and products thereof. NO NO Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/liter expressed as SO2 NO As processing aid, 10 ppm in finished product. Lupine and products thereof. NO NO Molluscs and products thereof. NO NO Labeling obligation according to Art. 9 1c of Reg. 1169/2009 NO NO Genetically Modified Organisms (GMO) Südzucker Group products are not subject to the labelling requirements of Regulation (EC) Nr. 1829/2003 and Regulation (EC) Nr. 1830/2003. Currently there is no approval for genetically modified sugar beet or sugar cane varieties in the EU for food production. Südzucker group does not trade sugar from genetically modified sources either Irradiation/Treatment with Ionising Radiation In Europe, irradiation is authorized only for a few exceptional foodstuffs for microbiological control (Directives 1992/2/EC and 1999/3/EC). Irradiation is not allowed for sugar. Südzucker Group products are not exposed to any treatment of ionizing radiation to extend storage life HALAL Status White Sugar is compliant with the definition as laid down in Codex General Guidelines CAC/GL for use of the Term Halal Kosher Status Südzucker Group offers Kosher certified White Sugar. Certificates are available upon request Vegan, Vegetarian Status White Sugar is obtained from raw materials that are not composed of, nor derived from animal origin components. Sugar can be consumed in all sorts of vegetarian and vegan diets Best Before Date (BBD) According to Regulation (EU) No 1169/2011, Annex X, an indication of the date of minimum durability, best before / use by date is not be required for solid sugar. 15. MATERIAL SAFETY DATA SHEET (MSDS) MSDS exist for White Sugar of the Südzucker Group and are available upon request. 16. REACH Sugar (Sucrose) is a single ingredient foodstuff and complies with the relevant European food regulations. According to Article 2 Nr. 5 of the EU-Chemical legislation REACH (EG/1907/2006) there is no need for registration for products used in food or feeding stuffs or intended for medicinal products for human or veterinary use. Furthermore sucrose is especially mentioned in Annex IV Exemptions from the obligation to register in accordance with article 2 (7)(a) of the above mentioned document. Therefore a pre-registration is not necessary (EINECS NO: , CAS No: ). CORPORATE SOCIAL RESPONSIBILITY (CSR) Südzucker Group has laid down its longstanding commitment for the principles of CSR in a Code of Conduct (available at website). This Code of Conduct refers to major aspects of CSR and covers also the aspects of respective standards like SA 8000 or BSCI. The Code of Conduct covers among others Südzucker positions towards environmental aspects. Finally, the European sugar sector was the first sector in the food industry on European level which signed a Code of Conduct with EFFAT (European Federation of Food, Agriculture and Tourism Trade Unions). The sugar production sites of Südzucker Group are registered on SEDEX. State 19th May 2014 Südzucker AG Mannh
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