GROUP PALM OIL POLICY

This policy stipulates the supply chain arrangements to be applied to the sourcing of palm oil and palm oil derivatives used in Genius Foods products.

The policy shall be applied in conjunction with any relevant customer palm oil policies and sustainability policies.

Genius Foods manufactures bakery products and free from bakery products across two manufacturing sites, with a non-manufacturing central sales office.

The Free From products are free from gluten and milk and are principally for diagnosed coeliac consumers. These products can contain palm oil or palm oil derivatives in various formats in functional ingredients containing emulsifiers, raising agents and fatty acids such as calcium stearate. Genius Foods take legal ownership and physically handle raw materials that are, or contain, RSPO Certified Sustainable palm products.

Palm oil is the oil obtained from the fruit of the oil palm tree, it is used primarily in food products such as; cooking oil, shortening, and margarine for example.

Palm Kernel Oil (PKO) is oil from the seed/nut of the fruit and is primarily used in the oleochemical industry for making soap, detergent, toiletries and cosmetics.

Approximately 60% of the palm oil consumed has been further processed into a palm oil ‘derivative’ or blend; 1. Split into liquid palm olein (80%) and solid palm stearin (20%). 2. Blended with other oils, or undergo further processes such as interesterification, to create new oils with different physical and chemical characteristics. Used as ingredients within shortenings, margarines for pastry and cakes, frying oils and emulsifiers. 3. Palm oil derivatives can themselves be ‘split’ a second time to produce ‘double fractionated’ palm olein, stearin as examples. These are used in the production of a wide range of food products including gravy granules, suet mixes, frying oils, pastry margarine, snack foods and toffee fat.

Palm kernel olein is used in confectionery, coatings and margarines. Palm kernel stearin is used in confectionery.

P-G-002 Issue No.2 Approver: Chris Peace Date: 27.04.18 Page 1 of 4

GROUP PALM OIL POLICY There are four options of certification for palm and palm derivatives: 1. Identity Preserved (IP) - Fully traceable, segregated, sustainable palm – can be traced back to the exact mill and point of origin and is isolated from other oils. 2. Fully segregated (SG) – Segregated certified sustainable supply chain process– not mixed with other oils. Up to final refinery, owners report all shipments and deliveries to the UTZ online monitoring system. 3. Mass balance (MB) (also known as controlled mixing) – Certified palm oil is mixed with conventional palm oil. All operators and processors in the supply chain need to be RSPO members (except subcontractors). 4. GreenPalm (book and claim) - RSPO certified palm oil producers are invited to register a quantity of their output with the GreenPalm programme. They are awarded one GreenPalm certificate for each tonne of palm oil which has been sustainably produced. They can then put those certificates up for sale on the GreenPalm web based trading platform. Manufacturers or retailers can then bid for and buy those certificates on line, in order to be able to claim that they have supported the sustainable production of palm oil. The palm itself used in products is sold, processed and purchased in the usual way.

Genius Foods does not recognise GreenPalm as a sustainable source of certified sustainable palm oil (CSPO) and palm kernel oil (CPKO).

Genius Foods shall handle MB and SG palm oil and palm derivatives.

The criteria within this policy apply to the palm oil and palm oil derivatives used in Genius products. Genius Foods source palm oil and its derivatives in a responsible manner.

Responsibility shall be nominated to a specific individual who shall have overall responsibility for and authority over the implementation of these requirements and compliance with all applicable requirements.

Certification and membership Genius Foods shall maintain membership of the Roundtable on Sustainable Palm Oil (RSPO) and hold multi-site Chain of Custody Supply Chain Certification through the Mass Balance (MB) system for all manufacturing sites. Each site shall be available for audit as required by the scheme membership.

Documented Procedures Genius Foods has written procedures to ensure the implementation and management of all the elements specified in the RSPO Chain of Custody System Requirements for the Supply Chain.

P-G-002 Issue No.2 Approver: Chris Peace Date: 27.04.18 Page 2 of 4

GROUP PALM OIL POLICY Purchasing and Goods In A minimum of one of the below documents will specify the material category agreed with the supplier (IP, SG, MB).

 Product specification  Purchase order  Delivery note  Invoice  Contract  Accompanying Certificate of Analysis/Conformity

An annual check the validity of the Supply Chain Certification of suppliers for all facilities that are Supply Chain Certificated shall be completed.

Where product is non-conforming, material and documents shall be controlled in line with the Non-Conforming Product Hold procedure. This procedure will also be used if a supplier is found to have an invalid Supply Chain certification.

Outsourcing Activities Where there are outsourced activities to independent third parties (e.g. subcontractors for storage, transport or blending or other outsourced activities) Genius Foods shall ensure that the independent third party complies with the intent and requirements of the RSPO Supply Chain Standard. The names and contact details of all contractors used for the processing or production of RSPO certified materials, shall be recorded where applicable. Genius Foods shall inform RSPO and the certification body about the names and contacts details of any new contractor used for the processing or production of RSPO certified materials.

Sales and Goods Out Genius Foods shall ensure that all sales invoices or relevant documents, e.g. delivery notes, shipping documents and specification documentation, issued for RSPO certified oil palm products delivered include sufficient information, this may include the following:  The name and address of the buyer  The name and address of the seller  The loading or delivery date  The date on which the documents were issued  A description of the product, including the applicable supply chain model (Identity Preserved (IP), Fully Segregated (SG) or Mass Balance (MB))  The quantity of the products delivered  Any related transport documentation

P-G-002 Issue No.2 Approver: Chris Peace Date: 27.04.18 Page 3 of 4

GROUP PALM OIL POLICY  Supply chain certification reference number

Registration Genius Foods recognises that they are not required to register transactions in the RSPO IT System as they are a manufacturer handling material after the final refinery. Genius Foods shall be registered on the RSPO e-trace system.

Training Key staff involved in control of Supply Chain Certification System, shall be trained in the understanding of the scheme requirements.

Claims Genius Foods will only make claims regarding the use or support of RSPO certified oil palm products that are in compliance with the RSPO Rules for Communications and Claims.

P-G-002 Issue No.2 Approver: Chris Peace Date: 27.04.18 Page 4 of 4