2021 Beef Letter of Guarantee Dear Valued Customer

AMERICAN FOODS GROUP, LLC

500 S. Washington Street Green Bay, WI 54301 Tel (920) 473-6330 Fax (920) 436-6466

January 1, 2021

Re: 2021 Beef Letter of Guarantee

Dear Valued Customer:

American Foods Group, LLC (AFG) facilities have been operating under a Pathogen Reduction/Hazard Analysis and Critical Control Point (HACCP) system while being federally inspected and verified by the United States Department of Agriculture (USDA) Food Safety Inspection Services (FSIS).

The following AFG harvest facilities have ante-mortem inspection conducted on all cattle intended for slaughter (9 CFR 309) and process only bovine species. The establishments covered by this letter include:

Est. 5511 Gibbon Packing, LLC Gibbon, NE Est. 410 Green Bay Dressed Beef, LLC Green Bay, WI Est. 2460 Cimpls, LLC Yankton, SD Est. 253 Long Prairie Packing Co., LLC Long Prairie, MN

HACCP Our establishments comply with FSIS HACCP (9 CFR 417) and SSOP requirements (9 CFR 416). Each HACCP plan is reassessed at a minimum of annually and have ongoing verification and validation programs that comply with the USDA Interim Final Rule published in the Federal Register on January 12, 2004. Generic E. coli biotype I testing is also performed on carcasses per 9 CFR 310.25.

E. coli O157:H7 and Non-O157 STEC [O26, O45, O103, O111, O121 & O145] are considered a ‘hazard reasonably likely to occur’ in the establishment HACCP plans. Each HACCP plan contains at least one Critical Control Point (CCP) involving a pathogen intervention method specific to reducing E. coli O157:H7 below detectable levels.

Each facility operates a validated carcass thermal pasteurization system (either hot water or steam) with a designated CCP organic acid carcass cabinet. Additional validated antimicrobial methods in place include - organic acid sprays, steam vacuums, pre-evisceration antimicrobial treatments, carcass spray chill processing aid application, and cold chain management systems. Our facilities perform extensive microbial tests on carcasses which are statistically evaluated to serve as a process verification that our interventions are continually impacting microbial reduction.

Offal products intended for raw ground beef are treated with one or more processing aids which are demonstrated effective in reducing surface microbial contamination, which is considered as a CCP in their HACCP system. All CCP critical limits are monitored at a frequency to ensure process control.

An organic acid based antimicrobial agent is applied immediately prior to the packaging of subprimals.

www.americanfoodsgroup.com

This agent is recognized by USDA-FSIS (Directive 7120.1) and CFIA as a “processing aid”, therefore, there is no implication to labeling or including it in the ingredient statement. This treatment has been microbiologically validated in the facilities utilizing indicator microorganisms.

E. COLI O157:H7 American Foods Group, LLC uses a robust sampling plan that utilizes N60+ and Manual Sampling Device [MSD] sampling on boneless beef trimmings, red offal (head, cheek meant, and hearts) and any other products destined for raw non-intact use.

100% of the sample is analyzed by an accredited third-party laboratory utilizing AOAC approved methodology using a multiplex PCR system for E. coli O157:H7. A negative Certificate of Analysis (COA) is then generated for all products destined for raw non-intact use. The absence of a COA is indication that the product has either not been tested or the customer has not purchased tested products at the time of sale. If a COA is provided for E. coli O157:H7, then the samples listed in that report represent products that were produced from a system that controls both E. coli O157:H7 and Non-O157 STECs.

AFG facilities conduct ongoing verification of their E. coli O157:H7 sampling programs. The verification program is conducted at a minimum of once quarterly with an increased frequency during high prevalence months (April through September). This program is also used to meet industry best practice expectation that customers conduct on-going sample verification of their raw materials. AFG incorporates Non-O157 STECs within this program to provide additional data for review and verification of our intervention’s effectiveness on these organisms.

NON-O157 STEC AFG continues to evaluate our existing food safety systems, and incoming data along with published scientific research. Peer reviewed literature establishes that the existing E. coli O157:H7 pathogen intervention strategies are equally effective on Non-O157 STECs. We concluded that our existing pathogen reduction technologies and beef slaughter process controls for E. coli O157:H7 are effective in providing the same control to other Non-O157 STECs [O26, O45, O103, O111, O121 & O145] for beef trimmings and non-intact beef intended for raw use.

AFG will continue to collect and review necessary data from baseline research and testing methods for Non-O157 STECs and reassess accordingly.

HIGH EVENT PERIODS AFG has a Hight Event Period (HEP) program when an abnormal number of presumptive positive E. coli O157:H7 results on trim have occurred in the same production day. If this occurs, the facility will hold and evaluate previously tested negative like-kind products. During this evaluation, a determination is made on whether or not products that previously tested negative may be associated with the presumptive positive product. If product is associated, that product is held and diverted to full lethality treatment or inedible use. Similar disposition of untested subprimal products may be taken if determined to be association with an Event.

PRODUCT INTENDED USE Each AFG facility produces subprimal products packaged into vacuum bags and either boxed or placed into combos that are not tested and are intended solely for intact use. AFG expects any customers who purchase vacuum packaged primals in boxes or combos, and utilizes these products for non-intact processes, to address the specific usage within their HACCP plan.

www.americanfoodsgroup.com

AFG also produces tested trim, red offals (head, cheek, heart meat) and subprimal products that are not bagged and packaged ‘naked’ in lined boxes or combos. These products are robustly sampled utilizing N60 or equivalent methods and are intended for non-intact use, such as grinding, needle tenderizing or injection.

NOTE: vacuum packaged beef subprimals in a combo or box are not intended for use in raw non-intact products.

FOOD SAFETY & QUALITY PROGRAMS American Foods Group, LLC follows a strict food safety management process that supports our food safety system. Our harvest facilities have supporting prerequisite programs encompassing: Good Manufacturing Practices (GMPs), Foreign Material Control, Pest Control Program, Product Hold Program, Food Defense Program, Allergen Control Program and a recall and traceability procedure; which provides for trace-back and trace-forward capabilities to ensure that the proper products and dates can be identified if necessary.

Third Party Audits - Our facilities have obtained certification under an approved Global Food Safety Initiative (GFSI) standard. In addition, each facility is evaluated annually by a 3rd party auditing firm using an E. coli Addendum, Animal Welfare (including transportation) by a PAACO Certified auditor and SRM audit.

Specified Risk Materials - AFG operations are in full compliance with Bovine Spongiform Encephalopathy [BSE] related regulations - 9 CFR 309, 310 and 318 et. al., Prohibition of the Use of Specified Risk Materials for Human Food and Requirements for the Disposition of Non-Ambulatory Disable Cattle.

Cattle processed at our facilities have not been subjected to air injection stunning (9 CFR 313.15(b)(2)(ii)). Our BSE control program also requires livestock producers to certify compliance with 21 CFR 589.2000 - Animal Proteins Prohibited in Ruminant Feed. All non-ambulatory disabled cattle are condemned and disposed of to rendering or landfill.

Drug Residue Testing - All AFG slaughter establishments operate with FSIS/USDA veterinarians that inspect and test suspect carcasses for chemical residues according to FSIS Directive 10,800.1 rev. 1 (03/03/2014). Each facility has implemented acknowledgement forms that producers sign to ensure understanding and compliance with the requirements for animals to be suitable for human consumption at the time of harvest.

Advanced Meat Recovery [AMR] - AFG utilizes mechanical meat/bone separation machinery to produce AMR. All product is produced in accordance to with 9 CFR 301, 318 and 320. AFG utilizes atomic absorption spectroscopy to test product for non-complying specifications [Ca. >130.0 mg/100 g, Exc. Fe. 3.5 mg/100 g) and Ridascreen 10/5 kits for SRM testing.

Enclosed is an executed copy of our continuing guarantee to support our commitment to delivering safe and wholesome product.

American Foods Group, LLC appreciates your partnership and commitment to food safety. For additional information and/or updates please visit our website at https://www.americanfoodsgroup.com/fsqa- documents/account/login or reach out to us directly at [email protected].

www.americanfoodsgroup.com

Sincerely,

Ashley Lembke, PhD Ali Mohseni, PhD VP Food Safety & QA EVP and Chief Food Safety Officer American Foods Group, LLC American Foods Group, LLC

www.americanfoodsgroup.com

CONTINUING GUARANTEE

American Foods Group, LLC (“Seller”) guarantees that each and every article of food delivered to or for (“Buyer”), as of the delivery date: (a) is not adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act (the “FDC Act”), the Federal Meat Inspection Act and the Poultry Products Inspection Act, in each case if applicable; (b) is not an article which, under the provisions of sections 404 or 405 of the FDC Act, if applicable, may not be introduced into interstate commerce; and (c) if the article contains a color additive, the color additive was from a batch certified in accordance with the FCD Act, if applicable. This guarantee does not apply to any article subjected to improper use, handling or storage after delivery or to use contrary to or inconsistent with Seller’s instructions. Seller shall not be liable for any breach of this guarantee arising out of or resulting from Seller’s compliance with Buyer’s specifications, labeling instructions or other requirements.

EXCEPT FOR THE EXPRESS WARRANTIES SET FORTH ABOVE AND THOSE IN A WRITING SIGNED BY AN OFFICER OF SELLER AND BUYER, SELLER MAKES NO REPRESENTATION OR WARRANTY WHATSOEVER WITH RESPECT TO THE ARTICLES, INCLUDING ANY WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. IN NO EVENT SHALL SELLER BE LIABLE TO BUYER OR ANY THIRD PARTY FOR ANY LOST PROFITS OR REVENUES, DIMINUTION IN VALUE, OR ANY OTHER CONSEQUENTIAL, INDIRECT, INCIDENTAL OR SPECIAL DAMAGES.

This guarantee shall remain in effect until terminated by Seller on written notice to Buyer, provided, however, that termination shall not be effective as to any orders accepted by Seller prior to termination. This guarantee supersedes and replaces any prior guaranties given by Seller.

American Foods Group, LLC

Ali Mohseni EVP and Chief Food Safety Officer

Date: 01-01-2021

www.americanfoodsgroup.com

Rancagua, January 2021

Dear client:

By way of this letter, we would like to inform you that all our plants make use of an Integrated Management System, made up of standards such as GFSI (Global Food Safety Initiative) and ISO and are certified with HACCP and BRC. These certify us as a safe company from the point of view of quality and food safety.

This information is valid for the following establishments:

- Planta Procesadora de Alimentos del Sur Limitada: LEEPP 06-06

- Planta Faenadora Lo Miranda Limitada: LEEPP 06-02

- Planta Faenadora San Vicente Limitada: LEEPP 06-08

- Sopraval S.A. LEEPP 05-09

We would like to reiterate that our commitment as Agrosuper is to deliver products of the highest quality and we work on a daily basis to achieve just that.

Yours sincerely,

Customer Service

Agrosuper Comercializadora de Alimentos Limitada

P.O. Box 768, Boaz, AL 35957; P (256) 505-4500

GUARANTEE LETTER

This letter guarantees each shipment or other delivery hereafter made by AlaTrade Foods LLC is hereby guaranteed, as of the date of shipment from the facilities of AlaTrade Foods LLC, to be, on such date, not adulterated, misbranded and otherwise free from defects within the meaning of the USDA / FSIS guidelines and not an article which may not be introduced into commerce.

This Guaranty is executed by AlaTrade Foods LLC, subject to the condition that if an article is shipped under a label designed or provided by the Guarantee, AlaTrade Foods responsibility for misbranding shall be limited to that resulting from failure of the article to conform to the standard, if any, for the product, the purchase specifications or any statements contained on such label.

This Guaranty is the original guarantee provided by AlaTrade Foods LLC to Guarantee and shall continue in effect with respect to all articles ordered by Guarantee from AlaTrade Foods LLC prior to receipt of written notice of it revocation at the above listed address.

In furtherance of the policy of AlaTrade Foods LLC and upon request of the Guarantee, has caused the Guarantee to become a named insured under its comprehensive general liability and product liability insurance polices, copies or which have been provided to the Guarantee. AlaTrade Foods LLC liability to Guarantee is limited to coverage set forth in said polices. Said polices and provisions therein shall not be canceled or changed unless the Guarantee has been given at least ten days written notice by AlaTrade Foods LLC or the insurance company.

Sincerely,

Michael Barnwell 01/04/2021 QA Director AlaTrade Foods LLC

Plants: Boaz (P-20699A) Albertville (P-32174) Phenix City (P-34453)

KINGS COMMAND FOODS, LLC., EST. #M1515A, P6121A, Kent, WA KINGS COMMAND FOODS, LLC., EST. #M1515B, P6121B, VERSAILLES, OH

King’s Command Foods, LLC (“Seller”) guarantees that each and every article of food delivered to or for Pacific Food Distributor (“Buyer”), as of the delivery date: (a) is not adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act (the “FDC Act”), the Federal Meat Inspection Act and the Poultry Products Inspection Act, in each case if applicable; (b) is not an article which, under the provisions of sections 404 or 405 of the FDC Act, if applicable, may not be introduced into interstate commerce; and (c) if the article contains a color additive, the color additive was from a batch certified in accordance with the FCD Act, if applicable. This guaranty does not apply to any article subjected to improper use, handling or storage after delivery or to use contrary to or inconsistent with Seller’s instructions. Seller shall not be liable for any breach of this guaranty arising out of or resulting from Seller’s compliance with Buyer’s specifications, labeling instructions or other requirements.

This guaranty shall remain in effect until terminated by Seller on written notice to Buyer, provided, however, that termination shall not be effective as to any orders accepted by Seller prior to termination. This guaranty supersedes and replaces any prior guaranties given by Seller.

January 5, 2021 Date Ali Mohseni EVP/Chief Food Safety Officer

Rev. 07-27-16

QUALITY PROGRAMS AND CONTINUING PURE FOOD GUARANTY

Effective Date: 01 January 2020 Dear Valued Customer,

Below you will find, along with a continuing guarantee, information which concerns the Quality, Food Safety & Regulatory Affairs programs of Amick Farms, LLC poultry slaughter establishments P-7987 and P-7927.

HACCP/ Prerequisites Amick Farms, LLC is committed to producing wholesome chicken products in accordance with all food safety and regulatory guidelines set forth by the US Department of Agriculture. Also, Amick Farms, LLC operates under a fully implemented HACCP Plan (Hazard Analysis and Critical Control Points) which meets or exceeds requirements set forth in 9 CFR 417. Amick Farms, LLC has identified appropriate Critical Control Points (CCP) for the process. The CCP limits are monitored at a minimum of each production day. The CCPs are validated by scientific research and internal monitoring. Furthermore, Amick Farms, LLC has in place Sanitation Standard Operating Procedures (SSOP) that meet all requirements set forth in 9 CFR 416. Additionally, Amick Farms, LLC has in place written supporting programs for Good Manufacturing Practices (GMPs), pest control, and, where necessary, allergen control.

Regulatory Amick Farms, LLC is in compliance with all USDA/FSIS performance standard requirements with regards to Salmonella and Campylobacter control resulting in a Category 1 standing with USDA/FSIS. Additionally, Amick Farms, LLC is a registered participant in the National Poultry Improvement Plan (NPIP) and testing birds for Avian Influenza according to this plan. There is a regular screening of all live poultry for pesticides and antibiotic/drug residues. Also, Amick Farms, LLC is in full compliance with all other applicable federal, state, municipal and local laws with respect to the manufacture, production, registration (if required), sale and transportation or distribution of such articles.

Animal Welfare Amick Farms, LLC is committed to meeting all applicable regulations that pertain to animal handling and the proper care of animals as regulated by the USDA Animal Welfare regulations, as well as the current National Chicken Council (NCC) animal care guidelines. To demonstrate our commitment to Animal Welfare; the following steps have been taken: • Amick Farms, LLC has training programs in place specifically designed to address animal handling issues. • Industry experts have been used to design equipment and review the animal handling and slaughter process. • Amick Farms, LLC completes daily monitoring audits to ensure animal handling requirements are met.

Amick Farms, LLC Post Office Box 2309 ▪ Batesburg-Leesville, SC 29070 (803) 532-1400 ▪ (800) 926-4257 ▪ FAX (803) 532-1441

Amick Farms, LLC is committed to the highest standards of animal welfare. Our commitment includes regular welfare checks and verifications; regular third-party audits by outside experts; and rigorous internal audits conducted by a Quality Assurance professional who has been certified by the Professional Animal Auditor Certification Organization, or PAACO, an independent organization that has been widely recognized for excellence and leadership in animal welfare auditing.

Audits Amick Farms, LLC conducts annual independent third party Food Safety and Animal Welfare audits. In 2009, Amick Farms, LLC obtained certification to be in compliance with Global Food Safety Initiative (GFSI) standards for Food Safety and Quality. The animal welfare audits conducted have confirmed compliance with the National Chicken Council Animal Care Guidelines.

Recall and Traceability Recall procedures are in place such that in emergency, all products that are produced can be traced as product codes and volumes shipped by the location shipped to. Amick Farms, LLC has a Recall Team made up of personnel identified according to the necessary disciplines needed for prompt action. Members of this team include Production, Sales, Technical Services, Public Affairs, and Legal.

Food Defense Amick Farms, LLC is access controlled, fenced and guarded. Visitors are restricted from access to production areas, except under certain strictly controlled circumstances. Amick Farms, LLC operates under a fully developed and implemented Food Defense program and these procedures are reviewed on a regular basis.

Continuing Pure-Food Guaranty

1. In consideration of purchases from Amick Farms, LLC (“Seller”) by customer ("Buyer") of articles subject to the Federal Food, Drug, and Cosmetic Act of 1938, as amended, the article(s) comprising each shipment or other delivery hereafter made by Seller to or on the order of Buyer is guaranteed, as of the date of such shipment or delivery, to be, on such date:

(a) not adulterated or misbranded within the meaning of said Federal Act, as amended, including the Food Additives Amendment of 1958 to said Federal Act, to the extent said Federal Act is then effective and applicable;

(b) not an article which may not, under the provisions of Sections 404 or 505 of said Federal Act, be introduced into interstate commerce;

(c) not adulterated or misbranded within the meaning of laws or ordinances of the state or city to which such article is shipped by Seller, the adulteration and misbranding provisions of which are substantially the same as those found in said Federal Act; and

Amick Farms, LLC Post Office Box 2309 ▪ Batesburg-Leesville, SC 29070 (803) 532-1400 ▪ (800) 926-4257 ▪ FAX (803) 532-1441

(d) where applicable, in compliance with the Federal Hazardous Substances Labeling Act.

2. This guaranty is provided by Seller subject to the condition that if an article is packed and shipped or delivered under a label designed or furnished by Buyer, Seller's responsibility for misbranding shall be limited to that resulting from the failure of the article to conform to the statements contained on such label.

3. Unless a sales agreement between the parties provides otherwise, Seller agrees to hold harmless, indemnify and defend Buyer, its employees, directors, and officers from and against all direct loss, cost, damage and expense (including reasonable attorneys’ fees) to the extent resulting from Seller’s breach of its continuing pure food guaranties as provided in paragraph 1 above.

4. This continuing pure food guaranty supersedes and replaces any continuing pure food guaranty previously given by Seller to Buyer and shall continue in effect until written notice of revocation is provided by Seller.

Thank you for the opportunity to provide you with this insight into our Quality, Food Safety and Regulatory programs.

Please feel free to contact me if you have any further questions.

Sincerely,

Frank Wier Director of Product Support and Regulatory Compliance Amick Farms, LLC Est. P-7987 & P-7927

Amick Farms, LLC Post Office Box 2309 ▪ Batesburg-Leesville, SC 29070 (803) 532-1400 ▪ (800) 926-4257 ▪ FAX (803) 532-1441

Food Safety and HACCP Compliance

This letter guarantees that all products provided to:

Pacific Food Distributors 12300 SE Carpenter Drive Clackamas, OR 97015 are in full compliance with the U.S. Food and Drug Administration’s Seafood HACCP regulations (21 CFR 123). All plants processing Aqua Star’ product have conducted a hazard analysis for each product as required in 21 CFR 123 and implemented a HACCP plan as well as Good Manufacturing Practices (21 CFR 110) and Sanitation Standard Operating Procedures (21 CFR 123.11(a)) as per US regulations. All plants are in compliance with the USFDA Bioterrorism Act requirement by registering the facility with USFDA and ensuring the security of the plant, transportation and personnel.

In addition, the product is not adulterated or misbranded within the meaning of the Federal Food, Drug, and Cosmetic Act, and may be introduced into interstate commerce without violating said act.

Dan Shyng Company Official (Print Name) Quality Assurance Manager Title

Dan Shyng January 4, 2021 Signature Date

Aqua Star Company Name

2025 First Avenue Suite 200 Street Address

Seattle WA 98121 USA City Region / Province ZIP/Postal Code Country

HOLD HARMLESS AND GUARANTY/WARRANTY OF PRODUCT

January 21, 2021 Buyer: Pacific Food Distributors 12300 SE Carpenter Road Clackamas OR 97015

Armanino: Armanino Foods of Distinction, Inc. 30588 San Antonio Street Hayward, California 94544

ARMANINO FOODS OF DISTINCTION, INC., for itself, its affiliates, divisions and/or agents (collectively, "ARMANINO"), for value received, hereby represents, and agrees to and with BUYER, its subsidiaries, affiliates, divisions, and/or agents and assigns (collectively, "BUYER"), as follows:

1. California Safe Drinking Water Act and Toxic Enforcement Act of 1986 ARMANINO acknowledges that BUYER is subject to the Safe Drinking Water and Toxic Enforcement Act of 1986 of the State of California, popularly known as Proposition 65. Proposition 65 requires that all persons doing business in the State of California provide clear and reasonable notice to all persons exposed to chemicals identified by the State to cause cancer or reproductive toxicity. BUYER has represented that it is required by each of its distributors to certify that its products contain none of the chemicals listed by the State which are known to cause cancer or reproductive toxicity or if any such chemicals are present, they pose no significant risk. As a result of this legal requirement, BUYER represents that it is required to obtain from its suppliers certification that the products manufactured by ARMANINO for BUYER either (i) contain no chemicals subject to Proposition 65 or that the chemicals meet State of California and federal regulations and are not present in concentrations that would pose a "significant risk" to consumers as defined in California law, or (ii) carry appropriate product label warnings. ARMANINO hereby certifies that the foregoing is true and correct in all material respects. In addition, ARMANINO agrees to notify BUYER of any changes to the content of the products manufactured hereunder if any such changes would affect the above certification. Because the list of Proposition 65 chemicals may be amended from time to time (generally on a quarterly basis), ARMANINO will use commercially reasonable efforts to notify BUYER of such changes as they may affect compliance with Proposition 65.

2. Representations and Warranties Regarding Adulteration and Misbranding ARMANINO hereby represents, and warrants that each and every article of ARMANINO contained in each shipment or other delivery hereafter made to, or on the order of, BUYER is hereby guaranteed as of the time of delivery of such shipment by Armanino (i) to not be adulterated or misbranded within the meaning of:

(a) the Federal Food, Drug and Cosmetic Act, as amended, and all rules and regulations promulgated thereunder; and not an article which may not, under the provisions of Sections 404, and 505 of such Act, be introduced into interstate commerce;

(b) the Federal Meat Inspection Act, as amended, and all rules and regulations promulgated thereunder;

(d) and similar state or local laws, and all rules and regulations promulgated thereunder.

(ii) to not be adulterated, misbranded or packaged in misbranded packages, within the meaning of the terms of the Federal Insecticide, Fungicide, and Rodenticide Act, the Federal Hazardous Substances Labeling Act, any applicable state pure food and drug acts or any other applicable federal, state or local laws, ordinances, rules or regulations.

30588 San Antonio Street ● Hayward, CA 94544 ● 510-441-9300 ● www.armaninofoods.com

4. Indemnification ARMANINO agrees to indemnify and hold harmless BUYER from and shall at ARMANINO's expense and at BUYER's option, defend against, any and all claims, demands, actions, suits or proceedings brought or commenced by federal, state or local authorities against BUYER alleging that such merchandise manufactured, packed or sold by ARMANINO to or on the order of BUYER was in breach of the representations and warranties set forth in Section 2 above. BUYER shall notify ARMANINO immediately of the receipt of notice of any such indemnifiable claim. Notwithstanding anything in this Agreement to the contrary, ARMANINO shall not be obligated to defend, indemnify and hold harmless BUYER to the extent that any such claims, demands, actions, suits or proceedings are the result of the negligence or misconduct of BUYER or its licensors and/or distributors or providers of freight handling the article of shipment and ARMANINO shall have a right of contribution against BUYER and any such person or entity.

5. Insurance ARMANINO agrees to provide, and maintain in effect at all times after the date of this Agreement, (a) product liability coverage in the minimum amount of Five Million Dollars ($5,000,000) per occurrence for products manufactured by ARMANINO for BUYER and (b) workers' compensation insurance, automobile liability insurance and comprehensive general liability insurance with coverage amounts consistent with general industry standards. ARMANINO shall furnish BUYER with a certificate or certificates of insurance which evidence that such insurance is in effect. ARMANINO shall provide endorsements to its insurance policies evidencing BUYER's status as an additional insured. Such endorsements shall provide that such insurance may not be canceled or materially modified without thirty (30) days' prior written notice to BUYER.

6. This Agreement shall be governed by the laws of the State of California. The guaranty contained herein is continuing and shall be in full force and effect and shall be binding upon ARMANINO and its successors and assigns, with respect to each and every article of food, drug, device or cosmetics shipped or delivered to BUYER or on behalf of BUYER to a third party, by ARMANINO (including goods in transit) before the receipt by BUYER of written notice of revocation thereof. This Agreement contains the entire agreement with respect to the subject matter contained in it and supersedes any prior guaranty and indemnity agreement delivered by ARMANINO to BUYER.

Dated this 21st day of January, 2020 ARMANINO FOODS OF DISTINCTION, INC., a Colorado corporation

By: Tim Anderson President & CEO

30588 San Antonio Street ● Hayward, CA 94544 ● 510-441-9300 ● www.armaninofoods.com

Product Guaranty

2/2/2021

Brian Walker PFD packaging Clackamas, Oregon

Asean Corporation wishes to advise you that in consideration of purchasing products from Asean and its “Stalkmarket Brand Family” (hereinafter called “Seller”) of certified compostable products, does hereby guarantee the following;

A) Guarantees that all products sold in all shipments, are not composed or comprise in part or whole, any poisonous, deleterious, or toxic substance which may render the contents to be placed therein, injurious to health, and not adulterated under the Federal Food, Drug, and Cosmetic Act. B) Articles of such adulteration, will not be introduced into Interstate commerce as directed by sections 404 and 505 of aforementioned Act. C) Are not adulterated within the scope of the law, meaning the food and drug laws of any state or municipality which are applicable to such shipments and deliveries. D) All products comply with all parts of the Code of Federal Register Title 21 as listed under Food and Drugs as it pertains to Food Contact surfaces. E) This Guaranty replaces any and all continuing guaranties previously given to Buyer by Seller. F) Seller Guarantees all compostable products are BPI and/or Dincerto Certified per ASTM 6400 and 6868 standards, All compostable and non- compostable products are FDA Approved for Food Contact, and all products are manufactured under ISO 9001 and ISO 14001standards and compliant. G) All products are compliant with California Proposition 65 requirements. H) All products are produced under BRC certificate of approval 00017516, and inspected by BRC auditor 108123 I) All products are ISO22000:2005 compliant for production of paper cups, and plastic lids for food and beverage contact packaging material

rd US Office: 16540 SW 72nd Ave HK Office: 23 Floor, On Hong Commercial Building #7 Building Portland, OR 97224 145 Hennessy Road, Wanchai USA Hong Kong Tel: 503-295-4977 Tel: 011-852-35823300 Fax: 503-295-4978 Fax: 011-852-35785367

www.stalkmarketproducts.com

J) All Products are produced under HACCP Codex Alimentarius CAC/RCP-1- 1969 Rev. 4 (2003) for production of paper cups and lids for food packaging and packaging materials

Best Regards, Asean Corporation

www.stalkmarketproducts.com

AZ GEMS INC.

405 MISSOURI CT. P (909) 809-9513 REDLANDS, CA 92373 F (909) 798-3607

JANUARY 4th, 2021

TO: HACCP COORDINATOR / QUALITY CONTROL MANAGER.

RE: CERTIFICATION OF COMPLIANCE (HACCP).

This letter will serve as AZ Gems, Inc. official notification that we continue to operate under the U.S. Federal Food & Drug Act and (21 CFR) Hazard Analysis Critical Control Point (HACCP) Guide. AZ Gems, Inc. and all of its import sources comply with all the procedures for the safe and sanitary importation and distribution of shrimp products as outlined by the U.S. Food and Drug Administration in the Federal Register Dated December 18, 1995 CFR Parts 123 and 1240 Mandating the application of Hazard Analysis Critical Control Point (HACCP) Principles.

All facilities processing products provided by AZ Gems have conducted a hazard analysis for each product as required by 21 CFR 23, and have implemented Goods Manufacturing Practices (21 CFR Part 110). In accordance with FDA Model Food Code 2013, Chapter 3, I certify that all shrimp products processed for or imported by AZ Gems, Inc. are frozen and stored per required temperature.

Please include this document as part of your HACCP File as a continuing Certificate of Guarantee of our HACCP Compliance.

Thank you, Bhargavi Sajja

Bhargavi Sajja

Vertically Integrated & Sustainable www.AZGems.com

General and Continuing Letter of Guarantee

January 21, 2020

Dear Business Partner/Customer,

The undersigned, Belcampo Butchery LLC, hereby guarantees, that from this point forward, that all products sold, shipped, and delivered to our business partners and customers are not adulterated or misbranded within the meaning of the Federal Food, Drug, and Cosmetic Act, and are in compliance with interstate commerce regulations. Our USDA- FSIS establishment, #44932/#P44932, meets all USDA requirements set forth in Title 9 Code of Federal Regulations for the production, sale and distribution of meat and poultry products.

Our facility operates under a Food Safety Management System based on HACCP principles. We are certified Organic, CCOF, and Humane. We take pride in producing a consistently safe, wholesome product through a wide range of programs. These programs utilize USDA and Industry approved and regulated systems and intervention processes.

Our products undergo robust microbiological testing that occurs throughout production that meets and exceeds all regulatory requirements and includes E. coli O157, non-O157 STEC. All testing is conducted per AOAC methods.

Most importantly, we are striving to fulfill all of our business partner and customer expectations by providing a consistently safe, quality product that meets or exceeds all expectations.

Send questions or update requests to [email protected] or call 530-842-5200.

Regards,

Courtney O’Brien Regulatory and Compliance Coordinator Belcampo Butchery LLC Yreka, California 96097

January 1st, 2020

To: Our Valued Customer

Re: Continuing Letter of Guarantee

Busseto Foods, Inc. is a manufacturer of dry salami and dry cured meats. We operate under the rules and regulations established by the United States Department of Agriculture (USDA). We have been assigned an Establishment number of 9882 by USDA (USDA Est. 9882). Busseto Foods manufactures products that comply with current Good Manufacturing Procedures (GMP), Hazard Analysis Critical Control point (HACCP) 9 CFR Ch.III Part 417, and Sanitation Standard Operating Procedures (SSOP).

Busseto Foods manufactures products that belong to the category of Non Heat Treated Shelf Stable product. Our HACCP plan has a total of two Critical Control Points (CCP); fermentation (pH) and water activity (aw). Prior to shipment of our products, we determine that all of our CCP’s have been met.

Busseto Foods traceability program is designed to allow us to trace product back to when it was made and what equipment was used. The first seven numbers represent shift, Julian Date, and year product was produced. The last two numbers represent equipment used (i.e. packaging machine, slicer, etc.). This may vary depending on customer request.

In addition to GMP, HACCP, and SSOP programs, Busseto Foods also actively implements the following programs:

• BRC Global Standards • Recall Program in compliance with USDA and FDA regulations • Foreign Body Management Program • Pest Control Program • Food Defense Program • Allergen Control Program

If you need any further information please contact Customer Service at 1 (800) 628-2633 Toll Free.

Sincerely, Shannon Avilla

Food Safety and Quality Assurance Manger

[email protected]

Busseto Foods, Inc. | P.O. Box 12403, Fresno, CA 93777 | 800.628.2633 | Fax: 559.485.9926 | www.busseto.com

225 Hubbard Avenue Butterfield, MN 56120 507-956-5103 Fax 507-956-5751

1/7/21 EJ Foods NW 2511 70th Avenue West University Place, WA 98466

Butterfield Foods hereby guarantees and warrants to EJ Foods NW, that all product(s), specifically Stewing Hens All Natural (Item 6535), comprising each shipment or delivery hereafter made to EJ Foods NW as of the date of shipment of delivery, is hereby guaranteed to be:

(1) neither adulterated nor misbranded within the meaning of the Federal Food, Drug and Cosmetic Act of 1938, as amended, the Federal Fair Packaging and Labeling Act of 1966, as amended, or any State or local food or drug law or regulation, the adulteration and misbranding provisions of which are substantially the same as those found in the Federal Acts;

(2) not adulterated or misbranded within the meaning of the terms of the Federal Insecticide, Fungicide and Rodenticide Act or the Federal Hazardous Substances Labeling Act;

(3) free from any artificial color, artificial flavor or preservative unless clearly designated as such by Butterfield Foods on its label affixed to the merchandise sold to EJ Foods NW hereunder, or by written exception appended to this Guarantee;

(4) that any flavor shipped or delivered hereunder not designated as containing an artificial flavor, does not to the best of the Butterfield Foods information and belief, contain any artificial flavor, nor has Butterfield Foods added any artificial flavor to it;

(5) Butterfield Foods products are packed is a USDA inspected facility and said product is produced under a HACCP Plan that includes, but is not limited to, critical limits for fecal contamination, pathogen control and chilling (stabilization). All critical limits and other requirements meet USDA regulations;

(6) Butterfield Foods (P-215) is an Organic Certified facility approved to produce organic whole raw chicken (fowl) from certified organic live suppliers.

(7) Butterfield Foods will not change any of the ingredients in the items supplied to EJ Foods NW without a 30-day advance notice;

This Continuing Food & Drug Guarantee shall be applicable to all goods furnished by the Butterfield Foods to EJ Foods NW. This letter of Guarantee shall continue in effect until cancelled by not less than ten (10) days prior written notice to EJ Foods NW by registered or certified mail.

Dated 1/7/21 ______Mitch Forstie Vice President Butterfield Foods

Auditor Number 258011

FSNS Certification & Audit, LLC., ANSI accredited CB, No. 1107 certifies that, having conducted an audit:

For the scope of activities: Slaughter and fabrication of beef carcasses including beef primals, sub primals, beef offal, beef trimmings, and ground beef; bulk, vacuum, and modified atmosphere packaging.

Exclusions from scope: Rendering and Hides & Traded Goods Module Product Categories: 1, 3

CS Beef Packers, LLC Site code: 2794635 17365 South Cole Road Kuna, Idaho 83634

Has achieved Grade: AA Meet the requirements set out in Global Standard for Food Safety Issue 8: August 2018 Audit Program: Blended Announced Certificate Number: 1200156

Date(s) of Audit: September 14-15 & 17-18, 2020 Certificate Issue Date: October 16, 2020 Re-Audit Due Date: August 23, 2021 - September 19, 2021 Certificate Expiry Date: October 31, 2021

Authorized by:

FSNS Certification & Audit, LLC. 199 W. Rhapsody; San Antonio, TX 78216, USA Certificate traceability reference This certificate remains the property of FSNS Certification & Audit, LLC.

If you would like to feedback comments on the BRCGS Standard or the audit process directly to BRCGS, please contact tell.brcgs.com Visit brcdirectory.com to validate certificate authenticity

Audit Report Global Standard for Food Safety Issue 8: August 2018

1.Audit Summary

Company name CS Beef Packers, LLC Site Code 2794635

Site name CS Beef Packers, LLC

Slaughter and fabrication of beef carcasses including beef primals, sub primals, Scope of audit beef offal, beef trimmings, and ground beef; bulk, vacuum, and modified atmosphere packaging.

Exclusions from scope Rendering and Hides & Traded Goods Module

Justification for Products produced in a different area of the facility. The site elected to exclude exclusion the voluntary, Traded Goods Module from the scope of certification.

Audit Finish Date 2020-09-18 Re-audit due date 2021-09-19

Head Office No

Additional modules included Modules Result Scope Exclusions from scope Choose NA Choose a module NA an item Choose NA NA Choose a module an item

2. Audit Results Audit result Certificated Audit grade AA Audit type Blended Announced

Previous audit grade AA Previous audit date 2019-09-19

Certificate issue date 2020-10-16 Certificate expiry date 2021-10-31

Fundamental 0 Number of non-conformities Critical 0 Major 0 Minor 3

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3.Company Details Address 17365 South Cole Road

Kuna, Idaho 83634

Country United States Site 208 810 7509 Telephone Number

Commercial Roger Cooper - Operations Email [email protected] representative Manager Name

Technical Matt Thompson - FSQA Email [email protected] representative Manager Name

4.Company Profile Plant size >25K sq.m s No. of 501-1500 No. of HACCP 1-3 (metres square) employees plans

Shift Pattern One Ten-hour shift

Subcontracted processes No

Other certificates held Halal

Regions exported to Asia North America South America Other Africa

Company registration USDA 630 number

Major changes since last None BRCGS audit

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4.Company Profile

Company Description

The facility was built in 2017 and harvest 1700 head per day on average. Their major product was ground beef which started in 2018. The facility consisted of approximately 500,000 sq ft. and employed 750 people. One extended shift had a 6:30 AM start up and ran for approximately 10 hour shifts. Contracted sanitation cleaned the facility overnight. Retail and food service were the primary customer base.

5.Product Characteristics Product categories 01 - Raw red meat 03 - Raw prepared products (meat and vegetarian)

Finished product safety rationale Low risk - Finished products were raw required finished product cooking prior to consumption and were stored at temperatures <44.6F

High care No High risk No Ambient high care No

Justification for area Harvest and Fabrication areas were physically segregated and staffed with designated employees. Finished products were raw required finished product cooking prior to consumption and were stored at temperatures < 44.6F.

Allergens handled on site None

Product claims made e.g. IP, organic Natural, USDA Grade Claims

Product recalls in last 12 Months No

Products in production at the time of Beef carcasses, variety meats, sub-primals, boneless beef trim, the audit ground beef, chubs, bricks and loaves.

6.Audit Duration Details On-site duration 29 man hours Duration of production 14 man hours facility inspection

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6.Audit Duration Details Reasons for deviation from The facility was well prepared with programs and records easily accessible. typical or expected audit Additionally, a significant portion of the square footage was designated as duration carcass storage where minimal processing activities occurred.

Next audit type selected Announced

Audit Duration per day Audit Days Audit Dates Audit Start Time Audit Finish Time

1 (start date) 2020-09-14 08:00 16:00

2 2020-09-15 08:00 14:00

3 2020-09-17 05:00 16:00

4 2020-09-18 07:00 11:00

Auditor (s) number Name Role

Alyssa McMahan Auditor Number 258011 Lead Auditor

Second Auditor Number N/A Sherri Speziale Observer

Present at audit Note: the most senior operations manager on site should be listed first and be present at both opening & closing meetings (ref: clause 1.1.11)

Name / Job Title Opening Meeting Site Inspection Procedure Closing Meeting Review Steve Cherry/Plant Manager X X Roger Cooper/Operations X X X X Manager Matt Thompson X X X X Kyle Hand/HACCP-BRC X X X X Coordinator Amanda Adair/Fabrications QA X X X X Superintendent Brandy Whitehead/Grind X X X X Superintendent

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Present at audit Maria Luna/Harvest QA X X X X Superintendent

GFSI Audit History Date Scheme/Standard Announced/Unannounced 2020-09-18 BRC, Food Safety Standard Announced

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Non-Conformity Summary Sheet

Critical or Major Non-Conformities Against Fundamental Requirements No. Requirement ref. Details of non-conformity Critical or Major? Anticipated re-audit date

Critical

No. Requirement ref. Details of non-conformity Anticipated re-audit date

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Major Requirement Proposed preventive Date No. Details of non-conformity Correction Root cause analysis Reviewed by ref. action plan reviewed

Minor Requirement Proposed preventive Date No. Details of non-conformity Correction Root cause analysis Reviewed by ref. action plan reviewed CS Beef Management The site did not added a section for Monthly Manager's The root cause of the document the review Review of Employee Meeting notes will be issue was identified to of the effectiveness of Food Safety and reviewed after every be human error and a the completed Quality Culture to the misunderstanding of meeting to ensure the Alyssa 1 1.1.2 activities and their Monthly Manager's the identified 2020-10-04 Employee Food Safety McMahan timescales of the Meeting to ensure that and Quality Culture timescales for review results of the surveys the plan and any Plan has been of the Employee Food for the food safety and updates/timeframes for reviewed. Safety and Quality quality culture. improvement are Culture Plan. communicated at least

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quarterly to the site's Senior Management.

A Box Shop Small Equipment Check List has been created and implemented to ensure A training on small The root cause was accountability of box A blue handled box equipment deemed to be lack of knives for Case Sealer knife was observed in accountability was proper training for area employees. the case sealer area conducted to ensure Case Sealer area Alyssa 2 4.9.2.1 Accountability will be 2020-10-04 which did not include equipment is employees in regards McMahan documented daily identification accounted for in the to small equipment (start of shift, lunch information. Case Sealer area. accountability (box break and end of shift) knives). on each area employee and verified by the area supervisor.

A Monthly Master Sanitation Verification Root Cause was determined to be There was no Check Off Sheet has A Training was been created to human error. During documentation of conducted on Master ensure that the MSS is the timeframe in quarterly cleaning of Sanitation Verification reviewed and verified question, the Master seven refrigeration to ensure items on the as being complete. Sanitation Schedule Alyssa 3 4.11.2 units on the Master 2020-10-04 was revised several McMahan Sanitation Cleaning Master Sanitation This document will times and due to this Schedule (units 24, 25, Schedule are help to ensure that all MSS items are change, seven 28, 30, 32, 37S and documented correctly. documented correctly refrigeration units were 37N). on the Master not documented as Sanitation Schedule. having been cleaned.

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Comments on non-conformities

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Additional Modules / Head Office Non-Conformity Summary Sheet

Critical

No. Requirement ref. Details of non-conformity Anticipated re-audit date

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Major Requirement Proposed preventive Date No. Details of non-conformity Corrective action taken Root cause analysis Reviewed by ref. action plan reviewed

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Minor Requirement Proposed preventive No. Details of non-conformity Corrective action taken Root cause analysis Date reviewed Reviewed by ref. action plan

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Detailed Audit Report

1. Senior management commitment

1.1 Senior management commitment and continual improvement

*The Commitment To Food Safety and Quality was posted throughout the facility in employee common areas and with current signatures by the Plant Manager and Operations Manager. The statement explained the site was committed to producing food products that were safe, legal, authentic, wholesome, and of the highest quality. The site demonstrated continuous improvement through corrective and preventive actions, reviewed operating procedures annually and archived those no longer in use, and properly trained supervisors and operators signed off by plant and operations management. The site conducted employee engagement surveys every two years of food safety and quality culture within each department. Goals listed for the facility included customer complaint index less ≤5 and ≤ 90 nonconformances issued by the USDA. Monthly management review meeting notes reviewed from May and August listed COVID-19 precautions, a new head splitter installed, floors repaired, BRC corrective actions working as intended, customer complaints , USDA non-conformances issued and HACCP reassessments reviewed since the last meeting. Management posted a confidential suggestion box in guard shack for employees to report concerns of food safety, integrity, quality and legality issues. They also communicated this system to the employees during hire and using monitors located throughout the facility as daily reminders. The FSQA Manager reviewed the suggestions and reported them during the management meetings. Employee food safety and quality issues were trended. The following updates were installed since the last audit: Ground Beef grind and packaging lines, grind area cooler racking, railing installed in the stimulator area to streamline the process and the flooring was resealed in the majority of the facility. The company kept informed of scientific and technical developments, new risks identified in raw materials, industry codes of practice and relevant legislation through the USDA website,weekly meetings with the inspectors, and emails, using Meatingplace notifications and industry trade associations. The site maintained hard and electronic copies of the BRCGS Standard Issue 8. BRC re-audits were conducted within scheduled time-frame. The sites most senior production managers attended the opening and closing meetings of the audit certification. Senior management ensured the root causes of non-conformities against the Standard from the previous audit were effectively addressed to prevent recurrence. The facility did not use the BRC logo.

The following minor non-conformity was identified:

1.1.2 - The site did not document the review of the effectiveness of the completed activities and their timescales of the results of the surveys for the food safety and quality culture.

1.2 Organisational structure, responsibilities and management authority

*The organizational chart defined the reporting structure from the Plant Manager to plant employees and was reviewed 9/12/20. The job descriptions and back-ups were identified for essential positions (dated 3/12/20). Position responsibilities for each department manager and FSQA superintendent dated 9/12/20 were reviewed. The FSQA Manager was responsible for overall food safety and quality at the site and reported to the Operations Manager. Employees were given on the job training and reviewed job standard operating procedures (SOP's) using Alchemy training upon hire and annually. Reviewed Fabrication

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employee job description and Quality employee SOP's for individual jobs dated 6/10/2020. The organizational chart, responsibilities and job descriptions were reviewed annually or as needed.

Details of non-applicable clauses with justification

Clause/Section Justification reference

1.1.13 The BRCGS logo was not utilized.

2 The Food Safety Plan – HACCP

The facility operated under three HACCP plans based on Codex Alimentarius: Harvest, Fabrication (Raw Not Ground) and Ground Beef (Chub, Patties, Loafs and Bricks). HACCP Team Members listed were: Plant Manager, Assistant Plant Manager, Operations Manager, Food Safety Quality Assurance (FSQA) Manager, HACCP/BRC Coordinator, Ground Beef Quality Assurance (GBQA) Superintendent, Plant Engineer, Safety Manager, Ground Beef (GB) Manager and Harvest Manager. The HACCP Team Leader was HACCP trained July 17-18, 2017. HACCP certifications were also held by additional Quality Assurance (QA) department personnel. The Team Leader discussed the HACCP Principles with the HACCP team annually. The facility was a cattle slaughter facility, producing beef primals, sub-primals, trimmings, raw ground and offal products. Sold to customers, further processors, grinding facilities, and the general public. The facility operated under Category 1 (Raw products requiring cook prior to consumption, slaughter and primary cutting) and Category 3 (Retail butchery, processing and packing). Prerequisite programs implemented but not limited to: Water Potability, Supplier Approval, Metal Detection, Food Defense, Good Manufacturing Practices (GMP’s), Sanitation, Pest Control, Recall Program, Traceability, Foreign Object Control, Residue Program, Sanitary Dressing Monitoring , Chemical Application, Sanitation Standard Operating Procedures (SSOP), Facility Audits, Labelling, Trailer Inspections, Environmental Testing, N60 Plus Procedures, Thermometer Calibration, AQL Program, Returned Product, Certificate of Authenticity (COA) Verification, HACCP Corrective Action, Plant Temperatures, (Manual Sampling Device (MSD) MicroTally Cloth, Lactic Acid Checks, Acidified Sodium Chlorite (ASC) Checks, Spray Chill, Carcass Chilling, Birdshot Carcass, Offal Sampling, Carcass Sampling, Residue Program, HEP, Offal Sponge Sampling, Material Receiving and Quarterly Validation were reassessed annually (at a minimum). HACCP Reassessments were conducted annually, or as needed. Programs were clearly documented. Reassessment dates were listed on the SOP Change Log. Records were reviewed for reassessments conducted on the Slaughter and Fabrication HACCP plans on 1/2/20 and the Ground Beef HACCP plan on 1/17/20 (this reassessment also condensed two previous ground plans into one). HACCP meeting notes were provided from plan reassessments. Product and process descriptions were provided for each plan and included the process category, products covered, product intended use, type of packaging, distribution, labeling instructions, shelf life, consumers, and intended use. Intended use was identified as further processing, retail, and food service sales for consumption by the general public. Flow charts were provided, color-coded and verified by the HACCP team on 1/20/20 (Harvest), 3/12/2020 (Fabrication) and 9/9/2020 (Ground Beef). The steps of the flow charts included receiving live animals/chemicals/packaging materials, CCP’s, process inputs/outputs, packaging, storage and shipping of finished products. Hazard analysis identified Biological, Chemical,

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Physical and Radiological hazards of concern including: E. coli O157:H7, Non-pathogenic E. coli O157:H7, Salmonella, STEC O24, O45, O103, O111, O121, O145, Specified Risk Materials (SRM), sanitizer, metal, hard plastic, wood, lead shot, antibiotic residue, needles, fecal material, hair, bruises, abscesses, lactic acid and dry ice. The Harvest HACCP plan listed five CCP’s. CCP1 – Carcass zero tolerance for E. coli O157:H7 and Salmonella, monitoring for zero visible fecal, milk, and ingesta as defined in FSIS Directive 6420.2 using 50 candlepower lighting, documented once per audit (or at failure) on CCP1 form, CCP2 – Carcass Hot Water Wash/Inspection had a critical limit of 198F at the header, and a visual verification that product passed through the cabinet. Hourly monitoring was conducted of the hot water temperature and visual verification of proper coverage. CCP3 – Carcass Lactic Acid Application had a critical limit of 2-5% solution at the mixing tank and temperature range of 75-150F over the carcass and visual verification the product passes thru the cabinet. CCP4 – Offal Lactic Acid Cabinets had a critical limit of 2-5% solution at the mixing tank and temperature range of 75-150F over the carcass and visual verification the product passed thru the cabinet, and CCP5 – Variety Meats Zero Tolerance (Head/cheek meat) of E. coli O157:H7 and Salmonella. Fecal inspections were conducted by inspecting 30 lbs., of both products, once within the first hour, once within the last hour, and once per period of production. The Fabrication HACCP Plan listed two CCP's: CCP F1 – Cold Storage of sub-primal boxed product with a critical limit of < 44.6F within two hours of final packaging time listed on the product label and CCP F2 – Cold Storage of combo boxed product with a critical limit of < 44.6F within two hours of final packaging time listed on the product label. The Ground Meat HACCP Plan listed CCP G1 - Final grinder product temperature, with a critical limit of ≤ 44.6F within two hours of final packaging monitored once per hour of ground beef production per final grind time listed on the case label. Product temperature monitoring was conducted after the final grinder once per production hour. Monitoring activities were conducted by QA or properly trained designated employees. Verification activities included daily direct observation of monitoring procedures, daily record review, and daily thermometer verification. Corrective actions were in accordance with 9 CFR 417.3(a) requirements. CCP records were reviewed from the week of 5/4- 5/8/2020. A deviation was identified for one hour on 5/7/2020 on CCP 5 noting 23 cases of head meat tagged back to the last acceptable check. The failure with plant inspectors resulted in performance coaching of the employee involved in the failure and staff followed up to ensure the employee learned from this incident. The FSQA staff inspected the 30 lb. cases every 30 minutes until four consecutive checks were passed. Validations were conducted quarterly, records were observed for the first three quarters (E. coli O157:H7, and non-E. coli O157:H7). HACCP records were maintained for three years.

Details of non-applicable clauses with justification

Clause/section Justification reference

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3. Food safety and quality management system

3.1 Food safety and quality manual *The site’s Food Safety and Quality procedures were maintained in an electronic Quality Manual and hard copy which was fully implemented and available to relevant facility personnel. The procedures and work instructions were legible, unambiguous, translated, as needed, in Spanish, Koran and Swahili and detailed enough for relevant personnel to understand. The hard copies were maintained in the FSQA office and were available for relevant personnel to view. Reviewed the color-coding policy, dated, 2/1/20 and the slaughter work Instruction, dated 3/23/2019.

3.2 Document Control *Reviewed the Document Control Policy, dated 2/22/2017 which was authorized by the FSQA Manager. A list of controlled SOP’s and documents were listed by title, version, date and reason. Their authorization, original date and current version number were listed in the body of each policy. As documents were updated, they were distributed throughout the plant by giving production and QA management hard copies on the slaughter side and removing the old versions from their respective folders. The Fabrication and Ground Beef areas utilized the electronic versions. As these were updated the change was in effect for the next business day. Production did not have access to change the electronic versions of the documents. The electronic documents were password protected, stored securely and backed up daily, to prevent loss.

3.3 Record completion and maintenance *The Record Completion and Maintenance Policy dated 1/2/2020 was reviewed. Records were legible, maintained in good condition and easily obtained. They were stored securely in electronic form using passwords and authorized access. They were also backed-up daily and retained for 3 years. Errors on manual forms were corrected by placing a single line through the error and initialing. Electronic forms were corrected during the daily document review by typing the correction in the column.

3.4 Internal audits

*The BRC Internal Audit Schedule defined internal audit scheduling and audit requirements, reviewed date 1/2/2020. The frequencies of the audits were based upon risk, activity type and previous audit performance. An internal BRC audit was completed in its entirety annually by covering different sections at least four different times throughout the year. Auditors were independent of their area of responsibility, and maintained internal auditor training certificates from FSNS dated 2/29/12, 1/31/19, and 1/17/19. Completed audit reports were provided of the internal audits conducted against policies developed to meet the BRC standard (Mar, July, August 11 and August 25, 2020). Monthly Housekeeping/Sanitation audits were completed as required by the schedule. Completed reports from the previous twelve months evidenced compliance to 3.4.3 and facility requirements.

3.5 Supplier and raw material approval and performance monitoring

3.5.1 Management of suppliers of raw material and packaging *The HACCP hazard analysis included risk assessments for raw and packaging materials. Supplier approval and monitoring procedures were outlined in the Supplier Approval SOP (QA SOP 8) dated 1/2/20. Suppliers were required to meet all USDA/FSIS requirements and provide third party audit results or supplier audits which include traceability, product safety HACCP review and good manufacturing practices (GMP’s), control of non-conforming product, trace system in place, quality and food safety evaluation of product provided, allergen control program, certificate of analysis (COA), new supplier risk

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assessment, supplier questionnaire (low risk products), letters of guarantee (LOG) and product specifications. Live cattle suppliers submitted signed Producer’s Wholesomeness Certificate and Market/Dealer Certificates every three years. Certificates were verified weekly against the FSIS Repeat Violator List. Approval was based on historical relationships with the site. The site did not purchase from brokers. Supplier approval documents were reviewed and compliant. The site conducted supplier monitoring through the ability to meet company requirements, LOG’s, third party audits, supplier questionnaires, HACCP reviews, GMP’s and allergen control program compliance. Approved suppliers were listed on the List of Approved Suppliers/Services dated 8/14/20. Exceptions were permitted (in dire situations or products used for research and development)) with corrective actions (CA) in place. Prior to purchasing from non-approved vendors, incoming goods were inspected and verified through testing, if needed. Suppliers were reviewed every three years at a minimum, or as needed.

3.5.2 Raw material and packaging acceptance, monitoring and management procedures *Raw Material and Packaging Receiving and Monitoring Procedures required incoming trailers to be sealed, clean and in good physical condition. Suppliers were verified as listed on the List of Approved Suppliers. The Raw Material Receiving Policy (GB SOP 1), dated 1/2/20, explained the procedures for receiving boneless beef from external suppliers. Meat trailers were maintained ≤40F. Shipments required a COA indicating products were tested for E. coli O157:H7 and found negative. The Material Receiving Policy (CP 24), dated 1/2/2020, listed the procedures for receiving packaging and chemicals. Packaging, raw materials, and ingredients were inspected organoleptically. Live animals were subjected to FSIS ante- mortem inspection. Inspections were recorded on the electronic Receiving Log.

3.5.3 Management of suppliers of services *Supplier Raw Material Vendor Phone list was viewed showing approved suppliers as active. This list also included the type of material purchased and phone contact. The Service Approval and Performance Monitoring SOP, dated 1/2/20, listed procedures for service supplier approval and monitoring. Suppliers were approved based on historical relationship, required to provide a LOG indicating there was no potential food safety risks associated with the services and a signed contract. Contracted services included pest control, laundry, pathogen laboratory testing, certifying bodies, sanitation, select maintenance services, food vendor and waste removal. Signed contracts provided for sanitation and laboratory services were reviewed and current. Service suppliers were monitored for the quality of services provided.

3.5.4 Management of Out sourced processing

*Processing was not outsourced.

3.6 Specifications *The Finished Product Specification (QA SOP 18), dated 1/2/2020, explained the process for customer specifications approval. If no formal specifications were agreed upon, then the schedule was the approved specification. Specifications were developed for raw and finished products. Hard copy and electronic versions were maintained. Specifications were reviewed for raw beef trim, dated 1/2/20, (lean point was verified through in-plant testing conducted on every batch of product). Information listed was necessary to manufacture their products, such as: ingredients, UPC code, GTIN, pack size, box type, product weight, container weight, product temperature, shelf-life, boxes per pallet and product packaging. A finished specification was reviewed for Niman Coarse Grind 80L, dated 1/2/20, and contained identification information, product description, ingredients, packaging instructions, package and case weights, labeling instructions, storage, shelf life, and palletizing instructions. Specifications were reviewed every three years, or as needed.

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3.7 Corrective and preventive actions *The SSOP Corrective Actions and HACCP Corrective Actions (CP7), both dated 1/2/2020, were reviewed and detailed the procedures for each program to conduct and document corrective action (CA) and preventive action (PA) investigations. Deviations were reviewed for critical control point (CCP) and non- CCP nonconformances. The site utilized the Five-Why analysis procedure to investigate root cause analysis. The documented CA included date of incident, product involved, or issue, amount of product involved, description of incident, product disposition and corrective and preventive actions. Corrective actions were reviewed for an incident involving cheek meat and an issue with condensation dripping from a cooling unit, no product was affected. Root cause analysis of the CA and trends were reviewed during management review meetings.

3.8 Control of non-conforming product *Control of Non-conforming product was listed in the QA Hold Tags (QA SOP 4) SOP, dated 1/2/2020. Procedures covered placing non-conforming product, materials, or equipment on hold. Red QA tags were used to identify non-conforming carcasses, boxes or equipment. Tags were released by QA personnel only and verified daily. The QA Hold Tag Log was utilized to document use of such tags, and included the date, QA name, reason for tag, corrective action, release date, and disposition of product (if applicable). The Hold Log from Ground Beef was reviewed and current.

3.9 Traceability

The Recall Program was implemented which identified recall team, roles, responsibilities, and contact information. Processing aids and packaging materials were traced using manufacturers information. Live animals were tracked using producer information. Finished products were traced using product code and production date.

A vertical exercise was completed during this assessment on product code 10701 85L produced on 5/7/2020. The facility produced 15 combos of finished product which shipped to one customer distribution center. Packaging materials were traced using manufacturers lot information which was documented on the Packaging Product Traceability record. Processing aids were tracked using manufacturers lot information and purchase order which was documented on ASC - Carcass Spray Cabinet log, Lactic Acid - Subprimals and Trim log, and CCP monitoring logs. Carcasses entering fabrication were tracked using a carcass identification number placed at harvest hot scale. Live animals were tracked using producer name and ear tag. The auditor initiated traceability exercise was completed in less than two hours with 100% identified and traced.

Mock recalls were conducted a minimum of twice per year with two mock recalls provided from 2019 and 2020. Each exercise was completed within two hours and included live animals, packaging, processing aids, and finished product to the first point of distribution.

Rework was tracked on production logs which included product code, production date, and date reworked.

3.10 Complaint-handling

*Customer Complaint (QA SOP 24) Procedure outlined procedures, responsibility, investigation, and follow-up for customer complaints received. Complaints were received by the FSQA Manager and communicated to management personnel for investigation and corrective action. Documentation was provided for a quality defect (5/12/20) and a Costco defect (6/10/20), and included investigative results

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which were reported to the customer. Complaints were tracked through an Excel spreadsheet and trended every time a complaint surfaced. The complaints were reported during the management review monthly meetings. Unaddressed trends were not observed.

3.11 Management of incidents, product withdrawal and product recall

*Emergency Breakdowns (QA SOP 9), dated 1/2/2020, outlined the crisis response team, team objectives and considered situations for fire, water damage, or other facility/building disaster, supply chain deficiencies, electrical power outage, labor shortage, bomb threat, plant evacuation, and water safety issues. The Recall Program outlined the FSQA Manager was the recall coordinator, communication plans, recall procedures, product recall team with responsibilities, external contacts, legal counsel, media contacts, support organizations, customer contact list, and mock notification letters. Recall procedures were tested 6/10/2020 in conjunction with the trace exercise described in section 3.9 of this audit. Procedures included provisions to notify the certification body of a recall within three working days.

Details of non-applicable clauses with justification

Clause/section Justification reference

3.5.4 Processes were not outsourced.

3.5.4.1 Processes were not outsourced.

3.5.4.2 Processes were not outsourced.

3.5.4.3 Processes were not outsourced.

3.5.4.4 Processes were not outsourced.

4. Site standards

4.1 External standards The facility was located in a rural area of Kuna, ID. The surrounding areas did not pose a risk to the facility or products produced. Grassy areas and landscaping was maintained and did not create a pest harborage area. External traffic areas were paved and observed in good repair. Pipes through walls from external bulk tanks were sealed to prevent pest entry. Areas for bird roosting were not observed. Openings which might permit pest and contaminant ingress were not observed.

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4.2 Site security and food defence *The Food Defense Plan outlined food security measures, identification of risk, plant security, building access accountability, plant personnel, contractor approval policy, and visitors/delivery. The facility conducted an annual Food Defense Assessment with the most recent dated January 2020. Access to the facility was controlled through locked doors with access codes, security cameras, partial perimeter fencing, and locked external bulk storage. Visitors were required to sign in, read the visitors policy, show identification, and were escorted at all times. Food Defense training for employees was conducted annually through Alchemy. The site conducted Food Defense training in January 2020 with a shelter-in- place exercise on 1/25/20. Training records were reviewed from January 2020. The facility was registered with the FDA Bioterrorism Act ending in 4668. The facility was registered with USDA as Est number 630.

4.3 Layout, product flow and segregation

Site maps indicated the locations of receiving, processing, storage, shipping, risk areas, welfare, and break rooms of the facility. Flow of product, personnel, rework, waste, and inedible materials, were included in the site maps. Access points for personnel, raw materials and packaging materials were identified on the maps. Contractors and visitors were informed ammonia was used on site and were escorted at all times. Sufficient work space was provided for storage and personnel to perform their duties. Temporary structures were not present.

4.4 Building fabric, raw material handling, preparation, processing, packing and storage areas

Walls were constructed of pre-stressed concrete, easily cleanable and in good repair. Floors were constructed of sealed concrete and slip resistant coatings easily cleanable and in good repair. Floors were sloped to drains to prevent pooled water where wet cleaning was utilized. Drains were easily accessible for sanitation. A drain map was provided to show locations and flow through the facility. Ceilings were observed in sanitary conditions. Stairs to overhead platforms and overhead platforms were equipped with kick plates and bottom plates to protect from contamination of materials or personnel below. Ventilation openings were screened and equipped with backdraft prevention louvers and fans. Glass windows were protected in the processing areas. External personnel doors were self-closing and sealed to prevent pest entry. Dock doors and levelers were observed properly sealed. Lighting was sufficient for cleaning and inspection in the facility. Lights were shielded to protect from breakage. ILTs (insect light traps) were located away from products or packaging material and positioned to prevent attraction of insects from the outside. Ventilation was adequate as condensation and dust accumulation were not observed. There were no suspended ceilings.

4.5 Utilities – water, ice, air and other gases

Water was supplied from wells located on the company property. Quarterly water testing from point of use from the slaughter, fabrication and grinding areas for coliforms and residual chlorine was reviewed from 3/19/2020 with acceptable results. Chemical analysis was conducted annually with results provided for 2020. Sites were alternated throughput the year. An up to date water distribution schematic was provided. Backflow prevention testing was conducted annually. Most recent test was conducted on 4/11/20. Filters were utilized on air compressor units in contact with food at a size of 0.3 microns. Air filters were checked 3/30/20 and were set on a monthly preventive maintenance schedule.

4.6 Equipment

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Processing equipment was constructed of stainless steel and other food grade materials and was well maintained. Rough welds, excessive greasing, hollow tubing and metal to metal wear were not observed. Equipment layout and design did not impede maintenance, sanitation or inspections.

4.7 Maintenance

*The Preventive Maintenance Program (QA SOP 26), dated 1/2/20, outlined procedures for maintaining the facility, addressed preventive maintenance, corrective maintenance, the addition of new equipment and procedures for maintaining product safety in the event of unplanned or non-routine maintenance work. Preventive maintenance (PM) was tracked using the Manager Plus (eMaintenance) system. PMs were generated based on the specified frequencies of weekly, monthly, and quarterly inspections based on manufacturer recommendations and facility history. Daily records were reviewed from the Fabrication department (rib, loin line) 8/3, 8/48/12 of various department inspections. Work orders were given to maintenance for work needed each day. Frequencies were adjusted based on inspection results. Temporary repairs were made using approved, cleanable materials and were scheduled for permanent repair as soon as practical as outlined in the Maintenance repair policy. Unplanned work orders required QA inspection prior to release. Tool and part accountability and the restoration of sanitary condition following maintenance on food contact equipment were documented. Tools were cleaned before each task. Food grade greases which did not contain known allergens were used by the maintenance department and segregated from non-food grade greases. Reviewed an allergen letter from Sealed Air for various oils and greases used on their equipment. The maintenance areas were well maintained and organized.

4.8 Staff facilities

Staff facilities included break room, locker room, and toilet areas. Designated changing areas were provided for all personnel. Lockers were provided for storage of outer clothing and personal items for all employees at the facility and inspected daily. Hand wash sinks were provided in restrooms and processing areas. Sinks were equipped with hands free, warm water taps, liquid soap, single use paper towels, waste containers, and hand wash advisory signage. Hand washing was required prior to starting work, after break, eating, smoking, blowing their nose, using the rest room, or other potential contamination. Toilets were provided in sufficient numbers for employees in each department and did not open directly into production areas. Break rooms were provided for employees including shelving for storage of employee lunches. Designated break areas outside were equipped with containers for waste. Smoking including electronic cigarettes was permitted in designated areas equipped with canisters for smokers’ waste. Shelves were provided for storage of employee lunches.

4.9 Chemical and physical product contamination control: raw material handling, preparation, processing, packing and storage areas

4.9.1 Chemical control

The Chemical Control Program outlined procedures for purchasing, segregated storage, restricted access, labeling, and use of chemicals in the facility. SDS were available for employee access. Chemicals were handled in compliance with OSHA and EPA requirements. An approved list of chemicals was provided. The FSQA Manager was responsible for reviewing and approving new chemicals. Strongly scented

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chemicals were not allowed in the production area during operations. Chemicals were observed properly labeled and securely stored in designated locations throughout the facility.

4.9.2 Metal control The Foreign Object Control (CP 10) outlined procedures for controlling knives and blades used in the processing areas. The facility only allowed company-issued safety knives in the processing areas. Knives/hooks were issued to employees who were responsible for maintaining the condition and cleanliness. The items were engraved with the employee initials or numbers. Tools were issued as needed to employees in the Grind Room. Inspections were conducted at the beginning of the shift, throughout the shift and end of each shift and documented on the on the operational sanitation form. Documents reviewed from 5/4/20 were compliant. Staples, paper clips, push pins, and snap off blades were not permitted in production areas. Corrective and Preventative Action Reports were reviewed from the Fabrication Room and QA Tag Log documented during inspections. Records reviewed from 5/5/20 were compliant.

The following minor non-conformity was identified:

4.9.2.1- A blue handled box knife was observed in the case sealer area which did not include identification information.

4.9.3 Glass, brittle plastic, ceramics and similar materials *The Glass and Brittle Plastic Inspection (QA SOP 7) Policy outlined procedures for handling glass and brittle plastic in the facility; breakage procedures included documentation of the incident, responsibility, isolation of the area and potentially affected products, cleaning of the area, inspection and verification to resume production, changing of work wear and inspection of footwear. A Glass and Brittle Plastic List was maintained and included location, type and number of the items present. Daily and monthly inspections were performed to verify the condition of the glass and brittle plastic items. Daily operational records were reviewed from 5/9/20 and monthly recorded inspections were reviewed from the Fabrication Room dated 5/8/2020 and the Ground Beef Room dated 5/4/20. In the Ground Beef Room item G-53 (Pressure gauge) was identified with condensation inside. All records were acceptable. No ceramic steels were used in the production areas. The Glass/Brittle Plastic map was reviewed and found acceptable. Glass training was conducted with the QA Leads and Supervisors on 6/10/20, Training documents were reviewed for plant training from 7/4 and 8/4/20.

4.9.4 Products packed into glass or other brittle containers *Products were not packed into glass or other hard brittle plastic containers.

4.9.5 Wood *The Pallet and Spacer Inspection (QA SOP 16) Policy, dated 1/2/20, described the acceptable condition of wooden pallets. Wood was only present in the plant in the form of wooden pallets. Pallets were inspected prior to entry into the production area. Segregated storage was utilized for damaged pallets. Dump stations in the ground beef area were equipped with two stage dumping to minimize the risk of introducing wood into the process.

4.9.6 Other physical contaminants

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*Foreign Object Control (CP 10), dated 1/2/20, listed debagging and deboxing procedures outlining methods to prevent raw material contamination due to packaging. The facility used metal detectable pens in processing areas.

4.10 Foreign-body detection and removal equipment

4.10.1 Selection and operation of foreign-body detection and removal equipment *A foreign material risk assessment was included in the HACCP plan outlined in section 2.0. Foreign material detection (Metal Detector Check CP 9 dated 1/2/20) included metal and X-ray detection. Devices were located prior to or after packaging. Device monitoring was conducted at a frequency that met customer requirements. The facility was able to isolate and hold potentially affected product in the event of device failure. Documented checks were reviewed and found acceptable.

4.10.2 Filters and sieves

*Filters and sieves were not present.

4.10.3 Metal detectors and X-ray equipment Metal was identified as a physical hazard of concern in HACCP hazard analysis. X-ray (Meat Master) detection was utilized on the round line, and the two trim lines in the fabrication area. Equipment was verified hourly using 3.0mm ferrous, non-ferrous, and stainless-steel standards. Metal detection was implemented in ground beef production at initial grind and final grind. Initial grind metal detector was verified prior to use with 7.0 mm ferrous, 8.0 mm non-ferrous, and 9.0 mm stainless steel standards. Final grind line metal detectors were verified hourly using 2.0 mm ferrous, 2.5mm non-ferrous, and 3.0mm stainless-steel standards. Rework ground beef x-ray was also verified prior to passing product through (and hourly while in use) using 0.8 mm ferrous, non-ferrous, and stainless-steel standards. Memory reset of product rejection systems was verified at each test. Records reviewed from the week of 5/4/2020 in association with the vertical audit were properly completed. Checks were compliant with the exception of 5/9/20. The Meat Master went down and product was diverted to a secondary metal detector. Documents were reviewed which indicated the CA and procedures taken to ensure all product passed through a working metal detector. In the event a detection system failed to detect a standard, product was placed on hold to the last acceptable check, product was reworked through a properly functioning system, and additional employees were utilized to perform 100% product inspection.

4.10.4 Magnets *Magnets were not utilized.

4.10.5 Optical sorting equipment *Optical sorting equipment was not present.

4.10.6 Container cleanliness – glass jars, cans and other rigid containers *Product was not packed into glass jars, cans, or other rigid containers.

4.11 Housekeeping and hygiene

The facility was observed visibly clean and maintained in sanitary condition. Sanitation was conducted by a contract sanitation company (PSSI). Sanitors received training at hire and annually on safety, chemical handling, chemical security, titration, allergens, food defense, GMP’s HACCP, bacteria control, cleaning

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and sanitizing activities, visual inspection, pre-operational inspection, drain cleaning, and equipment specific cleaning techniques. Reviewed employee training documents 6/4-6/6/20 and Supervisor and Lead training on cage security from 5/22/20. Sanitation cleaning instructions were developed and included step- by-step cleaning procedures for cleaning each piece of equipment (including disassembling, if required) or area of the facility. SOP’s for the CO² mixers for lines 1 and 2, cutting boards and refrigeration units were reviewed. A Master Sanitation Schedule (MSS) was maintained, outlined less than daily cleaning and responsibility. The MSS documented the area cleaned, frequency of cleaning, date cleaned and responsible party. SDS and labels were maintained for each chemical. Reviewed documents for KC-505, liquid alkaline cleaner dated 3/8/2016. Chemical concentrations were monitored daily and weekly by the chemical supplier with titration of each chemical used in the facility. Titration records were reviewed. Chemicals were dispensed using an electronic control panel with recipes for each chemical use and restricted user access. Chemicals could only be transported, mixed, or applied by trained personnel. Sanitation effectiveness was verified through visual inspections of the area/equipment, adenosine triphosphate (ATP) swabbing and microbiological swabbing. Visual inspections were performed on a daily basis following the end of the sanitation shift and documented on the Pre-Operational Inspection form. ATP swabbing of five Harvest, seven Fabrication and five Ground Beef sites was conducted daily. Upper limit was less than three relative light units (RLU’s), greater than or equal to three RLU’s required corrective actions. CA included re-cleaning and re-swabbing in the event of an ATP failure. Release of the line was conducted after acceptable results. APC swabbing was conducted weekly by sampling five food contact sites from each area (Harvest, Fabrication and Ground Beef). The upper limit was ≤ 100 cfu/cm. CA included re-cleaning and re-swabbing in the event of an APC failure. Records reviewed for the year indicated failures with multiple pieces of equipment involved with the start-up of a grind line on 1/7/20. The equipment was recleaned and resampled with acceptable results. Equipment sampled 5/8/20 and 8/4/20 indicated acceptable results. The air plate action limit was documented at 100 cfu/cm² as outlined in the Pre-op policy. Drains were sampled monthly for Listeria and Salmonella. Results from testing were reviewed for the week of 5/4/20. Cleaning equipment was suitable for intended use.

The following non-conformity was identified:

4.11.2- There was no documentation of quarterly cleaning of seven refrigeration units on the Master Sanitation Cleaning Schedule (units 24, 25, 28, 30, 32, 37S and 37N).

4.11.7 Cleaning in place (CIP)

*CIP was not utilized.

4.11.8 Environmental monitoring

*Environmental Testing SOP defined sanitation verification requirements. ATP swabs were collected daily from five contact and non-contact surfaces each in each area, which were selected through a random number generator. Action limit was established at 3 RLU, and corrective actions for swab failures included re-cleaning, sanitizing, and swabbing of tested items. APC swabs were collected from five randomly selected surfaces weekly. Action limit was established at 50,000cfu/sq. cm. Listeria spp. swabs were collected on five randomly selected drains per area per month. Corrective actions in the event of a presumptive positive included intensified cleaning, re-training of sanitation employees, and intensified swabbing. Trending of swab results for 2020 did not identify negative trends. Pre-operational findings, swab failures and results, effectiveness of the environmental monitoring program were reviewed annually, most recently on 1/2/20.

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4.12 Waste

Waste was collected in color-coded, dedicated containers and removed from the site on an as needed basis by a third party. A certificate of destruction for SRM product was reviewed from 2/18 and 5/4/20. A license was not required by the state of Idaho for waste removal. Waste flow observed did not pose a product contamination risk.

4.13 Management of surplus food and products for animal feed

Waste collection was provided by a local licensed waste company. A corporate letter regarding the handling of inedible product made into animal feed was provided for review but not required at this site since no products were intended for animal feed. The Surplus Foods and Pet Food Products (QA SOP 12) dated 1/2/20 for customer-branded products explained surplus foods were eligible for plain packaging with generic labels to sell to other customers. Products eligible for employee sale or donation did not meet customer specifications, but met regulatory requirements.

4.14 Pest management

Integrated Pest Management was contracted to Sprague. License, insurance, and certifications were current. Weekly services included interior and ILT traps. Monthly service was provided for exterior bait stations. Interior traps were appropriately located and maintained to prevent contamination. Exterior bait stations were secured and tamper resistant with bait anchored inside. ILTs were appropriately located to prevent contamination of product. A current site map dated 1/14/20 detailed bait stations, interior traps and ILT’s. The pest sighting log was maintained including pest, location, additional comments, and action taken. An approved pesticide log, pesticide labels and SDS were available for review. Viewed the SDS and labels for Contract All Weather Blox. Pesticides were not stored on site. An annual survey of the pest control system was conducted by the supervisor of the pest control technician on 1/27/20. The report was reviewed. Service reports included service comments, material summary, open conditions, conditions resolved this visit, pest summary, device summary, area inspections, device inspection details, and material application details. Pest control devices included a barcode for scanning during service. A work request was provided with a corrective action report for recommendations made by the PCO for plant start-up, since then, no issues were identified. Inspections for bird entry points and nesting areas were monitored during monthly inspections. In the event of infestation, or evidence of pest activity action was taken to identify potentially affected product and to minimize the risk of product contamination. Any potentially affected products followed the QA Hold program. Employees received pest awareness training during annual GMP training.

4.15 Storage facilities

The Materials Receiving Policy, dated 1/2/20, defined product, chemical and packaging material storage requirements. Packaging and incoming ingredients were stored separately from finished product. Obsolete packaging materials were tagged and segregated for disposition. Chemicals were stored in totes in the chemical storage area. Carcasses, raw materials and finished products were stored in refrigerated coolers. First in-first-out (FIFO) rotation was verified through the Canopy electronic system. Materials were observed stored off the floor and in racks away from walls. Partially used packaging was returned to the warehouse and properly protected. Each pallet of finished goods was identified with a pallet identification number based on date of production and ensured proper rotation of finished product. Plant Temperatures SOP explained temperatures of refrigerated areas were monitored continuously through an electronic

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alarm system. Alarm notifications were received by site management and maintenance technicians in the event ambient temperature parameters were exceeded for more than two hours. Temperatures were visually verified by QA at a frequency of once per production period. Fabrication, offal, and ground beef processing areas were maintained at or below 50F. Product storage coolers and hot boxes were maintained at or below 40F. Storage freezers were maintained at or below 5F. Temperature monitoring and verification records reviewed in association with the vertical audit were within defined parameters.

4.16 Dispatch and transport

*Trailer Inspection Policy (QA SOP 15) dated 1/2/20 outlined trailer acceptability, inspections, general loading requirements, temperatures and product safety prior to shipping and during transport. Trailers were pre-chilled to below 44.6F prior to loading. Trailer conditions were documented on the Trailer Inspection Form. Records reviewed from the week of 5/4/20 demonstrated program compliance. Outbound trailer inspections included temperature monitoring and condition. Forklifts were observed properly maintained to prevent contamination. Temperature monitoring devices were required on trailers depending on customer specific requirements. Transporter agreements outlined securing of trailers during transit, restriction of mixed loads, and actions to take in event or breakdown, accident, or unit failure.

Details of non-applicable clauses with justification

Clause/section Justification reference

4.3.5 Temporary structures were not present.

4.4.5 There were no suspended ceilings.

4.13

4.13.1

4.13.2

4.13.3

4.14.3 Pest control was contracted.

4.15.4 Controlled atmosphere storage was not present.

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4.15.5 Outside storage was not utilized.

4.9.4.1 Products were not packed into glass or other hard brittle plastic containers.

4.9.4.2 Products were not packed into glass or other hard brittle plastic containers.

4.9.4.3 Products were not packed into glass or other hard brittle plastic containers.

4.10.2.1 Filters and sieves were not present.

4.10.2.2 Filters and sieves were not present.

4.10.4.1 Magnets were not utilized.

4.10.5.1 Optical sorting equipment was not present.

4.10.6.1 Product was not packed into glass jars, cans, or other rigid containers.

4.10.6.2 Product was not packed into glass jars, cans, or other rigid containers.

4.11.7.1 CIP was not utilized.

4.11.7.2 CIP was not utilized.

4.11.7.3 CIP was not utilized.

4.11.7.4 CIP was not utilized.

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5. Product control

5.1 Product design/development

*Product Design and Development Policy (QA SOP 11) outlined finished product specification development, new product/changes to formulas, formula maintenance, packaging, and shelf life testing. Initiation of new products were communicated to the site from the corporate sales team. Changes were made by FSQA Manager. Processing trials were conducted during new product development to assess process capability, quality, and safety. HACCP plan review was conducted for new products, ingredients, or changes to existing products. Once approved, trial production and shelf-life testing of sample finished products was conducted. New product shelf life testing included: microbiological, chemical and/or organoleptic criteria. The site had not developed new products in the past twelve months. Records were reviewed from on-going shelf life testing started 2/20/20.

5.2 Product labelling

*The Labeling Products (QA SOP 14) defined the new label approval process and requirements. New labels were approved by USDA/FSIS. Labels were reviewed when changes were made to product specifications, and required approval from the FSQA Manager. Label changes were automatically entered into the electronic printing system. Labels are printed in-house but received from its corporate facility. Label and film verification's were conducted against an approved proof at receiving, once per production period, and at product changeovers. Records reviewed in association with the vertical audit from the week of 5/4/20 and during the facility tour demonstrated program compliance. Label approval was reviewed for Boneless Beef for Cooking Only, dated 6/22/2017 and Natural Beef dated 8/9/2017, records demonstrated compliance.

5.3 Management of allergens

*Allergen ingredients were not utilized at the site. Potential allergen contamination GMP requirements explained hand washing was required after eating and drinking, after using the restroom, and when hands became contaminated. Visitors and contractors received allergen awareness through GMPs at arrival. Risk assessment for potential allergen contamination was included in the HACCP hazard analysis as discussed in section 2 of this assessment.

5.4 Product authenticity, claims and chain of custody

*A vulnerability assessment was conducted on 3/12/2020 for each of the raw materials and ingredients used at the facility. Grade change monitoring form was observed for the period of 5/4 – 5/8/20. Natural products were scheduled first of the day then change-over to regular products. The grades were scheduled starting with highest grade first then allow time for product changes. This is all documented on the grade change form. The assessment included fraud or adulteration, motivations, controls in place, and history of each raw material. The facility kept informed of fraud or adulteration risks through reviewing information from USDA and BIFSCO (Beef Industry Food Safety Council). The facility maintained a Halal Certification, the current certificate was issued by Islamic Society of California. Procedures were implemented to maintain product identity throughout processing. The Carcass Separation Program (SL SOP 1), dated 1/2/20, documented cattle grades as less than/or greater than 30 months and the grading requirements for prime, choice and select. Yields were conducted daily by accounting personnel to ensure

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mass balance was achieved. The Beef Vulnerability Assessment was dated 3/12/20 and was reviewed annually, or as needed.

5.5 Product packaging

*Packaging specifications and certificates of conformity were maintained for each packaging material supplier. Packaging materials were verified at receiving by QA and were stored away from ingredients and finished products. Raw material liners used in processing were appropriately colored and tear resistant. Storage Procedures (FAB SOP 17) dated 1/2/20 described obsolete packaging and labels were segregated from use until disposition. No packaging materials were discarded in the past 12 months. Approved supplier Sealed Air documents consisted of GFSI certification, Certificate of Conformance dated 1/19/20, and Letter of Guarantee (LOG) dated 1/12/20. Packaging material supplier BMSI (Veritive distributor) sent COC dated 11/6/2019.

5.6 Product inspection and laboratory testing

5.6.1 Product inspection and testing

*Finished product testing conducted included E coli, APC, total coliforms and Salmonella. Microbiological testing for 21 day old 80 Lean Ground Beef was conducted on 2/20/20 and included APC, lactic acid bacteria, organoleptic analysis, appearance, package integrity, color, odor and texture. Records were also reviewed for 7 Day SL 90 Lean Boneless Trim on 2/28/20, 45-day SL Hand trim Shuck Roll. Results were acceptable. Shelf-Life Study (QA SOP 20) outlined the bi-annual requirements (or as needed) of conducting shelf-life analysis. Shelf life testing was conducted on an ongoing basis. Products were evaluated for organoleptic qualities, aerobic plate count (APC), upper limit greater than or equal to 50,000 cfu/cm2, and Lactic Acid Bacteria at pre-determined intervals up to the stated shelf life. Shelf life testing reports supported current shelf life claims. Generic E. coli 1 out of 300 head produced per regulatory requirements was conducted in harvest. Swabs were conducted quarterly on 10 head at hide on, hide off, after pre-wash, before hot water, after hot water, after lactic, after chill, after ASC. Swabs were analyzed for APC and results from 2019 and 2020 quarters were provided for review. Variety meats (hearts, head meat, cheek meat, salivary glands) were sampled for E. coli O157:H7 each lot produced where a lot was a production day. Trim was sampled for E. coli O157:H7 on each bin produced with up to five bins considered as a lot. Ground beef was sampled E. coli O157:H7 per customer request on every 10,000 pounds produced for that customer. APC, coliform, and generic E. coli sampling was conducted per 10,000 pounds of ground beef produced per customer requirements.

5.6.2 Laboratory testing

*The facility utilized a third party laboratory for routine and pathogen testing. Laboratory utilized maintained ISO/IEC 17025:2005 accreditation through A2LA with a certificate valid until 7/31/21. An onsite laboratory was not in use.

5.7 Product release

Products were subject to pre-shipment records review in accordance with regulatory requirements conducted at the end of each production day. If product was not identified out of specification or placed on hold for any reason, it was acceptable to ship. Finished products were released via the On Hold and

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Release Policy by QA after record review of CCP monitoring and batch information was completed, and finished product testing was complete. A lot was defined as between one and five combos. Products requiring positive release were head/cheek/salivary glands. Customer requirements dictated sampling. If a positive result was obtained from the lab it was placed on QA hold, if present. If not, product was returned or stopped from delivering. Affected product on hold was then used for cooking only. Once a cooker was found the product was shipped, case counts verified and cooker sends verification of lethality of cook. Record reviewed from 2/19/20 with lethality treatment on 4/3 and 4/6/20.

5.8 Pet Food

Pet food was not produced on site.

Details of non-applicable clauses with justification

Clause/section Justification reference

5.2.3 Claims were not made.

5.3.2 Allergens were not utilized.

5.3.3 Allergens were not utilized.

5.3.4 Allergens were not utilized.

5.3.5 Allergens were not utilized.

5.3.6 Allergens were not utilized.

5.3.7 Allergens were not utilized.

5.3.8 Allergens were not utilized.

5.8 Pet food was not produced on site.

5.8.1 Pet food was not produced on site.

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5.8.2 Pet food was not produced on site.

5.8.3 Pet food was not produced on site.

5.6.2.2 An onsite laboratory was not present at the facility.

6. Process control

6.1 Control of operations

The Validation Study for E. coli O157:H7, Salmonella, and Listeria monocytogenes in Ground Turkey and Beef conducted by R.Y. Murphy et. al involved a cross-functional team from the University of Arkansas, dated 2004 was used to support the decision to note their products were required cooking to 165F. Specifications outlined component assembly, code date, and packaging requirements. Specifications were utilized to communicate processing activities to employees on each line. Product quality audits were completed on each product category. Equipment adjustments were made by authorized individuals. Critical areas were either locked by a key or code access such as metal detectors, x-rays, equipment adjustments, mechanical areas and process computers. Incoming materials were inspected for product integrity. Product changeovers were monitored and recorded on the processing paperwork. Label and code date verification was completed once a period or at each product change over and recorded on the audit form which included a control label. Metal detection, x-ray and scale calibration verification were recorded on operational forms. In the event of a deviation, products were retained and assessed for quality and safety prior to release. Corrective and preventive actions were recorded on the corrective action form.

6.2 Labelling and pack control

Grade Change Policy (QA SOP 34), dated 1/2/20, stated label verification was conducted at receiving for accuracy of information. Labels were also verified when issued to production, change-overs, and end of shift. Line clearance verification was included on the Product Change Monitoring Form. Product changeovers were observed and found acceptable. Labels were removed from the line and the current product label was placed in-line. Records were reviewed from the week of 5/4/20 and acceptable. A Boxed Product Return form, dated 1/2/20, was reviewed from 5/9/20 with documented checks conducted for the day. Production employees documented non-conforming label issues and notified QA for correction with documented release.

6.3 Quantity, weight, volume and number control

Finished product (individual package or case weight) sold as net weight was in accordance with NIST 133 handbook. Net weight verification was conducted every hour of production and documented on the Box Weight Inspection Check (GB SOP 10). Maximum allowable variances (MAV) were established for each finished product weight. When an MAV limit was exceeded products were retained to the last acceptable check. Tares were verified at the beginning of production and at change-overs. Products were required to

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meet the stated package weight and labels were pre-printed. Checkweigher verification was performed daily by the maintenance staff. Scale Calibration Check (GB SOP 14), dated 1/2/20, lists procedures to ensure the scales were functioning properly. Records reviewed from the week of 5/4/20 were completed at the established frequency and met product stated weights. A third-party check of the scales was completed annually.

6.4 Calibration and control of measuring and monitoring devices

Equipment Calibration Policy outlined calibration frequencies of thermometers, scales, pH meter, moisture meter, and water meters. Thermometers were calibrated daily using the methods recommended by Kansas State University. The method included using dial and digital thermometers and an NIST certified thermometer. The NIST certification was dated 4/24/20. Scales were calibrated annually, valid through USDA Packers and Stockyards Program, and verified daily using certified weights valid through 3/12/21. The In-line Fabrication Carcass Cabinet pH meter was calibrated quarterly by a third-party vendor utilizing 4.0 and 7.0 buffer solution standards in accordance with manufacturer’s directions. Records were reviewed and demonstrated compliance. Product measured with equipment found significantly out of calibration followed the On-Hold and Release Policy. Devices which could not be calibrated were removed from service. Procedures in the calibration policy listed instructions for product assessment in the event a device was found out of calibration.

Details of non-applicable clauses with justification

Clause/section Justification reference

7. Personnel

7.1 Training: raw material handling, preparation, processing, packing and storage areas

Training was conducted at date of hire and annually for employees and included good manufacturing practices (GMPs), sanitation, HACCP, chemical control, food defense, allergens, pest awareness, and job specific tasks. Temporary employees were not employed. Visitors were required to sign in, read the visitors policy including GMPs, hand washing procedures and ammonia awareness and show identification. CCP training was conducted annually as job specific tasks. CCP training records were verified for CCP monitors observed during the on-site assessment. Employees related to packaging were appropriately trained. Training records reviewed from 4/13 and 4/14/20 for the Fabrication department, 5/19 and 8/5/20 for Harvest and 6/15-6/22 for Ground Beef. The records included date, trainer, trainee,

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duration, and topic. Training competency was assessed through on the job observation and quizzes. Internal training reference materials were maintained.

7.2 Personal hygiene: raw material handling, preparation, processing, packing and storage areas

GMP Policy outlined hygiene requirements. Jewelry including watches, false nails, and nail polish were not permitted in the facility. Strongly scented after shave or perfume was not permitted. Hand washing was required before and after work, after every break, including lunch, smoke and restroom breaks. GMPs were monitored daily by QA. Blue metal detectable bandages were provided for employees with minor cuts and covered with a glove. Metal detection checks on bandages were performed and the purchase order number was recorded to enable tracking. Records were reviewed from 7/6/20 and demonstrated compliance with the program. Personal medicines were stored in employee lockers and not permitted on the production floor without a doctor’s note.

7.3 Medical screening QA SOP 1 GMP Policy outlined persons with communicable disease, infected or open boils, lesions and sores were not permitted in production or storage areas. Persons with such symptoms were to report conditions to supervisors or management. Visitor Policy outlined requirements for visitor health requirements. COVID-19 monitoring procedures put in place were: Temperatures monitored by IR, health screening at entrance, hand sanitizer stations installed all over the facility, hygiene/hand washing focus, plexiglass dividers installed in break areas, mask wearing for all employees, barriers in hallway to aid in one-way single file lines, temperature checks at break times and visitor screening/temperature monitoring.

7.4 Protective clothing: employees or visitors to production areas

Protective clothing requirements were outlined in the GMP Policy. Protective clothing was defined as plant coats and uniforms. Color coded frocks were provided with snap closures and without pockets above the waist. Frocks were laundered by a third-party service provider, delivered protected and stored separately from dirty laundry. ATP swabs were conducted on employee frocks daily. Records were reviewed from 9/17/20 with acceptable results. The results were totaled to date and trended. Hairnets and beard nets were required in processing areas. Mustaches were covered per company policy. Protective clothing was changed upon soiling or as needed, at least daily. Employees handling product were required to wear blue plastic disposable gloves. Gloves, arm guards, and aprons were cleaned or changed as often as necessary to prevent product contamination.

Details of non-applicable clauses with justification

Clause/section Justification reference

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8. High-Risk, High-Care and Ambient High-Care Production Risk Zones

8.1 Layout product flow and segregation in high-risk, high-care and ambient high-care zones

Low-risk.

8.2 Building fabric in high-risk and high-care zones

Low-risk.

8.3 Maintenance in high-risk and high-care zones

Low-risk.

8.4 Staff facilities for high-risk and high-care zones

Low-risk.

8.5 Housekeeping and hygiene in the high-risk high-care zones

Low-risk.

8.6 Waste/Waste disposal in high risk, high care zones

Low-risk.

8.7 Protective clothing in the high-risk high-care zones

Low-risk.

Details of non-applicable clauses with justification

Clause/section Justification reference

8.1 Low-risk.

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8.1.1 Low-risk.

8.1.2 Low-risk.

8.1.3 Low-risk.

8.1.4 Low-risk.

8.2.1 Low-risk.

8.2.2 Low-risk.

8.3.1 Low-risk.

8.3.2 Low-risk.

8.3.3 Low-risk.

8.4.1 Low-risk.

8.5.1 Low-risk.

8.5.2 Low-risk.

8.5.3 Low-risk.

8.6.1 Low-risk.

8.7.1 Low-risk.

8.7.2 Low-risk.

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8.7.3 Low-risk.

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9 - Traded Products 9.1 Approval and performance monitoring of manufacturers/packers of traded food products Voluntary Module not Included.

9.2 Specifications

Voluntary Module not Included.

9.3 Product inspection and laboratory testing

Voluntary Module not Included.

9.4 Product legality

Voluntary Module not Included. 9.5 Traceability Voluntary Module not Included.

Module 11: Meat supply chain assurance

Scope 11.1 Traceability

Voluntary Module not Included.

11.2 Approval of meat supply chain

Voluntary Module not Included.

11.3 Raw material receipt and inspection

Voluntary Module not Included.

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11.4 Management of cross-contamination between species

Voluntary Module not Included.

11.5 Product testing

Voluntary Module not Included.

11.6 Training

Voluntary Module not Included.

Module 12: AOECS Gluten-free Foods

Scope 12.1 Senior management

Voluntary Module not Included.

12.2 Management of suppliers of raw materials and packaging

Voluntary Module not Included.

12.3 Outsourced production

Voluntary Module not Included.

12.4 Specifications

Voluntary Module not Included.

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12.5 Management of gluten cross-contamination

Voluntary Module not Included.

12.6 Management of incidents, product withdrawal and product recall

Voluntary Module not Included.

12.7 Labelling

Voluntary Module not Included.

12.8 Product inspection and laboratory testing

Voluntary Module not Included.

Module 13 FSMA Preventive Controls Preparedness Module

Version 2 July 2018

Item Clause Module item Conforms Comments no. (Y/N) or Not Applicable (NA) 1 13.1.1 Handwashing areas, dressing and NA locker rooms, and toilet rooms Voluntary Module not Included. must have adequate lighting.

2 13.1.2 Water distribution system must NA Voluntary Module not Included. prevent backflow from, or cross- connection between, piping

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systems that discharge waste water or sewage.

3 13.1.3 All food contact surfaces of plant NA equipment and utensils used in manufacturing, processing, packing, or holding food must be corrosion resistant.

Seams on food-contact surfaces must be smoothly bonded or Voluntary Module not Included. maintained so as to minimize accumulation of food particles, dirt, and organic matter and thus minimize the opportunity for growth of microorganisms and allergen cross-contact.

4 13.1.4 Ice used in contact with food must NA be manufactured in accordance with Good Manufacturing Practice Voluntary Module not Included. (GMP) requirements of 21 CFR 117.

5 13.1.5 Where defect action levels (DAL) NA are established for a food, quality control operations must reduce defects to the lowest level possible. Voluntary Module not Included.

Defect levels rendering the food adulterated may not be reduced by mixing the food with another lot. 6 13.1.6 The hazard analysis must NA additionally identify and evaluate the following known or reasonably foreseeable hazards, which are associated with the food or facility: • Economic adulterants which affect food safety Voluntary Module not Included. • Environmental pathogens where ready-to-eat (RTE) food is exposed to the environment prior to packaging and the packaged food does not receive a kill step • Radiological hazards

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• Unintentional adulterants which affect food safety 7 13.1.7 All identified known or reasonably NA foreseeable hazards must be evaluated to determine “hazards Voluntary Module not Included. requiring a preventive control” (i.e., significant hazards).

8 13.1.8 Establish one or more preventive NA control(s) for each identified “hazard requiring a preventive control” (i.e., significant hazard) such that the control significantly minimizes or prevents the food manufactured, processed, packed, Voluntary Module not Included. or held by the facility from being adulterated under section 402 of the Federal Food, Drug, and Cosmetic Act or misbranded under section 403(w) of the Federal Food, Drug and Cosmetic Act.

9 13.1.9 Evaluate and update the recall and NA withdrawal procedure as necessary to ensure it contains procedures and responsibility for the following: • Notifying consignees of how to return or dispose of recalled product Voluntary Module not Included. • Conducting effectiveness checks to verify recall is carried out • Appropriate disposal (i.e., destroy, divert, repurpose) of recalled product 10 13.1.10 Establish monitoring activities and NA a written procedure for each preventive control consistent with Voluntary Module not Included. the requirements of BRC section 2.10.

11 13.1.11 Establish corrective action NA procedures when preventive controls are not implemented Voluntary Module not Included. consistent with the requirements of BRC sections 2.11 and 3.7.

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Corrective action procedures must be established and implemented when the presence of a pathogen (or indicator organism) is detected as a part of verification activities (i.e., product testing and/or environmental monitoring).

12 13.1.12 Validate all established process NA controls prior to implementation of the food safety plan, upon changes requiring re-validation or within 90 calendar days of the first food Voluntary Module not Included. production.

Validate allergen, sanitation and supply-chain controls as appropriate to the nature of the hazard, control and facility. 13 13.1.13 The PCQI (or authorized designee) NA reviews monitoring and corrective action records within 7 days. Where an alternate timeframe exceeding 7 days is used, the PCQI must document justification. Voluntary Module not Included. The PCQI (or authorized designee) reviews verification records for all preventive controls (e.g., calibration records, product testing, supply-chain audits) within a reasonable timeframe after the record is created. 14 13.1.14 Where product testing for a NA pathogen (or indicator organism) or other hazard is used as a verification activity, a scientifically valid and written testing procedure must identify the following: • Sampling procedure to include method, quantity, frequency, and number of Voluntary Module not Included. samples • Analytical method • Laboratory conducting analysis • Corrective action procedure where pathogen is detected

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15 13.1.15 Where environmental monitoring NA for a pathogen (or indicator organism) is used as a verification activity, a scientifically valid and written testing procedure must identify the following: • Adequate number and location of sample sites Voluntary Module not Included. • Timing and frequency of sampling • Analytical method • Laboratory conducting analysis • Corrective action procedure where pathogen is detected

16 13.1.16 Devices used to verify preventive NA Voluntary Module not Included. controls must be calibrated. 17 13.1.17 Identify a Preventive Controls NA Qualified Individual (PCQI) responsible for developing the food safety plan, validating preventing Voluntary Module not Included. controls, review of records, and reanalysis of the plan.

Document the PCQI’s training and qualification via job experience. 18 13.1.18 All records required by 21 CFR § NA 117 must include: • Date and time of activity being documented • Signature/ initials of individual performing Voluntary Module not Included. activity or conducting record review • Information to identify the facility (e.g., name and location) • Identity of the product and lot code where applicable 19 13.1.19 The owner, operator or agent in NA charge of facility must sign and date the written food safety plan Voluntary Module not Included. initially and then upon any changes following reanalysis.

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20 13.1.20 All documents and records relating NA to the food safety plan (i.e., all records required by 21 CFR § 117) must be retained at the facility for 2 years after the record is created. Voluntary Module not Included. Where records are stored offsite, they must be retrievable within 24 hours with the exception of the food safety plan, which must remain onsite.

21 13.1.21 Where a hazard requiring a supply- NA chain-applied control is identified in the hazard analysis, the receiving facility must establish and implement specific supplier approval and verification activities. Voluntary Module not Included. Where a hazard requiring a supply- chain-applied control is identified AND the control is applied by an entity other than the receiving facility’s supplier, the receiving facility is responsible for verifying implementation of the control. 22 13.1.22 Supplier approval must be NA documented before receiving and using raw materials and ingredients. Voluntary Module not Included. Verification activities must be conducted before receiving and using raw materials and ingredients on a temporary basis from unapproved suppliers. 23 13.1.23 One or more supplier verification NA activities (defined in § 117.410(b)) must be conducted for each supplier before using raw materials Voluntary Module not Included. and ingredients AND periodically thereafter at an adequate frequency.

24 13.2.1 Human food by-products held for NA distribution as animal food must be held under conditions that will Voluntary Module not Included. protect against contamination, including the following:

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- During holding, human food by- products for use as animal food must be accurately identified.

* Labeling that identifies the product by the common or usual name must be affixed to or accompany the human food by- products for use as animal food when distributed.

* Shipping containers (e.g., totes, drums, and tubs) and bulk vehicles used to distribute human food by- products for use as animal food must be examined prior to use to protect against the contamination of animal food from the container or vehicle when the facility is responsible for transporting the human food by-products for use as animal food itself or arranges with a third party to transport the human food by-products for use as animal food.

25 13.3.1 A Qualified Individual (QI) is NA responsible for developing the site’s food defense plan, conducting a vulnerability assessment, identifying mitigation strategies, and conducting a reanalysis of the plan. The QI Voluntary Module not Included. responsible for developing the food defense plan shall be identified on the site’s organizational chart.

One or more QI’s shall be responsible for implementing mitigation strategies at actionable process steps. 26 13.3.2 The site shall have a written food NA defense plan, which includes the following: Voluntary Module not Included. • A vulnerability assessment identifying significant vulnerabilities and actionable process steps

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• Mitigation strategies appropriate to reduce the vulnerability • Procedures for food defense monitoring, corrective action and verification 27 13.3.3 A written vulnerability assessment NA shall be prepared for each food type manufactured, processed, packed, or held, which evaluates the following key criteria (at a minimum): • Scale and severity of threat if a contaminant is added to product • Degree of physical access to the product • Ability of an attacker to Voluntary Module not Included. successfully contaminate product—including consideration of an inside attacker A vulnerability assessment shall be documented for each food type regardless of the outcome and provide justification as to why each point, step or procedure in the operation was or was not identified as an actionable process step.

28 13.3.4 Written mitigation strategies shall NA be established and implemented for each actionable process step identified in the vulnerability assessment. Voluntary Module not Included. Justification shall be documented explaining how the strategy significantly minimizes or prevents the vulnerability.

29 13.3.5 Written monitoring procedures shall NA be established and implemented to Voluntary Module not Included. include the activity and frequency for monitoring food defense mitigation strategies.

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Procedures shall include recordkeeping requirements for all monitoring activities. 30 13.3.6 Written corrective action NA procedures shall be established and implemented when mitigation strategies are not properly implemented. The procedure shall include the following criteria: • Method for identifying and Voluntary Module not Included. correcting a lack of implementation • Method for reducing the likelihood of recurrence • Recordkeeping requirements for corrective actions 31 13.3.7 Written verification procedures NA shall be established and implemented to ensure that food defense monitoring and corrective action are performed according to procedures. Verification procedures shall describe activities to verify implementation of mitigation strategies.

Verification procedures shall include: • A review of monitoring and corrective action records within an appropriate Voluntary Module not Included. timeframe (e.g., 7 days) • Other verification activities as appropriate (e.g., internal audit) • Method for verifying that reanalysis of the food defense plan was conducted • Frequency for verification activities • Recordkeeping requirements of all verification activities

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32 13.3.8 Reanalysis of the food defense NA plan shall be documented and performed every three years or whenever • A change in facility operations which creates a new significant vulnerability • Knowledge about a new threat applicable to the Voluntary Module not Included. food or facility becomes known • Mitigation strategies are not implemented as intended • FDA requires reanalysis based on new threats or scientific evidence 33 13.3.9 All records required by 21 CFR § NA 121 must include: • Date and time of activity being documented • Signature/ initials of individual performing Voluntary Module not Included. activity or conducting record review • Information to identify the facility (e.g., name and location) • Identity of the product and lot code where applicable 34 13.3.10 The owner, operator or agent in NA charge of facility must sign and date the written food defense plan Voluntary Module not Included. initially and then upon any changes following reanalysis.

35 13.3.11 All documents and records relating NA to the food defense plan (i.e., all records required by 21 CFR § 121) must be retained at the facility for 2 years after the record is created. Voluntary Module not Included. Where records are stored offsite, they must be retrievable within 24 hours with the exception of the food defense plan, which must remain onsite.

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36 13.4.1 Vehicles and transportation NA equipment must be maintained and stored in a sanitary condition appropriate for the intended use to prevent food from becoming unsafe during transportation. Where inspection reveals that vehicles or containers are not in a clean condition, they shall not be used. Voluntary Module not Included. A documented procedure shall describe cleaning and storage practices of all vehicles and transportation equipment maintained by the site whether leased or owned and as appropriate for the intended use. The procedures shall be fully implemented. Cleaning activities shall be recorded. 37 13.4.2 The site shall ensure that contracts NA with U.S. shippers, receivers, loaders, and carriers specify their responsibility for compliance with FSMA’s Sanitary Transportation rule. Where the site acts as the shipper or receiver, it shall ensure compliance with the rule.

Voluntary Module not Included. Responsibilities shall ensure transportation operations are conducted in a manner to prevent food from becoming unsafe during transport (i.e., apply controls) and that responsibility for compliance with the regulation is assigned to competent supervisory personnel.

38 13.4.3 Where the site arranges NA transportation, it shall document sanitary design requirements and cleaning procedures of vehicles appropriate for the type of food to be transported. These requirements shall be Voluntary Module not Included. communicated to the loader and carrier.

Where the site does not arrange transportation, the above provision shall be documented in the shipping service contract to ensure

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the shipper documents sanitary specifications of vehicles for the loader and carrier, which are appropriate for the type of food. 39 13.4.4 Contracts with loaders shall specify NA that the loader is responsible for Voluntary Module not Included. following sanitary specifications provided by shipper.

40 13.4.5 Where the site receives NA temperature controlled product immediately following Voluntary Module not Included. transportation, it shall conduct an assessment to determine whether the food was subject to temperature abuse. 41 13.4.6 Contracts with carriers shall specify NA that the carrier is responsible for the following sanitary activities where agreed to in writing with shipper. • Sanitary condition of vehicles and transportation equipment • Following shipper’s sanitary specifications (including pre-cooling Voluntary Module not Included. requirements where applicable) • Recording compliance with operating temperature where critical to food safety • Procedures for the use of bulk vehicles, which includes recording the previous cargo and most recent cleaning for the shipper 42 13.4.7 Contracts with carriers shall specify NA that the carrier implements a training program for all personnel engaged in transportation activities, which covers Voluntary Module not Included. • Awareness of potential food safety problems that may occur during food transportation • Basic sanitary transportation practices to

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address those potential problems • Responsibilities of the carrier 43 13.4.8 The site shall keep all records NA related to U.S. transportation operations and transportation service contracts as original or Voluntary Module not Included. electronic records for a minimum of 12 months beyond termination of the activity or contract. Offsite records shall be retrievable within 24 hours. 44 13.4.9 The recordkeeping policy shall NA ensure all sanitary design requirements and cleaning procedures for vehicles are Voluntary Module not Included. maintained onsite and all offsite records are retrievable within 24 hours.

45 13.5.1 Personnel (permanent and NA temporary) who handle produce or food contact surfaces must receive additional training on the following: • Principles of food hygiene Voluntary Module not Included. and food safety Produce safety standards applicable to an individual's job

46 13.5.2 Personnel (permanent and NA temporary) who conduct harvest activities (including washing and cooling) must receive additional training on the following: • Recognizing produce contaminated with known or reasonably foreseeable Voluntary Module not Included. hazards • Inspecting harvest containers and equipment to ensure that they are clean, maintained and do not contaminate produce with hazards

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• Correcting problems with harvest containers or equipment 47 13.5.3 One or more supervisors or NA individuals responsible for the operation must have successfully Voluntary Module not Included. completed food safety training equivalent to standardized curriculum recognized by the FDA. 48 13.5.4 A supervisor shall be identified with NA responsibility for the operation and ensuring compliance with Produce Voluntary Module not Included. Safety regulation. This individual shall be identified on the site’s organizational chart. 49 13.5.5 Personnel (permanent and NA temporary) shall avoid contact with animals or take measures such as hand washing and protective Voluntary Module not Included. clothing to prevent contamination of produce and food contact surfaces following contact with worker animals. 50 13.5.6 The water distribution system NA supplying agricultural water used for harvest, packing, holding—and associated equipment—shall be maintained, regularly inspected and equipment properly stored to prevent the system from being a source of contamination to produce and food contact surfaces. The Voluntary Module not Included. system shall be inspected for conditions, which could introduce known or foreseeable hazards into or onto produce. Where testing of the water source or system inspection reveals contamination, deficiencies shall be corrected such as the repair of well caps or sanitary seals. 51 13.5.7 Agricultural water treatment must NA be delivered and monitored at a frequency that ensures water is safe, of adequate sanitary quality, Voluntary Module not Included. and meets the microbial quality criteria of no detectable generic Escherichia coli (E. coli) in 100mL.

FSNS Certification & Audit, LLC. 199 West Rhapsody Drive, San Antonio, TX 78216

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52 13.5.8 Potable water quality standards NA used shall ensure the microbial quality criterion is met, which is no Voluntary Module not Included. detectable generic E. coli in 100 mL. 53 13.5.9 Where agricultural water does not NA meet microbial quality criteria or is determined to be unsafe and not of adequate sanitary quality, water use must be discontinued along with treatment or other correction that reestablishes sanitary quality and microbial criteria. Where water treatment is not Voluntary Module not Included. performed, re-inspection of the entire affected agricultural water system shall be conducted followed by the identification of conditions leading to the introduction of hazards into or onto produce or food contact surfaces, correction, and verification of correction to ensure water meets microbial quality criteria. 54 13.5.10 Agricultural water testing may be NA performed by the site (or site representative) or by a third party provided representative samples of the site's water source is secured. Aseptic water sampling must be performed. The method of analysis for water testing is U.S. Voluntary Module not Included. Environmental Protection Agency (EPA), ‘‘Method 1603: Escherichia coli (E. coli) in Water by Membrane Filtration Using Modified membrane-Thermotolerant Escherichia coli Agar (Modified mTEC), EPA–821–R–09–007),’’ December, 2009 or equivalent method. 55 13.5.11 During harvest, packing and NA holding operations (e.g., hydrocooling, washing), manage water to maintain its safety and sanitary quality and prevent Voluntary Module not Included. contamination of produce to include establishing and following a water-change schedule for recirculated water.

FSNS Certification & Audit, LLC. 199 West Rhapsody Drive, San Antonio, TX 78216

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Visually monitor the water quality of water used for harvest, packing, and holding activities for organic build-up (e.g., soil, plant debris). Maintain and monitor the temperature of water used for harvest, packing, and holding activities as appropriate to the commodity and operation to minimize infiltration of pathogens into produce. 56 13.5.12 Dropped produce (i.e., produce NA that comes in contact with the ground prior to harvest) where the produce would not normally touch Voluntary Module not Included. the ground as a part of growing and harvest (e.g., cantaloupe, almonds, etc.) shall not be distributed. 57 13.5.13 Sewage disposal and septic NA systems shall be controlled and appropriate for the site to prevent Voluntary Module not Included. the contamination of produce and food contact surfaces. 58 13.5.14 Plumbing shall not allow backflow NA or cross-connection between waste Voluntary Module not Included. and potable water lines. 59 13.5.15 All produce safety related records NA must be reviewed, dated, and signed within a reasonable Voluntary Module not Included. timeframe after being made by the supervisor or responsible party. 60 13.5.16 All produce safety documents and NA records must be retained at the site for 2 years after the record is created. Where records are stored offsite, they must be retrievable within 24 hours. Voluntary Module not Included. Records related to equipment or processes used by the site for analyses, sampling, or action plans—including the results of scientific studies, tests, and evaluations—shall be retained at the site for at least 2 years after their use is discontinued.

FSNS Certification & Audit, LLC. 199 West Rhapsody Drive, San Antonio, TX 78216

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61 13.5.17 Specific additional requirements for NA the harvesting, packing, and holding of sprouts. Establish and implement a written Environmental Monitoring plan for the testing of Listeria spp or Listeria monocytogenes. The environmental monitoring plan shall include the following criteria: • Target test (i.e., Listeria spp. or L. mono) • Sample frequency (no less monthly) • Sample timing (i.e., when Voluntary Module not Included. in the process are samples collected) • Sample sites where the number of samples and location are sufficient to determine the efficacy of controls (includes food contact and non-food contact surfaces) The plan shall describe aseptic methods for sample collection and testing according to FDA's ‘‘Testing Methodology for Listeria species or L. monocytogenes in Environmental Samples,’’ Version 1, October 2015 (or equivalent). 62 13.5.18 Specific additional requirements for NA the harvesting, packing, and holding of sprouts. The environmental monitoring plan shall include a corrective action plan if any samples are positive for Listeria spp. or L. mono. If Listeria spp. or L mono are Voluntary Module not Included. identified in the harvesting, packing, holding area, the following activities shall occur as a part of the corrective action process: • Resample positive surfaces and the surrounding area to determine the extent of contamination

FSNS Certification & Audit, LLC. 199 West Rhapsody Drive, San Antonio, TX 78216

F834 English Food Template v8 09/09/2020 Page 55 of 56 Report No. 1200156 Auditor: A. McMahan

• Clean and sanitize the affected and surrounding areas • Resample and re-test to confirm the elimination of Listeria spp. or L. mono • Conduct finished product testing as appropriate • Take additional action to prevent recurrence and to prevent adulterated food from entering commerce

FSNS Certification & Audit, LLC. 199 West Rhapsody Drive, San Antonio, TX 78216

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This report shall not be reproduced in part without the permission of FSNS Certification & Audit, LLC. If you would like to feedback comments on the BRCGS Standard or the audit process directly to BRCGS, please contact tell.brcgs.com CenSea, Inc. 400 Skokie Boulevard, Suite 110 Northbrook, IL 60062 USA Tel: 224 723-5800 Fax: 224 723-5245

January 1, 2019

To Whom It May Concern:

LETTER OF GUARANTEE FOR SEAFOOD PRODUCTS IMPORTED AND/OR DISTRIBUTED BY CENSEA, INC.

All seafood supplied by CenSea, Inc., to your company has been produced in a US FDA registered facility that complies with applicable regulations listed below. CenSea, Inc., will only import or source products domestically from facilities that provide documentation to verify their compliance.

• 21 CFR 110 - Good Manufacturing Practices • 21 CFR 117 - Current Good Manufacturing Practice and Hazard Analysis and Risk Based Preventive Controls for Human Food (Subparts C & G exempt) • 21 CFR 123 - Seafood HACCP Regulations • 21 CFR 123.12 - Special Requirements for Imported Products • 21 CFR 1240 - Control of Communicable Diseases for Molluscan Shellfish

Please include this continuing Certificate of Guarantee from CenSea as part of our Seafood HACCP file.

______

Joe Rosenberg Chief Operating Officer CenSea, Inc.

January 2, 2021

To our Valued Customer

All beef products produced by Central Valley Meat Co., Inc. for shipment to food processors are produced under a USDA Grant of Inspection. Central Valley Meat Co., Inc. products bear the USDA Mark of inspection as establishment number 6063A. The beef products are produced according to the rules and regulations of the Federal Meat Inspection Act and the Food Drug and Cosmetic Act.

Central Valley Meats operates under a written HACCP and SSOP plan(s) whereas products are released for shipment only if they met the required criteria cited within those plans. Our HACCP plan has been designed to comply with all relevant USDA rules and regulations as required.

Throughout our slaughter process we maintain various microbiological intervention devices consisting or hide washing, steam vacuums, organic sprays and hot water pasteurization wash. The hot water pasteurization wash and lactic acid spray are our validated intervention pathogen devices in place to reduce E.coli 0157:H7 and STECs to below detectable levels. These interventions are CCPs in our HACCP plan.

Proper handling of livestock for slaughter is extremely important to all of us in the meat production chain, both ethically and economically. Our Animal Handling Program strictly adheres to the USDA Humane Slaughter At of 1978 and the AMI Good Management Practices for handling and slaughter of cattle. Central Valley has in place an animal welfare program that is monitored daily by trained personnel. The animal welfare program is audited by a recognized third party auditing firm on both an announced and unannounced schedule.

To the best of our knowledge we certify that the cattle slaughtered at our facility have been fed in compliance with the August 1997 Food and Drug Administration regulation 21 CFR589.2000. This regulation prohibits the feeding of ruminant meat and bone meat to ruminant animals. Documentation is required from our cattle suppliers and is maintained at our facility.

To further enhance safeguards against Bovine Spongiform Encephalopathy, (BSE), programs have been put in place to ensure that cattle processed at Central Valley Meat shall comply with the following documents:

 Comply with the USDA-FSIS July 13, 2007 final rule, Prohibition of the use of Specified Risk Materials for Human Food and Requirements for the Disposition of Non Ambulatory Disabled Cattle; Prohibition of the Use of certain stunning Devices Used to Immobilize Cattle During Slaughter.  Directive 6100.1  Directive 6100.4  Notice 56-07

We have developed procedures to assure that no downer cattle are slaughtered and no air injection stunners are used. The brain, skull, eyes, triegeminal ganglia, spinal cord, distal ileum and the tonsils are

Central Valley Meat 10431 8 ¾ Ave –Hanford California 93230 1 559 583 9624 removed and diverted to inedible rendering during slaughter. The vertebral column from animals aged 30 months of age and older is removed during the fabrication process and is diverted to inedible rendering. Central Valley Meat has in place a written SRM program which complies to all relevant SRM regulations such as CFR 310.22 and FSIS Directive 6100.4. All relevant employees are trained on SRM jobs prior performing duties associated with such jobs.

Within our slaughter process, high risk cattle may be subject to residue testing. Therefore, we have asked our cattle supply chain to certify that the cattle purchased for slaughter are free of illegal drug residue at time of purchase. We maintain a drug residue control program, which utilizes USDA best available practices. The USDA in our facility routinely test cattle for residue under the National Residue Surveillance Program.

All boneless beef products that are known to be intended for raw ground beef are sampled and tested for E.coli 0157:H7 prior to being released from our facility. A robust sampling plan is in place whereas all lots of boneless beef are sampled using the N60 or the IEH N60 Plus method. Product is samples and analyzed in accordance with the USDA Laboratory Guidebook MLG 5.03. Central Valley Meat will only release boneless beef for the production of raw ground beef after a negative test result is received for each lot and the product is accompanied with a Certificate of Analysis (COA). Product not accompanied with a COA such as sub primal and other intact products are not intended to be used for the production of ground meat and are to be used as intact product. CVM does perform N60 verification sampling that is designed to verify the adequacy of our trim sampling program. Trim verification sampling is performed a minimum of 8 times per year (three times in the 2nd & 3rdquarters and once in both the 1st and 4th quarters). N60 verification samples are analyzed for E.coli 0157:H7 and STECs. The N60 sampling is audited once a year by a recognized third party organization.

Central Valley Meat has in place a written pest control program. Pest Control services are conducted by a third party company with licensed and trained personnel. Certificates and insurance for the third party company are kept on file and renewed annually r as required should there be a technician change.

Central Valley Meats participated in a Global Food Safety Initiative auditing program scheme. The company has achieved certification of BRC at an “AA” level and the last audit was performed in September of 2020. If you require additional information or have questions please feel free to contact me.

Kind Regards,

Terri L Hall digitally signed 1 02 2021 6:34am

Terri L Hall Director of Food Safety and Quality Central Valley Meat

Central Valley Meat 10431 8 ¾ Ave –Hanford California 93230 1 559 583 9624

CERTIFICATE OF COMPLIANCE/REGISTRATION

January 4, 2021

Attn HACCP Manager:

With the support of the seafood industry, the United States Food & Drug Administration has developed HACCP (Hazard Analysis Critical Control Point) regulations that became effective on December 18, 1997. The HACCP guidelines are required for all seafood products imported into and exported from the United States, as well as all seafood products produced and distributed within the United States. This document is to certify that all of Chesapeake Bay Packing, LLC’s processing and unloading facilities are currently operating under the federally mandated HACCP requirements.

Chesapeake Bay Packing has conducted a hazard analysis for all seafood products, constructed a HACCP system, implemented Sanitation Standard Operating Procedures (SSOPs), is following Good Manufacturing Practices (GMPs) as outlined by the Code of Federal Regulations Title 21 and has been granted the ability to process and ship seafood by the United States Food & Drug Administration (CFN #1123349); the Virginia Department of Health Division of Shellfish Sanitation (#1147 RP); and the United States Department of Commerce Seafood Inspection Program (EU Approval #1121627).

In accordance with the Bioterrorism Act of 2002, has registered our facilities with the United States Food & Drug Administration. Our registration number is 19196018716.

Please include this document as our Certificate of Compliance/Registration as part of your HACCP records for 2021.

If you have any questions, please speak with your contact at Chesapeake Bay Packing or you may contact me directly at (757) 818-9000 or by e-mail at [email protected].

Sincerely, Maria Rios Maria Rios HACCP Coordinator

800 Terminal Avenue, Newport News, VA 23607 Telephone (757) 244-8440 Fax (757) 244-8622 www.chesapeakebaypacking.com

CHILEMAR INC.

Guarantee Letter

To Our Customers,

Chilemar Inc., certifies that appropriate quality control procedures have been implemented and maintained to ensure safety for our frozen and canned products supplied to your entity. We further certify that these products are produced in accordance with good manufacturing procedures, and the fish and fishery products hazard analysis critical control point requirements as described in 21 CFR part 123.

A product specification sheet is available to further ensure the product imported has met all the standard parameters of production.

Inspections of our manufacturing plants are made on a routine basis to make sue the products being processed meet all the necessary requirements for export to the USA.

Chilemar Inc. also has available a document from the Chilean Government authority to each manufacturing plant that is in compliance with FDA regulations including HACCP regulations.

Chilemar Inc. has also sent personnel for HACCP training for a better knowledge of the process.

Date: January 1, 2021

______Eugenio Sanchez President/CEO

Chilemar Inc., PO Box 803321, Santa Clarita, CA 91380 Tel. 818-629-2526 Fax. 818-936-0550

CKF Inc. 19878 57A Avenue Langley, BC V3A 6G6 Tel: 604-530-9121

4 January 2021

Re: Letter of Guarantee – Food Safe Product (Foam)

To Whom It May Concern:

CKF Inc., Langley provides foam containers for the food industry. This includes plates, bowls, food service containers, trays and egg cartons. Some trays contain an absorbent pad.

All materials used to produce the foam trays, and the formed trays itself, are food safe and comply with Part B, Division 23 of the Canadian Food and Drug Regulations outlined below. Absorbent pads used in some of the trays and the adhesive required to adhere the pads, also comply with Part B, Division 23 of the Canadian Food and Drug regulations. CFIA letter of Non Objection are kept on file. All materials used to produce the foam trays are FDA approved as per the suppliers’ FDA documentation.

CKF conforms to Good Manufacturing Principles (GMP). The Plant conducts an annual 3rd party GMP audit that includes a review of the HACCP program. The 3rd party audit takes place in March of each year.

CKF is also C-TPAT certified for product protection to the USA.

CKF does not use any synthetic fungicides, preservatives or fumigants on the premises. To the best of its knowledge, CKF packaging materials have not been made with or been exposed to synthetic fungicides, preservatives, or fumigants.

Based on CFIA’s definition of food allergens, CKF has no knowledge of any food allergens affecting or coming into contact with the product.

Yours Sincerely,

Darwin Dayao QA Manager CKF Inc., Langley and Delta BC 778-689-0489 [email protected]

2526 Dike Road Woodland, WA 98674 Phone: (360 225-9575 Fax: (360) 225-6295

January 4, 2021

FDA Continuing Letter of Guarantee (Reference: Federal Food, Drug, and Cosmetic Act)

FDA Food Facility Registration: • Last Updated: 10/20/2020 • Registration Expiration Date: 12/31/2021

For the purpose of Section 303(c) of the Federal Food, Drug and Cosmetic Act, Columbia Fruit LLC, Woodland, Washington guarantees that the articles comprising each shipment or other delivery to you as of the date of such shipment or delivery, will not be adulterated or misbranded within the meaning of said Act, or within the meaning of any applicable state or municipal law in which the definitions of “adulteration” and “misbranding” are substantially the same as those contained in said Federal, Foods, Drug and Cosmetic Act. As such laws are constituted and effective at the time of such shipment or delivery, nor will be an article which may not under the provisions of Sections 404, 505 or 512 of the said Federal act be introduced into interstate commerce.

All Food Contact packaging utilized by Columbia Fruit is certified to meet FDA standards for food contact.

Columbia Fruit complies with pesticide residual levels per country of destination.

Columbia Fruit bases our food safety plan on H.A.C.C.P. per USDA and BRC requirements, as well as Preventive Control for Human Food principles as required by the Food Safety Modernization Act guidance developed by FDA.

This guarantee is continuing and shall be in full force and effect until revoked in writing.

Sincerely,

Erin Creed Quality Assurance Admin CONTINENTALcm MILLS FOOD PRODUCTS OF CHOICE

GENERAL AND CONTINUING PRODUCT GUARANTEE

The undersigned, Continental Mills, hereinafter referred to as "Seller", hereby GUARANTIES the article comprising each shipment or delivery hereafter made by the Seller to Pacific Food Distributors, referred to as "Buyer", or on the order of the above-named Buyer, as of the date of such shipment or delivery, to be, on such date:

(a) not adulterated or misbranded or injurious to the health within the meaning of the Federal Food, Drug and Cosmetic Act, and all amendments thereto, including the Food Additives Amendment of 1958 to the extent said Act is then effective and applicable, and that such articles are not articles which may not be introduced into Interstate Commerce under the provisions of Sections 404 and 405 of said Act;

(b) not in a misbranded package within the meaning of the Federal Hazardous Substances Labeling Act to the extent said Act is then effective and applicable;

( c) in compliance with the requirements of the Poultry Products Inspection Act and the Meat Inspection Act to the extent that said Acts are then effective and applicable;

(d ) in compliance with and not adulterated or misbranded within the meaning of any identical or substantially similar state or municipal law, on the subject, to the extent said law is then effective and applicable; provided, however, that where any articles are packed and shipped or delivered under Buyer's labels, Seller's liability under this Guaranty, for any misbranding, shall be limited to liability for the failure, if any, of the articles to conform to the labels furnished to the Seller by the Buyer.

The Seller further agrees to indemnify and save the above-named Buyer and its affiliates, and their respective officers, directors, employees, agents, representatives and stockholders harmless against any expense which it may incur or damage which it may suffer by reason of the breach of such Guaranty, provided, however, that Seller is promptly notified by and is permitted, at its option, to deal therewith in pursuance of its own discretion and through its own representatives.

This is a Continuing Guarantee, subject to revocation on written notice thereof.

January 4, 2021 Seller: Continental Mills

By:

· y and Regulatory

7 29,99

General & Continuing Letter of Guaranty

Effective Date: January 1, 2020

The articles comprising each and every shipment or other delivery thereafter made by COUNTYFAIR FOOD PRODUCTS COMPANY to the direction of “Said Customer”, is guaranteed that, when shipped, all items we manufacture or purvey are in full compliance with the Federal Food, Drug and Cosmetic Act as amended, and are not adulterated or misbranded within the meaning of said Act, and may be introduced into the interstate commerce without violating said Act.

The raw materials that we use to produce all our products are of superior quality and meet or exceed our specifications. This guaranty will be in full force and effect for a period of two (2) years from date of issue. Seller will reissue the guaranty on or before the renewal date.

County Fair Food Products /Kruger Foods

Beth Wragg VP of Sales

County Fair Food Products Company 18362 E. HWY 4 Stockton, CA 95215 CULVER DUCK FARMS, INC. 12215 CR 10 • MIDDLEBURY, IN 46540 (574) 825-9537 • (800) 825-9225

Letter of Continuing Guarantee/HACCP Letter

Culver Duck Farm, Inc., (hereinafter called the “Seller”), does hereby guarantee that all Food, Drug and Cosmetic products hereafter sold by the Seller, does and shall at the time of the delivery thereof by the Seller, in all respects comply with the Federal Food, Drug and Cosmetic Act, Approved on June 25, 1938, and all acts and/or promulgated rules amending or supplementing the same, and with the pure food and drug laws of each and all of the states of the United States into which any such products may be shipped by the Seller, whether now in force or hereafter enacted, and are not and shall not be at the time of delivery thereof, knowingly adulterated or misbranded within the meaning of said acts or said laws or the rules and regulations of the Wholesome Meat Act or Wholesome Poultry Act, or be articles prohibited from introduction into interstate commerce under the provisions of Section 404 or 505 of the said Federal Food, Drug and Cosmetic Act, and are not and do not knowingly contain a misbranded hazardous substance or a banned hazardous substance.

Furthermore, the duck items with which we supply are HATCHED, RAISED and HARVESTED in the USA and produced in a facility (USDA Est. P-2028) that complies with the rules and regulations set forth under the guidance of the United States Department of Agriculture for producing products that are fit for human consumption. These guidelines include but are not limited to: “Hazard Analysis Critical Control Points Program” (HACCP, 21 CFR PART123 / 9 CFR CH.III part 417), Standard Sanitation Operating Procedures (SSOP, Part 123.1(a) / 9 CFR CH.III part 416) and the Good Manufacturing Practices (GMP/GAP, 21 CFR part 110).

This guarantee shall become void unless prompt notice in writing is given to the Seller by the Buyer of any claim that any product sold by the Seller to the Buyer is adulterated or misbranded or in any other respect fails to comply with this guaranty, stating particulars; and that no action on this guaranty shall be commenced after two (2) years from the time of shipment by the Seller to the Buyer of the product involved.

This agreement shall cover only products shipped by the Seller within five (5) years from the date here and shall terminate absolutely at the end of said five (5) years and shall not be renewed or extended except by a new writing signed by an authorized officer of the Seller.

Dated this 4th day of January, 2021

Thank you

Sean M. Smith Director of Compliance & Project Development Culver Duck Farms, Inc.

CONTINUING LETTER OF GUARANTEE

January 4, 2021

Pacific Foods

To Whom It May Concern:

The articles comprising each shipment or other delivery hereafter to be made by Daily’s Premium Meats are hereby guaranteed, as of time of shipment or delivery, to be:

Not adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act, or the laws of any of the states of the United States to the extent that such laws are then effective and applicable (including, but not limited to, such amendments as the Food Additives Amendment of 1958 to the Federal Food, Drug and Cosmetic Act); and, that none of said goods are articles which may not, under provisions of Sections 404 or 505 of the Federal F ood, Drug & Cosmetic Act, to be introduced into interstate commerce; Not adulterated or misbranded within the meaning of the terms of the Federal Insecticide, Fungicide, and Rodenticide Act, the Federal Hazardous Substances Labeling Act, the State Pure Foods Act; Not misbranded within the meaning of any federal, state, or local law when bearing labels furnished by the seller and affixed to such articles on repackaging by the buyer in accordance with instructions furnished by Daily’s Premium Meats.

Daily’s Premium Meats has implemented a HACCP plan and is in compliance with all requirements set forth in 9 CFR 417 HAZARD ANALYSIS AND CRITICAL CONTROL POINTS SYSTEMS. All critical control points identified in our process have been validated and our HACCP program is reassessed regularly to ensure product safety.

This guarantee shall continue in effect with respect to all product or merchandise purchased or ordered by buyer to the receipt of written notice of its revocation by Daily’s Premium Meats.

Shaun Huls Technical Services Manager Daily’s Premium Meats

3535 South 500 West| Salt Lake City, UT 84115| (801) 269-1998 voice | 801) 269-1409 fax | www.DailysMeats.com

January 4, 2021 Mr. Jason Tate Pacific Foods Distribution 12300 SE Carpenter Dr. Clackamas, OR 97015

RE: Continuing Letter of Guarantee

Dear Mr. Tate,

The article comprising each and every shipment or otherwise delivery hereafter made by Del Real Foods (the “seller), to or at the direction of Pacific Foods (the “buyer”) is guaranteed as of the date of January 4, 2021. Del Real hereby guarantees that, when shipped, all items we manufacture or purvey are in full compliance with the Federal Food, Drug, and Cosmetic Act amended as amended and not adulterated or misbranded with the meaning of the said act.

Del Real Foods operates under a very stringent food safety HACCP program, Good Manufacturing Practices (GMP’s) Programs and a Sanitation Standard Operating Procedures (SSOP) Program amongst other. In addition, Del Real Foods also complies with GFSI guidelines, SQF Food Safety and Quality categories.

Conditions of use of the article, including temperature and other pertinent limits are as follow: “Temperature storage conditions recommended by the manufacturer are to be strictly followed at all times”

Del Real Foods values your patronage, and we are happy to assist with further questions.

Thank you,

QA Manager [email protected] Office: (951) 681 0395 ext.5115

Cc: Ms. Samantha Ramirez, Ms. Jocelyn Williams, Mr. Michael Axelrod – Del Real Foods

11041 Inland Avenue - Mira Loma, CA 91752 – Tel: 951-681-0395 – WWW.DELREALFOODS.COM

January 4, 2021 Valid until superseded

FDA Food Contact Status and Good Manufacturing Practices DOLCO PACKAGING Food Cartons, Tills, and Trays From Bloomfield, NY; Decatur, IN; Dallas, TX; Lawrenceville, GA; and/or Wenatchee, WA

Dear Valued Customer:

This letter is in response to your request for a FDA compliance letter, a 21 CFR letter, a Letter of Guarantee, and/or a GMP letter for the products which Dolco Packaging, a part of Tekni-Plex, supplies to you.

The components of the above products comply with the applicable FDA regulations for food contact as described in Title 21 (Food and Drugs) of the Code of Federal Regulations.

In regard to current Good Manufacturing Practices (cGMP), our plants will manufacture, pack and store plastic components which meet our customers’ quality and sanitation requirements and the applicable FDA regulations in 21 CFR 174.5 and 21 CFR 110.

Therefore, the articles comprising each shipment or other delivery hereafter made by Dolco Packaging to, or on the order of your company, are hereby guaranteed, as of the date of such shipment or delivery, to be, on such date, not adulterated or misbranded within the meaning of the Federal Food, Drug, and Cosmetic Act, and not articles which may not, under the provisions of Sections 404, 505, and 512 of the Act, be introduced into interstate commerce.

Please E-Mail me at [email protected] if you have any questions about this matter.

TEKNI-PLEX, INC.

E. L. McKinley

Director, Regulatory Compliance-Americas elm/FDA010421

Tekni-Plex, Inc 460 E. Swedesford Road, Suite 3000 ▪ Wayne, PA 19087 ▪ Phone (484) 690-1520

January 5, 2021

Dear Valued Customer,

This letter serves as a guarantee that the seafood supplied by Eastern Fish Company to your company has been produced in a facility that complies with the HACCP Regulation 21 Code of Federal Regulations Parts 123 and 1240. “Procedures for the Safe Processing and Importing of Fish and Fishery Products”. These regulations require the application of Hazard Analysis and Critical Control Point (HACCP) evaluation principles to the processing of all domestic and imported seafood produced after December 18, 1997. The principles include:

1) conducting a hazard analysis of the seafood processing to determine if there is a significant likelihood that a food safety hazard may occur.

2) writing and implementing a HACCP plan if a significant hazard is identified.

3) monitoring eight key areas of sanitation regardless of whether a HACCP plan is necessary in order that conditions and practices conform with Good Manufacturing Practices (GMP).

Eastern Fish Company will import products only from facilities that provide documents to verify their compliance with the aforementioned regulations. It will also source products from U.S. suppliers who can demonstrate that they have taken steps to comply with the HACCP regulations. This letter is valid until Jan 5, 2022 and will be updated on a yearly basis.

Best Regards,

Jessica Lamana HACCP Coordinator QA/Sustainability Mgr.

January 5, 2021

Dear Valued Customer,

1) conducting a hazard analysis of the seafood processing to determine if there is a significant likelihood that a food safety hazard may occur.

2) writing and implementing a HACCP plan if a significant hazard is identified.

3) monitoring eight key areas of sanitation regardless of whether a HACCP plan is necessary in order that conditions and practices conform with Good Manufacturing Practices (GMP).

Best Regards,

Jessica Lamana HACCP Coordinator QA/Sustainability Mgr.

CERTIFICATE OF COMPLIANCE - 2021

January 1, 2021

Dear Valued Customers:

This letter is our guarantee that all seafood that Fortuna Sea Products, Inc. supplies to your company has been produced and stored in a facility which is in compliance with the United States Food and Drug Administration guidelines for Hazard Analysis Critical Control Points (HACCP) including section 123.12 special requirements for imported products. In addition, our company incorporates the Good Manufacturing Practices (GMP) and applicable Sanitation Standard Operating Procedures (SSOP).

Please keep this letter on file as the documentation you need to comply with HACCP procedures. This Certificate of Compliance will be renewed every 12 months, as HACCP is an ongoing program.

Bioterrorism Act of 2002 requires domestic and foreign facilities that manufacture, process, pack, or hold food for human or animal consumption in the United States to register with the FDA. Fortuna Sea has registered with the FDA.

Food Facilities Registration No. 14056131460

We look forward to strengthening our long-term relationship into the prosperous future. Please feel free to contact us if you have any questions.

Sincerely,

John Chiang President/Fortuna Sea Products, Inc.

DocuSign Envelope ID: 377512D2-EE6D-4868-B55F-891BF76B062F

COMMODITY GUARANTEE

1. In consideration of the purchase, from time to time, of articles of food or other commodities from the undersigned (hereinafter called "Seller") by Pacific Food Distributors (hereinafter called "Buyer"), the Seller:

(a) Does hereby guarantee that, as of the time of delivery, the articles of food[, drugs]1 or other commodities comprising each delivery hereafter made by Seller to, or on the order of, Buyer, shall, at such time, (1) not be adulterated or misbranded within the meaning of the Federal Food, Drug, and Cosmetic Act, as amended (the “FD&C Act”); (2) not be articles which are prohibited, under the provisions of Section 404 (21 USC §344) or 505 (21 USC §355) of the FD&C, from being introduced into interstate commerce; (3) not be adulterated or misbranded within the meaning of the pure food or drug laws or ordinances of any state or city which are applicable to such articles; and (4) not be in violation of the provisions of the California Safe Drinking Water and Toxic Enforcement Act of 1986 (California Health and Safety Code Sections 25249.5 et seq., commonly known as Proposition 65 and, hereinafter, the “California Safety Code Sections”), and the regulations established thereunder.

(b) Does hereby agree to indemnify and hold the Buyer harmless from and against any and all charges, actions and proceedings brought by any lawful governmental authority against the articles sold or delivered to Buyer and/or Buyer for or on account of any alleged adulteration or misbranding of such articles or any alleged violation of the California Safety Code Sections or the regulations established thereunder, all as referred to in paragraph 1(a) hereof for which Seller is providing guarantees hereunder, including any loss and reasonable expenses, if any, incurred by Buyer as a result thereof;

(c) Does hereby agree to indemnify and hold the Buyer harmless from and against any and all claims, demands, actions and causes of action which are hereafter made or brought against the Buyer by any person for the recovery of damages for the injury, illness and/or death of any person or animal which is caused or alleged to have been caused by the handling, consumption or use by such person or animal of any articles of food or other commodities that were sold or delivered by Seller to Buyer, including, but without limitation, any judgment rendered against Buyer in any such action and the reasonable attorney's fees and costs, if any, incurred by or on behalf of Buyer in connection therewith.

COMMODITY GUARANTEE - MASTER 2008.DOC 5/11/2012 -1- DocuSign Envelope ID: 377512D2-EE6D-4868-B55F-891BF76B062F

(d) Does hereby guarantee that the products sold or delivered by Seller to Buyer have been processed, produced, and packaged in accordance with applicable Sanitation Standard Operating Procedures (SSOP, under 9 CFR 416.11-416.16) and Hazard Analysis Critical Control Points plan requirements (HACCP, under 9 CFR 417).

2. This guaranty is executed by Seller upon and subject to the following conditions:

(a) With respect to paragraph 1 above, Seller does not guarantee against any articles becoming adulterated or misbranded or otherwise failing to comply with the California Safety Code Sections (and regulations) after the time of delivery to Buyer, and where the adulteration, misbranding or other failure to comply is not caused by any act or failure to act on the part of Seller; provided, that any such adulteration, misbranding or failure to comply which is found to exist after delivery, and which is caused by any defect in the processing or packing of such articles by the processor or packer thereof, by the defective condition of any raw materials used in the processing or packing of such articles or by any defect in the container in which the articles are packed, shall be regarded as having existed at the time of delivery for the purposes of paragraph 1 above; and provided, further, that in those cases in which an article is shipped under Buyer's brand label, Seller's responsibility or liability for misbranding shall be limited only to that resulting from the failure of the article to conform to the written purchase specifications or label furnished in advance by Buyer to Seller, but Seller shall not be responsible or liable for such misbranding if Buyer insists upon the use of Buyer's brand label after Seller has notified Buyer, in writing, of the defects of the label giving rise to any such liability;

(b) With respect to paragraph 1, the indemnity provisions therein contained shall be operative only if Seller receives reasonable notice from Buyer of the seizure of subject articles or the service upon Buyer of process in respect of any proceeding or action, as the case may be;

(c) With respect to paragraph 1, the indemnity provisions therein contained shall not be applicable to any loss or liability in connection with any claim, demand, action or cause of action which relates to the injury, illness and/or death of any person or animal if and to the extent it is established that such injury, illness and/or death was caused by the negligence or intentional misconduct of Buyer and/or such person and/or from a cause or causes beyond Seller's control.

3. Any guaranty that may have heretofore been given by Seller to Buyer which relates to the subject matter hereof is hereby revoked and this guaranty shall not be deemed to be modified or otherwise affected by any agreement hereafter entered into by Seller and Buyer unless specific reference to this guaranty is therein made. This guaranty shall continue in effect with respect to all articles of food and other commodities purchased or ordered by Buyer from Seller prior to the receipt of COMMODITY GUARANTEE - MASTER 2008.DOC 5/11/2012 -2- DocuSign Envelope ID: 377512D2-EE6D-4868-B55F-891BF76B062F

written notice of its revocation by Buyer at the address set forth below, or such other address as may be designated in writing by Buyer to Seller. Notice of the acceptance of this guaranty is hereby waived by Seller.

4. This guaranty shall be governed by, and construed and interpreted under, the laws of California.

Dated: January 4, 2021

Address of Seller:

FOSTER POULTRY FARMS PO BOX 457 Livingston, CA 95334

By: ______Tom Bower SR VP of Supply Chain

SELLER

Address of Buyer:

Pacific Food Distributors 12300 SE Carpenter Dr. Clackamas, OR 97015

Attn: Natalie Wood

COMMODITY GUARANTEE - MASTER 2008.DOC 5/11/2012 -3- DocuSign Envelope ID: 377512D2-EE6D-4868-B55F-891BF76B062F

(209) 394-7901 1000 Davis Street P.O. Box 457 Livingston, CA 95334

January 4, 2021

Attn: Natalie Wood Pacific Food Distributors 12300 SE Carpenter Dr. Clackamas, OR 97015

RE: Product Guaranty

Dear Ms. Wood;

Please find enclosed Foster Poultry Farms Commodity Guaranty, which includes assurances regarding California's Health and Safety Code, Section 25249.6 of Proposition 65.

It is our understanding that Foster Farms has sent you a Certificate of Insurance separately.

Very truly yours,

Becky Cornfoot

Becky Cornfoot Executive Administrator

Enclosure

cc: Dustin Feeney, Treasury Manager

GARIMARK FOODS, INC. CONTINUING PRODUCT GUARANTEE

The undersigned hereby certifies that each shipment or other delivery of articles of food, hereafter represented by the undersigned to, or on the order of the company to whom this guaranty is addressed, its divisions or subsidiaries (the “Company”) is hereby guaranteed, as of the date of such shipment or delivery, to be on such date, not adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act, as from time to time amended, not an article which, under the provisions of Section 404 or 505 of the Act, may not be introduced into interstate commerce, not in violation of the provisions of the Food Additives Amendment of 1958 and not to contain sufficient amounts of any toxic or cancer-causing chemical to require warnings under the California Safe Water and Toxic Enforcement Act of 1986. The undersigned represents and sells poultry products manufactured under approved HACCP plans with facilities under Regulatory Inspection by the United States Department of Agriculture whose personnel are responsible for monitoring and verifying compliance. This guaranty is in like terms extended and shall be applicable to any lawful state law or municipal ordinance in which the definitions of adulteration or misbranding are substantially the same as those in the Federal Food Drug and Cosmetic Act, as amended, to the extent that such state law or municipal ordinance is then elective and applicable to the articles or products when sold, shipped or delivered. The Company to whom this guaranty is addressed, as well as said divisions or subsidiaries agree to promptly, in writing, notify the undersigned of any demand, complaint or proceeding for the claimed violation of any of the above-mentioned laws, giving the name and address of the complaining party and the product concerned. The undersigned agrees to indemnify and hold harmless the Company against any judgment for damages entered against Company as a result of litigation in which it is determined that breach of this guaranty by the undersigned was the proximate cause of the damages, including costs of the litigation and attorneys’ fees, provided that the undersigned is promptly notified of any claim for such damages and is permitted to deal with such claim at its discretion through such attorney or insurer as it may designate. This guaranty is not assignable and is a continuing guaranty subject to revocation on written notice thereof. It revokes any continuing guaranty previously given.

GUARANTOR: GARIMARK FOODS, INC.

BY:

Gari Church President DATE: January 1, 2021

1000 Hurricane Shoals Road  Suite D-100  Lawrenceville, GA 30043  866-230-2465 www.garimarkfoods.com

20180824 POL.01.01

201 W. MAIN ST. - SUITE 203 – CHATTANOOGA, TN 37408  423-265-2313  FAX: 423-265-2468

CONTINUING GUARANTY AGREEMENT

Patti Jerome Pacific Food Distributors Office # 503-607-1119 Email: [email protected]

The undersigned hereby guarantees that no article compromising any shipment or other delivery hereafter made by Grain Craft with principle address at 201 W. Main St. – Suite 203, Chattanooga, TN 37408, is as of the date of such shipment or delivery adulterated or misbranded, or unsafe, within the meaning of the Federal Food, Drug and Cosmetic Act of 1938, with all revisions and amendments pertaining thereto (including the Pesticide and Food Additive Amendments of 1958) or within the meaning of any substantially similar state or municipal law, or is an article which may not under such law, or is an article which may not under such Act of Law be introduced into interstate or intrastate commerce. Notwithstanding the foregoing, you acknowledge that the products to be delivered are processed from raw agricultural commodities without any “kill step” and thus that such products may not be free from pathogens. Grain Craft understands that the products to be delivered will be further processed by you using sufficient preventative controls.

DATE: January 4, 2021 GRAIN CRAFT (Name of Seller)

BY: Kevin Kloberdanz, Western Regional Manager of Quality & Audit Compliance

January 2, 2019

2019 HACCP Certificate of Compliance

Dear Valued Customer,

This letter serves as notification that all seafood products sold by Southwind Foods (dba Great American Seafood) comply with all rules and regulations for the production of seafood products for human consumption that are promulgated by the appropriate Federal and State agencies of the United States of America. These include but are not limited to the following criteria: 1. We have more than the required number of personnel that have completed HACCP training. 2. We have completed a hazard analysis and if a significant hazard exists, developed and maintain a written HACCP plan. 3. We have developed and follow a Sanitation Standard Operating Procedure (SSOP) 4. We have established record-keeping practices necessary to monitor our products method of production and country of origin. 5. We purchase product only from HACCP approved sources. 6. Southwind Foods and Great American Seafood Imports have registered its facilities with U.S. FDA as required by the Bioterrorism Act of 2002 in 21 CFR 1.225.

Although exempt in the FDA Model Food Code 2009, Chapter 3. §3-402.11, ¶2. (B), I also certify that all frozen seafood products are processed for or imported by Southwind Foods are: 1. Frozen and stored at a temperature of -20°C (-4°F) or below for a minimum of 168 hours (7 days) in a freezer 2. Frozen at -35°C (-31°F) or below until solid and stored at -35°C (-31°F) or below for a minimum of 15 hours 3. Frozen at -35°C (-31°F) or below until solid and stored at -20°C (-4°F) or below for a minimum of 24 hours

This is a continuing certification and will remain in force until Southwind Foods notifies you of the contrary. Should you require anything further, please feel free to contact us. James R. Elie James R. Elie Vice President, Operations & Regulatory Compliance

January 22, 2020

Dear Valued Customer,

Global Tableware Solutions guarantee that our products have been evaluated for any potential human health hazards. All relevant route of exposure have been taken into account and based upon the intended application are considered safe for routine use. Please be assured that GTS is committed to delivering only safe, effective and high quality products to our customers.

GTS is not responsible for any labeling placed on any package by you relating to the quality or fitness of the product contained in or sold in packaging we provide to you, nor do we assume any liability for any misleading or false claims printed thereon. Furthermore, you agree to indemnify GTS for any claims brought against GTS arising out of the aforementioned labeling or product defect attributable to your products. Furthermore, GTS is not responsible for any adulteration of the packaging once it is shipped to you placed in your possession.

We agree to maintain in effect adequate insurance coverage with reputable insurance companies providing product liability and excess liability all with such limits as are sufficient to protect you and us from the liabilities against by such coverage.

Thank you for your interest in GTS products. Please feel free to contact our Broker, PAMS. Inc. if you need any additional information.

Sincerely, Global Tableware Solution

Global Tableware Solutions, Inc. 15578 Hellman Ave. Chino, CA 91710 Tel: 909-591-3331 Fax: 909-591-6683

January 4, 2021

Dear Valued Customer:

Harris Ranch Beef Company (HRBC; Est. #783) is a functionally-integrated beef company committed to producing safe, wholesome beef products of the highest quality. We are a federally inspected establishment that operates under the principles and procedures outlined in our written HACCP and SSOP programs that simultaneously assure compliance with all relevant USDA-FSIS regulatory requirements such as:

 HACCP and SSOP regulations 9CFR416 and 417  E. coli Biotype 1 Testing and Salmonella Performance Standard 9CFR 310.25  HACCP Annual Reassessment 9CFR 417.4(a)(3). The annual reassessment is effective January of each calendar year and includes reassessment of both E. coli O157:H7 and non- O157 STEC.

Harris Ranch’s unique production model affords us control over raw materials (i.e., cattle), not commonly experienced in the beef industry. Our sister company, Harris Feeding Company (HFC) employs several technologies designed to reduce the prevalence of E. coli O157:H7 in live cattle. While at HFC, cattle are fed Bovamine®, a direct-fed microbial, which has demonstrated a propensity to reduce the fecal shedding of E. coli O157:H7. Furthermore, all cattle trucks are washed in a state-of-the-art truck wash between each load of cattle transported to HRBC thereby reducing the possibility of cross-contamination across loads of cattle. In totality, these pre-harvest pathogen mitigation strategies reduce the pathogenic burden entering HRBC’s facility; subsequently enhancing our ability to preclude the occurrence of pathogenic organisms on our beef products.

Within the animal-to-carcass conversion process, Harris Ranch incorporates multiple hurdle intervention technology which directs the application of multiple-sequential, antimicrobial interventions thus providing synergistic microbial reduction on the carcass or cut surface. HRBC’s intervention system includes hock pasteurization, hot water pre-evisceration, pattern-focused organic acid application, carcass hot water pasteurization, carcass organic acid spray and rapid carcass chilling in conjunction with antibacterial spray chill application. Our hot water pasteurization and carcass organic acid spray are validated pathogen interventions, classified as a Critical Control Point in our HACCP Plan. Additionally, HRBC has identified our carcass chilling process and zero tolerance inspection as CCPs. Other hurdles used at HRBC include lactic acid treatment of primals, subprimals, and trimmings during the fabrication process. All antimicrobial interventions employed at HRBC have demonstrated efficacy against enteric pathogens, including E. coli O157:H7, Non- O157 (O26, O45, O103, O111, O121 & O145) Shiga toxin-producing E. coli (STEC) and Salmonella.

16277 S. McCall Avenue, P.O. Box 220, Selma, California 93662 Office: 800-742-1955 Fax: 559-896-3095 www.harrisranchbeef.com

Harris Ranch’s vacuum packaged subprimals have not been co-mingled due to direct product to product contact in a container and are microbiologically independent. The product contained within an individual vacuum package (single or multiple pieces) is considered a ‘lot’.

Additionally, Harris Ranch’s vacuum packaged products are intended for intact use only unless designated under a “Tested Trim (TT)” code and accompanied with a COA. Harris Ranch expects all customers to address the specific usage of products in their HACCP plans (i.e. intact or non-intact use).

All raw ground beef component testing for E. coli O157:H7 presence is facilitated utilizing methodologies equivalent or superior to N60 surface excision. Harris Ranch employs the industry’s most conservative microbiological lotting scheme – single combo bin or single pallet of boxed trim – subsequently enhancing sensitivity and probability of detecting pathogenic organisms, if in fact, they are present. Microbiological sublot integrity is maintained regardless if tested products are consumed within HRBC’s internal grinding operation or shipped to outside customers for use in raw ground beef production. Variety meat items commonly utilized in ground beef manufacturing (i.e., head meat, cheek meat, heart, and tongue root trim), are also tested for the presence of E. coli O157:H7 utilizing N60 methodology. All HRBC E. coli O157:H7 samples are sent to an accredited 3rd party laboratory where they are screened for the presence of the organism with an AOAC approved immunoassay or PCR methodology. HRBC utilizes test and hold for all products tested for E. coli O157:H7 pending negative results. For HRBC customers who request E. coli O157:H7 testing, a Certificate of Analysis (COA) is provided depicting negative results and the corresponding test methodology.

Harris Ranch follows FSIS’ Compliance Guideline for Establishments Sampling Beef Trimmings for Shiga Toxin-Producing Escherichia coli (STEC) Organisms or Virulence Markers (August 2014) when determining a high event period (HEP). During an Event Day, HRBC will direct the positive microbiological sublots to a full-lethality process, inedible rendering or landfill. Harris Ranch maintains control of the entire day’s production until that day’s E. coli O157:H7 results are received. During an Event Day, HRBC will conduct an investigation to determine if previously tested negative trimmings and subprimals or boxed beef from the same production timeframe may be affected. Those products that HRBC determines to be affected will be diverted to a full lethality process or otherwise destroyed.

In the event of an emergency, written Recall Procedures are in place to provide prompt identification and tracking of all affected products while assuring proper notification to customers. Mock recalls are performed at least twice annually. HRBC also has a written Food Defense program to assure systems are in place to prevent the risk of intentional food contamination.

Other pre-requisite programs in place include but are not limited to:

16277 S. McCall Avenue, P.O. Box 220, Selma, California 93662 Office: 800-742-1955 Fax: 559-896-3095 www.harrisranchbeef.com

 Pest Control: Licensed Technician  Allergen Control: Written procedures to assure allergens are controlled within our facility  Employee training: Upon hire and ongoing training that includes, but is not limited to: HACCP, SSOP, GMP’s, Product Handling, Employee Hygiene, etc.  Metal Detection: Utilized on boneless beef trimmings, ground product, fully cooked products and portion control products  Animal Welfare and Handling (Based on NAMI’s Recommended Animal Handling Guidelines and Audit Guide, September 2019, Rev. 2)  Ruminant Feed Ban: Meat offered for sale is derived from cattle that have been fed materials in compliance with the FDA regulation 21 CFR 589.2000.  Residue Control: HRBC complies with FSIS Directive 10,800.1(rev.1), March 03, 2014 “Residue Sampling. Testing and Other Verification Procedures under the National Residue Program for Meat and Poultry Products.

Specified Risk Materials (SRM’s) are handled in accordance with all USDA-FSIS regulatory requirements, including the SRM Final Rule, “Prohibition of the Use of Specified Risk Materials for Human Food and Requirements for the Disposition of Non-Ambulatory Disabled Cattle (and subsequently published “Requirements for the Disposition of Cattle that Become Non-Ambulatory Disabled Following Ante-Mortem Inspection on March 18, 2009 to augment the previous rule); “Disposition of Non-Ambulatory Disabled Cattle, FSIS Notice 74-10 Issued 12/22/10”; Prohibition of the Use of Certain Stunning Devices Used To Immobilize Cattle During Slaughter” issued in the Federal Register July 13, 2007; effective on October 1, 2007 specifically listed as:

1. Prohibition of the Use of Specified Risk Materials for Human Food and Requirements for the Disposition of Non-Ambulatory Disabled Cattle a. Non-ambulatory disabled animals are unfit for human food: HRBC does not accept or harvest non-ambulatory animals. b. All cattle – tonsils and distal ileum are inedible: The tonsils are removed from all carcasses. Eighty inches of the small intestine including the distal ileum, as measured from the ileocecal junction is discarded to inedible rendering. c. Cattle 30 months and older – the brain, skull, eyes, trigeminal ganglia, spinal cord, vertebral column are inedible (excluding the vertebrae of the tail, the transverse processes of the thoracic and lumbar vertebrae and the wings of the sacrum): HRBC relies on cattle birth records and/or dentition to determine the age of all cattle and segregates those identified as 30 months and older. Our segregation procedures assure that the SRM’s have been removed and properly disposed of as inedible. Bone-in products (that include the vertebral column) are produced from animals that

are under 30 months of age. If it is necessary to produce bone-in product from animals that are 30 months of age and older, specific written procedures are followed to control the SRM (vertebral column) as required by USDA-FSIS regulatory requirements, including proper documentation with customer order. In addition to meeting USDA- 16277 S. McCall Avenue, P.O. Box 220, Selma, California 93662 Office: 800-742-1955 Fax: 559-896-3095 www.harrisranchbeef.com

FSIS regulatory requirements for SRM, some customers consider the spinal cord, dura and dorsal root ganglia as an SRM in cattle of all ages, therefore, HRBC also removes the spinal cord, sheath (dura) and dorsal root ganglia (DRG) that extends from the spinal channel on all carcasses. 2. Meat Produced by Advanced Meat/Bone Separation Machinery and Meat Recovery (AMR) Systems: HRBC utilizes soft tissue separation equipment to recover meat from soft tissues (excluding bones from the vertebral column). This product is segregated and only used in the production of product intended for further processing (i.e. cooking). 3. Prohibition of the Use of Certain Stunning Devices to Immobilize Cattle During Stunning: HRBC does not utilize air injected stunning equipment.

As required under 9 CFR 417.4(a)(3), HRBC has reassessed its HACCP Plan for the SRM Final Rule effective October 1, 2007.

The Final Rule of mandatory Country of Origin Labeling (COOL) was repealed on December 18, 2015 for both muscle cuts and ground beef. All whole muscle and ground beef products produced by HRBC are “Product of USA” as defined by USDA-FSIS Food Standards and Labeling Policy Book. This declaration can also be found on the label of our products, which state, “Product of USA”.

Harris Ranch Beef Company is in compliance with the FDA Bioterrorism Act and is registered.

Harris Ranch Beef Company is BRC certificated and is also audited annually by a 3rd party for Animal Welfare, SRM’s and Verification/Validation of E. coli O157:H7 CCPs/interventions and testing (N60, or equivalent).

Harris Ranch Beef Company is committed to producing the safest and highest quality products possible. All programs are available for review onsite. If you have any questions or need clarification pertaining to the aforementioned information, please, do not hesitate contacting me.

Sincerely,

Curtis Pittman Director of Food Safety & Quality Assurance

16277 S. McCall Avenue, P.O. Box 220, Selma, California 93662 Office: 800-742-1955 Fax: 559-896-3095 www.harrisranchbeef.com

HOUSE OF RAEFORD FARMS OF LOUISIANA, L.L.C. Post Office Box 707 • Arcadia, Louisiana 71001 Ph. (318) 263-9004 • Fax (318) 263-3982

To: Whom it May Concern

Date: June 01, 2020

Re: Poultry Products Continuing Letter of Guarantee - P19865

Poultry products that have been produced and distributed by House of Raeford Farms of Louisiana, L.L.C., P-19865 meet all applicable requirements of the Poultry Products Inspection Act and the Food, Drug, and Cosmetic Act. All poultry products produced at House of Raeford are produced in compliance within an approved HACCP/SSOP program, with oversight by USDA/ FSIS Inspection. All poultry processing steps at House of Raeford have been assessed for the prevention of biological, chemical, and physical hazards. Validated interventions are in place for Biological hazards including Salmonella and Campylobacter identified within the HACCP Plan. We perform daily bird rinse samples at pre chill and matched sample rinse at post chill for Salmonella, Campylobacter and E. coli. These results are reported to us from an outside lab service for review. The Salmonella and Campylobacter results are tracked on a computerized spreadsheet.

Testing of flocks for residual pesticides are performed and analyzed to ensure that no chemical hazards are present in our products. We have a system in place to test all flocks prior to slaughter for the AI strain HPAI H5N1. All results are received prior to slaughter of the birds. Our company is registered as part of the National Poultry Improvement Plan (NPIP). Our registered NPIP # is 72-744.

House of Raeford’s all natural chicken products originate and mature on local U. S. family farms without the use of growth hormones or steroid supplements and have been minimally processed. In its fresh state, we do not add artificial ingredients, coloring, or chemical preservatives except by customer request.

Water potability certificates and testing are updated a minimum of bi-annually to ensure that no biological contaminates are present in our potable water supply. Our facility has a Process Verified Program (PVP) that is audited by USDA/AMS with the following approved claims; NAE, RUA, NAIHM, NAIHH, and USA Source Verified. (www.processverified.usda.gov)

The Processing Plant operates under a written GMP Company Policy. An approved Pest Control Program is in place from outside contractor. Our Food Defense Plan is implemented using the guidelines recommended by the USDA and is audited through USDA/AMS. Sanitation of the plant is performed by a Contract Sanitation Company (PSSI) with daily pre-operational inspection performed by QA Employees.

Our establishment is SQF certified to include a Supplier Approval Program. We also implement a Hold program within our Quality Assurance Department. Maintenance management follows a preventative maintenance program within our establishment that is followed weekly or as needed. Recall procedures are developed with mock recalls performed annually.

All poultry products produced at House of Raeford’s facilities have been produced under Quality Assurance and HACCP programs to ensure compliance with current customer and company requirements.

Mitzi Gaddy, QA/HACCP Manager – P19865 [email protected] Our Mission “To do the Right Thing in all things that we do”. CONFIDENTIAL COMMERCIAL INFORMATION

______

JANUARY 4th, 2021

BEEF HACCP LETTER OF GUARANTEE Dear Valued Customer,

Edible beef products from the plants listed at the end of this letter meet all USDA requirements for the production, sale and distribution of meat products.

REGULATORY COMPLIANCE Tyson Fresh Meats plants listed below are federal establishments and operate under the regulatory requirements set forth in Title 9 of the Code of Federal Regulations. . Carcasses E. coli Biotype I Testing (9CFR§310.25) . HACCP & SSOP (9CFR§416 and 417) . Salmonella Performance Standard as conducted by USDA-FSIS (9CFR§310.25) . Documented Annual Reassessment (9CFR§417.4 (a) (3)) effective January of each year. This annual reassessment includes review E. coli O157:H7 [EC7] and non-O157 STEC as defined by FSIS Federal Register Notice [Docket No. FSIS -2010-0023]. . Ante-mortem inspection of all cattle intended for slaughter (9 CFR 309). . Humane handling and slaughter of livestock (9 CFR 313).

HACCP CRITICAL CONTROL POINT (CCP) Critical Control Points are in place and validated for the control of enteric pathogens (specifically EC7). . Validated Final Carcass and Offal intended for raw ground use intervention. . Chilling . Zero Tolerance for feces, ingesta, and milk (FSIS Directive 6420.2) . Disposition for EC7 positive product.

INTERVENTIONS Tyson Fresh Meats beef plants employs multiple hurdle interventions to carcasses, primals, and trimmings after the final slaughter CCP intervention for the purpose of reducing microbial contamination that may be present on the surface of the carcass or cuts.

Treatment of carcasses with these validated interventions can result in surface discoloration of exposed lean tissues. Briskets, inside rounds and tenderloins are among the cuts that are most often exposed to these treatments and affected. Occasionally, trimming of the carcass surfaces may result in other discolored subprimal surfaces as the intervention contacts the expose protein and in turn, results in denaturing of the protein tissues. In addition, some offal products such as kidneys will also be affected by the carcass interventions, affecting the typical color of the product.

Tyson Fresh Meats employs a validated multiple hurdle process within the beef slaughter systems to address Enteric Pathogens, specifically E. coli O157:H7 and other non-O157 Shiga Toxin producing E. coli [STEC]. These hurdles include: . Hide-On Treatment – Animal hides may be treated March through October through a pre-harvest intervention and/ or a hide-on wash immediately after exsanguination. . Steam Vacuums and/ or Trimming – Strategically placed to address pattern opening areas. . Pre-Evisceration Cabinet System (PECS) – Eligible carcasses are surface treated with an approved processing aid for purpose of reducing microbial contamination.

Page 1 of 3

. Carcass Interventions – After FSIS final inspection, carcasses are treated with one or more pathogen reduction interventions which are demonstrated effective in reducing microbial contamination, which is considered as a Critical Control Point [CCP] of the slaughter system. . Carcass Spray Chill- Following carcass interventions, carcasses are treated with a processing aid during the spray chill process. . Offal Intervention – Offal products intended for raw ground beef are treated with one or more processing aids which are demonstrated effective in reducing surface microbial contamination, which is considered as a Critical Control Point [CCP] of the slaughter system. . Primal & Trim Treatment – Primals and trimmings are treated with an approved processing aid during the carcass disassembly process and prior to packaging. Under USDA- FSIS rules, ‘processing aids’ are considered Generally Recognized As Safe [GRAS] by the FDA, and do not have to be included in the products ingredient statement on the label. Processing Aids fall under approvals listed in FSIS Notice 7120.1 (http://www.fsis.usda.gov/Regulations_&_Policies/7000_Series- Processed_Products/index.asp). Additionally, being listed in FSIS Notice 7120.1 means that there is efficacy data submitted to USDA that supports its’ use for pathogen reduction when used as described in the approval.

STEC TESTING & ANALYSIS (FOR ALL PRODUCTS INTENDED FOR RAW GROUND USE) . Sampling: Tyson N60 Prerequisite Program requires a minimum of 60 pieces per lot collected per the outlined methods [or equivalent] within the August 2014 FSIS Compliance Guideline for Establishments Sampling Beef Trimmings for Shiga Toxin-Producing Escherichia coli [STEC] Organisms or Virulence Markers. Tyson Fresh Meats plants employ N60 surface excision or sampling via the IEH N60 Plus™ sampling device or via the Manual Sampling Device (MSD). . Analysis: The entire sample is analyzed via PCR or equivalent laboratory method. Laboratory methods are validated to meet USDA criteria (≥ 98% Sensitivity and ≥ 90% Specificity). . Verification of STEC lab methods are routinely performed at each Tyson Fresh Meats Laboratory in conjunction with the American Proficiency Institute Microbiological Performance Evaluation Program. . Tyson Fresh Meats Laboratories have been audited and certified per ISO 17025 standards. . Combo: Tested per customer order with an individualized COA to that specific product. . Boxed Trim & Offal: All tested trim and offal items are labeled with a product code ending in “T”. A labeling information sheet is provided on our website (link at bottom of this letter). . Ground Beef – All ground beef produced by Tyson Fresh Meats [IBP] is derived from trimmings tested negative for E. coli O157:H7 under the Tyson N60 [or equivalent] program. A ‘Tested Negative’ statement is printed on the Bill of Lading for each order of ground beef. . Tyson Fresh Meats utilizes a formal risk assessment program that evaluates specific investigatory findings from the ‘on-site’ investigation immediately following a High Event Period [HEP]. . STEC Verification Testing is conducted at a monthly frequency April through September with a quarterly frequency October through December. This verification sampling includes analysis for E. coli O157:H7, O26, O45, O103, O111, O121 and O145. . External sources of raw material must meet or exceed Tyson Foods, Inc. supplier requirements for STEC sampling and analysis.

3rd PARTY AUDIT Tyson Fresh Meats is audited on an annual basis by an independent 3rd Party standard. This audit encompasses food safety, regulatory compliance, STEC best practices and good manufacturing practices. GFSI Certifications provided for all processing / grinding plants (link at bottom of this letter). GFSI certification is achieved after successfully completing the certification audit and completion of 100% of corrective actions identified by the independent auditor.

Non-O157 STEC System Producing the safest food possible is Tyson’s primary goal. Tyson Fresh Meats [TFM] has reviewed our existing food safety systems, assessed our HACCP programs, and along with published scientific research, we conclude that our existing pathogen reduction technologies and beef slaughter process controls for E. coli O157 are effective in providing the same control to Other-STEC [Top6] in beef trimmings and non-intact beef intended for raw use.

Page 2 of 3

. Interventions currently in place for the reduction of Enteric Pathogens, including E. coli O157:H7, are effective in addressing non-O157 STECs. . Research conducted by Tyson Fresh Meats demonstrates that E.coli O157:H7 is an appropriate ‘indicator’ organism for Other-STEC in beef trimmings, therefore, testing for E.coli O157 is an effective screening program for the Other-STEC. From the currently available data we thus conclude that “a SYSTEM in control for E. coli O157:H7 is a SYSTEM in control for Other-STEC.” . Our robust and comprehensive E. coli O157:H7 trim testing program will continue on 100% of our beef trim as this program continues to verify our control of E. coli O157:H7. This research data tells us that this is the best approach for monitoring and controlling Other-STEC as well. For beef trimmings this will be reflected in our COA’s and LOG’s as “Our robust and comprehensive E. coli O157:H7 trim testing program will continue on 100% of our beef trim as this program continues to verify our control of E. coli O157:H7. This research data is telling us that this is the best approach for monitoring and controlling non- O157 STEC as well. Product was lot tested and found Negative for E. coli O157:H7 and was produced from a System that also controls non-O157 STEC.”

Research data will continue to be assessed and scrutinized to ensure that effect non-O157 controls are in place.

Customer Notification Tyson Fresh Meats plants have a recall plan on file that includes notification to affected customers of any product that may be adulterated or misbranded.

TYSON FRESH MEATS BEEF PLANTS EST. Location EST. Location Est. 245E Amarillo, TX Est. 278 Holcomb, KS Est. 245C Dakota City, NE Est. 245L Lexington, NE Est. 245D Emporia, KS [further processing] Est. 9268 Pasco, WA Est. 245J Joslin, IL

Send questions or update requests to [email protected]

Daniel R. Mallin Senior Director, FSQA Tyson Fresh Meats Dakota Dunes, South Dakota Please visit our website for all letters of guarantee provided: https://www.tysonfoods.com/sustainability/food/certifications-and-programs

Processing Aids Under USDA rule, ‘processing aids’ are considered GRAS by the FDA, and do not have to be included in the products ingredient statement on the label. Processing Aids fall under approvals listed in FSIS Notice 7120.1 (http://www.fsis.usda.gov/Regulations_&_Policies/7000_Series- Processed_Products/index.asp). Additionally, being listed in FSIS Notice 7120.1 means that there is efficacy data submitted to USDA that supports its’ use for pathogen reduction when used as described in the approval.

Q2: What is the definition of a processing aid? Answer: According to the Food and Drug Administration’s (FDA) regulations (21 CFR 101.100 (a) (3) (ii)), the definition of a processing aid is: a. Substances that are added to a food during the processing of such food but are removed in some manner from the food before it is packaged in its finished form. b. Substances that are added to a food during processing, are converted into constituents normally present in the food, and do not significantly increase the amount of the constituents naturally found in food. c. Substances that are added to a food for their technical or functional effect in the processing but are present in the finished food at insignificant levels and do not have any technical or functional effect in that food.

Page 3 of 3

January 5th, 2021

Dear Valued Customer:

Please be advised that all edible pork products from the Tyson Fresh Meats (TFM) production facilities listed in the following table, meet the applicable regulatory requirements for the production, sale and distribution of pork products. All TFM facilities are inspected by the United States Department of Agriculture (USDA) Food Safety Inspection Service (FSIS) daily, during posted hours of operation.

Tyson Fresh Meats, Inc. – Fresh Pork Plants

USDA Establishment Number* Location Est. 244 Storm Lake, IA Est. 244I Logansport, IN Est. 244L Columbus Junction, IA Est. 244M Madison, NE Est. 244P Perry, IA Est. 244W Waterloo, IA

* Confirmation of federal inspection by be found at: http://www.fsis.usda.gov/Regulations_&_Policies/Meat_Poultry_Egg_Inspection_Directory/index.asp

Such requirements include, but are not restricted to, the programs and procedures listed below:

• Compliance to the Federal Food, Drug, and Cosmetic Act, as applicable; • Compliance to Bioterrorism Act of 2002, as applicable to a USDA inspected facility; • Humane handling and slaughter of livestock (9 CFR 313); • Ante-mortem inspection of all swine intended for slaughter (9 CFR Part 309); • Post-mortem inspection of all swine carcasses and viscera intended for human consumption (9 CFR Part 310); • Implementation of SSOP (Sanitation Standard Operating Procedures, 9 CFR, Part 416, §416.11 - §416.17);

Tyson Fresh Meats, Inc., 800 Stevens Port Drive, Dakota Dunes, SD 57049 Page 1 of 3 • Implementation of HACCP Systems (9 CFR, Part 417, §417.1 - §417.8). All HACCP plans include at least one validated critical control point (CCP). A process flow chart for fresh pork and edible lard is found below:

• Testing of carcasses for E. coli Biotype I (9 CFR Part 310, §310.25) or per the current FSIS Salmonella Incentive Program (SIP) requirements; • Testing of carcasses for Salmonella as conducted by USDA in accordance with 9 CFR §310.25, or SIP waiver as applicable.

Please note that TFM pork slaughter facilities do not have “specified risk materials” as defined by current regulations. Specified risk materials (SRMs) are the parts of cattle that could potentially harbor the BSE agent in an infected animal. In U.S. regulations, SRMs are defined as the brain, skull, eyes trigeminal ganglia, spinal cord, vertebral column (excluding the vertebrae of the tail, the transverse processes of the thoracic and lumbar vertebrae, and the wings of the sacrum) and dorsal root ganglia of cattle 30 months of age and older. SRMs also include the tonsils and distal ileum of all cattle.

Tyson Fresh Meats, Inc., 800 Stevens Port Drive, Dakota Dunes, SD 57049 Page 2 of 3 In addition, Tyson Fresh Meats facilities have developed and implemented Food Safety and Quality Systems that are compliant with the requirements of the Global Food Safety Initiative (GFSI). All Tyson Fresh Meats plants have achieved certification to the current BRC Global Standard for Food Safety. Such requirements in addition to the programs and procedures listed above include, but are not restricted to, the programs and procedures listed below:

• Good manufacturing practices (GMPs), as applicable; • Pest control; • Traceability, Recall and Crisis Management procedures; • Internal and External Auditing procedures.

Please also be advised that all Tyson Fresh Meats facilities have developed and implemented a food defense plan specific to each facility, as recommended by FSIS/USDA.

If additional information is required, please contact me.

Sincerely,

Mindy Henry Senior Director Food Safety and Quality Assurance Tyson Fresh Meats, Inc. (605) 235-3463

Tyson Fresh Meats, Inc., 800 Stevens Port Drive, Dakota Dunes, SD 57049 Page 3 of 3

Interstate Meat Dist. Letter of Guarantee

To our valued customers:

All ground beef, boneless beef trimmings and fresh ground pork product processed by Interstate Meat Dist., Inc. are produced under a United States Department of Agriculture Grant of Inspection. All of our products are identified with the USDA mark of inspection identified with our establishment number 965 & 965A.

Interstate Meat Dist., Inc. implemented the Hazard Analysis and Critical Control Point (‘HACCP”) food safety system in 1998. We operate under USDA Standard Sanitation Operating Procedures (“SSOP’s”), Good Manufacturing Practices (GMP’s) and Interstate Standard Operating Procedures.

We have reassessed our HACCP Plan in light of the information outlined in USDA, FSIS Notice 44-02 dated 11-04-02. We recognize that in light of the information presented in the above mentioned Notice 44-02 that cattle have a higher incidence of E.coli 0157:H7 than previously thought, therefore E.coli 0157:H7 is a hazard likely to occur in beef trimmings.

We also recognize that as of June 2012 USDA declared the top 6 non-0157 STECs as adulterants in raw non-intact beef products. Our procedures and intervention, Sanova (Acidified Sodium Chlorite), currently in place for reducing E.coli 0157:H7 are effective in addressing non-0157 STECs.

We have reassessed our HACCP Plans in light of the information outlined in FSIS, USDA Notice 4-04 dated January 9, 2004. We are aware of the issuance of new regulations in the Federal Register on January 12, 2004, in response to the diagnosis by USDA of a positive case of BSE in Washington State. Interstate Meat Dist., Inc. is not a slaughter facility nor do we bone carcass or cuts. We have contacted all of our suppliers and they have acknowledged their awareness of the new regulation and their compliance with them.

We have reassessed our HACCP Plan with regard to the information in FSIS, USDA 65-07 dated 10/12/07. We have modified our Supplier Specifications, Microbial Testing Schedule and adopted the N=60 sampling method for E.coli 0157:H7. We have adopted quarterly verification testing frequency for e.coli 0157:H7 using the N=60 testing method for each of our Domestic Boneless Beef Suppliers. We have adopted verification testing of our finished ground product to be a minimum of six times annually for e.coli 0157:H7 using robust sampling methods.

We participated in an annual Third-Party Auditing program and have achieved a Good rating in Safe Quality Foods (SQF) Edition 8.0. Facility: 965, 965A Page 1 of 2 References: 2.4 Status: Published Document will be reviewed annually. Reviews and change Doc #: 61921 Print Date: 1/2/20 history are maintained in Qualtrax. Version: 1 Approval Record: Rodolfo Mendoza Approved on 1/2/2020 3:17:13 PM

Interstate Meat Dist. Letter of Guarantee

We reassess our HACCP Plans, Sanitation Standard Operating Procedures, Rodent Control Program, and GMP Programs annually to verify that the programs are working as they are intended and are effective for their purpose.

We purchase meat products from processing and slaughter facilities that are inspected by USDA and all products are identified as “inspected and passed” with the USDA mark of inspection and facilities approved by USDA for importation. We implemented Boneless Beef Supplier Purchase Specifications outlining the process requirements with regards to HACCP, SSOP’s, pathogen interventions and controls. All of our beef trimmings suppliers are sampling with N=60 or equivalent methods (combo packed) beef trimmings for E.coli 0157:H7 and supplying confirmation of negative results prior to delivery of combo packed boneless beef trimmings. Each of the suppliers has at least one validated intervention to eliminate or reduce e.coli 0157:H7 below detectable levels.

We have a CCP with a critical limit of 45 degrees F. to control the temperature of products and validate our plans routinely. We monitor our environment through microbial testing weekly. These tests are monitored on an ongoing basis for trend analysis of plant, equipment and both raw materials and finished products.

We are currently registered with the FDA Bioterrorism Act and comply with all applicable Federal, State of Oregon and Clackamas County regulations.

Interstate Meat Dist., Inc. will continue to strive to process and distribute safe wholesome food products by purchasing raw materials from responsible suppliers with controls and interventions in place to eliminate or reduce pathogens to undetectable levels and; through proper handling, temperature control and implementation of new procedures based on scientific studies and new technologies as they are developed. We stress the importance of proper handling and cooking of raw meat products by our customers as the critical and final step in the food safety system.

Respectfully, Interstate Meat Dist., Inc.

Facility: 965, 965A Page 2 of 2 References: 2.4 Status: Published Document will be reviewed annually. Reviews and change Doc #: 61921 Print Date: 1/2/20 history are maintained in Qualtrax. Version: 1 Approval Record: Rodolfo Mendoza Approved on 1/2/2020 3:17:13 PM

January 4, 2021

Dear Valued Customer:

JBS USA Food Company and JBS Food Canada, ULC (JBS) would like to inform you and your company of the Food Safety and Regulatory Programs, and other significant Programs which we have implemented at each of our beef harvest and/or processing locations noted below:

Regional Beef Plants Fed Beef Plant Canada Beef Plant Est. 562 – Green Bay, Wisconsin Est. 3D – Cactus, Texas Est. 38 – Brooks, Alberta, Canada Est. 532 – Omaha, Nebraska Est. 969G – Grand Island, Nebraska Est. 562M – Plainwell, Michigan Est. 969 – Greeley, Colorado Est.1311 –Souderton, Pennsylvania Est. 628 – Hyrum, Utah Est. 267 – Tolleson, Arizona

The programs outlined below have been implemented in order to comply with the United States Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) and with The Safe Food for Canadian Regulations regarding HACCP, Preventative Control Plans, and Control Measures for Escherichia coli O157:H7 in Raw Beef Products.

Food Safety Programs

Please be advised that each of the JBS beef facilities listed above operate under a fully implemented Hazard Analysis and Critical Control Point (HACCP) plan, which conforms to all applicable requirements set forth in 9 CFR Part 417. All products produced at these JBS facilities are subjected to these HACCP systems. Additionally, all JBS facilities perform generic E. coli biotype I testing on carcasses per 9 CFR 310.25 and participate in the USDA-FSIS pathogen sampling of raw beef; Canada – Export requirements for USA meat products Annex T.

Occasionally, due either to changes in the regulations, plant procedures, or nationwide information that may affect the hazard analysis or alter the critical control points, the adequacy of the HACCP Plan is reassessed as required under 9 CFR 417.4(a)(3)(i). We are in compliance with all parts of 9 CFR 417 and at a minimum, each facility re-assesses their respective HACCP plan annually.

JBS beef facilities Food Safety processes consist of Standard Operating Procedures (SOPs), Sanitation Standard Operating Procedures (SSOPs) 9 CFR Part 416, Hazard Analysis Critical Control Points (HACCP) 9 CFR Part 417, and validated technology interventions, which are designed to eliminate or reduce E. coli O157:H7 to below detectable levels. Our Food Safety Process utilizes technology interventions (Multiple Hurdle Strategy) during harvest and fabrication which may include steam vacuums, pre-evisceration wash and/or antibacterial chemical treatment, thermal pasteurization and/or antibacterial chemical treatment (CCP), organic acid, PAA, finished product antibacterial chemical applications, and cold chain management (CCP) systems. Our variety meat / offal processing also utilize antibacterial chemical application (CCP for Red Meat Offal) and cold chain management (CCP) systems.

JBS Beef Food Safety Letter 01.04.21 Page 1 of 6

Our ground beef systems utilize purchase specifications that require raw materials to be pre- screened and tested negative for E. coli O157:H7 and have a defined cold chain management. Our Food Safety Process is monitored by Operations personnel and verified by Quality Assurance and USDA-FSIS (or CFIA) personnel in each plant. Inspection and process verification by USDA-FSIS (or CFIA) personnel occurs before the mark of inspection can be placed on products which will enter into commerce.

Prior to shipment of our products, we determine that all CCPs have been met and that our process is under control per 9 CFR 417. If our CCPs have not been met or have been found to be ineffective, corrective and preventative actions are taken as required under 9 CFR 417.3. Effectiveness of our ability to meet the Critical Limits outlined in our HACCP plan is evaluated daily through pre-shipment records review and records verification checks.

In addition, all JBS beef facilities have implemented these programs:

 A written Good Manufacturing Procedures (GMP) program.  A Recall/Market Withdrawal Procedure, which provides for trace-back and track- forward capabilities to ensure that the proper products and dates can be identified if necessary.  A livestock certification program which requires all cattle producers to certify compliance with 21 CFR 589.2000.  A documented Pest Control Program.  A documented Food Security Program (Note: details of these programs are not shared or distributed to ensure the integrity of the program.).  All JBS beef plants are certified annually to the Global Food Safety Initiative (GFSI) standards under BRC for both food safety and quality.  We utilize insured and bonded Carriers to Transport JBS beef products. All loads are sealed at the originating establishment and maintained under seal by the carrier in the event of a multi-stop load.

E .coli O157:H7 Control and Testing

Please note that vacuum packaged beef subprimals and vacuum packaged offal red meats sold in a box are not intended for use in ground products.

We perform microbial testing of beef manufacturing trimmings, specially packaged sub-primals (i.e., unwrapped and bulk packed in combo), and bulk packaged offal red meats destined for direct utilization in raw comminuted finished products. Beef manufacturing trimmings (including unwrapped bulk packed sub-primals intended for further processing) that are tested for E. coli O157:H7, utilize a robust sampling method based on the International Commission on Microbiological Specifications for Foods (ICMSF) Case 15, two-class sampling plan for a severe hazard (i.e., N=60) or equivalent sampling method (i.e., N60 excision, N60+, or cloth). These samples (100% of sample) are analyzed by an accredited laboratory utilizing an AOAC approved methodology. Laboratory methods used have been demonstrated to be at least as sensitive and

JBS Beef Food Safety Letter 01.04.21 Page 2 of 6

specific as the FSIS methods and MLG 5.09 (January 15, 2015), 5A.04 (June 29, 2014), and 5B.05 (June 29, 2014) and the CFIA Control Measures for Escherichia coli O157:NM in Raw Beef Products.

If products have been tested for E. coli O157:H7, shipments will be accompanied with a Certificate of Analysis (COA) indicating the results of the tests in the form of a Raw Material Notification Document (RMND), a signed letter from the plant, or a copy of the laboratory results. Test results from sampled products represent complete lots unless otherwise noted. The absence of a COA is indication that the product has either not been tested or the customer has not purchased tested products at the time of sale. If a COA is provided for E. coli O157:H7, then the samples that are listed in that report represent products that were produced from a system that controls both E. coli O157:H7 and non-O157 STECs.

Analysis of samples for E. coli O157:H7 is conducted by 3rd party laboratories. Respective laboratories used by each facility location along with that laboratory’s accreditation information and testing methodologies are posted on our customer website (see details at the end of this letter).

Each of our establishments have a third party verification of our E. coli O157:H7 sampling program via an annual audit of the process that is performed between April and September. Additionally, raw material components which have previously been tested and found negative for E. coli O157:H7 are sampled and analyzed (E. coli O157:H7 and top 6 non-O157 STECs) to verify the effectiveness of our food safety systems. This sampling of beef manufacturing trimmings (including unwrapped bulk packed sub-primals intended for further processing) is conducted monthly and the results are posted quarterly on our customer website (see details at the end of this letter).

In our JBS Food Canada, ULC facility, boxed product known to be intended for raw ground use, i.e., beef trimmings from carcasses, head and cheek meat, hearts, hanging tenders and weasand meats are known to be intended for raw ground use and therefore robustly sampled utilizing N60 or equivalent methods. These products are identified by a “T” on the label within the product code on the individual boxes.

With specific regard to the ground beef products produced by all our facilities, all raw materials that will be used in the manufacture of these products are tested and found negative for E. coli O157:H7 prior to their use, as described in the methods above. Notification of raw material testing is provided on a load by load basis on the Bill of Lading documents accompanying every ground beef load. External sources of raw material used by JBS Food Canada, ULC must meet or exceed JBS Food Canada ULC requirements per Supplier Addendum.

JBS Beef Food Safety Letter 01.04.21 Page 3 of 6

Non-O157 Shiga Toxin producing E. coli (STEC)

Scientific research has shown that the same interventions that are effective for controlling, reducing, or eliminating E. coli O157:H7 are also just as effective on the non-O157 STECs (Kalchayanand, N. et al., 2012). Industry data has proven that a production system that controls the presence of E. coli O157:H7 also effectively controls the presence of non-O157 STECs. Our Food Safety processes consist of Standard Operating Procedures (SOPs), Sanitation Standard Operating Procedures (SSOPs) 9 CFR Part 416, Hazard Analysis Critical Control Points (HACCP) 9 CFR Part 417, and validated technology interventions, which are designed to eliminate or reduce E. coli O157:H7 to below detectable levels; hence, controlling the non-O157 STEC levels to the same degree. It is the opinion of JBS that testing beef manufacturing trimmings and ground beef for non-O157 STECs would not increase the robustness of our food safety programs. Therefore, we will not test our beef manufacturing trimmings or ground beef for the non-O157 STECs.

Event Program

Even with exhaustive interventions, processes, and testing; unfortunately, non-negative results are sometimes obtained. JBS evaluates each non-negative event to determine if the level of non- negative results in any given production period or day exceed statistically acceptable levels. If it is determined that the non-negative results constitute an “Event”, products produced before, within, and after the associated period or day are evaluated and appropriate disposition is made.

Beef Subprimal Antimicrobial Treatment

Our beef facilities apply multiple antimicrobial treatments to carcasses and primals/subprimals after the final slaughter Critical Control Point (CCP) intervention. Our facilities apply an antimicrobial solution to the subprimals and trimmings at the end of the fabrication process prior to packaging.

The antimicrobial treatments utilized are approved by USDA-FSIS as ‘processing aids’ and comply with the approval issued in Directive 7120.1 for use and labeling or by CFIA / Health Canada. These ‘processing aids’ have been validated through in-house sampling of generic microorganisms. Although these process aids are employed by all plants as a part of our multiple hurdle food safety approach, they are not defined as critical control points in our HACCP plans.

Additional Information

Our U.S.A. facilities are USDA-FSIS inspected establishments. Each animal slaughtered and processed at our facilities undergoes ante mortem and postmortem inspection by FSIS personnel, who determine which carcass and parts are free of disease and are wholesome.

JBS Beef Food Safety Letter 01.04.21 Page 4 of 6

JBS Food Canada, ULC is a licensed food business that CFIA verifies is compliant to the Safe Food for Canadian Regulations (SFCR), HACCP, and PCP requirements. By applying the Mark of Inspection, we are obligated to adhere to all applicable requirements contained therein.

Our U.S.A facilities have a comprehensive PCP (Preventive Control Program) in place, which includes a HACCP program, and meet the SFCR (Safe Food for Canadian Regulations) requirements and are eligible to export beef products to Canada.

JBS USA Food Company facilities comply with FSIS Directive 10,800.1 (rev.1), March 3, 2014, entitled “Residue Sampling. Testing and Other Verification Procedures under the National Residue Program for Meat and Poultry Products.”

In addition to the above, our process also includes a continuing product guarantee, which we provide to our customers upon request. Our Bill of Lading contains statements regarding HACCP Programs and SRM control.

Our food safety systems have been validated to show at least a 3 log reduction throughout our process.

JBS USA Food Company is compliant to USDA-AMS-ARC regulations based on an export country’s specific requirements – view approval at website: https://www.ams.usda.gov/services/imports-exports/bovine-ovine-and-caprine-export- verification-programs.

You are cordially invited to visit our facilities and review our processes, with proper notification provided through your Sales Representative or other JBS contact. We trust this information is useful to you and we look forward to serving you as a customer and as a partner of JBS.

We hope that you find this information useful in reassessing your programs with regard to the above mentioned regulations. The most recent version of this letter and other related food safety information can be found under ‘Our Business – Beef – Food Safety – Food Safety Log In’ on our www.jbssa.com website located at: http://jbssa.com/food-safety/

We look forward to continuing to provide you with wholesome, quality products.

JBS Beef Food Safety Letter 01.04.21 Page 5 of 6

If you need additional information, please contact the respective Beef Food Safety Team: Regional Beef Sherri Williams 970-506-8153 [email protected] Scott Leach 970-506-7542 [email protected] Corri Piper 970-506-7691 [email protected]

Fed Beef Brian McFarlane 970-304-7022 [email protected] Art Rogers 970-506-8258 [email protected] Renata Dolazza 970-506-7557 [email protected]

Canada Beef Warren Klymchuk 403-501-2144 [email protected]

Respectfully,

Art Rogers Technical Services JBS USA FOOD COMPANY

Reference:

Kalchayanand N, Arthur T, Bosilevac J, Schmidt J, Wang R, Shackelford S, and Wheeler T. 2012. Accepted J. Food Protection. Evaluation of Commonly Used Antimicrobial Interventions for Fresh Beef Inoculated with Shiga toxin-producing Escherichia coli serotypes O26, O45, O103, O111, O121, O145, and O157:H7.

JBS Beef Food Safety Letter 01.04.21 Page 6 of 6 CONTINUING PRODUCT GUARANTEE

Hormel Foods Corporation (HFC) 1 Hormel Place, Austin MN 55912 - including its subsidiaries and divisions: Alma Foods LLC Hormel Foods Corporate Mexican Accent LLC Applegate Farms LLC Services LLC Mountain Prairie, LLC Burke Marketing Corporation, dba Hormel Foods Int'l Corp. Osceola Food LLC Burke Corporation Hormel Foods Sales LLC Progressive Processing LLC Century Foods International LLC Hormel Health Labs LLC Rochelle Foods LLC Columbus Manufacturing Inc Jennie-O Turkey Store Inc Sadler's Smokehouse LLC Dan's Prize Inc. Jennie-O Turkey Store Sales Swiss American Sausage Co., a Dold Foods LLC LLC division of Provena Foods Inc. Fontanini Foods, LLC Justin's LLC Skippy Foods, LLC Lloyds Barbeque Company LLC

(collectively "Hormel Foods") hereby guarantees that each food product hereafter shipped or delivered by it to any location, distributor, store, office or warehouse of: PACIFIC FOOD DISTRIBUTORS 12300 SE CARPENTER ROAD PO BOX 2810 CLACKAMAS OR 97015

(the "Buyer") is, on the date of such shipment or delivery,

a) As to FDA regulated food products: not adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act (FDCA) as amended, and is not a product which may not, under the provisions of sections 404 and 505 of the FDCA, be introduced into interstate commerce; or

b) As to USDA-FSIS regulated food products: not adulterated or misbranded within the meaning of the Federal Meat Inspection Act (FMIA) or Poultry Products Inspection Act (PPIA), as applicable.

This guarantee shall not apply to misbranding arising out of the use of Buyer-applied or supplied labels, or any label elements required by Buyer.

Hormel Foods' civil liability, if any, shall be determined by its General Terms of Sale applicable to sales of said products by Hormel Foods and by normal judicial processes.

Hormel Foods agrees to indemnify, defend and hold Buyer harmless from and against any claim, demand, cause of action, liability or loss directly or indirectly arising from or proximately connected with Hormel Foods' breach of the Guarantee set forth above, except to the extend caused by Buyer's (including its agents or employees') acts or omissions, or breach of any agreement between the parties.

This is a continuing guarantee subject to revocation at any time by written notice to Buyer. This continuing guarantee agreement is not assignable and revokes any prior guarantee agreement between the parties. Signed at Austin, Minnesota, this 5th day of January, 2021.

HORMEL FOODS CORPORATION 1 Hormel Place, Austin, MN 55912-3680

BY:

JEFF B. HORNER Risk Manager

2263 West 190th Street, Torrance, CA 90504, USA p: 1-310-879-4877 ● f: 1-855-881-9888

To: Pacific Food Distributors Attn: Roger Jones

Re: HACCP Certificate of Compliance

January 14th, 2021

Dear Roger:

On December 18, 1997, the new FDA Seafood HACCP Regulation went into effect mandating the use of HACCP food safety systems in the processing and handling of all fish and fishery products intended for human consumption. This regulation applies to all product produced in the United States as well as foreign countries that may be destined for importation into the United States.

Keysource Foods strongly supports HACCP and has worked closely with our overseas suppliers to develop HACCP-compliant systems since the regulation’s passage in 1995. We were successful in raising the foreign processors’ awareness and obtaining their cooperation in improving manufacturing practices.

With our commitment to provide quality seafood products in mind, we would like to assure our loyal customers that all our products are processed under the strictest health and sanitary standards. We are pleased to inform that all our suppliers are fully compliant with the HACCP Regulation.

We look forward to continuing our relationship long into the future. Please do not hesitate to contact us if you have any questions. Thank you very much.

Sincerely,

Roger Lin Keysource Foods Corporate Office Koch Foods, Inc. 1300 West Higgins Road Suite 100 Park Ridge, Illinois 60068 Phone: 847.384.5940

January 4, 2021

LETTER OF GUARANTEE:

All products produced from Koch Foods facilities (P-9141, P-308, P-34296, P-7487, P-509, P-19152, P-19378, P-9181, P-6529, P-6666, P-1254, P-18554, P-548, P-646, P-18554A, P-18554 and P-20795) and JCG Foods facilities (P-548 and P-646) are USDA inspected. They operate and follow the 9CFR regulations and our HACCP plans are in compliance with USDA regulations and all requirements of 9CFR 417. The 9CFR regulations mandates clean, wholesome and safe for human consumption product is produced that is not misbranded. We monitor finished product temperatures at time of ship for temperature compliance as well as pallet appearance.

All of Koch Foods and JCG Foods operations operate under a Standard Sanitation Operational Program (SSOP) that addresses operational and pre-operational sanitary conditions. We also adhere to established Good Manufacturing Procedures (GMP’s) as well as product quality inspection criteria and “in house” procedures. Koch Foods and JCG Foods processing facilities are USDA inspected and have assigned plant ID numbers which meets FDA registration requirements. Koch and JCG feed mills and hatcheries have registered with FDA.

If I can be of further assistance, or if you have any other questions please feel free to contact me at any time. My contact numbers are listed below.

Sincerely, Susan L. Holmes Susan L. Holmes Director of Quality Assurance Koch Foods, LLC 123 S. Fairmont Ave. Morristown, TN 37815 (O) (423) 522-2314 (C) (423) 736-1863 (F) (423) 586-5710 Email: [email protected]

Koch Foods, Inc. • 4100 Port Union Drive • Fairfield, OH 45014 • 513 874.3500

www.KochFoods.com

TO: Quality Control Manager

DATE: 1/02/2020

RE: Certificate of Compliance and Product Guarantee

This letter is our guarantee that all products Lawrence Wholesale, LLC supplies to your company have been produced and stored in a facility that is in compliance with the United States Food and Drug Administration and the Poultry Products Inspection guidelines for Hazard Analysis Critical Control (HACCP, 21 CFR part 123 / 9 CFR CH.III PART 417), adheres with Good Manufacturing Practices and Good Agricultural Practices (GMP/GAP, 21 CFR Part 110), and operates under a program of proper Sanitation Standard Operating Procedures (SSOP, Part 123.1(a) / 9 CFR CH.III PART 416). All products sold by LAWRENCE WHOLESALE LLC are properly labeled to declare the country of origin and method of production when required by 7 CFR 60. We further guarantee the products supplied to you are free of or are within acceptable norms for chemical as well as bacteriological contamination. The products we supply conform to our buying and import requirements regarding product technical specifications, labeling and packaging requirements. 100% net quantities as stated in relevant documents: purchase orders, invoices, bills of lading etc. All beef, chicken, and pork items we purchase come from USDA approved facilities. We agree if any articles shipped by us are found to violate any of the applicable state or federal laws pertaining to such product, or otherwise deemed unmarketable by any government authorities, we shall take appropriate action to resolve the issue in agreement with the customer.

Please keep this letter on file as the documentation you need to comply with HACCP procedures. This continuing guarantee will renew every 12 months.

Thank you and best regards,

Lawrence Wholesale, LLC HACCP Coordinator [email protected] (323) 235‐7535

FDA Registration Number: 11621418478

4353 Exchange Ave. Vernon, Ca 90058 (323) 235-7535

Attn: Customers of Liberty Seafood

January 1, 2021

Please be advised that Liberty Seafood is aware of the HACCP rules and is in compliance per HACCP requirements.

These steps include:

1. Designating personnel to review the FDA HACCP regulations, 2. Development of product safety specs for each type of product that we import, and 3. Maintain on-site, current copies of signed product safety specifications as they relate to each of the products we import from that individual producer.

We obtain, maintain and review for HACCP plan appropriateness / truthfulness of all of our suppliers overseas. We obtain and maintain from each supplier a current letter of guarantee, which indicates that a HACCP trained individual has conducted a hazard analysis, developed appropriate HACCP and sanitation monitoring programs, and oversees the programs’ implementation when producing product for export to the United States.

We obtain and maintain current statements from cold storage facilities and common carriers regarding

Liberty Seafood is COOL compliant with labeling and

We understand that this is a continuing guarantee that we will renew with you once every 12 months upon request. If you have further questions or needs, please don’t hesitate to reach out to us by phone or email as follows:

Phone – (610) 940-9227 x107 |Email – [email protected]

Sincerely,

Mark McCloskey – President

CONTINUING COMMODITY GUARANTY & WARRANTY

LITEHOUSE, INC. (“Seller”) in consideration of the purchase, from time to time of merchandise by Buyer, hereby agrees as follows:

1. That no article or product comprising any shipment or other delivery hereafter made by it (or any of its subsidiaries) to Buyer (or any subsidiaries of Buyer) is or will be as of the date of such shipment or delivery: (a) adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act, as amended, or an article which may not, under the provisions of Section 404 or 505 of the Act, be introduced into interstate commerce, or (b) adulterated or misbranded within the meaning of the terms of the Federal Insecticide, Fungicide and Rodenticide Act, the Federal Hazardous Substances Labeling Act, the pure food acts or any other applicable federal law or an article which cannot be legally transported or sold under the provisions of any federal law, or (c) the Canadian Food and Drugs Act and Regulations, including the Safe Foods for Canadians Regulations (SFCR), or (d) misbranded within the meaning of any federal law when bearing labels furnished by the Seller.

2. That all articles and products (except those made or designed to the specifications of the Buyer) hereafter sold or delivered by the undersigned to Buyer (or any of its subsidiaries) will be manufactured, fabricated, packaged, labeled and otherwise produced in compliance with applicable provisions of all federal laws, statutes and regulations, and that all items hereafter sold or delivered by the undersigned to Buyer (or any of its subsidiaries) will be merchantable quality.

3. In the event of complaints, claims or legal actions, alleging damage, death, illness or injuries, in any way resulting from, or claimed to result from the use of any products packaged, sold or delivered by the undersigned to Buyer (or any of its subsidiaries), the undersigned shall indemnify and save Buyer and its subsidiaries harmless from loss and liability in connection therewith, provided that the undersigned is given the opportunity to defend and assume full responsibility of investigation, litigation, judgment and/or settlement of any such complaint, claim or legal action and on the condition that the undersigned is notified, in writing, within ten (10) days of any such complaints, claims or legal actions.

(Created Date: 09/22/2003) Page 1 of 2 04/01/2019 REV 06 QMS 042-049

4. To indemnify Buyer and its subsidiaries to the extent of reimbursement of its purchase price (but not for consequential damages), in case of any property loss arising from or in connection with any articles or products hereafter sold or delivered by the undersigned to Buyer (or any of its subsidiaries) which articles or products are found by any federal administrative agency or court to be adulterated or misbranded, or unsafe or otherwise rendered unmarketable by action of public authority on the grounds of adulteration, misbranding, or the lack of safety, if the undersigned is notified of the claim, in writing, within ten (10) days of such claim; provided, however, that the undersigned shall not be liable to Buyer or its subsidiaries under this paragraph if such loss is due to and including, but not limiting, the fault, negligence, wrongdoing or misconduct of Buyer or its subsidiaries.

5. To indemnify and hold Buyer and its subsidiaries harmless and defend any suit or suits filed against Buyer or any of its subsidiaries, by reason of any defect or infirmity, or any infringement of any patent, trademark, or copyright or violation of any ordinance, law, statute, rule or regulation, as to any item hereafter sold or delivered by the undersigned (or any of its subsidiaries) to Buyer or any of its subsidiaries provided that the undersigned is notified in writing within five (5) days of such suit filing and is given the opportunity to defend against such suits. This warranty does not apply to trademarks, patents or rights, designs, requirements, or specifications, if any, supplied or required by Buyer itself or its subsidiaries.

IN WITNESS WHEREOF, the undersigned has executed this instrument this 05 day of Jan. 2021.

LITEHOUSE, INC.

By:

Title: VP Technical Services ADDRESS: 100 Litehouse Drive Sandpoint, Idaho 83864

(Created Date: 09/22/2003) Page 2 of 2 04/01/2019 REV 06 QMS 042-049

Letter of Guarantee

Date: Friday, January 1, 2021

To: All Customers

LK Packaging guarantees all products are shipped in good faith to meet customer requirements and specifications.

All poly bags that are indicated as food grade meet the requirements of the FDA for direct contact with food products, and all components comply with 21 CFR for food, drug and cosmetic packaging.

Item LDPE Low Density Polyethylene LLDPE Linear Low Density Polyethylene HDPE High Density Polyethylene PP Polypropylene PPE Polypropylene Co-Extruded Ready Chef Go Bags BOPP Poly Sheets Co-Extruded Vacuum Pouch Laminated Poly-Nylon Vacuum Pouch

Product is manufactured using good manufacturing practices:

• Clean, barefoot, virgin resin of desired specification. • Product is BPA Free. • Quality control checks in place to ensure product conformity.

Complies with the following FDA Regulations:

21 CFR 175.320, 21 CFR 177.1010, 21 CFR 177.1520, 21 CFR 177.1350, 21 CFR 178.2010, 21 CFR 178.3295, 21 CFR 178.3570, 21 CFR 179.45

All information is provided in this letter is accurate, to the best of our knowledge, as of the date this letter was issued.

Sincerely yours,

Manny Cortez Quality Assurance Manager [email protected]

Each user of the material should make their own tests to determine the specific products suitability for their particular application. Users must make their own determination of its safety, lawfulness, and technical suitability in its intended application.

700 South Hwy 91 Richmond, Utah 84333

Calendar Year 2020

CONTINUING PRODUCT GUARANTEE

Lowers Food.Est.828M/P-966 hereby guarantees to the buyer of “Lower Foods brand products that they, at the time of shipment, will not be adulterated, misbranded or unsafe, and comply with the Federal Meat Inspection Act, the Federal Food, Drug and Cosmetic Act, and all applicable food additive regulations and are not articles which may not, under the provisions of Sections 404, 505 or 512 of the Act, be introduced into interstate commerce.

This guarantee is non-assignable and is a continuing guarantee, subject to revocation on written notice thereof.

Sincerely,

Doug V Gatherum Lower Foods, Inc HACCP Coordinator SQF-Practitioner

DocuSign Envelope ID: A3A3B878-635F-450C-A382-5CC872BFC358 DocuSign Envelope ID: A3A3B878-635F-450C-A382-5CC872BFC358

Metafoods, LLC 2970 Clairmont Rd NE Suite 510 Atlanta, Georgia, 30329 Phone (404) 843-2400 Fax (404) 843-0165 E-Mail [email protected]

Re: Certificate of Compliance

January, 2021

Dear Customer,

This letter is our assurance that all seafood products we ship to your company conform to the product specifications outlined in the purchase order we receive from you prior to shipment. If for unforeseen reasons there is any adjustment to those specifications, we will obtain your company’s authorization prior to shipment

This letter is our guarantee that all seafood that MetaFoods, LLC supplies to your company has been produced and stored in a facility that is in compliance with the United States Food and Drug Administration guidelines for Hazard Analysis Critical Control (HACCP), 21 CFR part 123, adheres with current Good Manufacturing Procedures, 21 CFR Part 110, and operates under a program of proper Sanitation Standard Operating Procedures, Part 123.1(a).

All products sold by MetaFoods, LLC are properly labeled to declare the country of origin and method of production, when required by 7 CFR 60.

Further, MetaFoods, LLC is registered with the U.S. FDA under Title III of the Bio-Terrorism and Response Act of 2002.

Sincerely,

Sam Schwartz Director FDA Registration Number: 18310393152

12200 N. Ambassador Dr. Kansas City, MO 64163-1244 1-800-449-BEEF

January 1, 2021

Dear Valued Customer:

National Beef packing is supplying this letter to clarify to our customers our Food Safety and Regulatory Compliance Programs that have been implemented to help ensure a quality and safe food product. National Beef Packing has implemented approved HACCP Programs and has periodically reassessed our established HACCP Programs and SSOP Programs as per all FSIS Notices and regulations

Plants Covered

Est. 262 Dodge City, Kansas Est. 208A Liberal, Kansas Est. 8 Tama, Iowa (Iowa Premium)

HACCP and Interventions (Process aids) National Beef’s Food Safety process utilizes a multiple microbial reduction strategy that maintains the highest quality of product possible. Our HACCP Programs helps us to ensure that all products produced in our facilities are the safest in the industry. National Beef’s multiple microbial reduction process includes numerous process aids and a validated CCP intervention (may very between plants): (a) Finalyse (live animal treatment) – (Est 262 and 8) Hide on Carcass Wash Cabinet (Est 208A) (b) Steam vacuum(s) – placed in strategic locations after hide removal (Est 262 and 208A) (c) Pre-Evisceration Hot Carcass rinse with Organic acid spray (d) Thermal Pasteurization – Plant CCP step designed and validated with both scientifically peered and in-house microbial data to help eliminate or reduce pathogenic microbial (E. Coli O157:H7) to below detectable limits. CCP is monitored and validated daily (e) Spray Chill treatment (Set 8) (f) Carcass Cooler Organic Acid carcass sprays (first as cattle exit Hot Box and second as they enter the fabrication floor) (g) Continued cold chain management throughout the remaining processes of the facility. (h) In addition to these interventions we have traditional inspection and trimming throughout the slaughter floor. (i) Offal Interventions – treatment of all products that are intended for grind (j) Primal and sub-primal products are subject to an antimicrobial spray after trimming but prior to or at bagging. The antimicrobial treatment has been tested in our establishments and has shown to be effective in the reduction of bacteria and is monitored as per our application program.

Regulatory Compliance National Beef has met the FSIS requirements of 9 CFR 417 and 416 concerning our HACCP and SSOP Programs. We continue to validate our systems through monitoring of the hot water wash critical limits and routine testing of carcasses and trimmings for presence of E. coli O157:H7 daily as well as testing carcasses for Generic E. coli. Our facilities are also in compliance with FSIS regulated Salmonella testing on carcasses and ground beef.

National Beef is in compliance with the FDA Bioterrorism Act and is registered.

All cattle suppliers to National Beef are required to have current (within the past calendar year) signed affidavits on file attesting to compliance with all FDA feed and drug regulations and with 21 CFR 589.2000. Suppliers who do not have a current affidavit on file in our Kansas City headquarters are not eligible for marketing livestock to National Beef.

National Beef has implemented the appropriate programs/policies to ensure compliance with 9 CFR Parts 309, 310, 311, 313, 318, 319, etc. These Notices and Rules deal with three Regulations that prohibit the slaughter of non-ambulatory disabled cattle, a description and requirement to remove specified risk material (SRM) that are considered to be inedible and restricts the use of captive bolt stunners that deliberately inject compressed air into the cranium of an animal and does not allow “pithing”. • National Beef has programs and policies in place that prohibits the use of classified non- ambulatory (downers) from our edible process. • We are currently identifying all animals that are classified as 30 months of age or older using dentition identification on the slaughter floor. These identified carcasses have the vertebral column (excluding the vertebrae of the tail, the transverse process of the thoracic and lumbar vertebrae, and the wings of the sacrum), removed on the fabrication floor. • All SRM’s are removed from the edible food chain (from all animals - all tonsils and the distal ileum of the small intestine; and from animals 30 months or older the head – skull, eyes, brain, and trigeminal ganglia; and the vertebral column – spinal cord and dorsal root ganglia). • The captive bolt stunner that National Beef uses does not inject air into cranium of the animal nor does National Beef use any “pithing process” in stunning or SRM removal.

National Beef is assuring that we have addressed the following regulatory requirements: • Testing of carcasses for E. Coli Biotype I (9 CFR Part 310, §310.25), effective June 1997. • Implementation of SSOP (Sanitation Standard Operating Procedures, 9 CFR, Part 416, §416.11 - §416.17), effective January 26, 1997 • Implementation of HACCP Systems (9 CFR, Part 417, §417.1 - §417.8), effective January 27, 1998 for plants with greater than 500 employees. • Testing of carcasses and/or ground beef for Salmonella as conducted by USDA in accordance with §310.25. Federal Register Docket 00-022N, dated 10/7/02 (E. coli O157:H7 Reassessment) • Completion of annual reassessment of HACCP plans in accordance with 9CFR 417.4 (a) (3) effective January 26, 2004 which included review and verification of adequacy of the HACCP plans in addressing E. coli O157:H7. Directive 6420.2 – Issued 3/31/04 • CCP’s are in place and effect for zero tolerance requirements for head meat, cheek meat and weasand meat. Directive 10,010.1 Revision 3 – Issued 3/31/10 CFR Title 21 Part 589.2000 • Prohibits the feeding of ruminant meat and bone meal to ruminant animals Labeling • USDA approval for the following label disclaimer/instructional statements are available on site at the producing est.:

Disposition CCP’s • All materials that are tested for E. coli O157:H7 that are not negative are addressed within the HACCP plans under a product disposition CCP. • These materials are controlled and are cooked or otherwise disposed of to inedible.

• Records reflect appropriate disposition of affected material. Other FSIS Regulations/Notices • FSIS Notice 56-07 • FSIS Directive 6100.1 and 6100.4 • National Beef facilities are Federally Inspected and meet and comply with all FSIS Regulations and Notices including but not limited to FSIS Notice 65-07.

Pathogen Testing for Trim Destined for Grind (trim unpackaged in combos) National Beef Packing Co. has implemented a prescreening test protocol for all beef trimmings that have been identified as destined for used in raw ground beef. This protocol requires that these designated trimmings be: • Lotted (in no more than 5 combos per lot) • Sampled: Maybe conducted in one of the following methods: o N=60 surface incision pieces per lot for a min. 375gm final sample o IEH shaver method o Cloth (MicroTalley) Sampling Method • Tested for E. coli O157:H7 (PCR DNA testing using BioControl GDS system, this method has been validated to meet USDA Criteria ≥98% Sensitivity and ≥90% Specificity). • Verification of lab methods are done on a routine basis at our internal Food Labs in conjunction with the American Proficiency Institute Microbial Performance Program • All customers that have signed the testing agreement with National Beef can receive COA’s on tested lots. Those COA’s clearly identify a N=60 sampling and PCR testing process. • All ground beef produced at National Beef is derived only from raw material that has gone through stringent sampling and testing as described in this letter. • National Beef has implemented a risk based statistical process to monitor and react “High Event Periods”

Non-Intact National Beef Packing Co is clarifying that all product that we intend to go to a non-intact process will be tested and accompanied with a COA. For all other products (beef primals, sub primals or other muscle cuts produced at National Beef Packing Co) are to be considered as intact product and sold as intact. National Beef expects any customer who purchases vacuum packaged muscle cuts and then uses that product for other than intact production, to address that specific usage within their HACCP plan.

Animal Welfare National Beef is committed to following all of the requirements of the “Humane Methods of Slaughter Act 1978”. We are federally inspected facilities who have constant FSIS supervision on all aspects of our process. • National Beef QA Department conducts weekly routine, random, unannounced audits of its live animal and knocking processes. These audits are done in accordance with AMI recommendations and the McDonalds Animal Handling Audit set up by Dr. Temple Grandin. They consist of 100 animal observations per audit and evaluate the following: Stunning

Efficacy, Animal Vocalization, Bleed Rail Insensibility, Electric Prod Use, and Animal Slipping and Falling. Facilities, equipment and unloading practices are also audited and monitored. We also have routine third party audits of our humane handling processes and have a routine review conducted by Dr. Temple Grandin in each of our facilities in addition to the above-mentioned audit regime. • All audit results are shared with Plant Management and it has been and continues to be our Company’s policy to treat each animal that comes through our facility humanely. • Plant Quality Assurance/HACCP personnel train all plant personnel that are involved in every critical aspect of the operation that deals with the live animal from live animal receiving through stunning at the knocking box area and bleed areas. National Beef employees are trained and must be approved by plant QA department for each of those positions on proper humane techniques of animal handling practices. The training includes a detailed class room setting training of both written and visual (pictorial) aids to clearly describe plant policies and expectations. • Any animal that arrives at the facility that is immediately identified as a “Suspect Animal”, a FSIS Veterinarian is notified, and appropriate disposition is made. • National Beef has an active downer policy that prohibits the fabrication of any downer carcasses. A downer carcass will be considered any animal that is unable to enter or exit a trailer/truck under its own power, that does not pass USDA FSIS Ante mortem Inspection, or that is identified as a non-ambulatory animal at any time prior to the slaughter process.

Non O157 STEC National Beef Packing considers food safety our top goal in meeting our customers’ needs and doing our part in ensuring that we are supplying the highest quality product. NBP has reassessed our aggressive HACCP plan. In this reassessment, we used internal data, along with available published scientific research and current USDA FSIS guidance and public comments to determine that our current food safety system controls that we use to address E. Coli O157:H7 are effective in addressing the 6 STEC’s. Consistent with USDA FSIS guidance and several recent public comments by FSIS, it is our position that it is prudent to wait on the implementation of testing until more can be learned about the prevalence of STEC’s and until additional internal assessments can be made about the test systems that is currently available and their efficacy/accuracy. National Beef will the use our effective robust N=60 trim sampling methodology for all trimmings that are destined for grinding to help ensure that we are not only adequately monitoring for and controlling E. Coli O157:H7, but also effectively addressing the 6 STEC’s.

In addition, NBP will continue to conduct on-going STEC testing and research to further validate our processes on the control of STEC’s. We will add STEC testing in as part of our routine Quarterly Validation of taking negatively tested trim, grinding and retesting for both E. Coli O157:H7 and the 6 STEC’s (this is done monthly in the summer months). We believe that this action is consistent with USDA FSIS expectations.

Sincerely,

Brenden McCullough

V.P. Technical Services National Beef Packing Co. LLC

NEBRASKA BEEF, LTD. 4501 S. 36th Street, Omaha, NE 68107 (402) 733-1711 January 12, 2021

HACCP Food Safety Letter of Guaranty

Dear Valued Customer:

Nebraska Beef hereby states that each and every edible article contained in and comprising each shipment, is guaranteed at the time and place of such shipment, to be not adulterated or misbranded within the meaning of the U.S. Federal Meat Inspection Act and the U.S. Federal Food, Drug and Cosmetic Act. The programs and initiatives implemented and maintained within our Food safety system are as follows;

1. Nebraska Beef is a USDA inspected establishment (EST# 19336) and is eligible to export to over 13 countries including both Canada and Mexico. 2. The HACCP process descriptions utilized at NB are “Beef Slaughter” and “Raw—Not Ground.” Both HACCP plans have been validated by in-plant scientific studies with on-going verification procedures conducted daily. These HACCP plans are maintained on file within our establishment and are available for in-plant customer review upon request and visitation. 3. Nebraska Beef utilizes a total of eight (8) antimicrobial intervention cabinets from hide off carcasses, through the finishing of whole muscle and beef trim fabrication. Each intervention treatment is validated to reduce E. coli O157:H7, Non O157 STEC, and Salmonella to below detectable levels. Four (4) of the eight treatments are identified as critical control points (CCP) in the HACCP Plan. 4. The finished products provided are single ingredient raw beef items (various cuts) packed in boxes or corrugated combos. All of these raw beef items meet the USDA definition of the “Natural” claim in that it contains no artificial ingredients and is minimally processed. 5. Our establishment has a contingency plan that covers continuity of operations. 6. No Big 8 allergens are contained within the single ingredient raw beef items supplied. 7. All single ingredient raw beef is Gluten-Free. 8. Daily Generic E. coli testing of carcasses per 9 CFR 310. 9. Sanitation Performance Standards per 9 CFR 416. 1 through 416.6. 10. Sanitation Standard Operating Procedures (SSOP) per 9 CFR 416. 11 through 416.16. 11. Hazard Analysis and Critical Control Points Systems (HACCP) per 9 CFR 417. Hazards considered in our Hazard Analysis include Biological, Physical, Chemical and Radiological. 12. Routine Salmonella testing conducted during validation periods, and regularly by USDA, FSIS pathogen sampling protocols. 13. Reassessment of HACCP system performed annually as required by 9 CFR 417.4 (a) (3), when there is an occurrence of unforeseen hazards, and in response to new USDA and/or company policies that may impact the food safety process. NOTE: USDA Policies are Regulations, Directives, Notices, memorandums, etc. 14. Non-ambulatory disabled livestock (downers) are ineligible for slaughter. 15. NB utilizes only captive bolt stunning equipment—no air-injected stunners are used. 16. NB implements a program which ensures the proper removal, segregation, and disposal of all Specified Risk Materials (SRM) of bovine animals in accordance with 9 CFR 310.22. 17. The vertebral columns of all ≥ 30 months of age cattle are removed during the fabrication process, which ensures that no bone in Beef Loin and Ribs from ≥ 30 months of age cattle enters into commerce (specifically—feather, chine, and vertebral bones). 18. Product prepared using advanced meat recovery system (AMR) is properly labeled and tested daily for E. coli O157:H7, monthly for calcium content/added iron, and weekly for central nervous system tissue (CNS) per 9 CFR 318.24. NB does not harvest mechanically separated meat from the skull and vertebral column of bovine animals aged 30 months or older. 19. 50/50 Beef Trimmings are produced at 50% Lean ± 2% and is derived from cattle of domestic origin only (Product of USA). Combos are standard 46’ in height with an average weight of 2,000 lbs. and boxed 50/50 trimmings are packaged in industry standard 60 lb. wax lined boxes (acceptable for product contact). 20. Utilize a 2-combo lot at N=60 sampling plan for all raw beef intended for grinding under strictly enforced “Test and Hold” procedures. 21. High Event Program (HEP)—based on the 5% probability table as outlined in the August 2014 FSIS compliance guidance document for Sampling of Beef Trimmings, when more than 5% of beef trim lots intended for non-intact use test presumptive positive, all trim (Intended for Non-Intact Use) produced on that day will be diverted from non-intact use and rendered a proper disposition per FSIS Directive 10,010.1. In addition, all whole muscle associated with presumptive positive trim lots will be retained and either tested for E. coli STEC pathogens or diverted to cooking under strict controls. 22. Physical lots are defined as one day’s production of like/grade product. Example: Prime Boneless Ribeye’s produced on 5/1/17—1 Lot, Choice Boneless Ribeye’s produced on 5/1/17—1 Lot, Select Boneless Ribeye’s produced on 5/1/17—1 Lot, etc. However, each individually packaged primal and/or sub primal has gone through a validated intervention and has not been “commingled” before packaging. Thus, each individual package is microbiologically independent in accordance with USDA, FSIS Guidelines. Note: in the rare event that unavoidable commingling of sub-primals occurs at our establishment, we maintain a re-conditioning procedure that includes passing these cuts through a validated anti-microbial treatment and ensuring that no commingling occurs after this treatment. 23. Whole muscle products packed in individually cryovac packages are not intended for conversion to non-intact products unless a COA is provided (upon customer request only). Subsequently, all Bill of Ladings are stamped with the phrase, “Our Primal and sub-primal Cuts of Beef are intended for Raw Intact Use Only.” However, if a customer makes a conscious decision to convert either the sub-primals or bench trim to non-intact items, there is an expectation that they utilize either a validated anti-microbial intervention or additional quality step in their process to address the relative pathogens of concern. 24. All packaging materials are acceptable food grade wrappings. Supplier guarantees and SDS are part of our supplier approval program per GFSI standards and are on file at our establishment. 25. All pathogen testing of beef trim performed by a third-party laboratory utilizing the PCR BAX method. 26. All beef trim test results are daily reviewed for anomalies and used to investigate potential process control issues. 27. Quarterly verification testing for E. coli O157:H7 on trim and variety meats. 28. Utilization of organic acid (lactic) interventions on Carcasses, variety meats, trim, and whole muscle that are validated to reduce E. coli O157:H7, Non- O157 STEC, and Salmonella to below detectable levels. 29. Utilization of a hot water pasteurization treatment on carcasses that is validated to reduce E. coli O157:H7, Non-O157 STEC, and Salmonella to below detectable levels. 30. All products are refrigerated throughout the process in order to maintain cold chain and prevent bacterial proliferation. 31. All cattle slaughtered by NB have been fed rations that do not contain prohibited meat and bone meal per 21 CFR 589.2000/2001. Our establishment maintains Livestock Owner certificates signed by every cattle supplier certifying compliance. 32. Chemical Residues (antibiotics, hormones etc.)—All cattle suppliers issue a signed Livestock Owner Certificate stating that all veterinarian treatments are administered in prescribed amounts, by trained individuals, and proper withdrawal times are strictly adhered to. USDA, FSIS conducts weekly residue sampling at our facility to verify compliance. All raw beef materials are free of pesticides, mycotoxins and other contaminates which could be harmful to humans or animals. Our single ingredient raw beef products contain no Clenbuterol, Ractopamine and Salbutamol. 33. Blood collection methods are compliant with 9 CFR 310.20. 34. NB has developed, and daily implements a written program consistent with a systematic approach to the humane handling of all livestock. The program meets all requirements of both the NAMI guidelines and the Humane Slaughter Act and is audited annually by an independent third-party auditing firm. In addition, NB maintains on staff two (2) PAACO Certified auditors who are responsible for proper Animal Welfare oversight. 35. NB complies with FDA/USDA/AMS food security requirements for both domestic and international sales. Compliance with the Public Health Security & Bioterrorism Preparedness & Response Act of 2002. 36. NB maintains a written Food Defense program that is assessed annually. 37. Maintains a written comprehensive recall strategy that conducts traceability exercises twice a year (trace forward and trace back). 38. Annual third-party audits are conducted for Animal Welfare and GFSI (BRC Certified—Grade AA—Highest rating possible). 39. NB slaughters only cattle of domestic origin. Pursuant to the COOL mandate outlined in 7 CFR § 65.500, all covered commodities are labeled “Born, Raised, and Harvested in the United States.” 40. NB hiring practices meets all requirements of the California Transparency in supply Chains Act of 2010. 41. Nebraska Beef fully complies with California’s Proposition 65 (Safe Drinking Water and Toxic Enforcement Act) in that all single ingredient raw beef items produced by NB does not contain any chemicals listed on the Proposition 65 list of chemicals. 42. NB has developed both sustainability and environmental impact policies that are strictly implemented and maintained daily. 43. Pursuant to section 5.4.2 of the GFSI (BRC) standards for food safety and quality, a vulnerability assessment was conducted to assign a risk factor for weaknesses in the supply chain in order to prevent food fraud. This assessment considered controls in place, with measured assurances of the controls along with historical evidence. The result rendered a low risk for fraud. 44. All customers will be allowed access to our facility for programs and records review. 45. Emergency Contacts are as follows; Primary Secondary Emile Randazzo—VP of Reg. Tony Joy—VP of Operations Affairs/QA Wk.: 402-733-1711/Cell: 402-578-8110 Wk.: 402-733-0418/Cell: 402-290-9213 [email protected] [email protected]

Our mission at Nebraska Beef is a commitment to food safety and a dedication to the production of the highest quality beef that is both safe and wholesome for our customers and their consumers. As a customer of Nebraska Beef, we thank you for your interest and continued business and if there is any additional information you need, please do not hesitate to contact me.

Sincerely, Emile Randazzo Emile Randazzo VP of Regulatory Affairs 402-733-1711 [email protected]

LETTER OF CONTINUING GUARANTEE October 1, 2020

1. TomaTek (“Seller”), having its principle office located at: 2502 N Street Firebaugh California. 93622 guarantees that, as of the time of delivery by Seller, each article contained in every shipment or delivery for item(s) are:

 Not adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act (the “Act”) as amended and not an article, that may not, under the provisions of the Act, be introduced into interstate commerce;

 Not adulterated or misbranded within the terms of the Poultry Products Inspection Act, Federal Insecticide, Fungicide, and Rodenticide Act, the Federal Hazardous Substance Act, the Poison Prevention Act, the Toxic Substance Control Act, the Fair Packaging Act, state Pure Food Acts, or other federal, state or local laws, and their respective regulations, and is not an article which cannot be legally used, transported or sold under the provisions of any federal, state or local law, regulation or ruling; and

 Not misbranded within the meaning of any federal, state or local law when bearing labels furnished by the Seller and/or labels supplied by Seller and affixed on repackaging by the Buyer in accordance with instruction furnished by the Seller.

Any guaranty heretofore given by Seller to Buyer which relates to the subject matter hereof is hereby revoked and this guaranty shall not be deemed to be modified or otherwise affected by any agreement hereafter entered into by Seller and Buyer unless specific reference to this guaranty is therein made. This guaranty shall continue in effect with respect to all articles purchased or ordered by Buyer from Seller.

If you have any question, please contact the QA contact listed below.

Yolanda Gamino QA Supervisor [email protected] Toma-Tek, Inc. 2502 “N” Street Firebaugh, CA. 93622

Nielsen Citrus Products Company, Inc. 15641 Computer Lane • Huntington Beach, CA 92649 • U.S.A. Phone: 714-892-5586 • Fax: 714-893-2161 • www.nielsencitrus.com

Continuing Product Guaranty

January 2, 2021

Nielsen Citrus Products Company, Inc. states that each article contained in each shipment or other delivery hereafter made to, or on the order of the above addressee is hereby guaranteed as of the date of such shipment or delivery to be on such date:

1. Not adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act as amended, and not an article which may not, under the provisions of Section 404 and 505 of the Act, be introduced into interstate commerce; 2. Not adulterated or misbranded within the meaning of the terms of the Federal Insecticide, Fungicide and Rodenticide Act, and the Federal Hazardous Substance Labeling Act, and 3. Not adulterated or misbranded within the meaning of any applicable state or local law in which the definitions of adulteration or misbranding are substantially similar to the Federal Act.

This continuing guaranty is subject to revocation on written notice.

Earl Nielsen

Property of Nielsen Citrus Products Company, Inc. ▪ Huntington Beach, CA USA This document contains confidential commercial information pursuant to 5 U.S.C. section 552 (b)(4) and may not be reproduced without permission. File: Continuing Guaranty NCP.doc Page: 1 of 1

January 1, 202

1 PRODUCT GUARANTEE

This hereby certifies that the articles comprising each shipment or delivery from Northwest Gourmet Food Products, Inc. are guaranteed not to be adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act or any amendment thereunto including the Food Additives Amendment of 1958 or any substantially similar state or municipal law. Furthermore, the articles comprising each shipment or delivery do not bear or contain any food additive, pesticide or other substance which is unsafe within the meaning of the Federal Food, Drug and Cosmetic Act and are within the provisions of Sections 404 and 405 of the Act and may be introduced into interstate commerce. All products are also manufactured in compliance with regulatory and legislative labeling requirements applicable to their intended country of destination.

We also guarantee to supply products consistently produced at the highest standard through the use of HACCP and GMPs. Additionally, we are compliant with the Public Health Security and Bioterrorism Preparedness and Response Act of 2002, are registered with the FDA as required under 21CFR 1.225 through 1.243.

Northwest Gourmet Food Products, Inc. will indemnify our buyers and hold them harmless from and against any and all claims, demands, damages, liability proceedings or actions, which may arise out of a violation of this guarantee made herein.

Sincerely, Paul Gilroy Paul Gilroy President

600 SW 7th Street · Renton WA 98057· P 425.793.5001 · F 425.793.1005 · www.nwgourmetfoods.com

Letter of Continuing Commodity Guarantee

Oberto Snacks Inc. (seller) hereby guarantees that the products comprising each shipment of products hereafter shipped or delivered by Oberto Snacks, Inc. is hereby guaranteed, as of the date of such shipment and or delivery, not to be adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act, and it’s amendments, and is further guaranteed not to be an article which may not, under the provisions of Section 404 or 505 of the act, be introduced into Interstate Commerce. This guarantee shall be in like terms extend and shall be applicable to any State Law or Municipal Ordinance in which the definitions and Official interpretations of adulteration or misbranding are substantially the same as those in the Federal Food, Drug and Cosmetic Act.

In the event of any claims or legal action alleging damages, death, illness, or injuries, in any way resulting from any such articles, the seller hereby agrees to indemnify and hold buyer harmless from any and all loss and liability, including buyer’s reasonable legal expenses, arising from the negligence of the seller, and seller assumes full responsibility and expense of investigation, litigation, judgment and/or settlement of any such claim, or legal action in which the negligence of the seller is alleged, upon the condition that the seller be notified promptly of any such complaints, claims, or legal actions other than any claims or legal action.

This is a continuing guarantee subject to revocation at any time by a written notice to the buyer. Such revocation shall be effective with respect to the shipments made after delivery of such notice to buyer.

______Jim Bevilacqua Date: 01 January 2021 Vice President Manufacturing Oberto Snacks Inc.

January 4, 2021

Certificate of Compliance

This letter certifies that all food products provided by Orca Bay Foods, LLC. are processed in compliance with the FDA regulations and guidelines to include:

• HACCP (Hazard Analysis and Critical Control Points) and Fish and Fishery Hazards and Control Guidance Fourth Edition pertaining to 21 CFR 123. • FALCPA (Food Allergen & Consumer Protection Act). • CGMP’s (Current Good Manufacturing Practices) and with proper operation of our SSOP’s (Sanitation Standard Operating Procedures). • FD & C Act (Food Drug & Cosmetic Act) o All products are properly labeled to declare the country of origin and method of production, when required by 7 CFR 60. • Bioterrorism Act of 2002 and FSMA (Food Safety Modernization Act) o Orca Bay Foods, LLC is the primary packer that manufactures food for human consumption.

Orca Bay Foods, LLC FDA BTA Registration number is: 14728088440

Company Name: Orca Bay Foods, LLC 2729 6th Ave S, Suite 200 Seattle, WA 98134 Contact: Philip Crean, Owner Phone: 206-285-7445 Fax: 206-283-6317

Facility Name: Orca Bay Foods, LLC 206 SW Michigan Street Seattle, WA 98106 Contact: Emily Hajec, QC Manager Phone: 206-762-7256 Fax: 206-762-7314

This is a continuing certification and will remain in force until Orca Bay Foods, LLC notifies you to the contrary.

Phil Crean, President

5 th January 2021

TO WHOM IT MAY CONCERN

Re: Letter of Guaranty

This letter is to advise that all New Zealand and Australian beef and lamb products distributed by Pilot

Brands comply with current regulatory procedures and good manufacturing practices and have been produced in USDA certified plants with current HACCP plans.

All processing plants supplying New Zealand beef and lamb to Pilot Brands are regulated by The New Zealand Ministry of Primary Industries (NZMPI) and are USDA certified. All processing plants supplying

Australian beef and lamb to Pilot Brands are regulated by the Australian Quarantine and Inspection Service (AQIS) and are USDA certified. All New Zealand and Australian beef and lamb products are shipped with valid health certificates and are received and cleared in the USA at USDA licensed facilities and maintained under strict product safety and cold chain integrity guidelines.

Pilot Brands operates a USDA licensed cold storage and distribution facility in Vernon, California (I-526) at which customer inspection is welcome by appointment. The company has a comprehensive product recall procedure in place, and in the unlikely event a recall may become necessary will comply with all required regulation.

It is our opinion that the requirements of the certification and licensing detailed above together with Pilot Brands’ policies provide a level of assurance that ranks in the top tier of the food industry, however neither Pilot nor, for that matter, any other company can guarantee pathogen free raw materials.

We look forward to your continued support.

Sincerely,

Andy McIsaac VP Marketing

Pilot Brands PO Box 10107, Zephyr Cove NV 89448 Tel: 800-621-5262 Fax: 775-588-8380 [email protected] www.pilotbrands.com

Letter of Guarantee

Pitman Farms is a 3 generation family owned business. Pitman Farms produces Mary’s Chickens, Turkeys, and Ducks and strives on providing: the highest level animal welfare practices throughout all processes of our operation, practicing responsible sourcing, and safe sound processing procedures.

Pitman Farms herby guarantees that product shipped under the Mary’s branded name follows the standards:

 No Antibiotics are used: in pre‐hatch, injected into the eggs prior to hatching, feed, water or by injection.  Mary’s birds are fed a vegetarian diet that is antibiotic free and gluten free  Mary’s birds are raised with above industry standards in living space indoors and outdoors and provided most natural habitat possible.  Pitman Farms complies with Animal Welfare and Human Handling Principles in conjunction with the National Chicken Council Animal Handling Guidelines, National Turkey Federation Animal Care Guidelines, and is an active participant of raising our poultry by standards identified by the Global Animal Partnership (GAP) and Certified Human.  All of Pitman Farms poultry are Hatched, Raised and Harvested in the United States  Processing facilities are USDA inspected and use HACCP programs providing an effective approach to food safety and protecting public health.  Pitman Farms is certified to the Global Food Safety Standards and is audited annually.  Committed to the importance of safety and responsible sourcing of employees.  Mary’s Air‐Chilled Poultry are cooled individually using cold air. The Air‐Chilled method prevents the absorption of water, greatly reducing and potential of bacterial cross contamination.  Mary’s Chickens and Ducks are processed using a controlled atmosphere stunner. Providing no live shackling and works in a multiply cycles that controls a percentage of CO2 gas that is administrated to insure the birds are in a complete deep sleep.  Committed to providing environmental friendly practices where we can by using solar energy, energy efficient vehicle, smaller carbon foot print and using recyclable boxes and packaging.  Pitman Farms is compliant with the California State Proposition 65; our products do not contain any of the materials noted on the prop 65 list of hazardous ingredients  Pitman Farms is compliant with the California State Proposition 12; HSC 25990 through 25994.  Products hereafter shipped or delivered are not adulterer or misbranded within the meaning of the Federal Food , Drug and Cosmetic Act as amended, to the extent said Act is then effective and applicable, or an article which may not, under the provision of Section 404 or 505 of said Act, be the introduced into interstate commerce or adultered or misbranded within the meaning of any identical or substantially similar state or municipal law, on the subject, to the extend said law is the effective and applicable.  Pitman Farms complies with the Nutritional Labeling Education Act.  Pitman Farms complies with and is resisted under FDA Bioterrorism Registration.

By the acceptance of this Guaranty, Company, its divisions or subsidiaries, agree to notify the undersigned in writing within a reasonable time to any claim for violation of any of the above‐ mentioned laws, giving the name and address of the complaining party and the product concerned.

This is a continuing guaranty subject to revocation by Pitman Farms on written notice thereof.

Date This _1______day of ___January______, 2021

Pitman Farms

2021 PRODUCT GUARANTEE AND INDEMNIFICATION AGREEMENT

We (the undersigned) guarantee to you that any articles comprising any shipment or other delivery hereinafter made by us to you or any of your affiliates, as of the date of such shipment or delivery and insofar as applicable, shall not be adulterated or misbranded within the meaning of the Federal Food, Drug & Cosmetic Act, and shall not be an article which may not, under the provisions of Section 404 and 505, be introduced into Interstate Commerce. Additionally, said articles shall conform to all applicable Consumer Product Safety Standards, bans and rules issued under the Federal Consumer Product Safety Act (the "Act") and the Federal Hazardous Substances Act ("FHSA") and shall not be an article which is a banned hazardous product under the Act, or a banned hazardous substance under FHSA. In addition and insofar as applicable, said articles have been inspected by the United States Department of Agriculture and shall not be adulterated or misbranded within the meaning of the Poultry Products Inspection Act and all of its amendments, the Federal Meat Inspection Act (“FMIA”) with all of its amendments, and shall not be an article which may not, under the provisions of Part 302 or 325 of FMIA, be introduced into Interstate Commerce. We further guarantee that any said articles shall comply with all other federal laws, rules and regulations of all political subdivisions of the United States of America, including HACCP and with the laws, rules and regulations of the respective states and their respective political subdivisions whether now or hereinafter acted. All guarantees made herein are subject to the fact that we do not guarantee against such goods becoming adulterated or misbranded within the meaning of any Act by reason of causes beyond our control.

We agree that if any articles now or hereinafter shipped by us are found to violate any of the above indicated laws, rules and regulations, or are otherwise rendered unmarketable by any authorities administering same, we shall accept return of the product, if said product shall not have been seized or condemned by the governmental authority, and shall refund to you the cost thereof as billed to you together with any reasonable and necessary transportation charge incurred in said return. If any such article shall have been seized by governmental authority, we shall refund to you the cost thereof as billed to you but will be entitled to defend, in our own name, and at our own expense, any such seizure, and to obtain possession of such articles in the event that we are successful in such defense.

We further agree that if any claim shall be made against you alleging any trademark, copyright, patent or any other license infringement or injury and/or damage from the use or purchase of any article shipped by us, we shall indemnify, defend, and hold you harmless of and from any and all liability arising by virtue of such claim, including costs, expenses and attorneys' fees, provided that the injury or damage is not due to the negligence or misconduct of you, your successors, agents, employees or other third parties, and that you shall give us prompt notice of such claim. We agree that upon said notification, we shall assume your defense with counsel acceptable to us. We will send a Certificate of Insurance with respect to our Products Liability Insurance, which provides a Broad Form Vendor's Endorsement. This Agreement shall constitute a continuing guarantee of the matters above stated which shall be subject to termination by written notice.

For: Perdue Foods LLC

By: ______(Authorized signature)

CONFIDENTIAL

CONTINUING FOOD GUARANTEE AND INDEMNITY AGREEMENT

To: PACIFIC FOOD DISTRIBUTORS

1. The undersigned Seller, on behalf of its affiliates, divisions, subsidiaries and successors (“Seller”), hereby guarantees that all food products (“Products”) Seller ships or delivers to PACIFIC FOOD DISTRIBUTORS, shall, as of the date such Products leave Seller’s custody and control:

(a) Not be adulterated or misbranded within the meaning of the United States Federal Food, Drug and Cosmetic Act and any amendment thereto, and shall not be articles of food which may not, under the provisions of such Act, be introduced into interstate commerce; and

(b) Not be adulterated or misbranded within the meaning of the terms of the United States Federal Insecticide, Fungicide and Rodenticide Act and any amendment thereto; and

(c) Not be adulterated or misbranded within the meaning of any state or local law or regulation which is comparable to the Federal Food, Drug and Cosmetic Act or the Federal Insecticide, Fungicide and Rodenticide.

2. Seller agrees to defend and indemnify PACIFIC FOOD DISTRIBUTORS, its affiliates, divisions, subsidiaries, successors, and assignees from any and all claims, actions or suits made or brought by any third party (collectively “Claims”) that allege bodily injury and/or property damage as a result of or in connection with the consumption of the Products or that alleges bodily injury and/or property damage as a result of any breach by the Seller of one of the foregoing guarantees, provided PACIFIC FOOD DISTRIBUTORS gives Seller timely notice of any such claim, action or suit, and except to the extent that such Claims arise from (1) negligent acts or willful misconduct of PACIFIC FOOD DISTRIBUTORS; (2) PACIFIC FOOD DISTRIBUTORS’s failure to hold, store or distribute the Products in accordance with good business practices from the time of its receipt of the Products until final sale by PACIFIC FOOD DISTRIBUTORS; or (3) Pacific Food Distributors Content, herein defined as statements, trademarks, product claims, images or other content or intellectual property included on Product labels, packaging or consumer communications other than the following label elements (a) statement of identity (name of the food),(b) net quantity statement, (c) ingredients list, (d) nutrition facts panel, (e) any required allergy labeling, (f) production codes, (g) country of origin, if required, and (h) other elements to the extent required by the Federal Food, Drug and Cosmetic Act. PACIFIC FOOD DISTRIBUTORS agrees to indemnify Seller against Claims related to Pacific Food Distributors Content of Products. However, in no event will Seller be responsible for any liability associated with products sold or consumed in any country or territory other than the United States, Canada, Mexico or Puerto Rico.

3. This food guarantee is continuing, superseding all prior guarantees, and shall remain in full force unless revoked by written notice.

RED GOLD, LLC

DATE: October 1, 2020 (Authorized Official) P.O. Box 83 Elwood, IN 46036

CONTINUING PURE FOOD GUARANTY

Reser's Fine Foods, Inc. (“Seller”) hereby agrees to the following provisions for all deliveries or shipments of food products provided to PACIFIC FOODS (the “Buyer”) by Seller (the “Products”).

1. As of the date of shipment, the Products shall: a. not be adulterated or misbranded within the meaning of the Federal Food, Drug, and Cosmetic Act (“FD&C Act”), as amended, including regulations adopted thereunder; b. comply with the Federal Meat Inspection Act (“MPIA”) and the Poultry Products Inspection Act (“PPIA”) if meat or poultry make up the Products; c. not be articles that are prohibited under the provisions of Section 404 of the FD&C Act from being introduced into interstate commerce; d. be manufactured, handled, stored and distributed from facilities which are appropriately registered, licensed and permitted under Federal, state and local laws, including the Public Health Security and Bioterrorism Preparedness Act of 2002 (“Bioterrorism Act”); e. if the Products contain an ingredient additive, comply with the applicable regulations of the FD&C Act pertaining to additives; and f. be labeled in compliance with the California Safe Drinking Water and Toxic Enforcement Act of 1986 (“Prop 65”).

2. This Guaranty is executed by Supplier upon and subject to the following conditions: a. with respect to subsections (1(a) and 1(c) above, Seller does not guarantee against any Products becoming adulterated or misbranded within the meaning of the FD&C Act after shipment or delivery to Buyer, by reason of causes beyond Seller’s control.

Any guaranty heretofore given by Seller to Buyer which relates to the subject matter hereof is hereby revoked and this Guaranty shall not be deemed to be modified or otherwise affected by any agreement hereafter entered into by Seller and Buyer unless specific reference to this Guaranty is therein made. This Guaranty shall continue in effect with respect to all Products purchased or ordered by Buyer from Seller until Seller provides written notice of its revocation to Buyer.

This Guaranty is effective as of the Date of Execution below and shall remain in effect unless revoked by the Seller after providing reasonable notice to the Buyer.

Date of Execution: ___1/26/21______

Signed: ______

Printed: __Arletha Parks______

Title: __Dir. of Regulatory & Consumer Affairs__

Date Issued 1/01/2021

1629 County Road E 511 9TH Street Willows, Ca 95988 Crescent City, Ca 95531

CONTINUING GUARANTEE

The undersigned, RUMIANO CHEESE COMPANY (“Rumiano”) with principal offices at 1629 County Road E, Willows, California 95988 hereby certifies:

1. That the article(s) comprising each shipment or other delivery to or for buyer hereafter made by Rumiano to, or on the order of: Pacific Foods its parent and all subsidiaries, affiliates and divisions (“Buyer”), is hereby guaranteed, as of the date of the earliest of shipment or other delivery to or for Buyer, to be, on such date, (a) not adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act (the “FDCA”), as amended, including the Food Additives Amendment of 1958; (b) not an article which may not, under the provisions of Section 404 or 505 of the FDCA, be introduced into interstate commerce; and (c) not adulterated or misbranded within the meaning of any state or municipal food and drug law, regulations, or ordinances, the adulteration and misbranding provisions of which are the same as those found in the FDCA.

2. In the event any article(s) referenced in Section 1, above, is packed, shipped, or delivered by or for Rumiano under a label or labeling furnished or designated by the Buyer, the guarantee set forth in Section 1 shall not apply as against any misbranding resulting from the use of such label or labeling. In such event, Rumiano’s responsibility shall be limited to that resulting from the failure of the article to conform to the label furnished or designated by the Buyer or the failure of the article to conform to Rumiano’s specifications.

3. Rumiano does not, with respect to Section 1, guarantee against any article(s) becoming adulterated or misbranded within the meaning of the FDCA after the earliest of shipment or other delivery to or for Buyer by reason of any cause beyond Rumiano’s control, or in any way by reason of the fault or negligence of Buyer, its affiliated or agents.

The guarantee and conditions set for above are continuing and shall be in full force and effect until revoked in writing.

By: Tony Rumiano Title: Corporate Secretary

Date: 1/6/2021

Rumiano Cheese Company P.O. Box 305m Crescent City, CA 95531 P.O. Box 863, Willows, CA 95988 (707) 465-1535 ph. · (707) 465-4141 fax (530) 934-5438 ph. · (530) 934-5114 fax www.rumianocheese.com

Sanderson Farms, Inc. Post Office Box 988 • Laurel, Mississippi 39441-0988 Telephone (601) 6494030• Facsimile (601) 426-1461

January 4, 2021

To Whom It May Concern:

All the poultry products produced by Sanderson Farms, Inc., Processing Divisions (P-247, 320, 522, 671, 7264, 18557, 19688, 32182, 34308, 40183, 51179, 45910 and 46374) are processed under the official inspection and supervision of USDA. These manufactured products meet all legal dispositions and are fit for human consumption. This product has been inspected by USDA and packaged under strict and sanitary conditions in accordance with all regulatory requirements and current good manufacturing practices. All products are subjected to a multi-hurdle approach designed to remove contamination and reduce microbiological levels, including Salmonella and Campylobacter, which may be present. This approach consists of applying approved antimicrobials and utilizing carcass rinses throughout the evisceration, chilling, and post-chill processing operations. Products are sampled daily and analyzed against Sanderson Farms and USDA performance standards.

Also, Sanderson Farms conducts a comprehensive pesticide monitoring program for chlorinated hydrocarbon pesticides and PCB’s. The sampling program assures that birds from each farm are randomly selected within two weeks of slaughter and analyzed for these pesticide residues. We also analyze each load of feed grade fat that is received at the feed mills as well as samples of finished feed from each mill each day. Furthermore, the animals from which the product was obtained were fed within all the regulatory requirements of Center of Veterinary Medicine, Food and Drug Administration, no hormones have been added, and products from these animals do not contain any antibiotic residues.

Sanderson Farms, Inc. programs and practices are listed below: ➢ USDA 9 CFR 417 - HACCP programs ➢ USDA 9 CFR 416.11-416.17 - Standard Sanitation Operating Procedures ➢ USDA 9 CFR 416.1-416.6 - Sanitation Performance Standards ➢ USDA 9 CFR 381 – Poultry Products Inspection Regulations ➢ Good Manufacturing Practices ➢ Food Defense Program

All poultry flocks have been raised in areas that are free of Highly Pathogenic Avian Influenza (HPAI) and all flocks are tested prior to slaughter. Sanderson Farms does not import any poultry or poultry products from foreign countries.

In regards to animal welfare, Sanderson Farms has a policy that complies with USDA’s Humane Slaughter Act of 1978. This policy includes our intent to comply with the National Chicken Council Animal Welfare Guidelines, and provides for discipline up to termination of employment for inhumane treatment of poultry. Each processing and production division is audited at least once per year by both internal and third party auditors. We require that all animal welfare auditors be certified by the Professional Animal Auditor Certification Program (PAACO).

I certify that the statements listed above are true to the best of my knowledge and belief.

Sincerely,

Jonathan B. James, DVM, MS Corporate Quality Assurance Manager Sanderson Farms, Inc. January 1, 2021

Re: Letter of HACCP Compliance

This letter is Sea Port Products’ guarantee that, as a seafood importer, we are following the U.S. Food and Drug Administration’s (U.S. FDA’s) importer verification requirements, including taking affirmative steps to ensure the seafood we import was processed in accordance with 21 CFR Part 123.

We guarantee we will have on file documentation of the performance and results of one of the following affirmative steps for each supplier:

1. The processor’s HACCP plan and a written guarantee from the processor that the imported seafood is processed in accordance with the U.S. FDA’s HACCP regulations under 21 CFR Part 123; 2. A lot-by-lot certificate issued by a competent third party certifying that the seafood was processed in accordance with the U.S. FDA’s HACCP regulations under 21 CFR Part 123; or 3. Any other affirmative step that, as an importer, we take to receive the appropriate level of assurance of compliance with the U.S. FDA’s HACCP regulations under 21 CFR Part 123.

All HACCP and sanitation records from our overseas suppliers will be maintained at Sea Port Products’ Kirkland, Washington office.

We also guarantee:

1. Frozen seafood will be packed in clean, food grade containers. 2. All containers will be clearly marked and include all U.S. FDA required labeling. 3. Product will be in compliance with declaration of weight, count and composition requirements. 4. When freezing is required under the U.S. FDA Food Code for parasite destruction, products have been frozen and stored at the minimum times and temperatures specified in § 3-402.11 of the Food Code. 5. When applicable under U.S. FDA regulations, supplier’s HACCP Plans will address the control of environmental pesticides, contaminants, and unapproved antibiotics to assure our seafood products are not contaminated. 6. Some frozen seafood products are treated with moisture retention agents (to retain moisture) and/or carbon monoxide (to maintain color) approved preservatives by the U.S. FDA. If used, these preservatives will be labeled in the ingredients list. 7. Some shellfish seafood are treated with metabisulfites at the time of harvest to prevent black spots. If sulfite residue is more than 10 ppm, it is included on the label, as required by U.S. FDA.

Should you have any questions, please do not hesitate to contact us.

Matthew Wilbur Quality Assurance Manager (425)827-2800 [email protected]

Our Wave embodies a perpetual commitment to change. We adapt to the tides of the seafood industry; maintaining quality, supply and service, and ultimately improving our value to our customers, our suppliers, and our network.

West Coast 131 7th Avenue West, Kirkland WA 98033 East Coast 536 Fayette Street, Perth Amboy, NJ 08861 Phone: (425) 827 2800 Fax: (425) 827 7125 Phone: (732) 826 9400 Fax: (732) 826 8195

Calendar Year 2021

Food Safety and Quality - Letter of Guarantee

All Seaboard Foods/Farms products come from facilities that are USDA/FSIS Inspected establishments which have comprehensive Food Safety and Quality Assurance systems and a qualified staff in place to maintain compliance, wholesomeness, quality and continuous improvement.

Seaboard Foods facilities comply with all USDA/FSIS, FDA/FSMA and USDA/APHIS regulations in addition to following the regulatory requirements of export regulating bodies they supply. Some of the specific regulatory, quality and compliance items are: • All products manufactured and shipped as Seaboard Farms or Seaboard Foods products are in full compliance with USDA / FSIS and the Federal Food, Drugs and Cosmetics Act, are not adulterated or misbranded and are in compliance with interstate commerce regulations. • All food for animals, products, and procedures comply with FDA/FSMA regulations in adherence with 21CFR, Parts 11,16,117,500,507, and 579, cGMP, Hazard Analysis and Preventive Controls and Bioterrorism Act of 2002. • Strict adherence to USDA/FSIS (9CFR) and Seaboard Foods policies/procedures, Antemortem (9CFR, 309), Postmortem (9CFR, 310), Sanitation (9CFR 416), Pest Control, Traceability and Recall (FSIS Dir. 8080.1, Rev4, Recall of Meat and Poultry), Food Defense and Crisis Management, Current Good Manufacturing Practices, and personal hygiene (CFR21, Part 110). • All Food Safety HACCP programs, activities, pre-shipment reviews and verifications comply with USDA FSIS HACCP (9CFR 417) regulations. • Foreign material prevention and detection is achieved through training, auditing and significant investment in various types of technology such as: metal detectors and X-Ray machines. • All facilities test for Enterobacteriaceae pre and post evisceration (9CFR 310). This testing procedure is completed and monitored using Statistical Process Control methodologies. • Our facilities are Global Food Safety Initiative certified, using SQF Edition 8 certification compliance as verified by annual 3rd party GFSI/SQF auditing bodies to confirm compliance. • All Facilities comply with USDA FSIS Humane Handling (9 CFR 313) regulations and have USDA/FSIS approved Robust Systematic Approach to Humane Handling in place and are audited by a 3rd party annually to confirm compliance. Each facility maintains a PAACO (Professional Animal Auditor Certification) certified auditor on site. • The FSQA (Food Safety Quality Assurance) system complies with USDA/FSIS Directive 7000.1. This includes Standard Weight, Labeling, Label Claims, % Injected, Nutritional Labeling and other regulatory requirements designed to protect the consumer in ways other than ensuring food safety. Most importantly, we are striving to fulfill all of our customer’s expectations by providing a safe, high quality product that meets all expectations. This letter of guarantee covers all pork primal, sub-primal and pork trim products supplied to our customers. In addition, we do not process or handle products derived from the bovine species or cloned animals. Applies to USDA FSIS EST#’s; 13597-Seaboard Foods, Guymon OK , 31965 – Triumph Foods, St Joseph MO, 46071-Seaboard Triumph Foods, Sioux City, IA http://www.fsis.usda.gov/Regulations_&_Policies/Meat_Poultry_Egg_Inspection_Directory/index.asp • Products produced by and for Seaboard Foods LLC conform to Seaboard Foods specifications as well as regulatory requirements.

Sincerely,

12/06/2020 Paul Clayton VP Foods Safety Quality Assurance, Seaboard Triumph Foods, LLC Phone: 913-676-8769 / Cell: 720-308-8251 / [email protected]

9000 W. 67th Street | Shawnee Mission, KS 66202 | (913) 261-2600 | SeaboardFoods.com Dean Erstad Sr. Vice President Sales 418 East Conde Street Janesville, WI 53546 [email protected] Tel. (608)757-6078 Fax (608) 757-8324

PURE FOOD GUARANTEE

Seller, Seneca Foods Corporation and subsidiaries, represents and guarantees that articles of food sold by the Seller to Buyer PACIFIC FOOD DISTRIBUTORS, INC. 12300 SE CARPENTER DRIVE CLACKAMAS, OR 97015

Are not adulterated or misbranded within the meaning of the Federal Food Drug and Cosmetic Act and are not articles which may not, under the provisions of the Act, be introduced into interstate commerce; and all such articles of food comprising each and every shipment to the Buyer are free from any substance which may be found harmful or objectionable by the United States Department of Agriculture, the United States Department of Health, Education and Welfare, or any other department or agency of the United States Government or any of the several states, or other political subdivisions and that such articles of food are not unsafe or otherwise rendered unmarketable or prohibited by any law governing the introduction of such items into interstate commerce.

The Seller agrees that if any articles of food shipped by it to the Buyer are found harmful, adulterated, misbranded, unsafe or otherwise unmarketable by any governmental agency, the Seller shall accept return of the said articles of food and shall refund to the Buyer the cost thereof as billed to the Buyer and any fines, penalties or other government charges imposed by reason thereof.

The Seller further agrees that if any claim shall be asserted against the Buyer relating to any article of food sold or shipped by the Seller on the basis that such articles of food are or were harmful, adulterated, misbranded, unsafe or otherwise unmarketable, the Seller shall immediately indemnify, defend, and hold the Buyer harmless of, and free from, any and all liability which may arise by virtue of such claim; provided, however, that Seller’s indemnification obligations hereunder shall not apply to the extent that such claims are caused by negligence of Buyer and, provided further, that the Seller is given prompt notice of any claim and is authorized to deal therewith as the Seller deems best and Seller shall control all aspects of litigation or settlement of such claims and Buyer shall not resolve or settle any such claim without the written consent of Seller.

This representation shall constitute a general and continuing guarantee of the matters and things stated herein and supersedes any previous Pure Food Guarantee.

SENECA FOODS CORPORATION

Dean Erstad Sr. Vice President Sales 1/5/2021

Seneca Foods Corporation – Technical Services 418 East Conde Street, Janesville, WI 53546

CONTINUING GUARANTEE

Shining Ocean, Inc. ("Seller"), hereby guarantees that each and every article subject to the Federal Food, Drug and Cosmetic Act (the “Act”), as amended, and contained in or comprising each shipment hereafter made by Seller, to or on the order of Pacific Food Distributors ("Buyer"), is hereby guaranteed, as of the time and place of such shipment, to be: 1) not adulterated or misbranded within the meaning of the Act; and 2) not an article which cannot be introduced into interstate commerce under the provisions of Sections 404 of the Act.

This guarantee is in like terms extended to any other applicable federal or state law or municipal ordinance in which the definition of adulteration and misbranding are substantially the same as those in the Act.

All products manufactured by Seller are in compliance with all applicable requirements of the FDA Seafood HACCP Rule as stated in CFR 21 Part 123 and are produced under a valid HACCP plan. This document serves as a HACCP certificate of compliance.

Seller’s facility is registered with the U.S. Food and Drug Administration as required by the Public Health Security and Bioterrorism Preparedness and Response Act of 2002, as amended, and is in compliance with all applicable regulations thereunder.

This Guaranty covers only articles shipped by Seller to Buyer, and shall not extend to the benefit of persons or entities other than Buyer. This Guaranty is continuing and shall be in full force and effect and shall be binding upon Seller with respect to each and every article shipped to Buyer by Seller. This Guaranty is subject to revocation by Seller upon written notice to Buyer.

Shining Ocean, Inc.

Dated: 12.26.2018

By: Jimmy Wilson QA Supervisor

Ver 2 December 28, 2020

Sierra Meat and Seafood Company and the Durham Ranch brand, establishment #1438 and P-1727 for Poultry, currently operates under the control and oversight of the USDA and FDA, and has in place SSOPs, GMPs, and validated HACCP Plans. Critical Control Points for our beef HACCP plans are a product temperature of 44 F. Product temperatures are monitored three times daily. Ambient room temperatures are monitored twice daily. All refrigerated areas are also monitored 24/7 electronically and will alert management of any temperature problems. To reduce or eliminate E. Coli O 157 :H7, we utilize intervention on all beef products which is an ozonated water wash. We require a COA on all beef raw material intended for grinding. Additionally, we test forE. Coli O157:H7 once per month on ground beef products that are derived from purchased raw materials. When grinding beef derived from our table trim, each batch is tested forE. Coli O157:H7, and held until negative test results are received. We have a working, calibrated metal detector. We guarantee our products to not be adulterated or misbranded as defined by the Federal Meat Inspection Act, Poultry Product Inspection Act, Federal Food Drug and Cosmetic Act. Additionally, Sierra Meat and Seafood Company has achieved SQF Level 2 certificationwith Excellent rating score, on GFSI (Global Food SafetyInitiative) certification.

Sierra Meat and Seafood Company only processes products fromsuppliers that provide Letters of Guarantee and comply with the following: 1. For beef suppliers: validated intervention steps to reduce or eliminate E. Coli 0157:H7 below detectable levels, which may include Zero Tolerance Inspection, Lactic Acid spray at 2% (or analogous process) on Carcasses and Steam Vacuums. 2. For beef suppliers: Non-Ambulatory, Downer or Disabled Veal Calves and or cattle are condemned per PSIS Regulation 9CFR309.2 and are not utilized in production. 3. SRMs are removed and disposed of per federal regulation 9CFR 318.24. 4. For beef suppliers: Carcasses and Trimmings are tested forE. cau0157:H7, and COAs are provided for any trim or ground items. 5. All animals are handled in compliance with the USDA PSIS Humane Handling and Slaughter Act of 1978 (PSIS Directive 69000.1, Revision I). 6. Metal detectors are utilized in grinding or other areas where metal inclusion might be possible. 7. A functioning, documented pest control program is in place and is monitored.

A written Recall Program is in place and is tested every 6 months. The program includes a written procedure to be followedin case of a recall and a list of management contact personnel and their specific assignments in case of a recall. Sierra Meat Company is currently registered with the FDA and in full compliance with the Bio-Terrorism Act of 2002.

Regards, -��A Santhosh K Venkataramanappa Director of QA/QC/HACCP

toll free (800) 444-5687 fax (775) 284-2638 www.sierrameat.com 1330 Capital Blvd., Reno, NV 89502 Sierra Trading Group Inc. 1641 W Main Street, Suite 301, Alhambra, CA 91801 Tel : (626) 309-9558 Fax: (626) 309-0538 E-mail: [email protected]

January 1, 2021

Dear Customer,

This letter is to certify that Sierra Trading Group Inc is operating in compliance to Section 303 (c) (2) of the Federal Food, Drug, and Cosmetic Act, and to the Code of Federal Regulation, 21 CFR, part 123, which outlines “Procedures for the Safe and Sanitary Processing and Importing of Fish and Fishery Products”, commonly referred to as the HACCP regulations established by the U.S. Food and Drug Administration (USFDA).

Sierra Trading Group Inc continues to conduct hazard analysis for all of our seafood products and develop and implement HACCP plans accordingly.

Our further commitment to HAPPC compliance is that Sierra Trading Group, Inc will only purchase product from HACCP approved suppliers.

Please feel free to contact us with any questions.

Sincerely,

______Jason Tai President

CONTINUING PRODUCT GUARANTY

This Continuing Product Guaranty (this “Guaranty”) is made by SMITHFIELD PACKAGED MEATS CORP. and SMITHFIELD FRESH MEATS CORP. (“Seller”) in favor of PACIFIC FOOD DISTRIBUTORS (“Buyer”).

1. Seller warrants to Buyer that all products that Seller sells to Buyer (“Products”) are at the time of delivery to Buyer: (a) not adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act, as amended, and its regulations (the “FD&C Act”), or within the meaning of any state food and drug law with identical or substantially the same adulteration and misbranding provisions as found in the FD&C Act; (b) not articles that may not be introduced into interstate commerce under the provisions of the FD&C Act or any successor thereto; and (c) in compliance with all other applicable federal, state, and local laws and regulations. However, with respect to Products sold under Buyer’s brand label, Seller’s responsibility for branding or misbranding is limited to direct damages resulting from the Product’s failure to conform to the Buyer’s specifications or labels that Buyer furnished to Seller. TO THE FULLEST EXTENT ALLOWED BY LAW, THE WARRANTIES IN THIS PARAGRAPH 1 ARE EXPRESSLY IN LIEU OF ALL OTHER WARRANTIES, EXPRESS OR IMPLIED, AND SELLER MAKES NO WARRANTY AS TO MERCHANTABILITY OR FITNESS OF PRODUCTS FOR ANY PARTICULAR PURPOSE.

2. Seller shall indemnify, defend, and hold harmless Buyer from and against liabilities, losses, claims, demands, and judgments brought against or incurred by or on behalf of Buyer arising out of (a) Seller’s breach of any warranty in paragraph 1 or (b) the injury, illness, or death of any person or damage to any property caused by any Products; provided, Seller has no obligation to Buyer to the extent Buyer’s damages are caused by (i) damage or change to any Products occurring after delivery to Buyer or (ii) the negligence or willful misconduct of an agent or employee of Buyer or any third party.

3. Seller’s obligations in paragraph 2 are conditioned on (a) Buyer providing immediate notification to Seller of any third party claim, action, suit, or proceeding against Buyer (a “Third Party Claim”) and (b) Seller’s control of the required defense, including selection of counsel. Buyer’s settlement of any Third Party Claim without Seller’s express written consent shall render this Guaranty null and void.

4. Seller’s liability to Buyer under this Guaranty is limited to Buyer’s actual, direct damages. Seller will not be liable to Buyer for special, indirect, consequential, punitive, or exemplary damages, or for attorneys’ fees and costs Buyer may incur.

5. This Guaranty continues in effect with respect to all Products purchased or ordered by Buyer prior to Buyer’s receipt of written notice of its revocation from Seller. This Guaranty revokes any prior guaranties provided by Seller and may be amended only with Seller’s written consent.

Date: January 21, 2021

Warren J. Dorsa, Ph.D. Senior Vice President, Food Safety & Quality Smithfield Foods

Version: 7/24/20

January, 2021

Page 1 of 5 Dear Client

In this Guaranted Letter you can find the information you requested:

SRM Controls

SuKarne in our establisments TIF 105, 111, 120, 431 and 645 have reassess their HACCP and written prerequisite programs for control de SRM´s according to FSIS Directive 6100.4, Rev. 1, Verification Instructions Related to Specified Risk Materials in Cattle of All Ages and SuKarne establishments apply the following to SRM Control and disposition. SuKarne do not process Non-ambulatory bovine animals for human consumption, all cattle receive an ante-mortem inspection and enter the stunning box by their own feet. All cattle is age verify by the dentition inspection, if the cattle is equal or more than 30 months the carcass is mark with a green plastic tag a label with a code number 30 indicating that the carcass is equal or more than 30 months so the carcass is segregated to a designated rail and carcass cold room. The equipment utilize for the slaughter of Cattle equal or more than 30 months follow the SSOP procedures according to USDA regulations SuKarne facilities remove, segregate, and properly dispose of all Specified Risk Materials (SRM’s) at Slaughter and Fabrication. SuKarne do not operated for purposes of stunning cattle any air injection stunning device. SuKarne facilities do not produce bone-in products from cattle determined to be equal to 30 months and older. SuKarne segregation protocols have been reviewed and approved by USDA and SENASICA as applicable. SuKarne has a Zero Tolerance policy with respect to the presence of SRM (Specified Risk Material) including but not limited to spinal cord and dura. Specific positions and Work Instructions are in place dedicated to the removal of SRM. SuKarne SA de CV SRM Control Program is fully incorporated into the Quality Management System and HACCP Plans. And we comply with the specification requirements from clients in regards to the SRM control and disposition. SuKarne is committed to supplying products with the highest standards of food safety and quality.

E. coli O157:H7 and STEC Program

The annual HACCP reassessment has determined that while E. coli O157:H7 and Non O157:H7 STEC may be a hazard likely to occur on incoming cattle it has been concluded that due to the effective implementation of the HACCP plan and Sanitary Standard Operating Procedures the hazard has been effectively controlled.

+ 52 667 759 2600 Page 2 of 5 www.sukarne.com

Av. Diana Tang 56 Interior A, Col. Desarrollo Urbano La Primavera. C.P. 80300 Culiacán Rosales, Sinaloa.

The Interventions implemented in SuKarne Facilities are as follow:

Cattle Wash.- All cattle hides are wash to reduce the microbial load , and the operation is adjusted in their time according to the contamination observe , this way we minimized the risk of contamination during the carcass dressing procedures.

Knifes trimming. - All carcasses are visually inspected by experience employees to eliminate any possible contamination that could exist by knife trimming, so every carcass is inspected at least by several pair of eyes.

Carcass Steam Vacuuming. - All carcasses are subjected to a steam vacuuming operation, after knife trimming of the carcasses, to eliminated any possible contamination Organic acid application. - All carcasses are subjected to an organic acid application that will reduce or eliminated pathogenic bacteria that might exist.

Cold Carcass Sanitizer. - After the carcasses have been cool, before entering the fabrication area all carcasses are sanitized with an organic acid application as a multiple hurdle approach and prevention of bacteria growth.

Additionally the following control measures are implemented at all SuKarne facilities After stunning - esophageal plugging/clipping where required tying and bagging the bung.

Line speeds appropriate to providing adequate time for operators to complete hygiene inspections and dressing of the carcass.

Sanitizing hands and equipment between carcasses for high risk activities.

Prevention of carcass to carcass cross contamination by spacing on lines and in chillers.

To verify the ongoing effectiveness of these interventions SuKarne conducts sampling and testing of Beef Trimmings for E.coli O157:H7 and Non O157:H7 STEC in accordance with FSIS Meat Directive 10010.3 of raw ground beef components (N60 Method) additionally to the testing we have a high event period program for the follow up of the results, Each lot consists of 4500 kg (10,000 lb.) or less, the product is sampled and tested for E.coli O157:H7 using approved methods.

All product is subject to a ‘Test, Hold and Release’ sampling procedure. Only product that has complied with the HACCP requirements and returned negative test results for E.coli O157:H7 can be released for shipment.

These samples are test in our Lab with the BAX DUPONT QUALICOM PCR SYSTEM and we send samples to an accredited outside lab for verification.

The trim is subject to other intervention before sampling, product is release after tested with negative results only.

+ 52 667 759 2600

www.sukarne.com Page 3 of 5

Av. Diana Tang 56 Interior A, Col. Desarrollo Urbano La Primavera. C.P. 80300 Culiacán Rosales, Sinaloa.

All trim products comply with the FSIS regulations, and with the Mexican regulations established for Export Facilities.

Our process flow for subprimal deliver the product direct in to the packaging lines and do not involve the comingling of product inside a container.

Generic E coli

Sample collection. Samples are collected by sponging from three sites on the selected carcass. The sites are the flank, brisket and rump. Sampling frequency. The sampling frequency is according to the volume of production 1 test per 300 carcasses and all our facilities since do sampling by sponging opted for the Statistical process control option for results management

Pathogen reduction performance standards for Salmonella.

SuKarne Slaughter plants comply with the USDA Regulation 9CFR part 310.25 as is require to exporting plants. The Sample collection. Samples are collected by sponging from three sites on the selected carcass. The sites are the flank, brisket and rump Sampling frequency. The sampling frequency is according to the volume of production 1 test per 300 carcasses.

The Salmonella performance standard we use for our Cattle, is the one for Steers and Heifers with 82 (n) consecutive samples at a 1% Performance Standard or a Maximum number of positives to achieve the Standard (c) of 1 At this time we are in compliance with the salmonella performance standards, as we have not had any positive in our process this year.

Pest Control Program

SuKarne have implemented in their facilities as a prerequisite program a Pest Control Program that is monitored daily and verified weekly. The services are provided by an outside contractor, that is approve by the Government official Health Services as a License Pest Control Services Provider As part of the pest control services is the assessment and implementation of measures to control and the installation of bait stations on the outside perimeter of the plant and mechanical rodent traps where applicable inside the plant, the program also includes the flying insect control devices. All activities from the pest control contractor are monitored by plant personnel and evaluated

+ 52 667 759 2600 Page 4 of 5 www.sukarne.com

Av. Diana Tang 56 Interior A, Col. Desarrollo Urbano La Primavera. C.P. 80300 Culiacán Rosales, Sinaloa.

Cattle Purchasing Policies

SuKarne has purchasing policies and certification of cattle suppliers so we receive at our feedlots the best quality cattle everyday. Our supplier go to an approval process where they have to comply with the Good Feedlot Management and Animal Welfare Practices as to provide signed affidavits that they comply with SuKarne requirements and confirm that their animals have not be fed any prohibited materials. We have establish Animal welfare practices so our cattle is handle appropriately (handling and transport), We also have created a profile for each animal (SuKarne’s Individual Animal Control System) In our Feedlot operations we have establish Animal welfare practices so we maintain good health and weight in our herds. We also have the SuKarne’s Individual Animal Control System for disease control and management as for and weight management And we have establish also a Chemical testing program of food rations, to prevent any deviation from the government regulations and standards Our Feed lots have been certified as by the Mexican SENASICA FOOD SAFETY DIVISION with the certification of (Good Feedlot Management Animal Welfare Practices) Our Feed lots are also being certified as Feed lots free of Beta agonist products like Clembuterol.

Traceability/Recall Plan

SuKarne plants have implemented a recall plant cattle supplied to SuKarne SA de CV are sourced from within Mexico only and are assessed as fit for human consumption by passing both an ante-mortem and postmortem . Inspection conducted by Mexican Government officials. Carcasses are identified at each stage through the process using a sequentially numbered ticket that remains with the carcass until boning. Carcasses are trimmed according to the Mexican Standard Carcass Trim requirements. After carcasses are boned, sliced and packaged on-site they are labeled according to Mexican language and as require by the FSIS labeling of beef product categories to identify the product type. The carton label includes the date, time and Lot of packing which is used for traceability purposes. The recall program is tested as Mock Recall is exercise twice a year in each plant.

Validation and Verification

SuKarne have been operating under a Pathogen Reduction Hazard Analysis and Critical Control Points (HACCP) System. We have implemented Sanitation Standard Operating Procedures and the generic E coli testing performance criteria as requested by the FSIS 9CFR part 416.11 and 416.17 and 310 .25 and the Mexican NOM-008-ZOO-1994 and it´s Modification in February 1999, and NOM -009-ZOO-1996 and it´s modification in November 1996.

+ 52 667 759 2600 Page 5 of 5 www.sukarne.com

Av. Diana Tang 56 Interior A, Col. Desarrollo Urbano La Primavera. C.P. 80300 Culiacán Rosales, Sinaloa.

Emergency Contact List - 24 hours

Edwin Botero VP of Business Development Mobiler.-310 702-7319 E-mail. - [email protected]

SuKarne Quality Management System and HACCP Plan have been audited and approved by the Mexican SENASICA Inspection Service. SuKarne SA de CV is committed to supplying products with the highest standards of food safety and quality.

Yours sincerely,

María del Lourdes Cortez García Quality Control Manager

+ 52 667 759 2600

www.sukarne.com

Av. Diana Tang 56 Interior A, Col. Desarrollo Urbano La Primavera. C.P. 80300 Culiacán Rosales, Sinaloa. PO Box 2158 Manteca, CA 95336 Phone (209) 825-0288 / Fax (209) 825-0291

January 4, 2021

Letter of Guarantee

Dear Valued Customer:

This letter is to certify that the meat products supplied by Sunnyvalley Smoked Meats, Inc.(Est. 17823/P17823) comply with all applicable local, state, and federal regulations and standards.

We have multiple food safety and quality programs in place including HACCP (Hazard Analysis and Critical Control Point), SSOPs, GMPs and other SOPs to help ensure we produce safe, wholesome, quality products on a consistent basis. We operate under USDA/FSIS inspection and are SQF Level 2 certified (since 2011) through annual third party audits.

All raw meat, ingredients, and packaging materials used in processing are purchased only from suppliers who meet our strict Supplier Approval Program and the requirements therein, which can include Letters of Guarantee (LOGs), Certificates of Analysis / Certificates of Conformance (COAs/COCs), 3rd party audits, product specifications and more. We have current letters of guarantee on file from all approved suppliers which demonstrate, at a minimum, their compliance with all applicable government rules and regulations (including FDA’s Food Safety Modernization Act for foreign suppliers), their commitment to product safety and quality, and their guarantee to ship no misbranded or adulterated products. In addition to the LOGs, all ingredients and food contact packaging materials we receive are accompanied by a COA or COC, whether in advance or with the delivery.

All products are produced under the control of our HACCP Programs which are reviewed and reassessed on an annual basis by our HACCP / Food Safety Team. Each product has one or more critical control points (CCPs) in place with established critical limits to ensure food safety. In addition, we have implemented effective monitoring procedures and verification activities, along with review of all documentation prior to any product shipping from our facility. Ready to Eat product is randomly tested monthly for Listeria Monocytogenes and Salmonella and environmental sampling is performed on a monthly basis also. All RTE products that are packaged the day that product sampling or environmental sampling is performed are held pending receipt of negative test results prior to release to ensure that product is wholesome before shipping.

Each package is affixed with an official inspection legend on the label showing that the product was inspected for wholesomeness and passed in accordance with the USDA regulations.

The conditions stated in this letter are a continuing guarantee of the ongoing commitment to food safety and quality at Sunnyvalley Smoked Meats, Inc. Please contact me should you have any additional questions or require more details regarding our food safety and quality programs.

Sincerely,

Courteney Barker Quality Assurance Manager Sunnyvalley Smoked Meats, Inc. [email protected]

January 4, 2021

RE: Superior Farms Quality Assurance Programs (HACCP, SSOP, Pest Control, COOL, Recall, 3rd Party Audits)

To whom it may concern,

Thank you for your inquiry regarding the Quality Assurance programs at one of our facilities. Superior Farms facilities include:  Superior Farms – Dixon Division, establishment 2800 (formerly Superior Packing Co.)  Superior Farms – Denver Division, establishment 5883 (formerly Superior Colorado & Mountain Meadows Lamb)  Superior Farms – Grove Division, establishment 1974 (formerly Grove Meat Company)

Superior Farms guarantees that our products are safe, wholesome and produced in accordance with all applicable food safety and handling laws.

HACCP, SSOP, Recall, Pest Control: This letter shall serve as notification that all Superior Farms facilities operate with USDA approved HACCP and SSOP Programs that comply with the Code of Federal Regulations. We operate under our own strict Standard Operating Procedures which include a pest control program maintained by a certified technician. We maintain a documented recall plan as well, which is tested at least annually.

E. coli 0157:H7 and non-0157:H7 STEC’s: All aspects of the HACCP plans are reassessed at least annually in addition to any reassessment requirements established by the USDA. Specifically, all Superior Farms facilities’ HACCP programs were reassessed in January 2003 and again in October 2007 per FSIS Notice 65-07 in regards to E. coli 0157:H7. A purchase specification is in place requiring all beef and veal harvest operations to have one or more validated CCP’s on place to eliminate or reduce the occurrence of E. coli 0157:H7 and to have reassessed their HACCP plans to address control of the six non-0157:H7 STEC’s that have been classified as adulterants. A letter of guarantee or a completed vendor approval form must be on file to confirm this. Additionally, only N60 raw material testing is accepted as verification testing of bovine raw materials for grinding or system validation. Critical Control Points within our own facilities adhere to strict temperature controls in order to prevent the growth of any pathologic bacteria including E. coli 0157:H7 and each lot of bovine raw material intended for grinding is tested for E. coli 0157:H7 using the N60 sampling protocol or an even more robust protocol. Raw material testing is validated each quarter with finished goods testing on ground product.

2530 River Plaza Drive · Suite 200 · Sacramento, CA 95833 Main (530) 758-3091 · Customer Service (800) 228-5262 · Fax (530) 758-3152 www.superiorfarms.com Bovine Spongiform Encephalopathy (BSE): Our HACCP plans also address Bovine Spongiform Encephalopathy. The vendor approval program ensures that all beef and veal vendors verify that all non-ambulatory animals presented for slaughter are condemned, that air injection stunning is prohibited in all the company’s slaughter facilities, that automated meat recovery systems are not used for our product, that measures are in place to verify that all specified risk materials (SRM’s) are excluded from qualified edible product, and that product from animals 30 months of age or older is kept separate from other products.

Country of Origin Labeling: Additionally, all facilities are in full compliance with country of origin regulations. Affidavits stating where the animals delivered to our processing plants were born and raised are on file. All covered products have the country of origin printed on the box labels, as well as by product code on the bills of lading and invoices. We have made the transition to the more specific new terminology of Born, Raised and Harvested in the USA.

Third Party Audits: Our Dixon and Denver facilities are audited by third party agencies at least once a year. We participate in both Animal Welfare and GFSI certification food safety audits under the British Retail Consortium (BRC). Audit certificates are available upon your request.

Superior Farms does a wide variety of microbial / food safety testing and continues to actively participate in pathogen reduction programs. Superior Farms’ approach to food safety will always be to not only meet, but exceed, meat industry standards.

Should you have any additional questions concerning our HACCP programs or other Quality Assurance items, please contact one of the Managers below or myself.

Sincerely,

Andrea Perkins Superior Farms, Director of Food Science [email protected]

Superior Farms Dixon Grove Denver Division Establishment 2800 1974 5883 Number 7390 Rio Dixon Road 2222 W. Grove Street 4900 Clarkson Street Address Dixon CA, 95620 Blue Island IL, 60406 Denver, CO. 80216 Contact Laura Cruz, QA Manager Carlos Barba, General Manager Julie Munoz, QA Manager Phone Number (707) 693-2303 (708) 385-8400 (303) 749-5270

Email Address [email protected] [email protected] [email protected]

January 4, 2021 Valid until superseded

FDA Food Contact Status and Good Manufacturing Practices DOLCO PACKAGING Food Cartons, Tills, and Trays From Bloomfield, NY; Decatur, IN; Dallas, TX; Lawrenceville, GA; and/or Wenatchee, WA

Dear Valued Customer:

The components of the above products comply with the applicable FDA regulations for food contact as described in Title 21 (Food and Drugs) of the Code of Federal Regulations.

Please E-Mail me at [email protected] if you have any questions about this matter.

TEKNI-PLEX, INC.

E. L. McKinley

Director, Regulatory Compliance-Americas elm/FDA010421

Tekni-Plex, Inc 460 E. Swedesford Road, Suite 3000 ▪ Wayne, PA 19087 ▪ Phone (484) 690-1520

PURE FOOD GUARANTY AND INDEMNIFICATION AGREEMENT (Continuing Form)

Tyson Foods, Inc., for itself and its wholly-owned subsidiaries (“Seller”), guarantees that the articles of food (the “Products”) sold by Seller to Pacific Food Distributors (“Buyer”), for the period during which this guaranty is effective, shall not be adulterated or misbranded within the meaning of the Federal Food, Drug and Cosmetic Act, as amended (the “FDC Act”); the Federal Meat Inspection Act, as amended; the Poultry Products Inspection Act, as amended (collectively, and as applicable, the “Acts”); or within the meaning of any applicable state food and drug law, the adulteration and misbranding provisions of which are (i) identical with or substantially the same as those found in the Acts, and (ii) are not preempted by the Acts or otherwise by federal law. The Products are not articles that may not, under the provisions of section 331(d) of the FDC Act, be introduced into interstate commerce. Seller guarantees that no Products shall be classified as hazardous materials subject to Department of Transportation regulations contained in 49 CFR 177.800 – 177.870. Seller represents that it is in compliance with relevant HACCP food safety systems requirements of the USDA/FSIS, the provisions of the Public Health Security and Bioterrorism Preparedness and Response Act, the registration requirements of the Food Safety Modernization Act, and the country-of-origin labeling provisions of the Farm Security and Rural Investment Act, as amended. For Products shipped under Buyer’s labels, Seller's responsibility for misbranding is limited to direct damages resulting from the failure of the Products to conform to the labels furnished by Buyer and accepted by Seller. Notwithstanding anything to the contrary herein, Seller does not guarantee against the Products becoming adulterated or misbranded within the meaning of the Acts by reason of causes beyond Seller’s control after shipment. Seller agrees to indemnify and hold Buyer harmless from direct damages arising out of or resulting from any breach of this guaranty; provided, however, the foregoing shall not apply to any damage or liability resulting from (i) Product becoming adulterated or misbranded after such Product has left Seller’s control, (ii) the negligence or intentional act or omission of Buyer (including any employee or agent thereof) or any third party, (iii) Buyer’s refusal to cooperate with Seller in the investigation or defense of a claim covered by this guaranty, (iv) Buyer agreeing to settle a claim covered by this guaranty without Seller’s written consent, (v) the Products being resold by Buyer other than in the ordinary course of Buyer’s business, or (vi) any warranty, express or implied, that is not specifically stated herein. NEITHER PARTY SHALL BE LIABLE TO THE OTHER OR ANY THIRD PARTY, TO THE EXTENT PERMITTED BY LAW, FOR ANY LOSS OF BUSINESS, LOST PROFITS, BUSINESS INTERRUPTION, DAMAGE TO GOODWILL OR REPUTATION, DEGRADATION IN VALUE OF BRANDS OR OTHER INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES, EVEN IF A PARTY OR ITS AFFILIATES HAVE BEEN APPRISED OF THE LIKELIHOOD OF SUCH DAMAGES OCCURRING. EXCEPT FOR THE EXPRESS WARRANTIES HEREIN, SELLER HEREBY DISCLAIMS ANY AND ALL WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND ALL OTHER WARRANTIES, EXPRESS OR IMPLIED. This guaranty shall continue to be effective as it relates to the Products until it is revoked by Seller by the giving of written notice to Buyer. As to current or future Products sold to Buyer, this guaranty revokes and automatically supersedes any prior guaranty provided by Seller, and this guaranty may not be amended by any document issued by Buyer unless otherwise specifically agreed by Seller in writing.

TYSON FOODS, INC. Date: January 22, 2019

By: Its: Scott Rouse Chief Operations Officer

Tyson Foods, Inc. 2200 Don Tyson Parkway, Springdale, AR 72762-6999 Phone: 479-290-4000 Fax: 479-290-7967 Rev 10-17 www.tysonfoods.com

February 04, 2020 Food and Drug Guaranty

Volflex, Inc. (Volflex), with its principle place of business at 10920 W. Walnut Lane, Mokena IL, hereby guarantees to Pacific Foods PFD ("Buyer"), with its principle place of business in Clackamas, OR. That all food and drug products hereafter sold by Volflex, in all respects, comply with the Federal Food, Drug and Cosmetic Act, and all acts amending or supplementing the same, including, without being limited to, the Food Additive Amendment of 1958, and with the pure food and drug laws of each and all of the states of the United States, whether now in force or hereafter enacted, into which any such products shipped by Volflex and are not and shall not be at the time of delivery adulterated or misbranded with the meaning of said laws or be articles prohibited from introduction into interstate commerce under the provision of Section 404 or 505 of the said Federal Food, Drug and Cosmetic Act, and are not and do not contain a misbranded hazardous substance or a banned hazardous substance. Volflex agrees to indemnify and hold harmless Buyer for damages it may incur due to a breach of this guaranty; provided that this guaranty shall become void unless (1) prompt notice in writing is given to Volflex by Buyer with full information concerning any claim that any product sold by Volflex to Buyer is adulterated or misbranded or in any other respect fails to comply with this guaranty, (2) no settlement of any matter for which indemnification so sought is made without prior written consent by Volflex, and (3) the claim shall not have risen out of the negligence or wrongful conduct of Buyer or relating to products which have been altered, mishandled, adulterated or otherwise changed in quality or character since delivery by Volflex. The duty of Volflex to defend Buyer shall be satisfied by Volflex furnishing at its expense competent legal counsel to represent Buyer in dealing with the claimant and appearing for and defending Buyer in any court case, governmental proceeding or arbitration where the claim may be asserted.

This Agreement shall cover only product delivered by Volflex with one (1) year from the date hereof and shall terminated absolutely at the end of said one (1) year, and shall not be renewed or extended except by a new writing signed by an authorized office of Volflex. This Guaranty may be canceled at any time upon thirty (30) days prior written notice to Buyer by Volflex. Any such cancellation shall be affective only as to order shipped after the effective date of cancellation.

Dated this 4th day of February 2020.

Sincerely,

David Bunch Vice President Volflex, Inc. [email protected]

10920 Walnut Lane Mokena, IL 60448 Phone (708) 478-1117 . Fax (708) 478-1118

January 21, 2021 Food and Drug Guaranty

Dated this 21st day of January 2021.

Sincerely,

David Bunch Vice President Volflex, Inc. [email protected]

10920 Walnut Lane Mokena, IL 60448 Phone (708) 478-1117 . Fax (708) 478 -1118 CERTIFICATE OF CONFORMITY

SAI Global, accredited Certification Body No Z1440295AS certifies that:

Walt's Wholesale Meats, Inc. 350 S Pekin Rd., Woodland, Washington 98674 USA

BRC Site Code: 1466199

h aving conducted an audit for the scope of activities: Beef slaughter, boning of beef carcasses into refrigerated trim and primal cuts, vacuum or loose packed into plastic lined combos and boxes.

Exclusions from scope: None

Product Category: 01 - Raw red meat

Has Achieved Grade: A

Meets the requirements set out in the

BRC GLOBAL STANDARD FOOD SAFETY ISSUE 8: AUGUST 2018

Audit Programme: Announced

Certificate No.: CERT-0128612

Auditor No.: 123358

:Certificate Issue Date: January 8, 2021 Date of Audit: December 1, 2020 To: December 3, 2020

Certificate Expiry Date: January 29, 2022 Re-audit Due Date, From: November 20, 2021 To: December 18, 2021 Certificate No: CERT-0128612

Auditor Number: [Enter number]

Frank Camasta Global Head of Technical Services SAI Global Assurance

Registered by: SAI Global Certification Services Pty Ltd (ACN 108 716 669) 680 George Street Sydney NSW 2000 Australia with SAI Global Pty Limited 680 George Street Sydney NSW 2000 Australia (“SAI Global”) and subject to the SAI Global Terms and Conditions for Certification. While all due care and skill was exercised in carrying out this assessment, SAI Global accepts responsibility only for proven negligence. This certificate remains the property of SAI Global and must be returned to SAI Global upon its request. To validate certificate authenticity please visit www.brcdirectory.com

If you would like to feedback comments on the BRCGS Standard or the audit process directly to BRCGS, please contact tell.brcgs.com

January 4, 2021 Effective through December 31, 2021

Letter of Guarantee and Food Safety

To Wayne Farms Customers:

1. All product now being sold or which may hereafter be sold or delivered by Wayne Farms LLC (Seller) to its customer (Buyer) is not and will not be adulterated, misbranded, unlawfully shipped or unlawfully introduced into commerce within the meaning of the Federal Food, Drug and Cosmetic Act, as amended; the Federal Meat Inspection Act of 1967; the Poultry Inspection Act, as amended, or any other federal, state or municipal statutes, ordinances, rules or regulations pertaining thereto.

2. Seller shall indemnify and hold Buyer, its officers, agents, employees and customers harmless from any and all complaints, claims or legal actions for loss (including but not limited to damage, illness, injury, or death) related to or in any way arising out of or resulting from the purchase, sale, consumption or use of its products or services, including any claimed patent or trademark infringement, to the extent of Seller’s negligence, and subject to Seller’s Consumer Product Complaint Procedures, provided, however, that such indemnification shall not extend to any loss caused by the negligence of either Buyer, its customers, its invitees, or other third parties, or for consequential or punitive damages.

Unless Buyer receives written notice otherwise, this agreement shall apply to each and every purchase of Seller’s product by Buyer unless revoked by Seller in writing upon seven (7) days written notice.

The USDA Establishments covered by this letter include:

Facility Location Establishment # Albertville, AL P-1317 Danville, AR P-1009 Decatur-Fresh, AL P-1235 Decatur-East-Further Processing P-20214, M-21263 Decatur-West-Further Processing P-33885, M-33890 Dobson, NC P-445 Dothan, AL P-7342 Enterprise, AL P-7485 Laurel, MS P-519 Pendergrass, GA P-170 Union Springs, AL P-912 WFSP Foods P-45411, M-45411

Hazard Analysis of Critical Control Points (HACCP) The quality and safety of the products produced and marketed by Wayne Farms are guaranteed. We were a leader in the poultry industry in developing and implementing the principles of HACCP (Hazard Analysis of Critical Control Points) in our food processing facilities and have operated in the HACCP environment since 1992. All of our food processing facilities are in compliance with all U.S. Department of Agriculture (USDA) regulations and are operating under a fully implemented HACCP Plan that meets or exceeds all requirements set forth in 9 CFR 417. Wayne Farms has identified validated Critical Control Points (CCP) through conducting a hazard analysis for biological, chemical and physical hazards

Wayne Farms LLC – Corporate Headquarters 4110 Continental Dr. • Oakwood, Georgia 30566 • 770.538.2120 • www.waynefarms.com

Letter of Guarantee and Food Safety January 4, 2021 Wayne Farms LLC Effective through December 31, 2021 for each of our processes. Each facility’s HACCP plan is available for review by the customer at any time while at the facility.

Wayne Farms’ slaughter facilities comply with USDA/FSIS requirements consistent to meet the Salmonella/ Campylobacter whole carcass and parts performance standards. Each facility maintains appropriately validated interventions to control Salmonella and Campylobacter.

Wayne Farms facilities have in place Sanitation Standard Operating Procedures (SSOPs) that meet all requirements of 9 CFR 416. Furthermore, Wayne Farms’ facilities have in place written supporting programs encompassing:  Good Manufacturing Practices (GMPs)  Traceability procedures for all raw materials, packaging, ingredients and finished products to ensure proper identification for all products coming into and through the system and leaving the system.  Recall procedures are in place at each production facility such that if necessary, all products that are produced can be traced by product codes and volumes shipped to the first level of distribution and back to ingredients, packaging and farms. A mock recall will be held at each facility location a minimum of three times per year: one for finished goods traceability; one for raw material/ingredient traceability; and one for direct product contact packaging material traceability. The mock recall shall be considered successful if 100% of the product is identified within 2 hours.  Pest Control Program  Food Defense Program o Facilities are access controlled, fenced and guarded. All visitors/contractors must show a valid photo ID and must be authorized by plant management. Annual security audits are conducted at all locations. All incoming and outgoing trucks/trailer doors, including the vent door, must be locked (padlocked) or sealed, and the seal number(s) recorded on the shipping documents.  Bioterrorism o All Wayne farms processing facilities are registered with the FDA to meet the requirements of the Bioterrorism Act. All associates are trained on the Food Security Program annually. Associates are encouraged to report any signs of tampering or suspicious activity. We also have procedures in place to minimize the risk of tampering or other malicious, criminal, or terrorist action when shipping and receiving products.  Food Fraud o Wayne Farms facilities follow a risk-based evaluation protocol, compliance requirements, and best practices to identify, deter, and prevent intentional contamination of food products, the deliberate and intentional substitution, addition, tampering, or misrepresentation of food products for economic gain.  Allergen Control Program o Allergens have been considered in the hazard analysis for each Wayne Farms facility. In those facilities where allergens are present, programs have been established and validated through testing for the handling and control of any ingredient containing allergens.  Foreign Material Control o Each facility has foreign material control procedures in place that include a glass/brittle plastic policy with monitoring, metal detectors (where applicable), and monthly foreign material blitzes to identify potential foreign material threats.

Wayne Farms LLC – Corporate Headquarters 4110 Continental Dr. • Oakwood, Georgia 30566 • 770.538.2120 • www.waynefarms.com

Letter of Guarantee and Food Safety January 4, 2021 Wayne Farms LLC Effective through December 31, 2021

Audits The programs above as well as many other aspects of HACCP, sanitation and GMP’s are audited at each facility annually, internally, as well as by Merieux NutriSciences under the Global Food Safety Initiative (GFSI) standard of Safe Quality Foods (SQF) Food Safety Code. Each facility has maintained SQF 2000 Food Safety Code certification since 2010, with the exception of WFSP Foods (45411/P-45411) that just began operations in July 2014 and received SQF 2000 Food Safety Code certification in July 2015 and recertification each year thereafter. All of these programs and associated documents are available and open for review at the facility by the customer at any time.

Country of Origin Wayne Farms is a fully integrated poultry producer. All birds are hatched in facilities and raised on domestic farms located in the Southeastern United States. All poultry products sold by Wayne Farms are derived exclusively from poultry that have passed ante- and post-mortem inspection by USDA/FSIS at federally registered slaughter and processing facilities. All products sold by Wayne Farms will bear the official FSIS mark of inspection (USDA inspection seal) on the shipping containers for clear identification, and containers are labeled “Product of USA.” This meets the requirements of the Country of Origin Labeling (COOL) regulation as listed in 7 CFR Part 65.

Animal Welfare Wayne Farms has committed to an animal welfare program in compliance with the National Chicken Council Animal Welfare Guidelines to ensure the proper handling, treatment and wellbeing of poultry during the production process. It includes a documented training and development program focused on educating and reinforcing the best practices outlined in our Animal Welfare Program. Focused training is provided to ensure that all parties have the ability to successfully perform their jobs with respect to animal welfare. The Wayne Farms Animal Welfare Program also has a comprehensive auditing program supported by both internal and third party auditing that focuses on all aspects of our production system. Each Wayne Farms slaughter facility receives two third-party audits and two internal audits annually. Our third-party audits are performed by FACTA using a science-based humane PAACO-certified audit and PAACO-certified auditors.

Wayne Farms places personal responsibility and accountability on all employees, growers and persons associated with the company to fully adhere to and follow the Animal Welfare Program. Individuals who fail to do so will be subject to disciplinary action up to and including termination of employment, termination of agreements, or termination of grower contracts. Wayne Farms has an Employee Hotline where incidents of animal welfare violations can be reported anonymously for follow-up by Corporate Senior Management.

Residue Testing Wayne Farms conducts comprehensive pesticide residue monitoring on each flock before slaughter as part of its Pesticide Residue Testing Program.

Wayne Farms does not use antibiotics that are considered by FDA to be important to human medicine on a routine basis. However, we fully support the use of FDA-approved antimicrobial compounds when necessary to treat disease in order to prevent animal suffering and mortality. All antibiotic use is supported by evaluation of poultry health conditions, including use of diagnostic tests. All antibiotic use at Wayne Farms is overseen by licensed and USDA- accredited veterinarians, who are board certified by the American College of Poultry Veterinarians. Our veterinarians are involved in day-to-day flock monitoring to ensure antibiotics are used judiciously. We adhere to all Food and Drug Administration (FDA) regulations regarding the withdrawal of antibiotics from feed and water. These FDA withdrawal regulations ensure that all edible animal and poultry products when ready-to-eat are free from antibiotic residues.

Wayne Farms LLC – Corporate Headquarters 4110 Continental Dr. • Oakwood, Georgia 30566 • 770.538.2120 • www.waynefarms.com

Letter of Guarantee and Food Safety January 4, 2021 Wayne Farms LLC Effective through December 31, 2021

Avian Influenza Monitoring Wayne Farms is a registered participant in the National Poultry Improvement Plan (NPIP) and is testing birds for Avian Influenza from each flock according to this plan. Human Trafficking Wayne Farms is committed to identifying and protecting against employment practices or policies that provide opportunities for forced labor exploitation or human trafficking whether such policies or practices exist internally or inside its supply chain or distribution vendors. Furthermore, Wayne Farms is committed to training Human Resource personnel to recognize the indicators of suspected human trafficking and reporting of any suspicious activity to appropriate authorities.

At Wayne Farms, we have a passion for every aspect of what we do and make continuous improvement a way of life. Through finding and implementing best practices, creatively engaging our employees and having open and honest communication both internally and externally, we will work together with our suppliers and customers to produce quality products under strict food safety policies and procedures that meet our customers’ needs and requirements. As a valued customer, we appreciate your continued business and ask that you feel free to contact us if you need further information.

Bryan L. Miller, Ph.D. Vice President Quality Assurance and Food Safety

Wayne Farms LLC – Corporate Headquarters 4110 Continental Dr. • Oakwood, Georgia 30566 • 770.538.2120 • www.waynefarms.com

West Coast Trading & Imports

Pacific Food Distributors/ Packaging 12300 SE Carpenter Dr. Clackamas, OR 97015 February 1, 2021

Dear Pacific Food Distributors/ Packaging:

This letter is to state and guarantee that all the raw materials used in the manufacturing of the plastic bags supplied by my company, West Coast Trading & Imports, Inc. complies with the Food and Drug Administration (FDA) Specifications according to U.S. FDA 21 Code of Federal Regulations part 177.1520 (c) (2.1) which allows for polyethylene unmodified used in articles that contact food except for articles used for holding food during cooking, and (2.2) which allows for polyethylene unmodified used in articles for packing or holding food during cooking.

Sincerely,

John Lau, President

Hayward, CA 94544 (415) 822-1687 Main (415) 822-6311 Fax [email protected]

1509 Zephyr Avenue, Hayward, CA, 94544 •415-822-1687• [email protected] • www.wctpak.com

Wing Lee® Farms 13625 Yorba Ave., Chino, California, 91710 | Tel: (909) 628-2888 | Fax: (909) 628-6588 [email protected] | www.wingleefarms.com

01/01/2021

Letter of USDA Certification and Guarantee

Dear Valued Customer,

Please use this letter to certify that the Wing Lee® Farms poultry are hatched, raised, and harvested in the USA and produced at our slaughtering facility in Chino, CA (USDA Est. P- 33902) that is in full compliance with the the rules and regulations set forth under the guidance of the United States Department of Agriculture (U.S.D.A). These guidelines include, but are not limited to, Hazard Analysis and Critical Control Point (HACCP) plan and Standard Sanitation Operation Procedures, which conforms to all applicable requirements set forth in 9 CFR part 417 and 416 of the Federal Register respectively. Poultry products from our facility are fully inspected and passed under U.S.D.A. supervision and meet other regulatory requirements per F.S.I.S.-U.S.D.A. guidelines prior to shipment.

Sincerely,

Cindy Tang Vice President Wing Lee Farms

OA■OON z CAAPT■D

Zenner's Quality Meat Products, Inc. Food Safety Process consists of SSOP's, SOP's, Hazard Analysis Critical Control Points and validated technology interventions, which are designed to eliminate or reduce pathogens. Our Food Safety Process is monitored by Operations personnel and verifiedby Quality Assurance and FSIS/ USDA personnel in our plant. Inspection and process verificationby FSIS/ USDA personnel occurs before the mark of inspection can be placed on products which will enter into commerce.

Zenner's Quality Meat Products, Inc. has a Listeria testing program which consists of bi-monthly samples taken in different areas of our facility and sent to a certified lab.

Products are processed, stored, and shipped under proper refrigeration.

Any company from which we purchase raw materials, are required to provide us with letters of guarantee.

Our HACCP and SSOP plans are annually reassessed to reflect our ongoing commitment in foodsafety and quality.

Sincerely,

Ben Lucero HACCP Coordinator·<0/ � � 1/02/2021

2131 NW KearneySt. • Portland, OR 97210 • 503.241.4113 PO Box 10084 • Portland, OR 97296-0084 • Fax 503.241.4058

5100 HARVESTER RD. SUITE #2, BURLINGTON, ON L7L 4X4 Tel: 905-632-3572 Fax: 905-637-1062 Website: www.zfamerica.com

Date: January 1st, 2021 Attn: HACCP Coordinator

To whom it may concern,

This letter is our guarantee that all the seafood we, Zhangzidao Fishery Group America Corp. (DBA: ZF AMERICA, FDA registration number: 16824067372), supply to your company has been produced in facilities that meet or exceed the regulations of the United States Food and Drug Administration HACCP & sanitation standards. These requirements are defined under the Code of Federal Regulations Part 21 – Fish & Fishery Products, section 123 & 1240 and we are fully aware and understand all the implications of these regulations for production of products intended for import to the United States. All quality related & HACCP related records will be available for review for at least 2 years from date of production.

Our company understands that this is a continuous guarantee and by statue must be issued annually to your company.

Best Regards,

Kelly Yang

Kelly Yang President