GFSI BENCHMARKING REQUIREMENTS

GFSI GUIDANCE DOCUMENT VERSION 7.1

PART I
THE BENCHMARKING PROCESS

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 The GFSI Benchmarking Requirements
Version 7.1

PART I
THE BENCHMARKING
PROCESS
CONTENTS
Introduction .................................................................................................................... 3
1 Application ......................................................................................................... 3
1.1.1 GFSI Scopes of Recognition ....................................................................................4
Defining the Scope ...........................................................................................................5
Benchmarking Options ....................................................................................................8
1.1.2 Benchmarking .........................................................................................................7
1.1.3 Re-benchmarking ....................................................................................................7
1.1.4 Extensions to Scope of Recognition for Schemes Benchmarked Against V7.........8
1.1.5 Significant Change ..................................................................................................8
2 The GFSI Benchmark Methodology ..................................................................... 9
2.1 Introduction ...............................................................................................................9
2.2 The Key Procedural Steps ..........................................................................................9
2.2.1 Step 1: Scheme Owner Fills out the Self-Assessment ...........................................10
2.2.2 Step 2: Preliminary Desk Review of the Self-Assessment .....................................10
2.2.3 Step 3: Call to Go through Findings .......................................................................10
2.2.4 Step 4: Scheme Owner Updates (where applicable) and Resends Final Self-
Assessment ....................................................................................................................10
2.2.5 Step 5: Office Visit.................................................................................................10
2.2.6 Step 6: Public Stakeholder Consultation ..............................................................10
2.2.7 Step 7: GFSI Board Final Decision and Communication .......................................10
2.2.8 Step 8: Annual Assessment Based on GFSI Integrity Programme ........................11
2.2.9 Sanctioning ...........................................................................................................12
2.2.10 GFSI Appeals Procedure - GFSI Recognition........................................................12

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PART I
THE BENCHMARKING PROCESS
Introduction
The Global Food Safety Initiative works closely together
with stakeholders and Scheme Owners to provide
continuous improvement in food safety management
systems to ensure confidence in the delivery of safe food to
consumers worldwide. We have used this input to develop
the version 7 (V7) Benchmark criteria, and also adopt a new
approach towards our Benchmarking procedure. We seek
to increase transparency and streamline the Benchmarking
procedure in a more uniform manner, thus enabling GFSI
Benchmarked Scheme Owners to efficiently comply with
the criteria laid out in the GFSI Benchmarking Requirements
V7. It will contribute to the following GFSI objectives:
1. Reduce food safety risks by delivering equivalence and
convergence between effective food safety management
systems.
2. Manage cost in the global food system by eliminating
redundancy and improving operational efficiency.
3. Develop competencies and capacity building in food
safety to create consistent and effective global food
systems.
4. Provide a unique international stakeholder platform for
collaboration, knowledge exchange and networking
1 Application
Any Scheme Owner that wishes to be recognised must
apply via the GFSI website. The Scheme Owner downloads
an application form template and finds detailed guidance
for the completion of the application and supporting
documents. The Scheme Owner’s application must include
GFSI Benchmarking Requirements Part II (Requirements for
the Management of Schemes) and at least one industry
scope.
The GFSI Technical Manager shall review the application,
and if in agreement, shall send a contract to cover all
aspects of the benchmarking process as well as terms and
conditions.
The GFSI Technical Manager reserves the right to reject
or refer an application back to the Scheme Owner if the
quality of the application is poor.
This section is the first part of the GFSI Benchmarking
Requirements, which has been developed and published
by the Global Food Safety Initiative (GFSI) to specify the
requirements for the recognition of food safety schemes.
The detailed steps and procedures developed by GFSI
serve to demonstrate that the GFSI benchmarking process
is carried out in an impartial and transparent manner by
a technically competent Benchmark Leader under the
supervision of GFSI Technical Manager.
The objective of this document is to give stakeholders a clear
insight into the benchmark process for GFSI Benchmarking
Requirements V7. Further clarification will be provided
during the application process. The benchmarking process
carried out by GFSI is the method by which a food safety
Scheme Owner is objectively compared to the defined
requirements as set out in the GFSI Benchmarking
Requirements V7 to determine equivalence.
GFSI shall ensure that the process of GFSI benchmarking
and associated procedures are transparent and open
to stakeholder scrutiny. The systems and procedures
associated with the GFSI benchmarking process will be
reviewed, maintained and updated to ensure consistency
and integrity.
An applicant Scheme Owner shall be permitted to lodge
multiple benchmarking applications with GFSI, but shall
only be permitted to submit one re-submission within a
twelve-month period, if the initial application is deemed to
be unsuccessful.
A list with available Benchmark Leaders will be presented
on the GFSI website. The GFSI Technical Manager will
appoint a Benchmark Leader for the Scheme and record the
selection in the application file. The Technical Manager may
assign additional Benchmark Leaders to ensure that the
benchmarking takes place within the desired timeframe.
This will be done with the written consent of the Scheme
Owner.
Once the GFSI Technical Manager accepts the Scheme
for benchmarking, the benchmarking process will only
progress once a contract has been signed between the
applicant Scheme Owner and GFSI.
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After the signed contract is received, the GFSI Technical
Manager shall transfer all appropriate excel files for self-
assessment to the Scheme Owner and present a work plan.
This work plan of activities and key dates will be agreed
upon by the GFSI Technical Manager, the Benchmark
Leader and the Scheme Owner based on the number of
scopes and volume of documentation submitted.
Confirmation of acceptance of the work plan shall be
published on the GFSI website.
1.1.2 Benchmarking
DEFINING THE SCOPE
Every Scheme Owner that applies shall have a defined scope
in relation to food safety or services directly associated
with food safety, which shall be subject to certification by
accredited Certification Bodies.
GFSI has set up several requirements for the management
of the schemes. These requirements are described in Part II
and apply to all Scheme Owners wishing to go through the
GFSI benchmarking process for V7.
The GFSI sector and sub-sector scopes for recognition are as follows;
GFSI SCOPE OF
RECOGNITION
BENCHMARKING CATEGORY NAME
(Benchmarking
Category Code)
Farming of Animals for Meat/ Milk/ Eggs/
AI Honey
AII Farming of Fish and Seafood
Farming of Plants (other than grains and
BI pulses)
BII Farming of Grains and Pulses
C Animal Conversion
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GFSI has clearly defined scopes in relation to products or
services for which Schemes can seek recognition by GFSI.
The Scheme shall clearly specify the scope of activity
within its application to GFSI. GFSI has categorised the food
supply chain into sectors and sub-sectors in which there
is a defined series of requirements for food safety criteria
which are dependent upon the relevant sector. These
requirements shall be clearly defined in the standard of
the applicant’s Scheme as these shall be assessed against
the requirements of the relevant section of the GFSI
Benchmarking Requirements (Reference Part III Scheme
Scope and Key Elements).
A Scheme’s standard may have a major focus or historical
focus other than those related to food safety. Only those
requirements relating to food safety shall be assessed by
GFSI for the purpose of recognition.
The GFSI sector and sub-sector scopes for recognition are
as follows;
EXAMPLES OF PRODUCTS / SERVICES
AND METHOD OF PRODUCTION
Animals (other than fish and seafood) used
for meat production, egg production, milk
production or honey production
Growing, keeping, trapping and hunting
(slaughtering at point of hunting)
Fish and seafood used for meat production
Growing, trapping and fishing
(slaughtering at point of capture)
Growing or harvesting of plants (other
than grains and pulses) for food
Growing or harvesting of grains and pulses
for food
Lairage, slaughter, evisceration, bulk
chilling, bulk freezing of animals
Gutting, bulk freezing of fish
Storage of game
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De-shelling of nuts
Drying of grain
Grading of fruit and vegetables
Storage
Pre-process handling of plant products,
D nuts and grain
Cleaning, washing, rinsing, fluming,
sorting, grading, trimming, bundling,
cooling, hydro-cooling, waxing, drenching,
packing, re-packing, staging, storing,
loading and / or any other handling activity
that does not significantly transform the
product from its original harvested form.

Production of animal products including

fish and seafood
Meat, eggs, dairy and fish products
EI Processing of perishable animal products Deboning, cutting, washing, trimming,
grading, pasteurisation, cooking, curing,
fermentation, smoking, chilling, freezing,
packed in modified atmosphere, packed in
vacuum packing

Production of plant products (products

(including grains, nuts, and pulses)
Washing, slicing, dicing, cutting, shredding,
peeling, grading, pasteurisation, cooking,
E II Processing of perishable plant products chilling, juicing, pressing, freezing, packed
in modified atmosphere, packed in
vacuum packing or any other activity that
significantly transforms the product from
its original whole state

Production of animal and plant products

Processing of perishable animal and plant Mixing, cooking, chilling, freezing, packed
E III products (mixed products) in modified atmosphere, packed in vacuum
packing

Production of food products from any

source that are stored and sold at ambient
temperature
Aseptic filling, baking, bottling, brewing,
canning, cooking, distilling, drying,
E IV Processing of ambient stable products extrusion, fermentation, freeze drying,
pressing, frying, hot filling, irradiating,
milling, mixing and blending, packed in
modified atmosphere, packed in vacuum
packing, pasteurising, pickling, roasting,
salting and refining

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Production of feed from a single or mixed

food source
FI Production of feed
Drying, cooking, milling, mixing and
blending and extrusion

Production of food products from any

source for consumption outside the home
G Catering
Cooking, mixing and blending, preparation
of component products

Provision of finished food and feed

H Retail / Wholesale products to a customer
Retailing and wholesaling of food and feed

Supply of services related to the safe

production of food
Water Supply
I Provision of Food Safety Services
Pest Control
Cleaning Services
Test Laboratories

Provision of Storage and Distribution Storage facilities for food and feed
J Services Food and Feed Distribution vehicles for food and feed

Manufacture of Food Processing Production of food and feed processing

K Equipment equipment

Production of (Bio) Chemicals (Additives, Production of food and feed additives,

L Vitamins, Minerals, Bio-cultures, vitamins, minerals, bio-cultures,
Flavourings , Enzymes and Processing aids) flavourings, enzymes and processing aids

Production of food and feed packaging,

packaging materials, packaging
components in the form of raw materials,
M Production of Food Packaging
part processed, semi converted, converted
or fully finished packaging materials and
products for use in the supply chain.

The supply of finished food and feed

N Food Broker / Agent
products

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BENCHMARKING OPTIONS
1.1.2 Benchmarking
The requirements specified within this clause shall apply to
Schemes, which have:
• not previously undergone benchmarking by GFSI,
• been assessed previously, but have withdrawn the
application without completing the benchmarking
process.
• been previously recognised by GFSI, but have had
recognition withdrawn.
GFSI will require the applicant Scheme Owner to submit an
application for recognition to GFSI together with supporting
evidence proving that;
• the Scheme Owner is a legal entity.
and
• the Scheme Owner is not a Certification Body and shall
not be governed or owned by one or more certification
bodies.
and
• there is an agreement with one or more Accreditation
Bodies for Certification Bodies to operate to ISO/IEC
17065 or ISO /IEC 17021 for the scope of their Scheme.
The Accreditation Bodies granting accreditation to
the scope of the Scheme shall be members of the
International Accreditation Forum (IAF) and shall be
signatories to the Multilateral Recognition Arrangement
(MLA).
and
• contractual relationships exist with at least two
Certification Bodies that have accreditation for the
scope of the Scheme with an Accreditation Body.
and
• the Scheme has in place ten valid accredited certificates
(for each relevant scope of the application) issued
by Certification Bodies, including at least one valid
certificate issued by each contracted Certification Body
during a twelve-month period prior to the date of the
application.
and
• the Scheme has been operational for a minimum period
of twelve months prior to the date of application. During
this period, certificates have been issued to a number
of organisations. A Scheme is deemed to become
operational on the date on which the first accredited
certificate is issued by a Certification Body.
and
• the Scheme shall not be undergoing a significant change
(See criteria for significant change to its standard,
management, governance or operational procedures at
the time of application of recognition by GFSI).
and
• the Scheme shall not have any practices that are deemed
as restricting access to markets.
and
• the Scheme has undertaken a self-assessment to validate
that the Scheme management and requirements are in
compliance with the GFSI Benchmarking Requirements.
1.1.3 Re-benchmarking
The requirements specified within this section of the GFSI
Benchmarking Requirements shall apply to:
• Schemes that have successfully undergone
benchmarking by GFSI. All existing GFSI-recognised
Schemes under V6 have to undergo re-benchmarking
for all the scopes against the GFSI Benchmark criteria V7
within the time period of 12 months from publication of
V7. GFSI Board has the authority to extend this period
under special circumstances.
• Schemes which have been subject to suspension by GFSI
or have temporarily or voluntarily agreed on withdrawal
in accordance with the GFSI Executive Director for
any other reason for a period of less than 1 year from
suspension or withdrawal.
GFSI will require the applicant Scheme Owner to submit an
application for recognition to GFSI together with supporting
evidence proving that:
and
• there is an agreement with one or more Accreditation
Bodies for Certification Bodies to operate to ISO/
IEC ISO17065 or ISO /IEC 17021 for the scope of their
Scheme. The Accreditation Bodies granting accreditation
to the scope of the Scheme shall be members of the
International Accreditation Forum (IAF) and shall be
signatories to the Multilateral Recognition Arrangement
(MLA).
and
• there are contractual relationships with at least two
Certification Bodies, who are accredited with an
Accreditation Body for the relevant scope for which the
Scheme is applying for recognition.
and
• the Scheme has in place 10 accredited certificates
(for the relevant scope of the application) issued by
Certification Bodies, during a twelve-month period prior
to the date of the suspension or withdrawal.
and
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• the Scheme shall not be undergoing a significant change
to its standard, management, governance or operational
procedures at the time of application of recognition by
GFSI and will have completed all activities that remedy
or re-establish the Scheme after the suspension or
withdrawal.
1.1.4 Extensions to Scope of Recognition for
Schemes Benchmarked Against V7
The requirements specified within this clause shall apply to
Schemes, which are:
• already benchmarked against V7 for different scope/
scopes seeking to apply for a new GFSI scope of
recognition.
• seeking an extension for a new standard (scope of
accreditation) within the GFSI scope of recognition,
for which they are currently recognised. This will not
include change to the governance or ownership or the
management system.
• seeking an extension of an existing recognised scope,
where there has been change to the Scheme’s standard
or operational normative documents, but these changes
do not represent significant change which could
compromise the Scheme’s recognition by GFSI.
GFSI will require the applicant Scheme Owner to submit
an application for recognition to GFSI together with
supporting evidence proving that;
• there is an agreement with one or more Accreditation
Bodies for Certification Bodies to operate to ISO/
IEC 17065 or ISO /IEC 17021 for initial accreditation
programme or the scope extension of their Scheme. The
Accreditation Bodies granting accreditation to the scope
of the Scheme shall be members of the International
Accreditation Forum (IAF) and shall be signatories to the
Multilateral Recognition Arrangement (MLA).
and
• there are contractual relationships with at least two
Certification Bodies, who are accredited with an
Accreditation Body for the scope for which the Scheme
is applying for recognition.
and
• the Scheme has in place ten certificates (for the
relevant new scope of the application) issued by
contracted Certification Bodies to demonstrate market
demand, including at least one certificate issued by at
least two Certification Bodies. There must be formal
acknowledgment and evidence provided that accredited
certification for the scope extension shall be in place
within one year.
and
• the host Scheme has been operational for a period of
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twelve months prior to the date of application. A Scheme
is deemed to become operational on the date on which
the first accredited certificate is issued by an Accredited
Certification Body.
From the moment when GFSI starts to finalise the new
version of the benchmarking requirements, GFSI will no
longer accept any applications from new Scheme Owners
for a period of one year. A notice will be displayed on the
GFSI website to indicate the starting date of this one-year
period. Additionally, GFSI will not accept any applications
for scope extension from existing Scheme Owners in the
last 6 months of this one-year period.
1.1.5 Significant Change
A Scheme seeking continued recognition prior to a Scheme
change is defined as a Scheme which is:
• Recognised by GFSI on the Benchmark criteria V7 but will
be making a change to its governance or ownership, or a
significant change to its management system, standard
or normative documents, which could compromise the
Scheme’s recognition by GFSI.
• Scheme Owners will inform the GFSI Executive Director
in writing about the significant change. A significant
change can lead to additional actions from the
Benchmark Leader. The type of action will depend on
the impact of the significant change.
GFSI will require the applicant Scheme Owner to submit
an application for recognition to GFSI together with
supporting evidence proving that:
and
• there is an agreement with one or more Accreditation
Bodies for Certification Bodies to operate to ISO/
IEC ISO17065 or ISO /IEC 17021 for the scope of their
Scheme. The Accreditation Bodies granting accreditation
to the scope of the Scheme shall be members of the
International Accreditation Forum (IAF) and shall be
signatories to the Multilateral Recognition Arrangement
(MLA).
and
• there are contractual relationships with at least two
Certification Bodies, that have accreditation for the
scope of the Scheme with an Accreditation Body.
and
• the Scheme has in place 10 accredited certificates (for
each relevant scope of the application) issued by an
accredited Certification Bodies, during a twelve-month
period prior to the date of the application.
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2 THE GFSI BENCHMARK METHODOLOGY

2.1 Introduction
The benchmarking process is performed by a Benchmark
Leader, who has been selected and approved by the
GFSI Board in order to ascertain whether a Scheme
can demonstrate conformity with the requirements of
the GFSI Benchmarking Requirements. The Benchmark
Leader reports to the GFSI Technical Manager who will
supervise all the Benchmark activities and communication
with the Scheme Owners. All Benchmark Leaders will
undergo the same training. In addition to this, there will
be harmonisation activities several times a year to maintain
alignment of the evaluation approaches adopted by the
various Benchmark Leaders. The Benchmark Leader will,
under supervision of the GFSI Technical Manager, execute
the benchmarking process as described in this document.
GFSI will select the Benchmark Leader for the Scheme after
signing an impartiality declaration from both the side of the
Scheme Owner and the Benchmark Leader. A Benchmark
Leader may perform the benchmarking activities for a
maximum period of 3 years per Scheme.
The GFSI Executive Director may reassign the Benchmark
Leader at any time, at his or her discretion, if it is deemed
necessary to do so.
2.2 The Key Procedural Steps
The benchmarking process shall be carried out in
accordance with the following key procedural steps:
1. Scheme Owner fills out the Self-Assessment.
2. Preliminary desk review by Benchmark Leader.
3. Call to Go Through Findings.
4. Scheme Owner updates (where applicable) and resends
the final Self-Assessment.
5. Office Visit.
6. Public stakeholder consultation.
7. GFSI Board final decision and communication.
8. Annual assessment based on the GFSI Integrity
Programme.

GFSI BENCHMARKING - Methodology

SELF- Scheme Owner fills in the Self-Assessment (SA)

ASSESSMENT

BL details made available on GFSI

Review of SA by Benchmark Leader (BL) under
supervision of GFSI Technical Manager (TM) i website. GFSI appoints BL for
Scheme.

PRELIMINARY BL checks SA and evidence,

BL and TM inform SO SO updates SA and
ASSESSMENT of preliminary results resends it i identifies need for additional info
and communicates it to GFSI TM.

BL summary report Office visit carried out As part of BP GFSI performs an

and recommendation by BL and GFSI TM i office audit .

Based on recommendation of BL
Public Consultation (PC) i and TM, GFSI Board makes final
decision on GFSI recognition.
FINAL
ASSESSMENT
Based on the assessment, BL drafts
Board Decision Update S0 i report to be shared during PC with
stakeholders.

SO COMMUNICATION WITH STAKEHOLDERS

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2.2.1 Step 1: Scheme Owner Fills out the Self-
Assessment
The objective of the Self-Assessment is to allow the
Scheme Owner to demonstrate that the Scheme covers
all the requirements listed in the benchmark documents
of V7, including Part II Requirements for the Management
of Schemes as well as the appropriate sections of GFSI
Benchmarking Requirements Part III Scheme Scope and
Key Elements.
GFSI will provide an Excel sheet with the relevant scopes
that Scheme Owners may use to rank themselves against
the GFSI V7 benchmark criteria. For each criterion, the
Scheme Owner must evaluate: is the GFSI criteria covered
in their Scheme? What is the justification for it? What is
the name of the Scheme’s document where the criteria
are covered? On which page and in what paragraph? Can
objective evidence be uploaded to support this claim?
Along with the application materials provided to the Scheme
Owners, GFSI will also provide a detailed description of
what is expected from the Scheme Owners throughout the
process.
2.2.2 Step 2: Preliminary Desk Review of the
Self-Assessment
After the completed Self-Assessment is received, the
Benchmark Leader, under the supervision of the GFSI
Technical Manager, will perform a preliminary Desk Review.
For each GFSI criterion, the Benchmark Leader will review
the corresponding requirements in the Scheme Owner’s
standard and check the reference given by the Scheme
Owner on where it is covered. The Benchmark Leader will
assess the objective evidence delivered by the Scheme
Owner.
The Benchmark Leader will take note of any criteria where
additional information is needed and/or where he or she
does not agree with the ranking of the Scheme Owner.
These comments will be supported by comprehensive
explanations. All these findings are sent back to the Scheme
Owner in writing and form the basis of the conference call
in step 3.
2.2.3 Step 3: Call to Go through Findings
In a conference call, the Benchmark Leader and the GFSI
Technical Manager will exchange their findings in detail
with the Scheme Owner. This will give the Scheme Owner
greater insight into what extra information is needed or
what needs to be adjusted. During the conference call the
time frame for execution of actions will be agreed.
2.2.4 Step 4: Scheme owner Updates (where
applicable) and Resends Final Self-Assessment
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Within the agreed timeframe, the Scheme Owner will
update the Self-Assessment and/or send the necessary
additional information. In order to limit a possible back-
and-forth exchange of information the Scheme Owner will
be required to deliver the requested information and/or
adjustments to the final Self-Assessment. The final version
of the Self-Assessment must be signed off by the Director
of the Scheme Owner.
2.2.5 Step 5: Office Visit
The Benchmark Leader and the GFSI Technical Manager
will organise a visit to the nominated offices of the
Scheme Owner. The purpose of the visit is to reconcile any
discrepancies identified by the Benchmark Leader during
the review of the Scheme Owner Self-Assessment and
check the implementation of the Scheme Owner Integrity
Programme. Following the visits to the Scheme Owner’s
offices, the Benchmark Leader shall complete the report
with the findings.
The applicant Scheme Owner should ensure that all
resources including expert staff members, documentation
and records are available to support the visit and criteria
verification process.
The findings of this office visit will be reported and the
Scheme Owner will have to respond with a corrective action
plan. Timelines on when the corrective action plan needs
to be received will be agreed with the Scheme Owner and
will depend on the type of finding.
2.2.6 Step 6: Public Stakeholder Consultation
The spreadsheet with the findings and the Benchmark
Leader’s report will be made available by the GFSI Technical
Manager on the GFSI website for stakeholder consultation
for a period of four weeks. The Scheme Owner will be
given the opportunity to approve the content of the report
before it is made available in the public domain. The report
will only be put to consultation once agreed by all above
parties.
Any comments, observations or objections made by
stakeholders about the report will be collected by the GFSI
Technical Manager and shared with the Scheme Owner,
who shall address these points. The Benchmark Leader and
the GFSI Technical Manager will evaluate every response
from the Scheme Owner and will inform the GFSI Board in
the form of a final summary report previously agreed upon
with the Scheme Owner.
2.2.7 Step 7: GFSI Board Final Decision and
Communication
The GFSI Board will come to a decision based on consensus
following the recommendation that will be presented
by the Benchmark Leader and the GFSI Technical
Manager. If a vote is necessary, the votes of the majority
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of a quorum of the GFSI Board shall determine the final
decision. Records shall be kept of the numbers of votes
for, against and abstaining. The GFSI Board decision shall
be communicated in writing to the Scheme Owner by the
GFSI Executive Director, as soon as practicable after the
GFSI Board decision, and will be communicated on the
GFSI website. The GFSI Technical Manager shall ensure that
those stakeholders who submitted comments during the
stakeholder consultation receive feedback.In the event of
recognition by the GFSI Board, the GFSI Technical Manager
shall prepare a news release confirming this decision with
the co-operation of the Scheme Owner. The Scheme Owner
will be expected to issue a similar news release. The timing
of these announcements shall be agreed on by the GFSI
Executive Director and the Scheme Owner.
The GFSI Technical Manager shall publish the confirmation
of the Scheme’s recognition on the GFSI website
(Conformance Statement).
In the event that the final decision of the GFSI Board is non-
recognition, the reasons for the Board decision shall be
clearly documented and the GFSI Technical Manager shall
make the Scheme Owner aware of the reasons behind this
decision. The Scheme Owner shall have the right of appeal
against the GFSI Board decision and the appeal shall be
undertaken in accordance with the procedures specified in
Scheme Owner Agreement.
2.2.8 Step 8: Annual Assessment Based on
GFSI Integrity Programme
The Global Food Safety Initiative has the responsibility to
create a transparent and level playing field for all Scheme
Owners undergoing benchmarking against the criteria
described in the GFSI Benchmarking Requirements V7. In
order to ensure that benchmarked Scheme Owners have
implemented all the controls necessary to ensure food
safety, GFSI has introduced the Integrity Programme.
2.2.8.1 Execution of the Integrity Programme:
The execution of the Integrity Programme will be managed
by the same independent Benchmark Leader who
performed the benchmarking process for V7. The execution
will take place under the supervision of the GFSI Technical
Manager and ensure that the appropriate confidentiality is
in place throughout the process.
2.2.8.1.1 Elements and Frequency of Execution
of Integrity Programme
The GFSI Integrity Programme consists of three elements:
1. Random record review - two times a year
2. Scheme Owner Office Audit - once a year
3. Complaint Investigation - incident driven
2.2.8.1.1.1 Content of the Random Record
Review
The random record review is an administrative audit
that is based on a sampling exercise. Twice a year, the
Benchmark Leader will go on the platform of the Scheme
Owner and randomly select 5 audits performed by CB’s.
From the selected audits, the Scheme Owner will receive
a list with request for objective evidence of files related
to these audits. These requests are all related to Part 2
Requirements for the Management of Schemes and to the
scopes against which the Scheme Owner is benchmarked.
For example:
• Certificate and report and/or auditor notes
• Contract with the CB
• Examination file of the auditor
• Scope allowance of the auditor
• Etc.
The Benchmark Leader will report back its findings. These
findings will be discussed during the office audit.
2.2.8.1.2 Content of the Office Audit
The focus of the office audit will be on the execution of
the Integrity Programme of the Scheme Owner towards
the CB’s. Based on two random selected audits on the day
of the office visit, the Benchmark Leader will check the
implementation and effectiveness of the execution of the
Integrity Programme of the Scheme Owner. The check will
include:
• An investigation on the findings of the random record
review (when relevant)
• All elements of Part 2
• Use of the GFSI logo
• The implementation of the corrective actions plan from
previous audit (when relevant)
The findings of this office audit will be reported and Scheme
Owner will have to respond with a corrective action plan.
Timelines on when the corrective action plan needs to be
received will be agreed with the Scheme Owner, and will
depend on the type of finding.
2.2.8.1.3 Complaint Investigation
In the event of a serious complaint towards a GFSI-
recognized Scheme, the GFSI Technical Manager has
the right to investigate the complaint. This can be done
by a desktop investigation or an office visit. The GFSI
Technical Manager is responsible for the investigation of
any complaints or suspected non-conformity in relation
to the compliance of a GFSI-recognised Scheme with the
requirements specified within the GFSI Benchmarking
Requirements.
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In the event that a complaint or report is received by the
GFSI Technical Manager regarding the non-conformity
of a Scheme with the GFSI Benchmarking Requirements,
the Technical Manager will promptly acknowledge, in
writing, the receipt of the complaint or report to the party
concerned.
When a complaint is received, the GFSI Technical Manager
will initiate investigative procedures to verify the accuracy
of the complaint.
The Technical Manager shall ensure that the details of the
complaint are clearly understood and documented, and
that any claims or comments made by the complainant are
properly authenticated and appropriately documented.
This authentication shall be verified as being accurate
and correct by independent sources, in addition to the
complainant. It is the responsibility of the complainant to
provide information that can be appropriately authenticated.
It is at the discretion of the GFSI Technical Manager to
appoint the Benchmark Leader or an independent assessor
at any stage during the investigation process. The GFSI
Technical Manager must ensure impartiality and preserve
confidentiality.
If the Benchmark Leader or an assessor is appointed,
he or she shall carry out a thorough investigation of the
complaint and, where possible, provide a resolution for the
issues, fully document the complaint process, and provide
a detailed report to the GFSI Executive Director.
2.2.9 Sanctioning
Activities of the GFSI Integrity Programme may lead to
sanctions for the Scheme Owner. In the event that evidence
of nonconformity against the requirements specified in the
GFSI Benchmarking Requirements is found by a Benchmark
Leader during the annual assessment, the GFSI Executive
Director shall promptly contact the Scheme Owner
concerned.
The GFSI Technical Manager shall fully document the
process of investigation and decision-making. The GFSI
Technical Manager shall make a decision after the review
of the submitted evidence and will either:
1. take no action against the Scheme Owner,
or
2. convene a meeting of GFSI Board members to gain
agreement on one of three possible outcomes -
continued recognition, suspension of recognition, or the
withdrawal of recognition.
Irrespective of the decision taken by the GFSI Executive
Director, the Scheme Owner and the GFSI Board members
shall be informed in writing of the decision, and this will
include a full explanation for the actions taken.
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GFSI SUSPENSION OF RECOGNITION PROCEDURE
If, following the review of the evidence gathered and
submitted by the GFSI Technical Manager and consultation
with the Scheme Owner, the GFSI Board considers that a
period of suspension of recognition shall be imposed, the
Scheme Owner shall be informed of this decision, and
any remediation conditions imposed by the GFSI Board
to regain recognition status. The period of suspension of
recognition and expected outcomes shall be made known
to the Scheme Owner.
The Scheme Owner shall confirm to the GFSI Board that
these remediation conditions can be achieved within the
timescales set out by the GFSI Board, when evidence of
the results of the corrective action can be expected, and
continued conformity to the requirements of the GFSI
Benchmarking Requirements can be established.
If the GFSI Board is not satisfied with the commitment
of the Scheme under suspension to take the appropriate
corrective action, they shall withdraw recognition.
In the event that a period of suspension is imposed, the
GFSI website shall clearly specify the details and conditions
of the suspension.
2.2.9.1 GFSI Withdrawal of Recognition
Procedure
If, following the review of the evidence gathered and
submitted by the GFSI Executive Director and consultation
with the Scheme Owner, the GFSI Board considers that a
withdrawal of recognition is required, the Scheme Owner
shall be informed of this decision.
In the event that GFSI recognition is withdrawn, GFSI shall
issue a news release and the GFSI website shall clearly
specify the details and conditions of the withdrawal.
A Scheme Owner may choose to voluntarily withdraw
from GFSI recognition when unforeseen circumstances
put the Scheme into contravention of GFSI requirements.
In this instance, the Scheme Owner will make a request to
withdraw voluntarily, and a full dossier of the circumstances
at the disposal of the GFSI Executive Director.
The GFSI Executive Director will inform the GFSI Board
regarding the circumstances and convene a meeting to
discuss the issue as soon as possible. It is at the discretion
of the GFSI Board to grant voluntary withdrawal or to
launch the suspension process.
2.2.10 GFSI Appeals Procedure - GFSI
Recognition
The Scheme Owner has the right to appeal against any
decision made by the GFSI Board, the GFSI Executive
Director or any person contracted to the GFSI in relation
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to the benchmarking process, associated systems and

procedures. Only the Scheme Owner to which the decision
relates to has the right to appeal to the GFSI Board.
The Scheme Owner shall submit an appeal to the GFSI
Executive Director within 30 days of the matter in dispute
occurring. The appeal shall be submitted in writing to
the GFSI Executive Director, and shall clearly describe
the reason and provide a full explanation together with
substantive evidence to support the thorough investigation
of the appeal.
When the appeal procedure is initiated, the status of the
Scheme shall be amended on the GFSI website to reflect
that the Scheme is subject to an appeal.
Any appeal shall be heard by a Committee (the Appeals
Committee), which is a body specifically assembled by
the GFSI Board for the purposes of hearing an individual
appeal. The GFSI Board shall ensure that such an Appeals
Committee should not include any person or GFSI staff
member involved with the decision that is being appealed.
The Appeals Committee shall be assembled from members
of the GFSI Board and shall consist of a minimum of three
members of the Board. The GFSI shall ensure that the
investigation is conducted in an impartial and professional
manner, and without any actual or perceived conflict of
interest.
The final outcome of the investigation by the Appeals
Committee shall be heard by the GFSI Board, and the
decision made by the Appeals Committee shall be upheld
by the GFSI Board.
The decision submitted to the GFSI Board by the Appeals
Committee shall be conveyed to the Scheme Owner
that has raised the appeal. The decision of the Appeals
Committee shall be final and the appeal process will then
be closed.

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