Quality and safety policy

1. OBJECTIVE
Establish the global intentions and the general orientation of the organization related to its quality and safety performance

2. REACH
This policy is directed to all the operations – affiliates and subsidiaries – where the group operates, as well as new operations or any business expansion, covering all areas of manufacturing and distribution centers. This policy is established according to certification programs that meet the requirements approved by GFSI (Global Food Safety Initiative) which are recognized worldwide.

3. DEFINITIONS
a. Food: A substance (ingredient), could be processed, semi-processed or raw, intended for consumption, and includes beverages, chewing gum and any substance that has been used in the manufacture, preparation or treatment of “food”, but does not include cosmetics or tobacco or substances (ingredients) used solely as drugs.
b. Quality: is the point where a set of inherent characteristics meet certain requirements.
c. Coding: alphanumeric symbology used to identify the exact place and time of the product’s production.
d. HACCP: Hazard Analysis and Critical Control Points. According to the Codex Alimentarius, General Principles of Food Hygiene CAC/RCP 1-1969, the HACCP system makes it possible to identify, evaluate and control significant food safety hazards.
e. Food safety: Food safety as a concept implies that food will not cause harm to the consumer when prepared and/or consumed in accordance with its intended use.
f. Prerequisite program: Are the basic conditions and activities necessary to maintain, along the entire food chain, an appropiate hygienic environment for the production, handling and provision of safe finished products and safe food for human consumption.
g. Safety Management System: Effective management system that allows the organization to control safety-related hazards and that combines interactive communication, system management, prerequisite programs and HACCP principles, interrelates policy and objectives, and ensures the continuous improvement of processes.
h. Traceability: When considering a product, traceability can be related to the origin of materials, the history of processing, distribution and location of the product after delivery.

4. NORMS
4.1 Quality and Safety Policy As a Corporate Group dedicated directly or indirectly to the manufacture of food and beverages, we are committed to ensuring the quality and safety of our products through competent personnel, the continuous improvement of our safety management system, complying with legal, customer and other applicable requirements and maintaining effective communication with all stakeholders to achieve our objectives.
4.2 Manufacturing-specific safety policies
4.2.1 Glass, Brittle Plastic and Ceramic Control Policy
4.2.1.1 The safety of manufactured products must be guaranteed and the absence of elements or pieces of glass, brittle plastic and ceramics must be ensured during the production and transfer of the finished product, through an adequate handling and inventory of said elements, following a contingency plan to avoid contamination of the product in the event of unintentional glass breakage, brittle plastic or ceramic.
4.2.1.2 The use of glass, brittle plastic or ceramics within production plant facilities is restricted. The above materials may not be used in areas that could be risky for the safety of the products, except where necessary or when it is not feasible to remove them immediately.
4.2.1.3 Glass, brittle plastic or ceramics will not be introduced with personal belongings.
4.2.1.4 All plant and distribution center personnel must comply with the responsibilities set forth in the Glass, Brittle plastic and Ceramic Control Procedure.
4.2.2 Coding Policy on Finished Product
4.2.2.1 The traceability of manufactured products must be guaranteed and ensure that production complies with:
a) Packaging that must be coded correctly and legibly.
b) Verify and validate in each production, the first and last individual packaging and every hour, with the following minimum information contained: batch, plant identification, year, day, line and time of production.
4.2.2.2 All personnel must comply with the provisions of the Procedure of Coding in Finished Product of each commercialization country´s organization and regulations of products and use the one that is more demanding.
4.2.2.3 It must be insured that correctly coded products are distributed to the market.
4.2.2.4 It is not allowed to operate the production line when coding problems have been detected.
4.2.2.5 It is not allowed to commercialize product without coding.
4.2.2.6 In the event of a coding problem, production must be stopped and resumed until the necessary reparations are made.
4.2.2.7 The final product packaging team should apply the codes required by each product and package particularly, according to the products commercialization and local regulations.
4.2.2.8 If products with coding problems in the market are detected, the Product Recall Procedure should be applied.
4.3 Rules for the areas involved in the supply chain In order to ensure the safety and quality of the products, all the personnel involved during the general manufacture process –such as Purchase department, Research + Development, Logistics, People and Management, Projects, among others– should comply with the procedures, manuals and documents set in the Quality Pillar and Supply processes.
4.4 Compliance of Ethics and Integrity All employees should perform their task with strict adherence to ethics and integrity, fulfilling all the Ethics code and Internal Policy guidelines that apply to their corresponding areas, as well as the Anti-corruption Policy and the Anti-bribery Management System.

5. ROLES AND RESPONSABILITIES
Facility Manager

• Promote the commitment and compliance of the policy, internal procedures, legal requirements, among other things, established for each operating country.
• Promote the fulfillment of policy through the proposition and implementation of reduce harmlessness and quality risks.
• Insure that point 4.1 of this policy is shown and visible in the facility accesses.

Manufacture Director

• Promote the commitment and compliance of policies, internal procedures, legal requirements, among other things, established by each operating country.

Facilities and distribution centers employees

• Know and fulfill the Safety and Quality Policy.
• Know and fulfill the Glass, Brittle Glass and Ceramics Control Procedure and the Final Product Codification Procedure.
• Fulfill all the procedures related to the current policy and the Quality Pillar of the Supply procedures.

People and Local Management Manager (facility, country)

• Ensure the Quality and Safety Policy is included as part of the Inycie in the organization and in the annual training plan that covers all employees from every facility and distribution center.
• Guarantee the outreach and awareness of the present policy.
• Ensure that the Final Product Codification Procedures and the Glass, Brittle Plastic and Ceramics Control Procedure are included in the employee annual training plan of every production facility and distribution center.

6. RISKS
The present policy is focused on managing the mentioned risks, but not limited to the following list:

a) Strategic Risk:

• Loss of the franchise commercial relations.

b) Financial Risk:

• Loss of money because of withdrawal or loss of product because of quality or harmlessness problems.

c) Compliance Risk:

• Low quality commercialized products.
• Commercialized products that may cause harm to the consumers.
• Fine and penalties because of legal non-compliance.

d) Operative Risk:
• Facility closure (temporary or permanent) because of legal non-compliance.
• Non-compliance of the established production procedures.
• Wrong response in the product recall risk (lack of tracking).

e) Reputational Risk:
• Negative exposure of the company’s image.
• Product recall

7. SANCTIONS
Every misconduct associated with hiding or tampering with information related to the quality and safety aspects of the processes or products, or that endanger consumers health, comes with a severe sanction.

The present policy aims to enforce the following sanctions, but is not limited to the following list, depending on the severity of the misconduct in accordance with each country´s regulation:

• Verbal warning.
• Written warning.
• Employment suspension without pay.
• Loss of employment.

If the ethics and integrity violations are proven, the measures described in the Ethics Code, the Internal Policies that apply to the corresponding area, as well as the Anticorruption Policy and the Antibribery Management System, the disciplinary actions will be applied depending on the gravity of the misconduct and in accordance with each country´s established legal procedures and regulations.

8. ANNEX – RELATED DOCUMENTS

9. APPROVAL AND AUTORIZATION LEVELS

10. POLICY MODIFICATIONS