Prohibited to you are dead animals, blood, the flesh of swine, and that which has been
dedicated to other than Allah, and [those animals] killed by strangling or by a violent
blow or by a head-long fall or by the goring of horns, and those from which a wild animal
has eaten, except what you [are able to] slaughter [before its death], and those which are sacrificed on stone altars, … (Al-ma’idah 5, 3)
THE ISLAMIC COMMUNITY OF SERBIA
HALAL AGENCY SERBIA
HAS Policy and Guidance Notes on Auditing and Risk Management 2019
Doc. No.: HAS-023
The Halal Agency Serbia (HAS) defines risk as the threat that internal or external events will adversely affect its ability to achieve its strategy, policy and operational goals.
It recognizes that risk is something that cannot be wholly contained but aims to manage the exposure to those risks to a satisfactory level.
It is the intention that effective, proactive risk management supporting structured well managed risk taking is integrated into the culture of HAS.
HAS will identify and manage risks that endanger the achievement of the strategic aims defined in its Business Plan or the operational aims defined in HAS plans.
The approach adopted will meet the requirements of ISO/IEC 17065
HAS’s internal control framework incorporates its risk management approach. Management of risk will be embedded at all levels of the organization, supported by an active training and education program.
Risks will be assessed against estimation criteria approved by the HAS Board. These criteria cover the potential impact of the risk and the likelihood of its occurrence. The risk will be considered for its effect on strategy, operations, finances or reputation and whether they are external or internal.
The senior manager responsible for the work carrying a risk will, at the start of a year for operational services or at the start of a program or project, assess the risks that that work may be subject to.
They will use the estimation criteria noted above. They will also be responsible for identifying the acceptable tolerance level for the risks involved and confirming them with the HAS staff.
As risks are managed this tolerance level will be used as the prompt for the escalation of risk reporting to senior management.
Risks will be managed in accordance with an agreed approach ranging from terminating the risk, through possible reduction measures, acceptance and monitoring or passing the risk on. Review of the risks will be carried out by the manager assigned responsibility for it.
Risks will be reviewed:
· Annually by the Board of Directors as part of the planning cycle;
· Quarterly by the Exec Team as part of the business plan monitoring process;
· At each of its meetings by the Impartiality Committee;
· Monthly by the Exec Team on an exception basis;
· Monthly by HAS Staff for their own subset of risks;
A Local risk register will be developed as needed based on these policy principles.
Roles and responsibilities
Each level of HAS has a responsibility for risk awareness and management. The main roles and responsibilities are as follows:
The Board is responsible for confirming that the risk management approach will aid the achievement of policy aims.
The Technical Director is responsible for ensuring that the risk management framework is adequate and that processes are in place to ensure that it is working effectively.
Staff at all levels are responsible for ensuring that risks to their activities are identified, recorded, assessed and managed on an agreed basis. Internal Audits act as an independent review of HAS’s overall internal control framework, including risk management, and reports their findings to the Accountant and BOD.
Risk Strategy for Certification and Auditing
Halal Certification of Food Products is inherently risky due to the types of foods, ingredients; processing methods and so a policy to define what the risks are and how HAS will identify and manage the risk is necessary.
HAS will carry out Annual Audits (1 yearly) as a minimum. For higher risk plants and products, HAS will evaluate the risk and will carry out extra or additional audits, which must be paid for by the clients. The additional audits are necessary to ensure product compliance (ISO/EC 17021) to halal Guidelines as defined in the international Halal standards and related national Fatwa’s.
For the issuance of Batch Certificates, HAS auditor will either supervise production OR HAS will require additional information before the Batch certificate is issued.
The Certification Cycle will be for 3 years with year 1 being the initial Audit (with Desk audit carried out before on site audit)-this is an on-site audit (See table 1).
HAS have an internal Risk Map and H1-H9 Coding system for identifying Haram ingredients and manufacturing plants in order to help the auditors and ingredient reviewers to identify and mitigate risk during the Audit and Certification Process.
For Food Production Plant Halal Certification and Auditing: Risk Map
There is a second Classification System based on Process types/sectors:
There is another risk system H1-H9 which is used for ingredients classification.
H1 Halal status’H1’does not require Halal certificate or Questionnaire. This category includes:
Pure botanicals Plant materials
Pure minerals ingredients Pure synthetics ingredients
Heat processed dairy ingredients
H2 Halal status ‘H2’requires Halal Questionnaire and/or Halal certificate based on the information provided by the company. H2 ingredient may be moved to another category. This category includes
Single seafood Fish ingredients Enzymes
Ingredients processed with enzymes Smoke flavoring
Cheese and by products Fatty chemicals
Amino acids Mixtures Flavorings
H3 category includes all items that require a Halal certificate as determined by the information provided by the company or available from other sources
H4 Halal certificate by HAS or another acceptable Islamic organization
H5 This category requires Batch Halal certificate from HAS or an organization which follows Halal standard similar to that of HAS’s
Meat and meat ingredients Gelatin
Poultry products Beef products Beef Extract Beef tallow Chicken skin Chicken fat
H6 ‘H6’ includes ingredients that contain ethanol. No halal certificate is issued for this category. These may use in the Halal products but alcohol must be reduced to less than 0.1% in the final products.
H9 These products are from Haram sources and are not Halal certifiable
Pork and porcine by-products
Ingredients from Haram animals
The three classification systems used by HAS for Ingredients, Manufacturing Plant and Process Type have been developed using a risk-based approach. The risk has been defined by the following criteria:
Risk of Cross Contamination: Mixed lines, Segregation of RM and Products, Inadequate cleaning and sanitation etc.
· Risk of Haram Ingredients: source of ingredients, method of production, Halal certified ingredients by reputable HCB’s
· Risk of Inadequate and Ineffective Auditing due to lack of experience or wrong experience.
· Risk of Certified Clients not complying
To understand some of the HAS company and Auditing Risks, Roles and Responsibilities and How to mitigate against these risks, HAS have developed a Risk Register to define responsibilities and SOP’s to help identify and manage these risks.
HAS Company Risk Register
(Halal Agency Serbia)
Gospodar Jevremova 11
Republic of Serbia
Phone:+381 11 3035 285
Phone/Fax: +381 11 2622 428
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