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)



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. 


Risk Assessment 

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. 


Risk Tolerance 

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. 


Risk 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. 


Technical Director

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).


Table 1


Audit type




Initial Audit


Desk Audit (Stage 1 Audit) then

On Site Audit (Stage 2 Audit)


2 Auditors: 1 HIAE, 1 Technical Auditor

Review Documents, Application forms, Ingredients, Process etc

Check and Verify the details in the application and supporting documents conform to Food Safety, GMP and Halal Standards.

Audit time Calculation must be carried out using formula from Annex B UAE 2055-2: 2014


Re-certification Audit

On site Audit

Review Documents, Previous Audit forms, Ingredients, Process etc. Ensure Corrective Actions completed

, Ingredients, Process etc

Check and Verify the details in the application and supporting documents conform to conform to Food Safety, GMP and Halal Standards.


Re-certification Audit

On Site Audit

Review Documents, Previous Audit forms, Ingredients, Process etc. Ensure Corrective Actions completed

Check and Verify the details in the application and supporting documents conform to conform to Food Safety, GMP and Halal Standards.


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


Sample Risk











Production Plant type


















Meat Processing












Consumer Food Production






Dry Mixing and Blending Plants






Wet Mixing and Blending Plants






Packing Plants/Co Packers












Fermentation Plant






Nutraceutical Plant






Juice Manufacturer






Beverage Company







There is a second Classification System based on Process types/sectors:

Category codes and risk


Examples of sectors


Farming 1 (Animals)

animals; fish; egg production; milk production; beekeeping; fishing; hunting; trapping


Farming 2 (Plants)

fruits; vegetables; cereals; spices; horticultural products


Processing 1 (Perishable animal products)

including all activities after farming, e.g. slaughtering meat, poultry, eggs, dairy and fish products


Processing 2
(Perishable vegetable products)

fresh fruits and fresh juices; preserved fruits; fresh vegetables; preserved vegetables


Processing 3

(Products with long shelf life at ambient temperature)

canned products; biscuits; snacks; oil; drinking water; beverages; pasta; flour; sugar; salt


Feed production

animal feed; fish feed


(Bio)chemical manufacturing

additives; dietary supplements; cleaning agents; processing aids, bio-cultures and microorganisms


Packaging material manufacturing

packaging material


Other materials manufacturing

cosmetics, textile, leather products etc.


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.


H7 Reserved

H8 Reserved


H9 These products are from Haram sources and are not Halal certifiable

Pork and porcine by-products

Blood products

Alcoholic drink

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



HAS Control



Cross Contamination on site/line

Medium to low

Annual Audit

Questionnaire and Contract

Halal Training given as part of Audit.


High- plant can be delisted.

Loss in consumer Confidence

Audit report review

Annual Audit-visual inspection

Audit Not Carried out

Medium to Low

HAS periodically reviews all Production sites and has a risk rating.

High risk plants

High- Dry blending plants and plants in Multinationals producing

Database has flags

Auditor Competence


Rotation of Auditors, Training, Technical Director carries out witness audits

Dual Audits

Islamic Scholar as second auditor.

HAS have specialist auditors- veterinary Surgeon, Medicinal Chemist with industrial experience.

Can be high. Some larger production plants and flavours plants which do dry blending/wet blending, the sheer number of lines and scale mean that one auditor is not enough as it affects confidence in the audit.

HAS have a list of Plants where only the most experienced auditors will audit.

Change of Management of site


Due to the sheer number of M&A’s

Site management changes and changes in production/products have happened in the past. New QA staff are unaware of the Halal Guidelines

Very high. Some larger production plants and flavours plants which do dry blending/wet blending have changed hands several times in a few years

Annual audit, regular contact and Regular training

Multinational site -processes are moved from other sites


All Multinational companies regularly look at optimising manufacturing and consolidating lines

HAS ensure Corporate management have halal policy and are trained.

Regular audits

Impact is V. Low

Multinationals have excellent controls and are mostly kosher certified as well so it has a mitigating factor

Regular contact

Annual audits

National Guidelines Change and Conflict with halal guidelines


Stunning in abattoirs

Impact is very high

UAE Guidelines, Pakistan Guidelines don’t accept Stunning.

Regular updates to Abattoir’s

Attending training in Muslim/Islamic Countries

Food Safety, Cosmetics, guidelines changes


HAS need to Keep Staff trained and educated on the standards.

This involves culture change

Impact is high

Auditors cannot do effective audit without the relevant knowledge

Regular Auditor meetings and assessment

Loss of Recognition/



HAS must ensure compliance. Adequate resources and training are necessary


Loss of business and loss of consumer/client confidence

BOD regular management meetings and internal audits

Regular Plant Audits with Audit reports witnessed by plant QA staff.

Non-Acceptance of HAS halal Certificates by other halal agencies


This is predominantly a political issue

Increasing accreditation and awareness, this should resolve with time.

HAS make every effort to communicate with other agencies.

High- it affects trade for client companies

Feedback from clients.

Feedback from Regulators and Accreditation agencies







Halal doo

(Halal Agency Serbia)

Gospodar Jevremova 11

11000 Belgrade

Republic of Serbia

Phone:+381 11 3035 285

Phone/Fax: +381 11 2622 428

E-mail: info@halal.rs

Website: www.halal.rs

Dear Producer,

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According to The Economist, the global Islamic market was worth over $3.6 trillion in 2013, and the market is projected to be worth over $5 trillion by 2020.