What is your food fraud culture?

Following our Listeria crisis in South Africa, ‘food-safety culture’ has become the buzzword. There have been several symposiums and workshops centring on how to develop and realise a culture of food safety in our food-manufacturing environments. The challenge now for each of us in South Africa is to adopt the concept of food-safety culture as the DNA of our companies, and practise these learnings in all areas of manufacturing.

Updates to ISO 22000 are coming into effect this year, along with a new FSSC 22000 V.5, and food-fraud mitigation is at the forefront of the most important changes to these standards. With this in mind, we need to consider extending our attention from food-safety culture to include a focus on mitigating fraudulent practices.

Creating a working manufacturing culture that is focused on integrity and trust starts with leadership.

The age-old Top-Down method is most applicable when it comes to considering the culture of the company. The leaders of your company (directors/CEOs to middle managers) directly influence the culture of the company, as they can increase the risk of fraudulent behaviour by exhibiting any of the following:

• Condoning of unethical approaches, e.g. changing documentation, relabelling old stock
• Encouraging team members to cut corners, e.g. not passing all products through a CCP
• Bending the rules to meet targets that may be unrealistic, e.g. accepting stock that is not of the usual or acceptable quality, or is from a dodgy supplier
• Not realising the duress that employees are put under through absent leadership or too many unrealistic demands

When one leader exhibits just one of these points, the knock-on effect can be seen in each person they manage, because they will do the same – resulting in a cycle which becomes difficult to change.

Changing a company that exhibits a poor culture starts with the leaders gaining self-awareness, which needs to be coupled with empathy for their employees and the consumers.

A company that realises that every task is a team effort and treats every failure or mistake as a learning experience, coupled with strong values and ethics, is one with a sound culture, and one which will not be (or at least, be less at risk of being) subject to fraudulent practices, both in-house and from suppliers. Integrity seeks out integrity.

Food brands flourish when their leadership is strong and effective, using their employees’ strengths as a team while sharing information in an open and safe space.

Building the VACCP team

All too often, the technical or quality department, headed up by a food scientist or technologist, is left with the responsibility of risk assessments and management of the food-safety and quality-management systems. This would include assessing the vulnerability of the raw material and the supplier base to food fraud, through a Vulnerability Assessment Critical Control Point (VACCP) analysis.

It is often a challenge to collect the correct and accurate information required for the assessments from the production, procurement and product development teams, resulting in frustration. Effective leaders realise that it should not be up to just one person – or even one department of the whole manufacturing facility – to handle this responsibility alone; and so it is important to build an appropriate VACCP team.

The team should include representatives from the various departments in a facility; for example:

1. A procurer/buyer with knowledge of prices and suppliers.
2. A product developer with knowledge of ingredients and suppliers.
3. A production manager with knowledge of the amounts of raw materials used in various products.
4. A quality or technical person with knowledge of testing, history of incidents and quality of raw materials received from the supplier.
5. To top it off, someone from top management to be knowledgeable about challenges faced in terms of fraudulent activity in the business.

The VACCP team should meet at least once a month to catch up on any changes in raw material supply, suppliers’ certification status, etc., as well as to adjust the risk assessment created.

The VACCP team should also be trained adequately and equipped with the tools needed to assess vulnerabilities related to the food products that are manufactured, and the associated risks.

The aim of building these teams, of course, is not only to ‘tick the boxes’ in terms of audit criteria, but also to ensure that integrity flows through the company, to create a positive, anti-fraud company culture with direct influence on the company brand and how consumers see the company and the products it creates.

Working towards a culture of integrity

Determining the vulnerability of your raw materials, supply network and brand to fraudulent activity can be challenging; so FACTS has developed a Food-Fraud Mitigation Programme, which offers several services – tailored to your needs – to assist you with all food-fraud-related challenges.

FACTS endeavours to create customised solutions for our clients, to strive for integrity across the food industry in South Africa.