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Message Issue 4 Reviewed 05/25 Issued TS TVM1 1 : TREVORS WAREHOUSES LTD (T/A Trevors Foodservice) ============================= TACCP & VACCP MANUAL ============================= Contents 1. Introduction……………………………………………………………………………2 2. Company Profile………………………………………………………………………3 3. An Introduction to TACCP and VACCP…………………………………………..4 4. TACCP & VACCP Team……………………………………………………………..6 5. Quality Policy and Objectives……………………………………………………..8 6. Identification of Threat……………………………………………………………...9 7. Flow Chart TACCP & VACCP Plan…..............………………………………….10 8. TACCP Decision Tree……………………………………………………...………11 9. VACCP Decision Tree…….……………………………………………………......13 10. Verification, Validation and Review Procedure………………………………..16

Issue 4 Reviewed 05/25 Issued TS TVM1 2 1. Introduction The Company Quality Manual documents an overview of the Companies Systems that includes the prerequisite requirements upon which the Quality Management Systems, HACCP, TACCP and VACCP are based. Specific requirements for the control of hazards that are of a “generic” nature or a site wide nature are documented in the Quality and Food Safety Manual and the pre requisites of the HACCP Manual. This includes pest control, cleaning regimes, glass and hard plastic controls, waste etc. Controls for personnel and visitors are also documented in the Management System. The TACCP Assessment was original undertaken during July 2020. It is laid out in a format that meets the requirements of the business’s Receipt, Storage and Distribution of Good’s. It is designed to aid the management team at Trevors Warehouses Ltd to mitigate risk to their products from deliberate attack. The TACCP assessment was reviewed in May 2021 when the VACCP assessment was undertaken and incorporated into this manual. The scope includes the intake, storage and delivery of products to customers. The manual will be reviewed annually and any findings will be recorded. It will be assessed against any new threat during the intervening period. For ease, the manual has been colour co-ordinated with Green representing any TACCP related elements and Blue Italics representing the VACCP. General information covering both element has been kept in black. TACCP Scope The TACCP Team have identified the Scope of this study as being: The Receipt, Storage and distribution of all range of goods without any processing. The receipt and processing of orders from customers. From the intake of product to the arrival of the product at the customer’s facilities, taking into account all possible threats which could occur during this process, including those posed towards the IT systems used. VACCP Scope The VACCP team have identified the scope of this study as being: The Receipt, Storage ad distribution of goods without any processing. From the intake of product to the arrival of the product at the customers facilities, taking into account all possible motivations, opportunities that could lead to the vulnerability of food products.

Issue 4 Reviewed 05/25 Issued TS TVM1 3 2. Company Profile Trevors Warehouse Ltd is a family owned and run business and has been trading since 1962, operating initially as a supermarket brand. In 1988 the business diversified into wholesale distribution and started trading as Trevors Foodservice. Trevors Foodservice is a member of the Country Range Group of Companies. Trevors Foodservice accepts responsibility for the complete satisfaction of its customers and we take our legal compliance and best practice seriously. We exercise responsibility through adequate training of employees, adherence to proven procedures and commitment to meeting and exceeding the customer’s expectations. We have developed and implemented a TACCP and VACCP System to demonstrate our ability to identify, minimise and manage threats to our business, thus ensuring we consistently provide a service that meets statutory and regulatory requirements, and to address customer satisfaction through the effective application of the system. Intended use and consumers of products provided. Produce is received into the facility in pre-packed at source or in loose format. They are all suitable for all consumer groups. Products are distributed as pre-packed/labelled at source of origin. Goods are distributed to different sectors of the Catering Trade as follows: • Hotels and Guest Houses • Restaurants, Pubs and Cafes • Care and Nursing Homes • Offices • NHS and private Hospitals • Education – private and public • Foodservice It is expected that the food products will be used to prepare meals or snacks to be consumed by the general public. It is expected that cleaning and janitorial products will be used for health and hygiene purposes within the customer’s establishment.

Issue 4 Reviewed 05/25 Issued TS TVM1 4 3. An Introduction to TACCP & VACCP TACCP TACCP (Threat Analysis and Critical Control Points) is an official set of process guidelines which covers a systematic methodology for the avoidance and control of threats to all stages of the food production chain. It aims to protect food products from deliberate contamination with the intention to cause harm (behaviorally or ideologically motivated). TACCP builds upon existing processes of HACCP in ensuring the safety of food products TACCP complements existing business risk management and incident management processes. Examples of food threats under TACCP include malicious contamination, economically motivated adulteration, extortion, espionage, counterfeiting and cybercrime. The TACCP system has two major components: 1) The Threat Assessment of TACCP represents the logic in the Threat analysis which identifies the where and how threats to the food may occur. 2) The Critical Control Points of TACCP represents the critical control points that provide the control of the process and the proof of the control. The benefits of the TACCP system are as follows: • Helps food producers identify weak points in their supply chain and processing activities that may be vulnerable to fraud. • It helps the business minimise the chances of an attack. • Maintains vigilance • A Preventative System • A Systematic Approach • Helps demonstrate ‘Due Diligence’ • Internationally accepted • Strengthens Quality Management Systems • Facilitates regulatory inspection/external audits • Demonstrates Management commitment. VACCP VACCP (Vulnerability Analysis and Critical Control Points) is an official set of process guidelines which covers a systematic methodology for the avoidance and control of fraud vulnerabilities to the supply stages of the food production chain. It aims to defend a food supply chain from any form of dishonest conduct that impacts detrimentally on the quality or authenticity of food and drink. VACCP builds upon existing processes of HACCP & TACCP in ensuring the safety of food products VACCP complements existing business risk management and incident management processes. Examples of food vulnerabilities under VACCP include dilution of foods, mislabeling, substitution, or Counterfeiting of foods or their ingredients. The VACCP system has two major components: 1) The Vulnerability Assessment of VACCP represents the logic in the Vulnerability analysis which identifies the where and how food fraud may occur. 2) The Critical Control Points of VACCP represents the critical control points that provide the control of the process and the proof of the control.

Issue 4 Reviewed 05/25 Issued TS TVM1 5 The benefits of the VACCP system are as follows: • Helps food producers identify weak points in their supply chain that may be vulnerable to fraud. • It helps the business minimise the chances of an attack. • Maintains vigilance • A Preventative System • A Systematic Approach • Helps demonstrate ‘Due Diligence’ • Internationally accepted • Strengthens Quality Management Systems • Facilitates regulatory inspection/external audits • Demonstrates Management commitment.

Issue 4 Reviewed 05/25 Issued TS TVM1 6 4. TACCP & VACCP Team The TACCP team have determined to address the potential threats to the business through the process of Intake, Handling, Storage and Distribution of product from intake to delivery of the product to the customers’ facilities. Including the handling of all customer data. The TACCP study takes into consideration that the company operates prerequisite programmes, alongside the Procedures Manual and HACCP documentation, which includes: • Good Manufacturing Practice • Preventative Maintenance • Personnel and Training • Process Control • Calibration • Storage and Transportation • Traceability and Product Recall During the formulation of the TACCP study, the team will review the various codes of practice and food regulations and will take the following food safety legislation and Codes of Practice into consideration throughout the study; • PAS 96: 2017 Guide to protecting and defending food and drink from deliberate attack • Guidance Documents The VACCP team have determined to address the potential threats to the business through the process of Intake, Storage and Distribution of products. The VACCP study takes into consideration that the company operates prerequisite programmes, alongside the Procedures Manual, HACCP & TACCP documentation, which includes: • Good Manufacturing Practice • Preventative Maintenance • Personnel and Training • Process Control • Calibration • Storage and Transportation • Traceability and Product Recall During the formulation of the VACCP study, the team will review the various codes of practice and food regulations and will consider any past food fraud incidents to determine any potential vulnerabilities to the business operations.

Issue 4 Reviewed 05/25 Issued TS TVM1 7 The TACCP and VACCP Team consists of: Tracy Simmons – Business Support Manager (Team Leader - Level 3 HACCP, Level 3 Food Safety, Level 3 Effective Auditing and Inspection) Staff uniforms and special clothing Document control – creating, amending and distribution HR/Personnel matters to include staff Induction HR / Personnel Management Control and Maintenance of Quality Assurance System Food Safety – support, review of systems Accreditations and specifications maintenance H&S - Support, Record Keeping, Policies, Company checks – TS/SF/AW Internal Cleaning Inspections Management Meetings – Issue of agenda, minute taking and distribution and checking of follow up action Neil Martin – External Food Safety Consultant (Deputy Team Leader BSc (Hons), EnvDip NEBOSH, CSTR, CEnvHMCIEH, MIOA, MIES, MIAQM, a qualified environmental health practitioner.) Matthew Hitchen – Purchasing Director (Level 2 HACCP) Purchasing – stock items Sean Finnegan – Warehouse Manager (Level 2 HACCP) Operations Management – Warehousing and distribution activities Environmental/Waste Management Building Inspection Health and Safety Jason Whitehead – IT Manager IT Systems Contract Pricing

Issue 4 Reviewed 05/25 Issued TS TVM1 8 5. Quality Policy and Objectives The quality policy of Trevors Warehouse Ltd is designed to achieve sustained, profitable growth by providing goods and services, which consistently satisfy the needs and expectations of its customers. The level of quality is achieved through the adoption of a system of procedures that reflect the competence of the Company to its customers, both existing and potential, and to independent auditing authorities. All of our systems, policies and processes are inter-related. Achievement of this policy involves all members of staff, who are each responsible for the quality of their work. This policy is provided and explained to each employee. Top Management will ensure that Quality Objectives, including those needed to meet requirements for product and service, are established at relevant levels within the organisation. The quality objectives shall be measurable and consistent with the quality policy. The overall objectives of this Quality Assurance System are: - a) To maintain an effective system compliant with the HACCP Principles, TACCP, VACCP and all other statutory legislation. b) To achieve and maintain a level of quality which enhances the Company's reputation with its customers c) To ensure compliance with the relevant statutory and safety requirements. d) To identify and control possible threats to the Company’s operations This manual forms part of the Quality Assurance Manual together with the company’s Pre-requisite Programme, HACCP Manual, and Procedures Manual.

Issue 4 Reviewed 05/25 Issued TS TVM1 9 6. Identification of Threats Please refer to Threat Risk Assessment Risk Assessment Process Used to determine critical Controls A threat assessment has been carried out using the diagram below. Critical controls are applied when the threat assessment is high or extreme in the in the risk matrix below. Minor Significant MajorUnlikely 1 2 3Possible 2 4 6Likely 3 6 9SeverityLikelihoodRisk = Severity x LikelihoodRisk Assessment Matrix Assessment of threats and vulnerabilities TACCP The following threats have been assessed and are considered to be minimal owing to the nature of the business and therefore do not form part of the Threat Assessment • Extortion o The business does not have a widely recognised brand or stakeholders that are well known. • Espionage o The business does not have any intellectual property of any public significance. • Counterfeiting o The products do not have high enough value to be counterfeited. • Cyber Crime o Controls in data systems and security are deemed to be effective. This will be reviewed in light of any new evidence. • Professional Crime o The business does not have a widely recognised product, the products are also low in value • Malicious Mail and Packages o Controls in courier systems and the postal serve are deemed to be effective. This will be reviewed in light of any new evidence.

Issue 4 Updated 02/25 Issued TS TVM1 10 7. Flow Chart TACCP & VACCP Plan PURCHASE OF APPROPRIATE PRODUCE DELIVERY CHILLED, AMBIENT, FROZEN AND NON FOODS UNLOADING STORAGE: CHILLED, AMBIENT, FROZEN & NON FOODS And non-foods ORDER ASSEMBLY LOADING DISTRIBUTION: CHILLED, AMBIENT FROZEN & NON FOODS Returns Non Frozen ONLY (unless a quality issue) Return storage: Chilled, Ambient & Non Foods Items labelled as ‘R’ by driver identified by Management upon return to depot to instruct action to be taken Non storage - Returns Bay / Disposal Customer order taken and data inputted to computer. Invoice and pick slip created and sent to warehouse.

Issue 3 Reviewed 05/24 Issued TS TVM1 11 8. TACCP Decision Tree

Issue 4 Updated 02/25 Issued TS TVM1 12 9 a) TACCP Decision Tree

Issue 3 Reviewed 05/24 Issued TS TVM1 13 9. VACCP Decision Tree Form VACCP Team List all ‘raw materials/ products’1 Risk Evaluation: Ranking of Suppliers and Raw Materials / Products Identify and assess potential for fraud to occur2 Identify all Control Measures in Place Identify additional control measures required Evaluate risk again, following implementation of additional control measures Document all Significant Risks and control measures Identify records and checks to ensure control measures are maintained. Identify Key staff Identify critical products / processes Review and Revise

Issue 4 Updated 02/25 Issued TS TVM1 14 1. Inc suppliers, accreditation, country of origin, pricing trends and testing & sampling regimes, 2. Consider evidence of past issues of fraud, price fluctuations, supply change, accreditation, Opportunities, and Motivations to commit fraud.

Issue 3 Reviewed 05/24 Issued TS TVM1 15 9b) VACCP Decision Tree

Issue 4 Updated 02/25 Issued TS TVM1 16 10. TACCP & VACCP Verification, Validation and Review Procedure The TACCP & VACCP Team have verbally verified the process flow diagram and all the processes to ensure accuracy. Continuous assessment of the TACCP & VACCP system are conducted at the Management Meetings. Full reviews will be conducted once per annum on the complete TACCP & VACCP system and also when new or amended processes, or equipment are to be introduced or threats identified. This includes any work to be carried out by contractors. Validation of all control measures will be conducted by competent qualified staff and will be conducted during the Quality Assurance Auditing Programme as detailed in the Procedures Manual. In the event that any of the above verification procedures show that the TACCP & VACCP plan requires review, a meeting of the TACCP & VACCP team will take place in order to agree corrective actions. All team members and Department managers will ensure all staff within their area/department are trained in all control measures and CCP monitoring and adhere to the above guidelines.