INSTRUCTION FOR THE QUALITATIVE ASSESSMENT OF RAPESEED

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1 ZT " Kruszwica " S.A. ul. Niepodległości Kruszwica Version: Date of introduction: 1 / ZJ / Feb 2017 The document is binding with regard to the purchase of rapeseed by ZT "Kruszwica" S.A. and concerning the supplies delivered to the warehouses in Kruszwica and Brzeg, and to the warehouses of companies operating as commissioned by it. INSTRUCTION FOR THE QUALITATIVE ASSESSMENT OF RAPESEED TABLE OF CONTENTS: Purpose Sampling Primary sampling Preparation of a laboratory sample The size of a laboratory sample The way of packing and labeling samples Arbitration samples Additional sampling in accordance with the schedule of analyses in force in the Company Reduction of a laboratory sample to a test sample Preparation of a sample for tests Sensory evaluation The presence of live and dead storage pests The presence of residual fumigant (phosphine) Determination of impurities content Treatment of supplies containing mouldy, burnt and sprouting seeds and cleavers Determination of mouldy seeds and cleavers content Determination of burnt seeds content Determination of sprouting seeds content Determination of impurities content in accordance with PN-EN ISO 658 standard Standard scope Terms and definitions Principle of the method Small equipment and apparatus Sampling Carrying out a determination Separation of fine impurities Separation of oleaginous and non-oleaginous impurities Reporting results Determination of moisture content Determination of oil content Determination of erucic acid content Determination of BaP, 4 PAHs and pesticides content BaP and 4 PAHs content Pesticides content Determination of Genetically Modified Organisms (GMO) content Checking supplies of rapeseed for the presence of GMOs - an analysis using a qualitative test strip Checking supplies of rapeseed for the presence of GMOs - the PCR analysis Complaints Required quality documentation List of applicable standards and regulations List of basic laboratory equipment List of appendixes Concluding remarks... 10

2 Purpose The purpose of this Instruction is to describe how to conduct a qualitative assessment of rapeseed supplies delivered by Suppliers (Sellers/Contractors) under the contracts of sale or services contained by the Company. 1. Sampling. Activities related to sampling are performed by a person with the qualifications of an "Expert with which they were invested by the competent Inspectorate of Trade Quality of Agricultural-Food Products (WIJHAR-S). From each supply of rapeseed (vehicle, wagon) a sample is taken in accordance with the PN-EN ISO 542:1997 "Oilseeds. Sampling" standard, according to sections of the aforesaid standard. Only efficient instruments specified in the standard (see sections 4.2; 5.1; 5.2; of the aforesaid standard) are used for sampling. The following operations taking place while sampling are listed: 1.1. Primary sampling - samples from vehicles are taken from bulk batches using the Rakoraf automated probe in accordance with sections 5.1 and 5.2 of the aforesaid standard with guidelines provided in sections and of the standard. It is also possible to use other probes compatible with the standard. All samples are taken using the sealed envelope method at 5, 8 or 11 points depending on the tonnage. In the case of deliveries by rail, samples are taken from each wagon from the stream during the unloading, using a scoop for this purpose Preparation of a laboratory sample - primary samples (see section 3.3 of the aforesaid standard) taken from each batch of seeds are combined and thoroughly mixed, thus creating a general sample (see section 3.4 of the aforesaid standard). Thus prepared a general sample is divided using appropriate equipment (see section 5.3 of the aforesaid standard) in order to separate laboratory and arbitration samples (see section of the aforesaid standard) The size of a laboratory sample - for small seeds (rapeseed) it was defined in section 8 of the aforesaid standard (see Table No. 1 - size of oilseed samples) and can be between 1 kg and 2 kg The way of packing and labelling samples - is provided in sections 9.1 and 9.2 of the aforesaid standard. In the absence of type of packaging mentioned in section 9.1, it is recommended to use durable plastic bags (PE). A plastic bag is to be sealed using a heat sealer, adhesive tape, string or another effective way of protecting against its opening, making sure to remove excess air from the inside of the packaging. Upon sealing the bag, stick on it a label with full information about the supply (do not insert labels into the bag along with a sample of rapeseed!) Arbitration samples a duplicate (1 copy) weighing min. 0.5 kg (for the method of determination of impurities in accordance with the PN-EN ISO 658 standard) Arbitration samples (duplicates) shall be stored for a period of 1 month For the supplies of rapeseed with the presence of storage pests and/or residual fumigant duplicates will not be prepared Note: The Supplier will not be provided with an additional duplicate of a sample. In case of any doubts regarding quality parameters, the Supplier has the right to make a complaint, which will be considered on the basis of the secured arbitration sample (duplicate). 1.6 Additional sampling: for the erucic acid content; for the content of 4 PAHs (benzo(a)pyrene, benz(a)anthracene, benzo(b)fluoranthene and chrysene); for the content of pesticides; for the content of GMO The parameters mentioned in section 1.6 will be determined in the secured duplicate sample, which is stored for a period of 1 month. 2. Reduction of a laboratory sample to a test sample. The reduction of a sample is carried out in accordance with the PN-EN ISO 664: 2010 "Oilseeds. Reducing a laboratory sample to a test sample" standard. 2.1 Preparation of a sample for tests - a laboratory sample is divided (see section 5.2 of the aforesaid standard) in such a way so as to obtain the necessary amount of the sample for the determination of impurities and moisture. The analysis is performed upon sampling within less than 48 hours (see section 6 of the aforesaid standard). Strona 2 z 8

3 3. Sensory evaluation. Sensory evaluation is carried out in accordance with the PN-R-66149: 1997 "Grain oilseeds. Sensory evaluation" standard. Odour, colour and gloss are determined in a supplied laboratory sample and it is checked whether the heating of rapeseed has occurred or not. During the sensory evaluation a sample is examined for the presence of live and dead mites and other storage pests in accordance with the PN-R-66160: 1991 "Industrial oil plants. Determination of impurities and pests content in rapeseed and agrimony seeds" standard. See also section 10 of this Instruction. 3.1 The presence of live and dead storage pests. The presence of live storage pests of at least 1 piece and dead ones of more than 20 pieces/kg disqualifies rapeseed for further processing for food purposes. Their presence results in a refusal to receive/accept a delivery. A possibility of considering a complaint on this account is also precluded due to the lack of legitimacy of preparation of a sample duplicate. 3.2 The presence of residual fumigant (phosphine). Finding in a supply a chemical odour indicating the use of chemical fumigants for rapeseed and ineffective ventilation of seeds precludes the possibility of accepting a supply or considering a complaint due to lack of legitimacy of preparation of a duplicate sample. 4. Determination of impurities content. 4.1 Dealing with supplies containing mouldy, burnt and sprouting seeds and cleavers Determination of mouldy seeds and cleavers content. A test sample weighing 10 grams, with an accuracy not less than 0.01 g, is separated from a taken rapeseed sample. An automatic sample divider or slot divider is used for this purpose. Only mouldy seeds and cleavers are taken out from thus prepared a sample. Next, their percentage content is calculated (separately for each type of impurities) and added to the group of impurities which were determined in accordance with the PN-EN ISO 658 standard. In the case of exceeding the maximum levels specified in contracts, an appropriate refusal to receive rapeseed report is issued (see appendix No. 1 to this Instruction). Note: The determination is carried out without using a magnifying glass Determination of burnt seeds content If the odour of burnt seeds is found in an analysed sample, their presence should be confirmed by proceeding in accordance with section 2.2 of the PN-R-66160: 1991 "Industrial oil plants. Determination of impurities and pests content in rapeseed and agrimony seeds" standard. If the presence of burnt seeds was determined (charred on the inside), their percentage content will be added to the impurities that were determined in accordance with the PN-EN ISO 658 standard. In the case of exceeding the maximum levels specified in contracts, an appropriate refusal to receive rapeseed report will be issued (see Appendixes No. 1 to this Instruction) Determination of sprouting seeds content The content of sprouting seeds largely determines the quality of the raw material, especially at the stage of its storage and processing (lowering the efficiency of oil yield). Therefore, in view of the above, the determination of sprouting seeds content should be performed immediately upon sampling according to the PN-R-66160: 1991 "Industrial oil plants. Determination of impurities and pests content in rapeseed and agrimony seeds" in line with sections and of the aforesaid standard, but prior to the determination of impurities in accordance with the PN-EN ISO 658 standard. Note: Should the content of sprouting seeds not exceed 5% in a given supply of rapeseed, then they should not be added to the group of impurities in total. However, their presence must be indicated in the goods received document. The level determining the acceptance of a supply of rapeseed with sprouting seeds is max. 5.0%. In the event of exceeding the maximum level specified in contracts, an appropriate refusal to receive rapeseed report (see Appendixes No. 1 of this Instruction). Strona 3 z 8

4 4.2 Determination of impurities content in accordance with the PN-EN ISO 658 standard Scope of the standard The PN-EN ISO 658 standard specifies a method for the determination of impurities in oilseeds utilized as an industrial raw material. Different categories of impurities are also defined Terms and definitions The PN-EN ISO 658 standard uses the following definitions: Fine impurities of oilseeds - particles passing through a sieve with the mesh size depending on the tested species (0.5 mm for rapeseed) Non-oleaginous impurities - foreign, non-oleaginous bodies, fragments of stems, leaves and all other nonoleaginous parts belonging to the tested oilseeds, remaining on the respective sieves Oleaginous impurities - oilseeds other than the tested species Principle of the method Impurities are separated by sieving and sorting them into three categories: Fines; Non-oleaginous; Oleaginous; Small equipment and apparatus Sieves/screens with circular meshes of 0.5 mm and 3.15 mm in diameter; Tweezers, brushes and other useful instruments; Analytical balance with a readability of at least g; Automatic divider enabling to separate a sample weighing about 10 g Automatic screen Sampling The recommended sampling method is provided in the PN-EN ISO 542 standard Carrying out a determination A determination of impurities is performed quickly enough to avoid significant changes in the moisture of seeds Separation of fine impurities A determination is performed in the analytical sample with a mass of min. 200 g. The whole sample is screened on a sieve with meshes of 0.5 mm in diameter, using an automatic screen or manually. The collected fine impurities are weighed with an error not exceeding 0.01 g Separation of oleaginous and non- oleaginous impurities Oleaginous and non-oleaginous impurities larger than the diameter of tested rapeseed are separated from the seeds remaining on the sieve. This can be done using a sieve with the mesh diameter of 3.15 mm, and tweezers. Sorted impurities are weighed with an error not exceeding 0.01 g. In the case of presence of oleaginous and non-oleaginous impurities smaller than the diameter of the tested rape seed, at least 10 grams of seeds are taken with an error not exceeding 0.01 g from the fraction after the 3.15mm sieve. Collected small oleaginous and non- oleaginous impurities are weighed separately with an error not exceeding g Reporting results Results are expressed as the sum of the individual categories of impurities (i.e. total impurities) in accordance with the formulas specified in the standard. Mouldy, burnt, sprouting seeds and cleavers, if present in a supply, are added to the impurities determined in accordance with the DIN EN ISO 658 standard. 5. Determination of moisture content. Note: The determination is performed immediately upon sampling and delivering the sample to the laboratory. However, should this prove impossible, the sample of seeds must be secured in such a way so that no change to their moisture occurs during the storage. Strona 4 z 8

5 Rapeseed moisture is determined using: - an electric hygrometer in accordance with the PN-A-74009: 1990 "Cereal grains, seeds of legumes and rape, and cereal products. Determination of moisture content using electric hygrometers" standard, having a current certificate of validation/calibration. Rapeseed must be thoroughly pre-cleaned prior to the determination of moisture content using an electrical hygrometer. A perforated sieve with meshes of 2.8 mm in diameter can be used for this purpose. - the drier method in accordance with the PN-R-66163: 1962 "Determination of the water content in oilseeds, rapeseed cake and post-extraction meals" standard (a technical method, drying temperature of 130 C). Note: The calibration of hygrometers is performed at the Institute of Biotechnology of the Agro-Food Industry, Grain Processing Plant and Bakery, at Rakowiecka st. No. 36, Warsaw, office phone 22/ Driers should be checked (calibrated) in companies that are authorized to perform such activities. 6. Determination of oil content. The analysis of oil content is performed in a sample taken in accordance with the PN-EN ISO 542: 1997 "Oilseeds. Sampling" standard. The analysis is carried out: in an accredited laboratory in Poland in accordance with the current version of the PN-EN ISO 659 standard in plant laboratories using Soxtec 2050 system in Kruszwica, and Soxtec 8000 system in Brzeg 7. Determination of erucic acid content. The PN-R-66151: 1990 "Industrial oil plants. Rapeseed and double-improved agrimony seeds" standard sets the erucic acid content at the level of 2.0%. The analysis is carried out: in an accredited laboratory in Poland in accordance with the current version of the PN-EN ISO standard in plant laboratories in Kruszwica and i Brzeg, in accordance with the PN-EN ISO 5508 standard 8. Determination of BaP, 4 PAHs and pesticides content. 8.1 The content of BaP and 4 PAHs will be determined randomly in the supplies of rapeseed directed to the Plants in Kruszwica and in Brzeg. According to (EU) Commission Regulation No. 835/2011 of 19 August 2011 amending Regulation No. 1881/2006 as regards the maximum levels for polycyclic aromatic hydrocarbons in foodstuffs, the maximum content of benzo(a)pyrene in oils for direct consumption was set at max. 2.0 g/kg (ppb), and the sum of benzo(a)pyrene, benz(a)anthracene, benzo(b)fluoranthene and chrysene at max g/kg (ppb). In the case of exceeding the permissible level of 2.0 g/kg (ppb) of benzo(a)pyrene, and 10 g/kg (ppb) for the sum of benzo(a)pyrene, benzo(a)anthracene, benzo(b)fluoranthene and chrysene (with regard to oil content) the penalty stipulated in the contract will be applied. 8.2 Supplies of rapeseed are also tested for residual pesticides in an external laboratory accredited in accordance with (EC) Regulation No. 396/2005 of the European Parliament and of the Council of 23 February 2005, as amended. In case of exceeding the maximum permissible level of residues of the substances listed in the Regulation the penalty stipulated in the contract will be applied. 9. Determination of Genetically Modified Organisms (GMOs) content. Zakłady Tłuszczowe Kruszwica S.A. pursue a policy of purchasing GMO-free raw materials as one of the basic requirements of our customers. Therefore, we take action in this field aimed at monitoring this parameter. The analysis is performed using test strips available on the Polish market which determine the presence of protein characteristic of genetically modified varieties. It is a qualitative test, so using it we can determine whether the modification occurs, or if the raw material is free of it. The analysis using a test strip is simple to make, both in the field (analysis of part of a plant) and in the laboratory (analysis of rapeseed). The test is recommended by the National Institute of Hygiene and designed primarily to control raw materials when they are being loaded, transported, stored and processed in production to be able to quickly rule out the possible presence of GMO and contamination of other batches of raw material Checking supplies of rapeseed for the presence of GMOs - an analysis using a qualitative test strip While delivering rapeseed (by car, train), a qualitative analysis for the presence of GMOs is performed randomly. In the case of finding the presence of proteins characteristic of GMO varieties, a secured duplicate of the sample Strona 5 z 8

6 will be sent to an independent and accredited laboratory for reference analysis (e.g. GMO screening - detecting pfmv, bar, pat, nptii, t-nos). The cost of such analysis will be covered by the losing party Checking supplies of rapeseed for the presence of GMOs - the PCR analysis In addition, as part of monitoring, ZT "Kruszwica" S.A. examines rapeseed for the presence of GMOs using the PCR method in an accredited external laboratory, based on the approved test schedule. 10. Complaints. In the event of a dispute in respect of the results of a laboratory analysis, the Supplier shall, within 7 days of receipt of the results, have the right to indicate in writing the challenged analyses by means of the "Quality complaint form" (see Appendix No. 2) providing the required information. In the absence of the required information, the complaint will not be considered. The following supplies of rapeseed will not be covered by the subject of the complaint: those with the presence of live pests; those with the presence of dead pests of more than 20 pieces/kg of seeds; those with residual fumigant (phosphine) The Supplier making a complaint can download the form from the website Should the Supplier choose a joint analysis of conciliation for the settlement of the complaint, the parties shall agree on the date of its performance. Should an analysis performed in an accredited laboratory be selected, the sample will be sent within 5 business days as of the date of receipt of the complaint. The Supplier will receive results within 30 business days as of the date of receipt of the complaint. The quality complaint form should be sent by or fax to the following persons in the Plants in Kruszwica and in Brzeg responsible for the handling of quality complaints regarding supplies of rapeseed: First name and Surname Location Position Landline phone No. Mobile phone No. Fax No. address Piotr Teresiński Magdalena Kurdziel Plant in Kruszwica Plant in Brzeg Quality Control Manager Head of Quality Control Department 52/ / piotr.teresinski@bunge.com 77/ / magdalena.kurdziel@bunge.com 11. Required quality documentation. In accordance with the requirements of (EC) Regulation No. 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety (as amended), the Company keeps the documentation and necessary records that are used to identify the various stages of acceptance/receipt of rapeseed supplies at their own warehouses, i.e. the register of samples taken - maintained by the Expert, unless it is in the electronic form, which records the consecutive number for a supply of rapeseed and the necessary supplier's details. It is important that the information contained on the sample label be identical to the information in the relevant register. the register of qualitative analyses (printouts from the computer system), lab technician's notebooks in which they perform the necessary calculations, and a register of the "Refusal to receive rapeseed reports." the register of currently applied standards calibration or legalization certificates for laboratory equipment records of periodic checks of the lab drier and hygrometer. Strona 6 z 8

7 12. List of applicable standards and regulations. Standard symbol List of applicable standards PN-EN ISO 664:2010 Oilseeds. Reducing a laboratory sample to a test sample. PN-EN ISO 658:2004 Oilseeds. Determination of impurities content. PN-R-66163:1962 Determination of the water content in oilseeds, rapeseed cake and post-extraction meals PN-R-66160:1991 Industrial oil plants. Determination of impurities and pests content in rapeseed and agrimony seeds (as regards the determination of presence of burnt and sprouting seeds) PN-R-66151:1990 Industrial oil plants. Rapeseed and double-improved agrimony seeds. (as regards the content of erucic acid) PN-R-66149:1997 Oilseeds. Sensory evaluation. PN-A-74009:1990 Cereal grains, seeds of legumes and rape, and cereal products. Determination of moisture content by means of electric hygrometers. (including the amendment of the PN-90/A-74009/AZ1: 1998 standard) List of applicable regulations (EC) REGULATION No. 396/2005 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 23 February 2005 on maximum levels of pesticide residues in food and feed of plant and animal origin on their surface, amending Directive of the Council Directive 91/414/EEC (as amended) (EU) COMMISSION REGULATION No. 835/2011 of 19 August 2011 amending (EC) Regulation No. 1881/2006 as regards the maximum levels of polycyclic aromatic hydrocarbons in foodstuffs (EC) REGULATION No. 1829/2003 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 22 September 2003 on genetically modified food and feed (EC) REGULATION No. 1830/2003 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 22 September 2003 regarding the traceability and labelling of genetically modified organisms and the traceability of food and feed products produced from genetically modified organisms and amending Directive 2001/18/EC REGULATION OF THE MINISTER OF LABOUR AND SOCIAL POLICY of 6 June 2014 on maximum permissible concentrations and intensities of harmful factors in the work environment (Journal of Laws of 23 June 2014). A list of Polish standards and the possibility to check the current status of the standards are available on the Internet, at the website List of basic laboratory equipment. - A hygrometer with a valid attestation certificate or an electric drier (checked) - Laboratory scales - Equipment for sampling (an automatic or manual probe, a scoop) - Equipment for sample preparation (a flat bottom tray with a cross to reduce samples, slot divider, automatic sample splitter) 14. List of appendixes. Appendix No. 1 - Refusal to receive rapeseed report Appendix No. 2 - Quality complaint form 15. Final remarks - Only the instruments that are listed in the PN-EN ISO 542: 1997 standard should be used for sampling. - Only general guidelines were provided for determining quality parameters. Detailed information can be found in the standards mentioned in section 12 of this Instruction. - The laboratory separator should undergo a technical survey at least once a year to confirm its efficiency. - Quality test strips to determine protein specific for GMO rapeseed varieties can be purchased from the company NUSCANA, ul. Wieruszowska 12/16, Poznań, phone: 61/ , or Cereus Wena, ul. Biała 19, Toruń, phone: 56/ The technical condition of the electric driers used for the determination of moisture content in rapeseed should be checked in accordance with the PN-86/A "Cereal grains, legumes and cereal products. Determination of moisture content" standard (sections: 1.2a; 2.1; 2.2a; 2.2d and the part on the performance of the determination using semolina). Title Strona 7 z 8

8 - The electric hygrometer used to determine the moisture content in rapeseed at procurement must undergo periodic checks (calibration) confirmed by the issuance of the relevant document. - The standards mentioned in this Instruction can be purchased through the Internet at - The legislative acts mentioned in this Instruction can be found in the relevant Journals of Law and on the websites or Questions regarding the performance of qualitative assessment can be directed to the following persons: First name and Surname Location Position Landline phone No. Mobile phone No. Fax No. address Piotr Teresiński Dorota Siedlecka Plant in Kruszwica Plant in Brzeg Quality Control Manager Deputy Manager of the Crushing Department 52/ / piotr.teresinski@bunge.com 77/ / dorota.siedlecka@bunge.com Strona 8 z 8

9 Appendix No. 1 to the INSTRUCTION of ZT "Kruszwica" S.A. concerning the quality assessment of rapeseed REPORT No.... /OPR/... refusal to receive a supply of rapeseed SUPPLY PARAMETERS Delivery date: Supplier's name: Supplier's No. Supply No. Vehicle Reg. No. Gross weight [tonne]: CONDITIONS FOR REFUSAL Moisture in excess of 9.0% Result:.. % Total impurities in excess of 4.0% Result:.. % Mouldy seeds in excess of 0.4% Result:.. % Burnt seeds (charred on the inside) in excess of 1.0% Result:.. % Sprouting seeds in excess of 5.0% Result:.. % Cleaver seeds in excess of 2.0% Result:.. % Live mites and other live pests Result:.. Dead mites and other dead pests in excess of 20 pieces/kg seeds Result:.... GMO seeds (qualitative TRAIT test strip): Liberty Link Roundup Ready Foreign odour: burnt, chemical, musty, other :... Positive result Positive result Other requirements under the terms of the contract:.. SIGNATURES REPRESENTATIVE : of the Plant in Kruszwica/Plant in Brzeg/ Company acting as commissioned by ZTK 1.. SUPPLIER OR THEIR REPRESENTATIVE:

10 Appendix No. 2 to the INSTRUCTION of ZT "Kruszwica" S.A. concerning the quality assessment of rapeseed QUALITY COMPLAINT FORM (*) GENERAL INFORMATION Date of filing the complaint: Name of the entity filing the complaint: No. of the entity filing the complaint in the Buyer's IT system: Address: Tax Id. No. [NIP] Contact person and their telephone number: Delivery to the Buyer's warehouse in: Plant in Kruszwica Form of dealing with the complaint: Joint analysis of conciliation Plant in Brzeg Accredited laboratory in Poland: POLCARGO Sp. z o.o. w Szczecinie Another warehouse: J.S. HAMILTON Poland S.A. w Gdyni other : SUPPLY PARAMETERS Delivery date : Goods Received Note No. Contract No. Date of the contract: Reg. No. of the means of transport: Net weight of the supply [tonne]: Moisture, % Total impurities, % Oil content, % Odour CHALLENGED PARAMETER Signature (*) A complaint may be made only within the period specified in the contract. Should a complaint be made with regard to more than one supply, then each notification should be filled in on a separate form.

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