Nestlé WHO Code Assurance Nestlé Indochina Assurance Statement

Similar documents
EU TOY DIRECTIVE 2009/48/EC: OVERVIEW - REGULATORY CONTEXT AND MAJOR CHANGES

Re Introducing FSSC Jacqueline Southee, NA Representative, FSSC PJR Webinar Series August

Implementation procedure for certification and continued airworthiness of Beriev Be-200E and Be-200ES-E

Recommendations of the Expert Group on Preventing Motorcycle Injuries in Children

Internal Audit Report. Fuel Consumption Oversight and Coordination TxDOT Internal Audit Division

Microgeneration Installation Standard: MCS

Modern Slavery and Human Traffic Statement

Palm Oil Policy. Policy Name: Palm Oil Issue Number 008 Date of Issue: Dec 2016 Date of Approval Dec 2016 Policy Originator: Clare Hazel Page 1 of 5

Protecnica Ingenieria S.A.

This Regulation is established on the basis of subsections 26 (3) and (8) of the Waste Act.

RSPO Supply Chain Certification. OCTOBER 17-18, 2016

How to Prepare for a DOT Audit

Sumatran Orangutan Society (SOS)

Operational Profile 1.1 What are the main activities of your organization? Biodiversity protection, conservation and sustainable use of natural resour

Soft copies of working templates, procedures, compliance manuals and checklists.

SOUTH AFRICAN NATIONAL STANDARD

USAACE & Fort Rucker Preventative Law Program. Alabama Lemon Law

Antares Funds Equities

NCC Leisure Battery Verification Scheme. Leisure Accommodation Vehicles

Colgate-Palmolive Company

Media Factsheet: Value-based Intermediation Dialogue

GLOBAL CERTIFICATION SCHEME FOR FOOD SAFETY MANAGEMENT SYSTEMS

GLOBAL CERTIFICATION SCHEME FOR FOOD SAFETY MANAGEMENT SYSTEMS

MCCAIN FOODS (AUST) PTY LTD

COMMISSION RECOMMENDATION. of XXX

Gb Ingredients Ltd. Particulars. RSPO Annual Communications of Progress About Your Organisation. Membership. Particulars Form Page 1/1

Ensuring consumer trust in the safe supply of food and drinks. Cor Groenveld Market Development Manager FSSC 22000

Risk Management of Rail Vehicle Axle Bearings

Guidelines for Motorcycling

Motor Vehicle Policy Essential Knowledge

Robert Beckman Head, Ocean Law & Policy Programme NUS Centre for International Law

The North American Electric Reliability Corporation ( NERC ) hereby submits

The Alstom Integrity Programme 1/2 Tone at the Top Ethical rules and values guarantee our future Patrick Kron, Chairman and CEO Independence and autho

GIBRALTAR ERDF OPERATIONAL PROGRAMME POST ADOPTION STATEMENT

Consultation on the Maximum Weight limit of Agricultural Trailers and Combinations on Public Roads

Roundtable on Sustainable Palm Oil (Phase 2)

ALLEGATIONS RELATED TO LABOUR AND HUMAN RIGHTS AT INDOAGRI

International Palm Oil Purchasing Policy

Pilot Chemical Company

Addressing ambiguity in how electricity industry legislation applies to secondary networks

(a) "Motorist" shall refer to the driver of a motor vehicle.

Respecting the Rules Better Road Safety Enforcement in the European Union. ACEA s Response

STANDARD 14 SAFETY RATING

Strategy for Promoting Centers of Excellence (CoE) Activities

European Responsible Care Award Celanese Contractor Safety Improvements. About Celanese

Independence- Freedom- Happiness No.: 96/2012/TT-BTC

HyLAW. HyDrail Rail Applications Assessment. Main Author(s): [Dainis Bošs, Latvian Hydrogen association] Contributor(s):

Global Environment Centre

Audit Follow-up. Fleet Fuel Operations (Report #0801, Issued October 18, 2007) As of March 31, Summary. Report #0811 June 20, 2008

Emissions Legislation

Terms of Reference (ToR) Trade & Traceability Standing Committee (T&T SC)

FMI Australia Pty Ltd

UNIVERSITY OF ROCHESTER ENVIRONMENTAL HEALTH & SAFETY

AURELIA METALS LTD 2016 Annual Report

LIST OF OPEN TRAINING TRAINING PLANNER 2016/2017 Course location: Lagos, Abuja, Port Harcourt.

SFI SPECIFICATION 35.1 EFFECTIVE: AUGUST 26, 2008 *

FIA FORMULA E CHAMPIONSHIP VALUE CREATION & SUSTAINABILITY REPORT by EY

RSPO Accreditation and Certification. Requirements for Group Certification. 26 August 2010

Joint Operating Procedures for First Nations Consultation on Energy Resource Activities

Donington Park Racing Ltd. Noise Management Plan

RSPO Principles and Criteria Lead Auditor Course.

PRINTING OF BMI WHEELS

NESTE OIL NO-DEFORESTATION AND RESPONSIBLE SOURCING GUIDELINES FOR RENEWABLE FEEDSTOCK

Fuel Economy Standards in Asia

Road fatalities in 2012

Solidaridad. Particulars. RSPO Annual Communications of Progress Particulars Form Submit date: 16-Jul :34 GMT Page 1/1

NOTES FOR THE APPLICATION OF FEMAS IN THE UNITED KINGDOM

Maharashtra Electricity Regulatory Commission (Renewable Purchase Obligation, Its. Regulations, 2016 STATEMENT OF REASONS

Oleaginosas Del Peru S.A - OLPESA

Unilever Sustainable Palm Oil Sourcing Policy

June Safety Measurement System Changes

A MODEL SYLLABUS FOR THE TRAINING OF TECHNICIANS INVOLVED IN THE EXAMINATION, TESTING, MAINTENANCE AND REPAIR OF PETROLEUM ROAD TANKERS

THE LAW ON SOLID AND HAZARDOUS WASTES. Regulations based on Article 5

RESPONSE TO THE DEPARTMENT FOR TRANSPORT AND DRIVER AND VEHICLE STANDARDS AGENCY S CONSULTATION PAPER

Village of West Dundee IL 31 & IL 72 Red Light Running (RLR) Statistical Analysis Report May 14, 2018

IMPLEMENTING FSSC 22000

Diagnose and rectify faults in a motorcycle electronic ignition system

CN in Your Community British Columbia Photo: Squamish, 1BC

Britannia Superfine Ltd

CONSULTATION DOCUMENT

Sasol is a global integrated chemicals and energy company. Through our talented people, we use selected technologies to safely and sustainably

Amsterdam Boats. High-quality luxury boats and hospitality. Conditions of use and disclaimer. Version: August 2018

BACS APPROVED BUREAU SCHEME SUPPORT GUIDELINES

LACTALIS NUTRITION DIETETIQUE

Rema 1000 Denmark A/S

CarShare Wiltshire WHY CONSIDER A CAR-SHARING SCHEME

NZQA registered unit standard version 1 Page 1 of 5. Apply and remove portable earths in an electricity supply system

Mandate to CEN on the revision of EN 590 to increase the concentration of FAME and FAEE to 10% v/v

Exceeding the standards with MNS

Vehicle Management Policy and Procedure Document No: VMPol 001

.CITY & GUILDS. CROSS-BORDER..APPROVAL POLICY. Version 1.0 June 2015 For internal and external use

ecognition of Prior Learning (RPL)

FRESH SOLUTIONS FOR PAINTS AND COATINGS

Golden Veroleum (Liberia) Inc. (GVL)

Sainsbury's Supermarket Ltd (J Sainsbury PLC)

Request for Assistance (RFA)

MINISTRY OF EDUCATION AND HUMAN RESOURCES, TERTIARY EDUCATION AND SCIENTIFIC RESEARCH MAURITIUS EXAMINATIONS SYNDICATE NATIONAL ASSESSMENT AT FORM III

TreeHouse Foods, Inc.

Electric Vehicle Appendix Notes

HELLENIC REPUBLIC MINISTRY OF DEVELOPMENT DIRECTORATE-GENERAL FOR ENERGY DIRECTORATE FOR RENEWABLE ENERGY SOURCES AND ENERGY-SAVING EXTENSIVE SUMMARY

Transcription:

NESTLÉ INDOCHINA Independent assurance of compliance with the world health organisation (WHO) international code of marketing of breast-milk substitutes (1981) in Laos People s Democratic Republic November 2011

Independent Assurance Statement by Bureau Veritas Introduction Bureau Veritas has been commissioned by Nestlé S.A. to provide independent assurance of Nestlé Indochina s compliance with the World Health Organisation (WHO) International Code of Marketing of Breast Milk Substitutes (1981) and subsequent World Health Assembly (WHA) resolutions (herein known as the WHO Code) and Lao PDR s The Regulation of food products for infants and young children in the Lao People s Democratic Republic No. 777/MOH (2007) (herein known as the Lao PDR Decree). This follows similar work previously conducted by Bureau Veritas for Nestlé SA in other global operations. Scope of Work and Methodology The assurance was conducted in Lao PDR between 10 and 22 August 2011 by two assessors from Bureau Veritas UK Limited. The team has extensive experience of undertaking WHO Code compliance related work and was supported by a representative of Bureau Veritas Bangkok office in Thailand. Preceding the assurance activities in Lao PDR, Bureau Veritas conducted the following activities: completed a Gap Analysis of the WHO Code and Lao PDR Decree to consider where the scope of local decree differed from the WHO Code; requested a list of Nestlé Nutrition employees based in the regional head office in Bangkok, Thailand and the local office in Vientiane, Lao DPR, and details of hospitals and healthcare professionals, and distributors based in Lao PDR from Nestlé Indochina; identified other external stakeholders (through the Bureau Veritas representative in Lao PDR) and local NGOs concerned with the protection, promotion and support of breastfeeding; and independently determined a schedule of audit activities to take place in Lao PDR between 10 and 22 August 2011. During the assurance Bureau Veritas: selected 16 Nestlé Indochina staff for interview and review of their associated records, as part of its evaluation of Nestlé internal processes for managing compliance with the WHO Code and Lao PDR Decree within Lao PDR; undertook 1 interview with a key external stakeholder, a representative of one of Nestlé Indochina s distributors in Laos PDR; and, selected and visited 103 retail locations to visually assess compliance with the WHO Code and Lao PDR Decree, with particular reference to articles relating to labelling and promotion of products.

Findings The following is a summary of findings from interviews and document review undertaken with a range of key stakeholders. Nestlé Indochina The requirements of the WHO Code and Lao PDR Decree are well embedded throughout the business and are reflected in Nestlé Indochina Policy and Procedures Manual on marketing of breastmilk substitutes. All employees interviewed across a number of key departments demonstrated a good understanding of the requirements it places on their day-to-day responsibilities. Bureau Veritas identified some areas of improvement in relation to internal management procedures and manual that has been provided to Nestlé Indochina in a separate management report. Distributors Representatives of the distributors interviewed demonstrated a good understanding of the requirements for marketing products designated by the WHO Code and Lao PDR Decree within Lao PDR and the requirements it places upon their role and responsibilities. Government Despite best efforts, Bureau Veritas was unable to meet with any government officials during the audit. Multilateral organisations/ngos Despite best efforts, Bureau Veritas was unable to meet with any NGO with an interest in infant nutrition and health during the audit. Healthcare facilities and professionals Despite best efforts, Bureau Veritas was unable to obtain permission from the national Ministry of Health to enter Government Hospitals and conduct visual inspections of facilities and interviews with healthcare professionals. Retail Visual observations in a range of retail establishments indicate there is no systematic or intentional promotion of any Nestlé IF brands within Lao PDR through in-store advertisements, coupon redemption schemes, promotional pricing or any other promotional devices. Consistent pricing was evident at all retailers visited. However, Bureau Veritas observed promotional materials in 4% of the retail outlets visited during the audit that violate Article 14 of the Lao PDR Decree and, in one case, Article 5.3 of the WHO Code. The material that was observed was advertising products designated by the WHO Code and the Laos PDR Decree that included:

1) A poster advertising Bear Brand growing up milk products which displayed a pack shot of Bear Brand 1+ was observed in a market in Vientiane. This was an isolated observation, and Bureau Veritas is of the opinion, that this particular material was either placed some time ago and/or was imported through unofficial channels, since the brand logo is different to the version used in Lao PDR. 2) A sachet product hanger and a shelf talker branded with the infant cereal brand name Cerelac were observed in 2% of the retail units visited. These items are considered to have been imported into the market through unofficial channels due to the use of the English language observed on the material. 3) A sachet product hanger branded with the infant formula brand name Lactogen Complete was observed in 2 retail units in a market in Phong Hong, Parallel importing of Nestlé products in Lao PDR, including infant food products designated by the Lao PDR Decree is a significant issue for Nestlé Indochina which is beyond its area of control. Bureau Veritas observed parallel imported products in 28% of the retail units audited. Article 9 of Lao PDR Decree, requires all milk and food products suitable for infants up to the age of two years to carry a warning in the official national language (Lao) stating the importance of rearing infants on breastmilk. Taking into account the presence of parallel imported products, Bureau Veritas observed Nestlé products on sale without the stipulated warning notice in 63% of retail units visited. Nestlé local management explained that considerable effort had been expended on addressing the labelling issue and since l 2011 all designated products distributed directly by Nestlé Indochina and destined for Lao PDR, have the required labelling attached at the central Nestle Distribution centre before shipment. Nestlé Indochina has also distributed stickers (accounting for approximately one month s worth of products shipped) with the warning written in Lao and instructed its distributors to retrospectively attach the stickers to designated products already available in the retail environment. Bureau Veritas opinion From our assurance activities, evidence or observations, it is Bureau Veritas opinion that Whilst no significant evidence came to our attention to indicate that Nestlé Indochina is systematically operating in violation of the WHO Code and Lao PDR Decree in Lao PDR, the presence of promotional materials in 4% of the retail units visited (and identified above) constitute a non-conformance against Article 14 of the Lao PDR Decree and, in one case, non-conformance with Article 5.3 of the WHO Code; the presence of Nestlé infant nutrition products in Lao PDR which have been imported through unofficial channels contribute to the risk of non-compliance against the Lao PDR Decree and are considered to have an impact on the results of the audit; Nestlé s Policy and Procedures Manual on the Marketing of BMS should be reviewed and updated to ensure consistency against the more stringent requirements of the Lao PDR Decree, and some procedures further strengthened to ensure maximum control of compliance;

the presence of designated products without the required warning message in Lao constitutes a non-conformance against Article 9 of Lao PDR Decree; the absence of the warning message in appropriate language on infant formula and follow-on formula products also constitutes a non conformance against the Nestlé Instructions implementing Article 9.2 of the WHO Code; no other evidence (other than that described above) came to our attention to indicate that Nestlé Indochina is operating in contravention of the WHO Code or Lao PDR Decree within Lao PDR. Bureau Veritas recommendations Detailed findings and recommendations from our assurance activities have been provided to Nestlé S.A. as part of an internal Management Report. As a priority, Bureau Veritas suggests that Nestlé S.A. should: Work with Nestlé Indochina to fully understand the level of parallel importation of Nestlé infant food products into Lao PDR and how best to address the issues identified to promote compliance with the Lao PDR Decree by third party importers and retailers. Limitations Bureau Veritas was unable to obtain interviews with a number of key stakeholders, including Government officials, healthcare professionals and NGOs The interview with the distributor was organised by Nestlé Indochina Visual inspections of retail units were limited to Vientiane Capital, Vientiane Province and Phong Hong No interviews were conducted with mothers or their families This limited assurance is not intended to provide a definitive opinion as to whether or not Nestlé Indochina complies with the WHO Code or Lao PDR Decree within Lao PDR. Consequently, neither the limited assurance conducted by Bureau Veritas nor this statement constitutes a guarantee or assurance by Bureau Veritas that infringements against the WHO Code or Lao PDR Decree have not taken place. Statement of independence, impartiality and competence Bureau Veritas is an independent professional services company that specialises in quality, health, safety, social and environmental management advice and compliance with 180 years of history in providing independent assurance services. Bureau Veritas has implemented a Code of Ethics across the organisation which ensures that all our staff maintains high standards in their day to day business activities. We are particularly vigilant in the prevention of conflicts of interest. This assurance assignment did not raise any conflicts of interest. Bureau Veritas UK Ltd London November 2011