Joana Carvalho
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The sample size was defined according to the risk level of the suppliers, using the following calculation criteria:
High risk: √67 (rounded up) = 9 suppliers
Medium risk: 49 × 0.2 × (1 – 15%) (rounded up) = 9 suppliers
Low risk: √144 × (1 – 30 per cent) (rounded up) = 9 suppliers.
According to Annex A of the ProTerra Standard, suppliers not selected for face-to-face visits (but included in contracts or in the total list of suppliers) must be assessed for their fulfilment of sustainability obligations.
Verification should include cross-checking with public lists and official information, covering the following aspects: Environmental embargoes or infractions;, Slave or child labour;; Conflicts with indigenous or traditional communities; Deforestation. When analysing deforestation, auditors should use satellite images of adequate resolution, prioritising available official databases, such as PRODES Amazon and PRODES Cerrado, depending on the geographical context. Interviews with those responsible.
*- Increase audit efficiency: In the face of a large number of suppliers, it is not feasible to carry out face-to-face audits on all of them within the same cycle.
Ensure representativeness: The sample selected must adequately reflect the general situation, allowing reliable inferences to be drawn from the results.
Identify risks and non-conformities: Analysing samples makes it possible to detect recurring problems and critical points, enabling targeted corrective action and mitigation of audit risks.
* When non-conformities are identified, the following actions should be implemented:
Pause purchases from the supplier involved;
Label the related batches as non-conforming and notify subsequent buyers in the supply chain;
Initiate the procedure (Root Cause Analysis and Corrective Action Plan), which should include:
Identification of the root cause;
Definition of corrective and preventive actions;
Implementation schedule;
Training and process improvements.
All records and evidence of actions taken must be documented and kept.
The economic operator must submit evidence of the closure of the non-conformity to the Verifier de Base (VB) within 60 working days of the audit closure meeting. Example of Non-Conformity and Expected Corrective Action
An economic operator in the fruit-growing sector has several suppliers located in the southern regions of Minas Gerais, including farms and primary processing units. After surveying the total number of suppliers and contracts, sampling and an on-site inspection were carried out.
During the audit, it was found that the farms do not have policies and procedures in place and maintained to address worker complaints, as evidenced in interviews and document analysis, in violation of ProTerra MRV requirement 4.1.9.
Corrective action taken:
Immediate action: Suspension of purchases from the supplier and identification of the batches affected as non-compliant, with communication to subsequent buyers.
Systemic verification: Evaluation of similar occurrences among other suppliers of the same operator.
*Root cause analysis, which indicated a lack of management awareness and policies and procedures are implemented and maintained to address worker complaints,
Operator action plan:
Develop and implement the MRV ProTerra system and procedures policy, covering all levels (management and employees);
Record evidence of implementation (attendance lists, photos, videos, support materials);
The operator must submit evidence of the closure of non-conformities to the VB within 60 working days of the closure meeting.
The verification decision will be issued by the VB within 20 working days of receiving the evidence, with formal communication to the economic operator.1- Check satellite images with adequate resolution. In areas where specific contextual data is available, these should be used (e.g. PRODES Amazon, PRODES Cerrado), to confirm that no production has occurred on land with land use changes after 31 December 2020. Images to date to identify any changes in land cover. Provided by the accreditation body. Copies of CARs and geographical data cross-checks.
2- I would carry out a risk assessment, where I would check public lists of environmental embargoes, conflicts with indigenous communities or human rights issues and check that suppliers are listed. According to the geographical area or region, classify the suppliers as low, medium or high risk. For European operators or exports, check whether the suppliers maintain any declaration or approved documents proving compliance with the requirements of Article 10 of the EUDR.
I would assess whether the economic operator has established a structured action plan to engage these suppliers and bring them up to an adequate level of traceability in the medium term.
3- Use and management of pesticides, annual agricultural production has the potential to cause direct and indirect impacts on biodiversity and ecosystems. Use of energy where it must be used rationally, Conservation and management of the soil and its nutrients.1º would check in relation to the number of the sample, using Table 1 Minimum sample size of suppliers to be checked for sustainability requirements also by risk per biome.
Where the certification body would pass on which risk each biome falls under. For very high and high risk regions, the values indicated in Table 1 of PT MRV – ANNEX A would be checked.
– Cerrado/Atlantic Forest transition 86 square root of 86 =9.27 total of 10 samples
– Amazon 145 square root of 145 = 12.04 total of 12 samples.
– Caatinga 7 20% = 5.6 total of 6 samples
– Cerrado 5,931 square root of 5,931 = 77 samples
– Atlantic Rainforest 205 square root of 205 = 14.31 total of 15 samples.
To ensure the prevention of double counting
Whether the organisation has a formal internal procedure documenting how SAP manages the unique identification of each supplier, batch and business transaction.
SAP reports showing that supplier and batch codes are unique, with no overlap between records.
Cross-checking of data: invoices, delivery records, dates and volumes compared with system information. Internal audits or control tests carried out by the company (logs, batch samples).
Verification of reverse traceability (from batch to supplier and vice versa), demonstrating that the same batch does not appear in multiple transactions.
Random tests: select a few batches and check that they appear only once in the database and that the total volumes do not exceed the declared production capacity.As an auditor, I would check whether the organisation has a robust and effective management system to ensure implementation, maintenance and compliance with sustainability and traceability requirements.
1- Where you would check through interviews and documentation that the organisation has an MRV Management System Manual or equivalent, internal policies and procedures relating to sustainability, traceability, zero deforestation and legal compliance. Organisational chart and responsibilities: evidence that there are designated and trained personnel for MRV functions. Documented procedures for controlling documents and records. Verify traceability if double counting does not occur, Traceability and Chain of Custody
Evidence of control over the origin of products:
Supplier maps, traceability spreadsheets, invoices and contracts.
Proof that each link in the chain fulfils the MRV requirements.
Supplier document verification procedures. Where the operator must demonstrate how it establishes and maintains records as necessary to demonstrate compliance with the requirements of its supply chain management system and this Standard. Records must be and remain legible and traceable. Records must be kept for at least 5 years.
2- When a supplier has no traceability information (or presents it incompletely or inconsistently), this represents a serious risk of non-compliance, especially with regard to the deforestation cut-off date and the sustainable origin of the raw material. For all the suppliers for which the economic operator does not have traceability information, the economic operator must define an action plan to work with these suppliers to bring them into compliance.
action plan to work with these suppliers to bring them to a level of traceability in the medium term.
Review the risk assessment procedures to determine whether the procedures for differentiating between traceable and non-traceable suppliers are in place.
Review operational records to assess whether economic operators can distinguish between traceable and non-traceable items and how to avoid the impact caused by them.Hello everyone, my name is Joana Berticelli. I work as a lead auditor in sustainability protocols, with a degree in agricultural engineering and specialisation in occupational safety and the environment in Brazil. I am an author at Protoco Pro Terra, and I hope that this new MRV certification will allow me to further my knowledge and gain new insights. I am at your disposal.
