Appendix to the Guidelines for the implementation of an LMS

I. Job specifications

LMS Manager job specifications:

Specifications:

 Familiarity with national/local circumstances

 High level of language proficiency in the national/local language, if possible good language
skills in English or German
 Communication and motivational skills
 Systematic and conscientious approach to work

Specialist expertise:

 Comprehensive knowledge of the mabagrown® standard

 Knowledge of the cultivation/production/wild collection of botanicals

Areas of responsibility:

 Contact for MB, the field operators and the LMS auditors with respect to the LMS
 Documentation of all activities concerned with the implementation/monitoring of the LMS
with regard to the field operators
 Implementation of the mabagrown® criteria by the field operators
 Regular training of the field operators and LMS auditors
 Preparation and updating of the LMS audit checklist
 Coordination of LMS audits
 Monitoring and implementation of outstanding corrective action
 Approval of field operators
 Monitoring and motivation of field operators
 Preparation of mabagrown® audits

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LMS Auditor job specifications:

Specifications:

 Familiarity with national/local circumstances

 High level of language proficiency in the national/local language
 Systematic and conscientious approach to work
 Independence and neutrality with respect to the field operator
 Objective capacity for judgement

Expert competence:

 Comprehensive knowledge of the mabagrown® standard

 Knowledge about the cultivation/production/wild collection of botanicals
 Fundamental understanding of auditing

Areas of responsibility:

 Auditing of field operators

 Conscientious management of the audit checklists
 Specification of corrective action
 Communication with the LMS manager

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II. Guidelines for the identification of field operators

To determine whether a sub-supplier, contract grower, subcontractor, etc., has to be added to the
LMS, the following criteria must be checked through, in dependency on the supply chain. If at least
one of the criteria applies, this means that the field operator is of relevance for mabagrown®.

Cultivation/contract cultivation:
The field operator grows mabagrown® raw materials.
and/or
The field operator processes mabagrown® raw materials at its site (e.g. drying, storage, pro-
cessing, packaging, labelling). This includes subcontractors which are contracted by MBG’s
supplier to process or store mabagrown raw materials.

Note: If the company is a contractor which carries out its activities such as threshing, sowing or the
application of fertilizers/plant protection products at the site of MBG’s supplier, it does not need to
be included in the LMS. The decisive factor is whether the activity is carried out at the field opera-
tor’s site or at the supplier’s sites.
and/or
The field operator is an independent trader or purchaser of mabagrown raw materials.

Explanation: The field operator does not purchase goods solely on behalf of and on account of
MBG’s supplier but independently instead; i.e. it could also sell the goods to other purchasers.

Wild collection:
The field operator employs collectors at its own expense.
and/or
The field operator is an independent trader or purchaser of mabagrown® wild collection
products.

Explanation: The field operator does not purchase goods solely on behalf of and on account of
MBG’s supplier, but independently instead; i.e. it could also sell the goods to other purchasers.
and/or
The field operator processes mabagrown® wild collection products at its site (e.g. drying,
storage, processing, packaging, labelling). This includes subcontractors which are con-
tracted by MBG’s supplier to process or store mabagrown® raw materials.

Note: Collector families which cut and dry their harvested products themselves do not count as
field operators within the meaning of the LMS.

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III. Table 1: Description of the field operators

This list is for providing a description of the individual field operators. If a field operator in turn has sub-suppliers or subcontractors, they must also be
listed in this table under the applicable field operator and audited at the same time within the framework of the LMS audit.
The list must be kept permanently up-to-date. In particular, the results of the audits must always be kept up-to-date in order to maintain an effective
overview of the performance of the field operators. Changes and new entries need to be documented along with the date and the signature of the LMS
manager.

Dates and results of all audits

Task of the field opera-
Name of the field Field operator Address / Date of first and (approved/with conditions/not
MBGR products tor (cultivation/pro-
operator code location last training approved/immediately dis-
cessing/ drying, etc.)
qualified)

Updated on: Signature of LMS manager:

Updated on: Signature of LMS manager:
Updated on: Signature of LMS manager:
Updated on: Signature of LMS manager:

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IV. Guidelines on the performance of audits

Performance of the audit

Sufficient time should be allocated for the audit of the field operator, based on the total area of the
business and the number of employees and cultivation/wild sites. The LMS auditor uses the LMS
audit checklist as the basis for the auditing of field operators and should fill in the fields in such a
way that the assessment of criteria fulfillment can also be understood by outside parties.

The checklists which are provided by MBG as samples and which can be adapted by the supplier
after consultation with MBG are always divided into 4 sections and need to be filled in carefully during
the audit.

 Section A: General audit information

 Section B: Information about the field operator and its products
 Section C: Verification of the mabagrown® criteria
 Section D: Evaluation & approval

Evaluation system, audit result and approval of the field operator

During the audit the individual criteria in section C are rated on the following basis:
 “Excellent”: The criterion has been completely fulfilled.
 “Compliant”: The criterion has been fulfilled in part, but there is potential for improvement
 “Insufficient”: The criterion has not been fulfilled or has not been satisfactorily fulfilled

If a criterion is deemed to be not applicable, it must be marked with N/a in the comments column.
The grounds for the rating for the criteria fulfillment should always be given in the comments field.
However, the grounds for the rating must always be given in all cases in which a criterion has not
been fulfilled or only fulfilled in part or where the criterion is deemed to be not applicable. As a general
principle, all the criteria in the LMS audit checklist are checked in an audit. The data from the previous
audit can be used for assistance here, but must not be transferred without checking them.

For non-conformities (rating of “insufficient”), appropriate corrective action must be specified and a
reasonable compliance period stipulated for the corrective action (between one and six months,
depending on the complexity of the non-conformity). A summary of the non-conformities and asso-
ciated corrective action and compliance period must be provided on the final page of the audit report
(section D). If a non-conformity is rectified immediately while the audit is still in progress, it still needs
to be documented in the LMS audit checklist; however, there is no need for corrective action to be
stipulated. Regardless of the corrective action which needs to be fulfilled, further suggestions for
improvement can always be made as well, of course. These should be denoted by an “R” (“recom-
mendation”).

Minimum criteria are minimum requirements which must be complied with and without which a field
operator cannot become mabagrown® certified. These are presented in bold in the checklist. On the
final page of the audit report the total number of all applicable criteria must be given, along with the

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total number of criteria which have been fulfilled (criteria which have been given a rating of “Excel-
lent” or “Compliant”). If at least one minimum criterion has not been fulfilled and/or > 20% of all
criteria have not been fulfilled, the audit is deemed to have been failed.

At the end of the audit report, in section D, the LMS auditor provides their assessment with regard
to the approval of the field operator:
 “Approved”: The field operator does not have any requirements for corrective action to fulfill
and can be certified immediately.
 “Approved with conditions”: The field operator can be certified but must implement the stipu-
lated corrective action within the compliance period.
 “Not approved” The field operator cannot be certified. It must implement the stipulated cor-
rective action and can then be audited again.
 “Immediately disqualified”: If non-conformities were found during the course of the audit
which are not capable of being corrected, the field operator is excluded from the LMS imme-
diately, and its goods are therefore immediately excluded from mabagrown® at the same
time.
This applies to the following non-conformities:
- Use of prohibited plant protection products
- Active fraud
- Fumigation of the goods
- Destruction of valuable ecosystems for cultivation

The LMS manager makes a decision depending on the audit result and the stipulated corrective
actions on the approval/certification of the field operator (“approved”, “approved with conditions”,
“not approved”) or ensures that the field operator is immediately disqualified in the event of infringe-
ments which are not capable of being corrected.

V. Monitoring of corrective action and purchase of mabagrown® goods

Goods are only allowed to be purchased from the field operators which have passed the audit (“ap-
proved” or “approved with conditions”). The field operators should therefore be audited before the
goods are purchased.

Goods from field operators which have been found to have non-conformities and which have there-
fore been given a rating of “approved with conditions” can continue to be purchased. However, the
implementation of the corrective actions must be monitored. When corrective action requirements
have been fulfilled, this must be documented by the LMS manager on the final page of the audit
report along with the date and signature. If a field operator fails to implement the corrective action
by the stipulated deadline, it must be barred until the next audit, i.e. its goods are then no longer
allowed to be purchased. The field operator will only be certified again in this case once it has passed
a new audit.

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However, if a field operator has been given a rating of “not approved”, its goods are no longer allowed
to be purchased as from the time of the audit. If the goods have already been purchased as
mabagrown® goods, they must be separated out. The goods are only allowed to be purchased again
or sold on to MBG again after the corrective action requirements have been fulfilled and a follow-up
audit has been passed.

In a follow-up audit, the implementation of the corrective action is checked. For a better overview in
this case, a new checklist needs to be filled in and the audit marked as a follow-up audit in checklist
section A. However, it is sufficient to focus on the criteria for which there were non-conformities in
the previous audit.

In the event of infringements which are not capable of being corrected (rating of “immediately dis-
qualified”), the field operator is immediately excluded from the LMS. Its goods are not allowed to be
purchased under any circumstances. If the goods have already been purchased as mabagrown®
goods, they must be separated out and must under no circumstances be sold to MB.
The field operator can be audited again in the next growing period/season. If the audit has been
passed, the goods of this season can be purchased.

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VI. Table 2: Preparation of the mabagrown® audit

Documentation Available?
Remarks
Yes No

Description of the field operators (Table 1)

Overview of all training provided for LMS auditors (train-

ing contents and attendance lists)

Overview of all training provided for field operators (train-

ing contents and attendance lists)

Availability of the LMS audit reports