Supplier Compliance V36

1st June, 2022

© 2021 HH Global Ltd. Proprietary and Confidential

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TCCC Product Compliance & Testing

Contents :
1. Prohibited Items
2. Factory Certification
3. Product Testing
4. Pre-Shipment Inspection

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Purpose
Read this carefully and ensure the process is understood and followed

The purpose of this document is to provide you (HHG vendor for CCEP) additional support to ensure you meet
your obligations in relation to the following:
1. Prohibited Items
2. Suppliers Factory Certification
• SGP & Acceptable Alternatives (full information can be found here: Supplier Guiding
Principles | The Coca-Cola Company (coca-colacompany.com).
3. Product testing, documentation and reporting
• GPM Supplier Submission Form
• High Risk Items
• Product Testing
4. Pre-shipment inspections, documentation and reporting

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1. Prohibited Items
As of Feb 2021 this includes ALL vegetable fibre or melamine food contact items (CCEP specific)

• PVC materials (Please note: PVC material may possibly be used in exceptional circumstances, namely for
POS items that do not touch the consumer. Written permission is to be obtained from HH Global before
proceeding)
• Glue kits (inflatable items must not include glue kits)
• Sharp objects or weapons: e.g.: swords, knives, firearms, archery, darts, ice-picks, fishing lures
• Products which contain chemical hazards (e.g. petroleum distillates)
• Apparel for children under 12 with drawstrings (e.g. hooded shirts)
• Apparel for children under 12
• Clothing not meeting flammability standards in the US, EU or any NWEN country
• Products with small magnets appealing to children
• Fragrances, Cosmetic products, e.g.: lip balm, nail polish, Tattoos (exceptions granted)
• Personal Protective Equipment (PPE), e.g. helmet
cont. /
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Prohibited Items / cont.
• Branded Equipment for dangerous sports: Skiing, snowboarding, parachuting, BASE jumping
• Gas-powered vehicle and/or Scooters
• Lawn & Garden electric/gas equipment (exceptions granted)
• Products with electrical or fire hazards, e.g.: halogen lamps, candle sticks, items with open flames
• Products related to an unhealthy lifestyle, e.g. cigarette lighters, ashtrays
• Drinking containers:
• With inner tumbler of liquid for extra cooling of beverage
• Nothing greater than 500ml serving size
• Pull-up nozzle/spout with less than 11.3 kg tension limit before breakage
• Fluorescent/glow sticks
• Window/windscreen suction cups below 44.5mm in diameter

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2. Suppliers Factory Certification: Supplier Guiding Principles (SGP)

IMPORTANT
Suppliers located, or cotton
produced in either
Turkmenistan, Uzbekistan or
the Xinjiang region of China
CANNOT be used

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Supplier’s Factory Certification: SGP or accredited alternative with
Mutual Recognition
HH Global will not accept a quote from a supplier for the following items, unless they have a valid SGP audit:
• A high risk item
• An item produced in a high risk country (regardless of spend level)
• An order value greater than $55,000 USD (for non-high risk items)

If there is no valid certification, you (not HH Global) should contact the approved companies (see slide 11) directly
at the earliest opportunity to request an SGP audit and obtain costs which you need to consider in your pricing.
The approved company will supply the results of the audit to TCCC Global compliance & you (the supplier who
commissioned them), not directly to HH Global.
A valid SGP (or approved alternative) certificate must be supplied to the HH Global buyer at the earliest
opportunity by you (the supplier). Failure to provide this by the time of final cost negotiations may result in you
being excluded from the opportunity.

(see next slide for SGP relating to EU stock)

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Supplier’s Factory Certification: SGP or accredited alternative with
Mutual Recognition
Stock Item from EU

• An SGP ASR, is NOT required for orders fulfilled from EU stock

IMPORTANT

If an item is purchased by HH Global from a supplier who fulfils the order from their EU stock,
the supplier is the ‘Importer of record’ and it is their responsibility to ensure the item meets all
EU standards

In this circumstance we do not need an SGP audit from the factory in which the items were
produced

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Supplier’s Factory Certification: SGP or accredited alternative with Mutual
Recognition

• No Purchase Order from HH Global or authorization to proceed to production will be issued to

you where a valid SGP ASR is required and has not been provided to HH Global.
• Factories with a Yellow or Green SGP audit rating will be approved for production, as well as
ones which have a valid CAPR
• Factories with an Orange rating will need to follow up with improvements and obtain a Yellow or
Green rating before being approved for production.
• Spanish factories all need to have a Green rating

Is an existing SGP certificate still Valid?

For Green & Yellow audit rating – 1-3 years validity will be accepted based on the nature of the
findings and Non Compliances from current and previous audits.

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Supplier’s Factory Certification: SGP or accredited alternative with
Mutual Recognition

It is critical that the following rules are clearly understood and complied with at all times.
We have seen non-compliance with these rules which has then incurred considerable
expense for the supplier.

The SGP certificate or accredited alternative supplied MUST relate to the factory the product(s)
are actually produced in.
If production needs to be moved to another location (for any reason), it is your obligation to
notify HH Global immediately. You can only proceed once permission has been granted by HH
Global for the change. The alternative factory MUST also have the approved certification in
place.

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Suppliers Factory Certification: SGP or accredited alternative with
Mutual Recognition
• For all trade marketing materials (print, promotions, POS, racks) SGP audit compliance applies at the point of
manufacture.
• Where a supplier is a trader, SGP audits must be undertaken at the point of manufacture – the SGP audit of the
Trader is not compliant.
• TCCC accepts Coca-Cola SGP and SMETA audit protocols through mutual recognition. AIM mutual recognition
must be completed on the same day. TCCC may accept audits undertaken by peer organizations on a case-by-
case basis – please discuss with HHG Global.
FOR CHINA –
• SGP audits are to be undertaken by TCCC approved audit companies: Intertek, TUV-SUD, ESTS
• For SMETA Mutual Recognition – the 3 above plus - UL, SGS, BV, Control Union
FOR EUROPE -
• For SGP audits / SMETA Mutual Recognition - 3 approved labs: Intertek, SGS and BV

• SGP audit reports must be shared with HH Global for verification or approval.
• The following 5 countries are deemed to be high risk and all manufacturing locations MUST be physically audited
regardless of level of spend. (China, Turkey, Indonesia, Pakistan & Bangladesh).
• Specifically relating to apparel items from Bangladesh; manufacturing locations must be part of the Bangladesh
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Accord or Alliance.
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SGP Rate & Assessment Timeline

The mutual
recognition process
confirms that
approved alternative
factory audits to
SGP ASR’s are valid
for one year.

CEPG have now

confirmed this
has been
changed to a 3
year validity

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3. Product Testing: GPM Supplier Submission Form
• If your submitted price is to be used as the basis of an HH Global quotation to CCEP, the HHG project
manager may ask you to complete the GPM Supplier submission form

• Ensure this is the GPM Submission form (004) published Oct 2019

• You need to complete a GPM supplier submission form if the project quoted is to be produced in a high risk
country or the order value is greater than €5,000 Euro

• The form is completed at this stage to avoid any delay once the quotation has been approved

• The form should be returned ASAP to the HH Global Project Manager

• A request to complete the GPM supplier submission form for a project does not guarantee that an order will be
placed by HH Global

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GPM Submission Form

2019 GPM Supplier Submission Form (004)

This updated excel form now consists of three tabs;

• Tab 1 is the main form, showing an image, name

and short/reduced product specification.

• Tab 2 includes the actual order details.

• Tabs 3 onwards show our detailed specification

document for each product (if multiple products are
ordered).

The supplier only completes the blue section on Tab 1.

All other areas are to be completed by HH Global

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QC Testing Documentation
The supplier must send an enquiry to one of the 3 accredited testing labs requesting a quote for testing, the
enquiry to the testing lab should include the following information:
1. State that it is a TCCC Project
2. Identify the target user and their age grading. All ages (for items like plush toy), 3+ or 14+/adult.
3. Product Name and Description of the Item(s)
4. The markets for distribution
5. State if there is individual packaging for the product. If there is, it must also be added to the test

When the supplier sends samples for testing, they must state the name of the factory producing the items
• For Hong Kong and China, 3 approved labs for product testing and inspection are Intertek, SGS and UL
• For Europe, 3 approved labs for product testing and inspection are Intertek, SGS and BV

Testing reports should be ready and presented by the supplier to the HH Global project
manager before production commences – any exceptions to this must be approved by
HH Global
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Product Testing Required
• Bespoke High Risk items MUST always undergo third party testing, to be arranged by you the supplier and
results submitted to HHG. The HH Global project manager will always advise if the items are deemed as being
High Risk
• Item produced in a High Risk country. These are defined as being China / Pakistan / Bangladesh / Turkey /
Indonesia.
• High Risk items from EU stock with an order value from HH Global to you (the supplier) greater than € 27,000.
• For Hong Kong and China, 3 approved labs for product testing and inspection are Intertek, SGS and UL
• For Europe, 3 approved labs: Intertek, SGS and BV
• Items produced for a joint promotion related to certain organisations. The HH Global project manager will
advise if this is the case as part of the original brief.
• The approved independent testing houses will define and undertake the QC testing requirements.
• Testing is required for all items and has to be done on a per P/O basis or under written agreement from HH
Global
• All testing reports need to be sent to the HH Global buyer
• Ink testing is included within the full product testing

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Where Product testing is NOT required;
Items supplied from stock held in the EU (with the exception stated in slide 17).
• In this case, you must update the Letter of conformity supplied with your Quote to include the HH Global
PO and Reference Number, this allows HH Global & CCEP to match this specific order to the declaration
you have provided as the importer of record that these goods are compliant with all EU regulations.

Bespoke Items NOT produced in a high risk country with an order value less than €27,000.
• In this case you must provide HH Global with a Letter of Conformity for the product to be distributed into
the country of delivery.

See the following slide for testing of inks

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Product Testing: INK

Bespoke Items NOT produced in a high risk country.

• Ink MUST be tested for lead. (Testing is NOT restricted to the TCCC approved 3rd
party suppliers: BV, SGS or Intertek).
• Testing results must be held by the supplier & made available if required.

Items supplied from stock held in the EU.

• A copy of the ink data sheet or recent test report will be acceptable. It must have
been issued 1 year or less from the date of order.
• No added testing is required, however all items MUST meet EU standards with the
support of a Letter of Conformity issued by the supplier
• If a product testing report already exists, please supply to HHG to help identify the
testing that has been undertaken.

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Furniture – Product specification
Please ensure the following information is provided within your product specification if the item is
classed as weight bearing furniture

• Maximum weight for 1 person to use

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4. Pre-shipment inspection
For Bespoke High Risk Items
Items produced in High Risk Countries – Bespoke production

• Pre-shipment inspections cannot be undertaken by the suppliers own workforce.

• Inspection costs must be included in your quotations for the job.
• For Hong Kong and China, 3 approved labs for inspection are Intertek, SGS and UL
• For Europe, 3 approved labs: Intertek, SGS and BV
• All Pre-shipment Inspection reports needs to be sent to HH Global buyer to get final approval before
supplier can proceed to shipment
• If the products pass the inspections and get the approval from HH Global, the order is completed, packed
and shipped in line with the HH Global purchase order

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Exception to the Compliance Processes
For any products supplied that are either of the following – NO audit or testing is required

• If the item is a well known global retail brand, for example; Apple, Panasonic, Sony, Samsung,
Philips, LG, Nokia, Seb, Tefal, Acer, Samsonite, Clipsonic, Delsey, Luxury/designer brands such
as Gucci etc

• If the item is not branded with any Coca-Cola brand names, with a value less than €100,000

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Extract from Standard Supplier Agreement – Points 6/10/13
(Where Adare is mentioned below, this could be interchangeable with HH Global

See your supplier agreement for full details, these are a selection of the key elements relating to compliance

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Extract from Standard Supplier Agreement – Points 6/10/13
(Where Adare is mentioned below, this could be interchangeable with HH Global

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Extract from Standard Supplier Agreement – Points 6/10/13
(Where Adare is mentioned below, this could be interchangeable with HH Global

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HH Global, the HH Global logo, and the HHub logo are trademarks or registered trademarks of HH Global Ltd.
All other trademarks are presumed owned by their respective companies.

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