1. Purpose
This policy sets out Murzo Group's approach to food defence, food fraud prevention, product authenticity, intentional adulteration, malicious contamination, economically motivated substitution, misrepresentation, and supply chain deception.
The purpose is to protect consumers, customers, products, brand integrity, legal compliance, and public trust.
2. Scope
This policy applies to food, ingredients, novel foods, insect-derived products, substrates, feed-related materials, packaging, samples, prototypes, labels, claims, storage, transport, supplier activity, manufacturing, co-packing, and distribution where Murzo Group has responsibility or influence.
It applies to employees, contractors, suppliers, manufacturers, laboratories, co-packers, warehouses, logistics providers, customers, agents, and other partners.
3. Food Defence Principles
Food defence focuses on preventing intentional harm or malicious interference.
- Restrict access to food, ingredients, packaging, labels, storage, production areas, systems, and records according to risk
- Protect products from tampering, sabotage, malicious contamination, theft, substitution, or unauthorised handling
- Review vulnerable points such as receiving, storage, open product, chemicals, water, labels, waste, dispatch, and transport
- Escalate suspicious behaviour, unauthorised access, unexplained product changes, tampering signs, or threats promptly
- Maintain incident response links with recall, cybersecurity, physical security, complaints, and crisis communication procedures
4. Food Fraud & Authenticity Principles
Food fraud involves deception for gain and may include substitution, dilution, mislabelling, counterfeiting, concealment, grey-market supply, document fraud, origin fraud, organic or sustainability claim fraud, and theft.
Murzo Group will take a risk-based approach to authenticity controls and will not knowingly sell, supply, describe, or use food or ingredients that are misrepresented, adulterated, counterfeit, illegally sourced, or unsupported by evidence.
5. Vulnerability Assessment
Murzo Group may assess food fraud vulnerability by considering product value, scarcity, market pressure, supply chain complexity, country of origin, historical fraud, testing difficulty, supplier reliability, claims, and detectability.
Higher-risk products may require enhanced supplier checks, authenticity testing, chain-of-custody evidence, audit, certificates, market monitoring, or restricted sourcing.
6. Supplier & Ingredient Controls
Suppliers may be required to provide authenticity, origin, specification, chain-of-custody, allergen, safety, certification, and traceability evidence.
Murzo Group may restrict supplier approval, require corrective action, conduct targeted checks, suspend supply, reject goods, or notify customers where supplier evidence is inadequate or fraud risk is unacceptable.
7. Tamper Evidence, Chain of Custody & Logistics
Products, ingredients, labels, packaging, and samples should be protected during receipt, storage, handling, transport, and dispatch.
Controls may include seal checks, delivery checks, approved carriers, restricted access, segregation, batch checks, temperature checks, label reconciliation, delivery documentation, and investigation of unexplained discrepancies.
8. Testing, Monitoring & Intelligence
Murzo Group may use testing, document review, supplier review, complaint trends, market intelligence, authority alerts, customer feedback, audit findings, and industry information to identify food fraud or authenticity risk.
Testing and monitoring should be proportionate to risk and may focus on species, origin, composition, contaminants, allergens, dilution, substitution, or claim verification.
9. Incidents & Escalation
Suspected food fraud, tampering, malicious contamination, stolen goods, counterfeit goods, substitution, false certificates, or authenticity failure must be escalated promptly.
Murzo Group may hold affected product, widen traceability checks, notify customers, notify authorities, suspend suppliers, initiate withdrawal or recall, preserve evidence, and seek legal or technical advice.
10. Records, Review & Responsibilities
Murzo Group will keep records of vulnerability assessments, supplier evidence, authenticity checks, testing, incidents, corrective actions, investigations, product holds, customer notifications, and review decisions.
Food safety leads, procurement leads, product owners, quality contacts, logistics contacts, security contacts, and authorised representatives are responsible for applying this policy. It will be reviewed periodically and after significant incidents, supplier changes, market disruption, or new fraud intelligence.
