Product Recall & Withdrawal Policy

1. Purpose

This policy sets out Murzo Group's approach to product withdrawal, product recall, incident escalation, customer communication, authority notification, traceability, and corrective action.

References to Murzo Group include Murzo Group and its relevant group companies unless the context requires otherwise. The purpose of this policy is to protect consumers, business customers, end users, animals, the environment, brand integrity, and legal compliance where a product may be unsafe, defective, mislabelled, non-compliant, contaminated, incorrectly supplied, or otherwise unsuitable for continued sale or use.

2. Scope

This policy applies to Murzo Group, its group companies, workers, contractors, suppliers, manufacturers, co-packers, logistics providers, distributors, online channels, and business partners where they are involved in products, materials, samples, ingredients, packaging, components, or finished goods supplied under Murzo Group control or responsibility.

It may apply to food, feed, ingredients, substrates, insect-derived products, consumer products, packaging, samples, prototypes, development batches, private-label goods, client projects, imported goods, and products distributed through third-party or online channels.

3. Definitions

A withdrawal is the removal of a product from the supply chain before it has reached consumers or end users. A recall is the removal of a product from the supply chain where consumers or end users are advised to take action, such as stopping use, returning, disposing of, repairing, replacing, or modifying the product.

Corrective action may include product hold, withdrawal, recall, relabelling, repair, modification, suspension of sale, marketplace delisting, public warning, disposal, destruction, or other measures required to reduce risk.

4. Policy Principles

Murzo Group will take a precautionary, proportionate, evidence-led, and documented approach to product safety and incident response.

• Consumer and end-user safety takes priority over commercial considerations
• Potentially affected products must be placed on hold where safety, legality, identity, or suitability is uncertain
• Withdrawals and recalls must be escalated quickly and managed by authorised people
• Traceability records must support identification of affected batches, locations, customers, quantities, and status
• Communications must be accurate, timely, clear, and approved before release wherever practicable
• Root cause analysis and corrective action must follow significant incidents, withdrawals, recalls, or near misses

5. Incident Triggers

A potential withdrawal or recall must be considered where there is information suggesting that a product may present a safety, legal, quality, security, or suitability risk.

Triggers may include:

• Microbiological, chemical, allergen, physical, biological, radiological, or foreign-body contamination
• Undeclared allergens, incorrect ingredients, incorrect claims, missing warnings, wrong packaging, or mislabelling
• Unsafe design, defective components, product failure, fire, choking, electrical, mechanical, chemical, or injury risk
• Supplier notification, authority notification, customer complaint, consumer complaint, adverse reaction, illness, injury, or near miss
• Traceability failure, batch mix-up, unauthorised substitution, counterfeit concern, tampering, malicious contamination, or security issue
• Non-compliance with product specification, legal requirement, certification, client requirement, import condition, or market authorisation

6. Escalation & Initial Control

Any worker, contractor, supplier, or business partner who becomes aware of a potential product safety or compliance issue must report it promptly to the relevant Murzo Group manager, project owner, quality lead, food safety lead, compliance lead, or authorised representative.

• Affected stock must be identified and placed on hold where practicable
• Sales, dispatch, listing, fulfilment, or use may be suspended while the issue is assessed
• Relevant evidence must be preserved, including samples, labels, records, photos, complaints, test results, emails, and supplier information
• Initial facts must be recorded, including product name, batch or lot code, dates, quantities, locations, customers, known distribution, and immediate actions

7. Risk Assessment & Decision Making

Murzo Group will assess the nature, likelihood, severity, exposure, distribution, detectability, consumer or end-user vulnerability, and legal status of the issue before deciding the appropriate action.

Decision making may consider:

• Whether the product is harmful, unsafe, unfit, defective, mislabelled, incorrectly supplied, or legally non-compliant
• Whether the product has reached consumers, business customers, distributors, retailers, online customers, or other end users
• Whether a withdrawal, recall, public warning, direct customer notification, authority notification, or other corrective action is required
• Whether affected product can be corrected, relabelled, repaired, replaced, modified, disposed of, destroyed, or safely returned
• Whether specialist advice, laboratory analysis, insurer notification, legal review, or external technical advice is needed

8. Traceability & Affected Product Identification

Murzo Group must use traceability and batch records to identify affected products as quickly and accurately as reasonably practicable.

• Trace-back activity should identify suppliers, ingredients, components, packaging, process steps, dates, and source batches
• Trace-forward activity should identify customers, distributors, online channels, destinations, quantities, dates, delivery references, and stock status
• Where uncertainty remains, Murzo Group may widen the affected scope as a precaution
• Mass balance and stock reconciliation should be used where relevant to confirm product accounted for, product remaining, product returned, and product still in circulation

9. Product Hold, Segregation & Control

Products subject to investigation, withdrawal, recall, return, rejection, or disposal must be controlled to prevent unintended sale, use, distribution, or release.

• Held products should be physically segregated, system blocked, clearly marked, or otherwise controlled
• Stock status should be visible to relevant teams, warehouses, fulfilment providers, and logistics partners
• Returned or recovered products must not be restocked, reworked, relabelled, or disposed of without authorisation
• Disposal, destruction, repair, relabelling, or re-release decisions must be documented

10. Authority Notification

Where a product may be unsafe, harmful, unfit, non-compliant, or otherwise subject to regulatory notification, Murzo Group will notify the appropriate competent authority or enforcement body as required.

Depending on the product and jurisdiction, this may include local authority food teams, port health authorities, the Food Standards Agency, Food Standards Scotland, Trading Standards, the Office for Product Safety and Standards, market surveillance authorities, online marketplace reporting routes, or relevant overseas authorities.

Authority notifications should be clear, factual, and supported by available information about product identity, batch details, risk, distribution, corrective action, communication plans, and contact details.

11. Customer, Consumer & Public Communication

Murzo Group will provide appropriate information to affected customers, consumers, distributors, retailers, partners, and end users where a withdrawal, recall, or warning is required.

• Business-to-business notices should identify affected products, batch codes, quantities, actions required, response deadline, and contact details
• Consumer recall notices should be clear, prominent, and easy to act on
• Recall communications should state what the product is, what the issue is, what risk may exist, what consumers or end users should do, and how to obtain help
• Communication routes may include direct email, phone, customer letters, website notices, point-of-sale notices, marketplace notices, social media, press statements, or authority-issued alerts
• Public statements must be controlled and must not speculate, mislead, blame others prematurely, or disclose confidential information unnecessarily

12. Recall Execution & Effectiveness Checks

Where a recall is required, Murzo Group will manage the recall using a documented action plan proportionate to the risk and distribution of the affected product.

• Responsibilities, deadlines, contacts, affected products, distribution routes, and communication channels must be defined
• Responses from customers, distributors, retailers, marketplaces, and logistics providers should be tracked
• Returned, corrected, destroyed, or unrecovered quantities should be reconciled against known distribution
• Effectiveness checks may include follow-up calls, written confirmations, stock checks, marketplace checks, web checks, and authority updates
• Significant recalls must remain open until an authorised person confirms that required actions have been completed or appropriately closed

13. Suppliers, Contractors & Partners

Suppliers, manufacturers, co-packers, logistics providers, fulfilment partners, online marketplaces, and other partners must cooperate with Murzo Group during product safety investigations, withdrawals, recalls, and corrective actions.

• Partners must promptly notify Murzo Group of any concern that may affect product safety, legality, traceability, labelling, claims, or recall status
• Contracts, specifications, or purchase terms may require traceability, incident notification, recall cooperation, product hold, record access, and corrective action support
• Murzo Group may suspend use of a supplier, contractor, or partner where cooperation or product control is inadequate

14. Records & Decision Logs

Murzo Group must keep appropriate records of product withdrawal, recall, and incident-response activity.

Records may include:

• Incident reports, decision logs, risk assessments, authority notifications, and communication approvals
• Product identity, batch details, labels, specifications, distribution data, stock status, customer lists, and traceability records
• Customer responses, return quantities, destruction certificates, corrective actions, supplier responses, and closure decisions
• Root cause analysis, lessons learned, training records, mock recall exercises, and policy reviews

15. Root Cause Analysis & Corrective Action

Following a significant incident, withdrawal, recall, or near miss, Murzo Group will investigate the cause and define actions to reduce the risk of recurrence.

• Root cause analysis should consider people, process, supplier, equipment, system, labelling, formulation, storage, transport, communication, and management-control factors
• Corrective actions must be assigned to owners with target dates and completion evidence where appropriate
• Preventive actions may include supplier review, specification changes, label changes, process redesign, training, traceability improvement, system controls, testing, or audit
• Repeat incidents must be escalated and reviewed for wider management action

16. Testing, Training & Preparedness

Murzo Group may test recall readiness through mock recall exercises, traceability checks, scenario exercises, contact-list reviews, stock-reconciliation checks, and document reviews.

• Mock recall exercises should test whether affected product can be traced quickly and accurately
• Relevant workers and contractors should understand how to report product safety concerns and who to contact
• Emergency contacts, customer contacts, supplier contacts, logistics contacts, and authority contacts should be maintained where relevant
• Lessons from exercises, incidents, complaints, audits, and supplier issues should be used to improve readiness

17. Review

This policy should be reviewed periodically and when Murzo Group changes products, suppliers, markets, distribution channels, systems, legal requirements, competent authority guidance, product risk profile, or incident-response arrangements.

18. Responsibilities

Managers, product owners, food safety leads, quality leads, compliance leads, procurement leads, operations leads, and authorised Murzo Group representatives are responsible for implementing this policy within their areas.

Workers, contractors, suppliers, and partners must report product concerns promptly, follow product hold and communication instructions, preserve records, cooperate with investigations, and support withdrawal or recall activity where required.