Traceability & Batch Control Policy

1. Purpose

This policy sets out Murzo Group's approach to traceability, batch identification, lot control, product status, and recall readiness across relevant food, feed, substrate, farming, production, storage, supply, and distribution activities.

Its purpose is to support product safety, quality, regulatory compliance, responsible sourcing, incident response, and the ability to identify affected materials or products quickly and accurately.

2. Scope

This policy applies where Murzo Group, its group companies, suppliers, contractors, or partners handle, source, receive, process, pack, label, store, transport, sell, distribute, or dispose of traceable materials or products.

It may apply to:

• Food, feed, ingredients, substrates, packaging, processing aids, samples, trial batches, and finished products
• Insect-farming, food-production, product-development, research, storage, logistics, and supplier-management activities
• Contract manufacturing, co-packing, fulfilment, distribution, client projects, and third-party sites where Murzo Group retains responsibility or contractual oversight

3. Traceability Principles

Murzo Group aims to maintain traceability systems that can identify what was received, what was produced or handled, where it went, and who was responsible at each relevant stage.

• Traceability must be proportionate to product risk, legal duties, client requirements, and operational complexity
• Records should support one-step-back and one-step-forward traceability where food, feed, ingredients, substrates, or products enter or leave Murzo Group control
• Internal traceability should link inputs, process steps, equipment, dates, personnel, quantities, rework, waste, and finished batches where relevant
• Traceability information must be accurate, legible, retrievable, and protected from unauthorised alteration
• Systems should support targeted withdrawals or recalls and avoid unnecessary widening of affected product scope

4. Batch & Lot Identification

Materials and products requiring traceability must have a suitable identifier such as a batch number, lot code, delivery reference, production code, sample ID, or equivalent control reference.

• Batch identifiers must be unique enough to distinguish one traceable unit from another
• Batch size must be defined with regard to product risk, process control, recall practicality, and commercial impact
• Codes should not be reused in a way that could create ambiguity
• Split, combined, blended, reworked, relabelled, or repacked batches must retain links to original source batches
• Trial, sample, non-conforming, quarantined, or rejected batches must be clearly identifiable and controlled

5. Incoming Materials

Incoming traceable materials should be checked, recorded, and controlled before use or onward distribution.

Records may include:

• Supplier name, supplier batch or lot code, delivery date, product description, quantity, and condition on receipt
• Purchase order, delivery note, certificate of analysis, specification, allergen information, origin, or chain-of-custody documents where relevant
• Storage condition, expiry date, use-by or best-before date, temperature records, and inspection outcome where applicable
• Acceptance, rejection, quarantine, concession, or escalation decisions

6. Production, Handling & Processing Records

Where Murzo Group produces, transforms, handles, packs, labels, or prepares traceable products, batch records should identify what happened and when.

• Recipe, formulation, bill of materials, work order, process specification, or handling instruction used
• Input batches, quantities used, losses, yields, rework, waste, and finished output quantities
• Production date and time, equipment or line used, operator or responsible person, and relevant checks
• Critical control, quality, hygiene, allergen, temperature, cleaning, calibration, or inspection records where applicable
• Deviations, holds, concessions, corrective actions, and authorisations

7. Product Status, Quarantine & Release

Traceable materials and products must be controlled according to their status.

• Status categories may include received, awaiting inspection, quarantined, released, on hold, rejected, recalled, withdrawn, disposed, or returned
• Quarantined, rejected, suspect, or non-conforming products must be physically or systemically segregated to prevent unintended use
• Release decisions must be made by authorised persons and supported by suitable records
• Products must not be released if traceability, identity, safety, legal status, or quality is uncertain

8. Storage, Dispatch & Distribution

Storage and dispatch records must support identification of where products are located and where they have been sent.

• Warehouse, storage area, shelf, container, pallet, or location records should be maintained where relevant
• Dispatch records should identify customer or recipient, batch or lot code, quantity, date, destination, and transport details where applicable
• Temperature-controlled, high-risk, fragile, or time-sensitive products must be handled according to specified conditions
• Returns must be identified, assessed, and controlled before any decision to restock, rework, dispose, or investigate

9. Mass Balance & Reconciliation

Murzo Group may use mass balance checks to verify that traceability records are complete and plausible.

• Inputs, outputs, retained samples, waste, rework, losses, disposals, and stock on hand should be reconcilable where relevant
• Unexplained discrepancies must be investigated and corrected
• High-risk products, allergens, regulated materials, substrates, or safety-critical batches may require enhanced reconciliation

10. Withdrawal, Recall & Incident Readiness

Traceability and batch records must support prompt investigation, withdrawal, recall, notification, and communication if a product, input, or process is suspected to be unsafe, non-compliant, contaminated, mislabelled, or otherwise unsuitable.

• Murzo Group should be able to identify affected batches, suppliers, customers, locations, quantities, and status as quickly as reasonably practicable
• Relevant products may be placed on hold while a concern is assessed
• Where food or feed supplied by Murzo Group may be unsafe or legally non-compliant, appropriate competent authorities and affected business customers must be notified where required
• Where unsafe food has reached consumers, recall communication and authority engagement must be considered promptly
• Root cause analysis and corrective action should follow significant traceability failures, withdrawals, recalls, or incidents

11. Supplier, Contractor & Partner Controls

Suppliers, contractors, co-packers, storage providers, logistics providers, and other partners may be required to maintain compatible traceability and batch-control systems.

• Contracts or specifications may require lot coding, batch records, certificates, recall cooperation, retention samples, audit rights, and incident notification
• Murzo Group may request traceability evidence before accepting, releasing, or distributing products
• Partners must notify Murzo Group promptly of any issue that may affect supplied materials, products, batch identity, safety, legality, or recall status

12. Records, Retention & Data Integrity

Traceability records must be retained for a period appropriate to the product type, shelf life, legal requirements, client requirements, and risk profile.

• Records may be paper-based, digital, or hybrid, provided they are controlled, readable, retrievable, and protected
• Changes to records must be attributable and should not obscure the original information
• Access to records must be limited to authorised persons where records contain confidential, supplier, customer, personal, or commercially sensitive information
• Records must be disposed of securely when no longer required

13. Verification & Review

Murzo Group may verify traceability systems through document review, internal checks, supplier review, stock reconciliation, mock recall exercises, or targeted batch tracing exercises.

• Verification should test whether records can identify source, movement, status, and destination of affected batches
• Corrective actions must be assigned and tracked where gaps are found
• This policy should be reviewed when operations, products, suppliers, systems, law, client requirements, or risk profile change

14. Responsibilities

Managers, project owners, production leads, procurement leads, quality leads, and authorised Murzo Group representatives are responsible for ensuring that traceability and batch-control arrangements are suitable for their activities.

Workers, contractors, and suppliers must follow batch coding, labelling, segregation, record-keeping, release, hold, dispatch, and incident-reporting requirements. Any missing, incorrect, ambiguous, or suspicious traceability information must be reported promptly.