Pretty much, try to identify every instance of an employee carrying out any kind of activity that could be an opportunity to mitigate against food fraud, and integrate instructions into your policies and procedures. Sounds a bit vague, but here’re a couple of examples:
Challenge policy/stranger danger
Write a policy that states your company’s intention to challenge any individuals on site if they aren’t recognised. Incorporate this expectation into the induction training for all employees and detail the actions to be taken if they encounter anyone they don’t recognise.
Goods intake procedure
Incorporate inspection of vehicles, seals, and packaging integrity into your goods intake procedure and -if appropriate- include documented checks on your intake records. Make sure the procedure details actions to be taken in the event that evidence of tampering is discovered.
Storage and handling
Similar to intake controls, any RMs, WIP, or products should be stored covered and ideally in such a way as to prevent tampering. Procedures should detail actions to be taken in the event that evidence of tampering is discovered.
Supplier approval and performance monitoring
Include instructions for carrying out a vulnerability assessment at raw material approval. Make sure to include regular review of developing risks and horizon scanning. As a matter of policy, preferentially source raw materials from suppliers with favourable risk profiles over higher-risk sources.
Security and movement of people procedure
Make it policy to lock all security entrances and exits at all times when not in use. Include this in your procedure for people traffic and retain training records.
IT and cyber security
In general, it’s a good idea to have dedicated training on recognition of suspicious emails and dangerous attachments. There are various ways electronic security can be compromised – ranging from malicious software through phishing scams.
Make it company policy that if any employee witnesses suspicious or malicious activity, they are expected to escalate using your confidential reporting system.
Dispatch and transport
Write a policy to determine whether tamper-evident tape (or similar control) is appropriate for packaged product and incorporate the outcome into manufacturing instructions and include inspection at dispatch.
Manufacturing and recipe control
Identify all recipes that could be subject to substitution of raw materials and produce work instructions detailing permissible substitutions. For example, free-range egg may be used in place of caged egg, but caged egg may not be used in place of free-range egg.
You’ll probably find your facilities and processes have more specific opportunities for fraud risk mitigation, and it’s quite useful to look at each process step for vulnerabilities… But this is the sort of thing you can be looking at to make up a system for control across your business.