SSAFE

Food Fraud Vulnerability Assessment Tool

December 16th 2015

Table of Contents

Foreword/Acknowledgments ............................................................................... 3
Legal Considerations/Disclaimer .......................................................................... 3
Terms and Definitions .......................................................................................... 4
Introduction ......................................................................................................... 6
Scope of the Tool ................................................................................................. 7
Decision Tree ........................................................................................................ 8
The Assessment Team .......................................................................................... 9
How to Use this Guideline – the Guideline Structure ........................................ 10
The Components .................................................................................................................. 10
The Questions ....................................................................................................................... 10

ANNEX I - References & Further Reading ........................................................... 11

References ............................................................................................................................ 11
Further Reading .................................................................................................................... 13

ANNEX II - The Scientific Framework Behind the Tool ....................................... 14

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Foreword/Acknowledgments
This Food Fraud Vulnerability Self-Assessment Tool has been developed by SSAFE in
collaboration with Wageningen University and Research Center and VU University
Amsterdam. SSAFE has also collaborated with PwC to develop an electronic version of this
tool.

Legal Considerations/Disclaimer
SSAFE DOES NOT MAKE ANY REPRESENTATION OR WARRANTY REGARDING THE
DESIGNATIONS EMPLOYED AND THE CONTENTS OF MATERIAL IN THIS PUBLICATION, OR
WHETHER THE INFORMATION IN THIS PUBLICATION IS APPROPRIATE OR APPLICABLE TO
ANY PARTICULAR FACTUAL SITUATION. ALTHOUGH SSAFE HAS MADE EFFORTS TO VERIFY
THE INFORMATION IN THIS PUBLICATION, THE CONTENTS OF THIS PUBLICATION ARE
PROVIDED AS-IS, AND YOUR USE OF THIS PUBLICATION IS AT YOUR OWN RISK. YOU ARE
SOLELY RESPONSIBLE FOR ANY INTERPRETATION AND/OR USE OF THE INFORMATION IN
THIS PUBLICATION. NEITHER SSAFE, NOR ANY OF ITS MEMBERS, AFFILIATES, OFFICERS OR
DIRECTORS, NOR ANY OF ITS AGENTS OR ANY OTHER PARTY INVOLVED IN CREATING,
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POSSIBILITY OF ANY SUCH DAMAGES.

The foregoing Disclaimer is limited and amended to the extent required by law in specific
jurisdictions. This Disclaimer is in addition to the terms and limitations in the SSAFE Website
Terms of Use, located at http://www.ssafe-food.org/ssafe-terms-of-use/

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Terms and Definitions

Food Fraud
A collective term encompassing the deliberate and intentional substitution, addition,
tampering, or misrepresentation of food, food ingredients or food packaging, labelling,
product information, or false/misleading statements made about a product for economic
gain.

More specifically the following types of food fraud considered in this tool are:
• Dilution is the process of mixing a liquid ingredient with high value with a liquid of
lower value.
• Substitution is the process of replacing an ingredient or part of the product of high
value with another ingredient or part of the product of lower value.
• Concealment is the process of hiding the low quality of a food ingredients or product.
• Mislabeling is the process of placing false claims on packaging for economic gain.
• Unapproved enhancement is the process of adding unknown and undeclared
materials to food products in order to enhance their quality attributes.
• Counterfeiting is the process of copying the brand name, packaging concept, recipe,
processing method etc. of food products for economic gain.
NOTE: Grey market production/theft/diversion is out of scope for this tool. However, it may
be picked up anyway.

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Food Fraud Mitigation Measures
Hard and soft actions that are taken to combat against identified food fraud vulnerabilities.

Food Fraud Vulnerability
Susceptibility or exposure to a gap or deficiency that could place consumer health at risk
and/or have an economic or reputational impact on a food company’s operations if not
addressed.

Food Fraud Vulnerability Assessment

The process of collection and evaluation of information on potential food fraud risk factors
as well as mitigation measures which, when combined, determine the actual fraud
vulnerability.

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Introduction

Recent global food fraud scandals have further highlighted the need to strengthen
companies’ ability to mitigate against the risks of food fraud within their organizations and
across their supply chain. Authorities, consumers and other stakeholders expect food
companies to act proactively and mitigate against food fraud risks.

However, current food safety management systems are not designed for food fraud
mitigation, which requires a different perspective and skill set than food safety or food
defense. For instance, socio-economic issues and past food fraud incidents are not included
in traditional food safety or food defense risk assessments. Vulnerabilities relating to food
fraud can also occur outside the traditional activities of a company.

In this context, SSAFE has collaborated with Wageningen UR and VU University Amsterdam
to prepare a science-based tool for assessment of a company’s food fraud vulnerabilities and
provide a basis to develop company-specific intervention strategies.

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Scope of the Tool

The Food Fraud Vulnerability Assessment Tool provides companies with an assessment tool
that can be used in the company’s systematic process of assessing its vulnerabilities to food
fraud.

This tool refers to food fraud as intentional food adulteration (i.e. dilution, substitution,
concealment, unapproved enhancements, mislabelling) and counterfeiting for economic
gain only. Ideologically motivated acts in the food supply chain are out of scope.

This tool can be used by businesses across the food supply chain, irrespective of size,
geographical location or type of food business.

This tool can support companies in the implementation of the new GFSI requirements for
food fraud mitigation.

In this tool, references are made to sources and to other tools if more specific or further in-
depth analysis is required.

This tool provides a profile of a company’s potential food fraud vulnerability, and this profile
can form the basis for the development of company specific interventions to mitigate the
identified vulnerabilities.

This tool does not provide specific recommendations for mitigation techniques. However,
some of the referenced tools and information sources may provide such additional support.

This tool is not designed to detect fraud nor predict future food fraud incidents. However, by
addressing identified vulnerabilities, unknown fraudulent activities may be identified and
provide companies with the opportunity to stop them from occurring.

Companies can use this tool and its outcomes as an integral part of their food safety
management system.


SSAFE Food Fraud Vulnerability Assessment Tool

NOTE: Food fraud vulnerabilities are dynamic and may change over time. Therefore, this is a
“living tool” that requires regular usage.

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Decision Tree
The tool can be used to assess the vulnerability to fraud at an ingredient, product, brand,
facility, country or company-wide level and, where applicable, major direct suppliers and
customers. To help determine where to apply the tool (i.e. set your scope), the following
Decision Tree, or pre-filter, can be used.

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The Assessment Team
An assessment of food fraud vulnerabilities requires a wide range of expertise. Depending
on the selected scope of the assessment, knowledge with regard to general controls (e.g.,
internal audits, security, QA, laboratory analyses, external audits, supply chain),
procurement, finance and other management functions could be required. The tool provides
advice regarding what type of expertise may be required to answer each question.

Large companies should compose a multifunctional team, whereas smaller companies might
need external support from subject experts or consultants.

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How to Use this Guideline – the Guideline Structure

The Components

The Food Fraud Vulnerability Assessment Tool has seven parts:
i. A general information sheet regarding company information and the team that
completed the information in the tool
ii. A decision tree to help the user decide where to apply the tool
iii. Fifty assessment questions
iv. Main spider webs providing a general overview of the findings
v. Detailed spider webs providing further insight into the findings
vi. Outputs enabling the user to prepare potential mitigation strategies and techniques
for identified vulnerabilities
vii. A final report summarizing the outcome of the assessment



The Questions

The tool includes fifty questions for food fraud vulnerability assessment, and it is structured
in two dimensions. The first dimension involves the elements affecting criminal behaviour,
i.e. opportunities, motivations, and control measures. The second dimension concerns the
company and the layers of its external environment, i.e. its direct suppliers and customers,
its supply chain, and the (inter)national governance environment.

The opportunities section includes indicators related to product and process characteristics,
features of the chain/industry network, and historical evidence of fraud with particular food
products and ingredients.

The motivations section includes indicators for organizational aspects such as business
culture, historical offenses, and economic conditions of the company, suppliers and
customers. The indicators for motivations are subdivided according to the second dimension
– the environmental layers. Indicators are provided for the own company, the direct
suppliers, and the wider environment.
SSAFE Food Fraud Vulnerability Assessment Tool

The control measures section consists of 19 indicators for mitigation and contingency
control measures. A subdivision is provided for the environmental layers, i.e. the internal
hard controls, internal soft controls, and external controls at the level of the direct
suppliers/customers and the wider environment.

For each opportunity and motivations indicator, three descriptions are provided that reflect
three risk levels (low, moderate, and high). Similarly, for each control indicator, three
descriptions are provided to reflect the level of control. The description that reflects the
company situation needs to be selected for each indicator.

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 ANNEX I - References & Further Reading

References

Business Culture
Cohen, D. V. (1995). "Ethics and crime in business firms: Organizational culture and the impact of anomie." The
Legacy of Anomie Theory 6: 183-206.
Kaptein, M. (2008). "Developing a measure of unethical behavior in the workplace: A stakeholder perspective."
Journal of Management 34(5): 978-1008.
Kaptein, M. (2008). "Developing and testing a measure for the ethical culture of organizations: The corporate
ethical virtues model." Journal of Organizational Behavior 29(7): 923-947.
Kaptein, M. (2011). "Understanding unethical behavior by unraveling ethical culture." Human Relations 64(6):
843-869.

Conceptual Underpinning Management Systems
Kirezieva, K., J. Nanyunja, et al. (2013). "Context factors affecting design and operation of food safety
management systems in the fresh produce chain." Trends in Food Science & Technology 32(2): 108-
127.
Kirezieva, K., L. Jacxsens, et al. (2013). "Assessment of Food Safety Management Systems in the global fresh
produce chain." Food Research International 52(1): 230-242.
Luning, P. A., L. Bango, et al. (2008). "Comprehensive analysis and differentiated assessment of food safety
control systems: a diagnostic instrument." Trends in Food Science & Technology 19(10): 522-534.
Luning, P. A., W. J. Marcelis, et al. (2009). "Systematic assessment of core assurance activities in a company
specific food safety management system." Trends in Food Science & Technology 20(6–7): 300-312.
Luning, P. A., W. J. Marcelis, et al. (2011). "A tool to diagnose context riskiness in view of food safety activities
and microbiological safety output." Trends in Food Science & Technology 22, Supplement 1: S67-S79.

Economic Circumstances
Jenkins, A. and J. Braithwaite (1993). "Profits, pressure and corporate lawbreaking." Crime, Law and Social
Change 20(3): 221-232.
Martin, K. D., J. B. Cullen, et al. (2007). "Deciding to bribe: A cross-level analysis of firm and home country
influences on bribery activity." Academy of Management Journal 50(6): 1401-1422.
May, P. J. (2004). "Compliance motivations: Affirmative and negative bases." Law & Society Review 38(1): 41-
68.
McKendall, M. A. and J. A. Wagner III (1997). "Motive, opportunity, choice, and corporate illegality."
Organization Science 8(6): 624-647.
Orlitzky, M., F. L. Schmidt, et al. (2003). "Corporate social and financial performance: A meta-analysis."
Organization studies 24(3): 403-441.
SSAFE Food Fraud Vulnerability Assessment Tool

Simpson, S. S. and M. Rorie (2011). "Motivating Compliance: Economic and Material Motives for Compliance."
Explaining Compliance: Business Responses to Regulation: 59.


Empirical Data Management Systems
Luning, P. A., K. Kirezieva, et al. (2015). "Performance assessment of food safety management systems in
animal-based food companies in view of their context characteristics: A European study." Food Control
49: 11-22.
Osés, S. M., P. A. Luning, et al. (2012). "Food safety management system performance in the lamb chain." Food
Control 25(2): 493-500.
Sampers, I., H. Toyofuku, et al. (2012). "Semi-quantitative study to evaluate the performance of a HACCP-based
food safety management system in Japanese milk processing plants." Food Control 23(1): 227-233.

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Sampers, I., L. Jacxsens, et al. (2010). "Performance of Food Safety Management Systems in Poultry Meat
Preparation Processing Plants in Relation to Campylobacter spp. Contamination." Journal of Food
Protection 73(8): 1447-1457.

Food Fraud Occurrence and Analytical Methods
Aylott, R. (2013). Chapter 16 - Analytical Strategies Supporting Protected Designations of Origin for Alcoholic
Beverages. Comprehensive Analytical Chemistry. G. Miguel de la and G. Ana, Elsevier. Volume 60: 409-
438.
Capuano, E., R. Boerrigter-Eenling, et al. (2013). "Analytical authentication of organic products: an overview of
markers." Journal of the Science of Food and Agriculture 93(1): 12-28.
Cubero-Leon, E., R. Peñalver, et al. (2014). "Review on metabolomics for food authentication." Food Research
International 60(0): 95-107.
Esslinger, S., J. Riedl, et al. (2014). "Potential and limitations of non-targeted fingerprinting for authentication
of food in official control." Food Research International 60(0): 189-204.
Lopez, M. I., E. Trullols, et al. (2014). "Multivariate screening in food adulteration: untargeted versus targeted
modelling." Food Chemistry 147: 177-181.
Luykx, D.M.A.M. and S.M. van Ruth (2008). “A review of analytical methods for determining the geographical
origin of food products.” Food Chemistry 107: 897-911.
Manning, L. and J. M. Soon (2014). "Developing systems to control food adulteration." Food Policy 49, Part
1(0): 23-32.
Shears, P. (2010). "Food fraud - a current issue but an old problem." British Food Journal 112(2): 198-213.
Spink, J. and D. C. Moyer (2011). "Defining the Public Health Threat of Food Fraud." Journal of Food Science
76(9): R157-R163.
Spink, J. and D. C. Moyer (2013). "Understanding and combating food fraud." Food Technology 67(1): 30-35.
Tähkäpää, S., R. Maijala, et al. (2014). "Patterns of food frauds and adulterations reported in the EU Rapid
Alarm System for Food and Feed and in Finland." Food Control 47: 175-184.

Historical Evidence of Criminal Offences
Baucus, M. S. and J. P. Near (1991). "Can illegal corporate behavior be predicted? An event history analysis."
Academy of Management Journal 34(1): 9-36.
Piquero, N. L. and D. Weisburd (2009). Developmental trajectories of white-collar crime. The Criminology of
White-collar Crime, Springer: 153-171.
van Onna, J. H. R., V. R. van der Geest, et al. (2014). "Criminal Trajectories of White-collar Offenders." Journal of
Research in Crime and Delinquency: 1-26 DOI: 10.1177/0022427814531489 .

Organizational Strategy
Agnew, R., N. L. Piquero, et al. (2009). General strain theory and white-collar crime. The Criminology of White-
collar Crime, Springer: 35-60.
Huisman, W. (2015) Criminogenic Organizational Properties and Dynamics. In: Benson, M.B., F.T. Cullen and S.
von Slyke (ed.) The Oxford Handbook of White-Collar Crime, Oxford: Oxford University Press.
SSAFE Food Fraud Vulnerability Assessment Tool

Passas, N. (1990). "Anomie and corporate deviance." Contemporary Crises 14(2): 157-178.
Simpson, S. S., N. L. Piquero, et al. (2002). "Rationality and corporate offending decisions." Rational Choice and
Criminal Behavior: Recent Research and Future Challenges 32: 25.
Wang, X. and K. Holtfreter (2011). "The effects of corporation-and industry-level strain and opportunity on
corporate crime." Journal of Research in Crime and Delinquency 49(2): 151-185.

Legal Framework
Huisman, W. (2014) Compliance and corporate crime control, in: Weisburd, D. and G.J.N. Bruinsma (eds.) The
Encyclopedia of Criminal Justice, New York: Springer.
Huisman, W. and J. van Erp (2013). "Opportunities for Environmental Crime A Test of Situational Crime
Prevention Theory." British Journal of Criminology 53(6): 1178-1200.
Kagan, R. A. and J. T. Scholz (1980). The “criminology of the corporation” and regulatory enforcement
strategies. Organisation und Recht: 352-377.
Paternoster, R. and S. Simpson (1996). "Sanction threats and appeals to morality: Testing a rational choice
model of corporate crime." Law and Society Review: 549-583.

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Managerial Control Measures
Miceli, M. P., J. P. Near, et al. (2009). "A word to the wise: How managers and policy-makers can encourage
employees to report wrongdoing." Journal of Business Ethics 86(3): 379-396.
Miceli, M. P., J. P. Near, et al. (2012). "Predicting employee reactions to perceived organizational wrongdoing:
Demoralization, justice, proactive personality, and whistle-blowing." Human Relations 65(8): 923-954.
Parker, C. and S. Gilad (2011). "Internal corporate compliance management systems: Structure, culture and
agency." Explaining Compliance: Business responses to regulation, Christine Parker and Vibeke
Nielsen, eds., Edward Elgar.
Parker, C. and V. L. Nielsen (2008). "Corporate compliance systems: could they make any difference?"
Administration & Society: doi: 10.1177/0095399708328869.


Further Reading
BSI (2014). PAS 96 Guide to Protecting and Defending Food and Drink from Deliberate Attack.
http://shop.bsigroup.com/Browse-by-Sector/Food--Drink/PAS-96-2014/.
Campden BRI (2014). TACCP (Threat Assessment and Critical Control Point): a practical guide 2014 (Guideline
G72). http://www.campdenbri.co.uk/publications/pubDetails.php?pubsID=4640..
De Lange, E. (2013). Food Crisis, Fraud in the Food Chain, and Control Thereof.
http://www.europarl.europa.eu/oeil/popups/ficheprocedure.do?lang=en&reference=2013/2091(INI).
Elliott, C. (2014). Elliott Review into the Integrity and Assurance of Food Supply Networks – Final Report.
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/350726/elliot-
review-final-report-july2014.pdf.
European Commission (2015). RASFF – Food and Feed Safety Alerts.
http://ec.europa.eu/food/safety/rasff/index_en.htm.
FMI/GMA Trading Partner Alliance (2014). Brand Protection and Supply Chain Integrity: Methods for
Counterfeit Detection, Prevention and Deterrence. A Best Practices Guide.
http://www.gmaonline.org/file-
manager/Collaborating_with_Retailers/GMA_Inmar_Brand_Protection.pdf.
Food and Drink Federation (2015). Food Authenticity – Five Steps to Help Protect your Business from Food
Fraud. http://www.fdf.org.uk/corporate_pubs/Food-Authenticity-guide-2014.pdf.
FoodShield (2015). Economically Motivated Adulteration Databases. https://www.foodshield.org/discover-
tools-links/tools/.
Gee, J., L. Jack, et al. (2014). Minimising Fraud and Maximising Value in the UK Food and D4rink Sector 2014.
http://www.port.ac.uk/media/contacts-and-departments/icjs/ccfs/PKF_LittleJohn_-
_Fraud_in_the_food_sector_report.pdf.
USP (2014). FCC Forum December 2014 Appendix XVII: Guidance on Food Fraud Mitigation.
http://www.usp.org/sites/default/files/usp_pdf/EN/fcc/Notices/guidance_on_food_fraud_mitigation.
pdf.
USP (2015). USP Food Fraud Databank. http://www.foodfraud.org/node?destination=node.
Wilson, B. (2008). Swindled: The Dark History of Food Fraud, from Poisoned Candy to Counterfeit Coffee,
SSAFE Food Fraud Vulnerability Assessment Tool

Princeton: Princeton University Press, 400 pp.

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ANNEX II - The Scientific Framework Behind the Tool
The often-cited principle in food fraud mitigation is “Think like a criminal.” Criminology is the
science studying criminal behavior and criminal decision-making. This includes fraud, which
is an economically motivated crime.

In contemporary criminology, economically motivated crimes are seen as the outcome of the
aggregation of 1) opportunities, 2) motivations, and 3) the absence of control measures (see
Figure 1). These three elements have been the topic of extensive study and theory testing
and form the basis for this assessment tool.

Figure 1 – Fraud Vulnerability: the three elements affecting criminal behavior


Opportunities
In the case of food, ingredients and products are – by the nature of their composition,
qualities, and geographical or production origin – attractive for adulteration, substitution,
mislabeling or counterfeiting.

Motivations
Fraud can be committed by individual offenders working in a company or in organized
SSAFE Food Fraud Vulnerability Assessment Tool

networks, as well as by corporate offenders such as companies operating across the supply
chain. Fraudsters can be operators within the supply chain or external operators trying to
infiltrate or manipulate the supply chain.

Economic motivation assumes the pursuit of individual material gain or some kind of
business advancement. Depending on the offender and the situation, this economic
motivation can take two different forms: profit maximization or loss minimization. In other
words, greed versus need: the drive for more material gain versus the perception that law
breaking is unavoidable for economic survival.

Furthermore, additional factors such as organizational strategy, business culture, level of

competition, and relationships with suppliers will have an impact on the motivations to
commit food fraud.

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Mitigation Measures
Businesses and systems can implement control measures to detect or prevent fraud and
intervene in case of deviations. In criminology, informal guardians are distinguished from
formal guardians, and exercising guardianship (control) is the formal and professional duty
of the latter. From a company perspective, formal internal guardians can be food quality and
safety officers, while the national Food Safety Authority exercises formal external
guardianship. Informal guardians can be employees, suppliers, or customers. From a
company’s perspective, the most appropriate system to exercise guardianship is the Food
Safety Management System, which can (and should) include measures to mitigate the risk on
fraud such as detection systems or preventive measures in the form of both hard and soft
controls.

The Influence of the Environment
Research has established that people have the psychological tendency to place threats of
crime outside the social group or the organization to which they belong (the “alien
conspiracy”). However, criminological studies repeatedly show that in most cases where
companies are victimized by fraud, the offenders are employees. Therefore, potential
opportunities and motivations for food fraud should be assessed in both the internal and the
external environment of the company.

From the perspective of the company conducting the assessment, the internal and external
environment consists of various levels:
• The company
• The direct suppliers and customers across the company’s supply chain
• The industry segment
• The national and/or international environment.

Along this dimension of environmental layers, the company’s ability to manage
opportunities and motivations decreases. Similarly, the company’s ability to obtain reliable
data on the elements “Opportunities,” “Motivations,” and “Mitigation Measures” decreases
along the axis (as illustrated in Figure 2).

SSAFE Food Fraud Vulnerability Assessment Tool

Figure 2 - The environment of the company and the three elements of food fraud

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How The Scientific Framework Relates to this Tool

This food fraud vulnerability assessment takes the criminological framework as a starting
point. The three elements are the main factors determining a company’s vulnerability to
food fraud. The elements are producing risks in the following manner: Opportunities and
motivations are determined by the company’s internal and external environment and are
defined as the potential fraud risk factors. The potential risk resulting from these two
elements can be mitigated by the third element: the mitigation measures in place in the
company’s Food Safety Management System and/or external controls in the supply chain,
industry segment, and/or legal framework.

Companies operating in a high-fraud risk environment (e.g. due to opportunities, drivers or

motives inherent to the environment) will require advanced and specific fraud-monitoring
systems and preventative measures to limit their vulnerability. Contingency measures may
be required alongside mitigation measures to limit damage in case fraud issues occur within
the company or its environment.

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