Food Safety & Trade Compliance

1. Our commitment

Food trade depends on trust. We only trade products that can be lawfully produced, exported and imported, and we work with partners who share that standard. This policy applies to our staff, our agents and every supplier and buyer we work with. The specific responsibilities of each party in a sale are set in our Terms of Trade and in each contract.

2. Supplier approval

Before we source from a producer, packer or exporter, we request and review, as relevant to the product:

• Proof of legal existence and export authorization in the country of origin.
• Food safety certifications, such as HACCP-based plans, GFSI-recognized schemes (for example BRCGS, SQF or FSSC 22000) or GLOBALG.A.P. for fresh produce.
• Product specifications, certificates of analysis and, where applicable, pesticide residue, mycotoxin, microbiological or heavy-metal test results.
• For facilities that supply the U.S. market, their FDA food facility registration where required.

We review supplier documentation periodically and when we learn of a food safety incident.

3. Food safety and quality

• Products must meet the agreed specifications and the food safety requirements of the destination market.
• We may require pre-shipment inspection, sampling or laboratory testing by independent agencies.
• Packaging must be food grade, suitable for the product and the route, and clean and intact at loading.
• Temperature-controlled goods must be loaded at the agreed temperature, with records kept for the voyage.

4. Food entering the United States

For food imported into the United States, we and our partners work to meet the requirements of the U.S. Food and Drug Administration (FDA), the U.S. Department of Agriculture (USDA) and U.S. Customs and Border Protection (CBP) that apply to each product, including:

• Food facility registration of the foreign facilities that manufacture, process, pack or hold the food, where required.
• Prior Notice to FDA before the food arrives.
• The Foreign Supplier Verification Program (FSVP) obligations of the FSVP importer.
• Plant health and phytosanitary requirements for fresh produce, grains and other plant products, including USDA APHIS import permits where required.
• Country of origin marking and other CBP entry requirements.

The party acting as importer of record and FSVP importer is identified in each contract.

5. Exports and destination rules

For exports, we confirm with the buyer the requirements of the destination country before shipping, such as import permits, health or phytosanitary certificates, certificates of origin, maximum residue limits and language and labeling rules. We do not ship goods we know cannot lawfully enter the destination market.

6. Labeling and allergens

Packaged foods must carry the labeling required in the destination market. For the United States, this includes ingredient and nutrition information in English and the declaration of major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Undeclared allergens are a leading cause of recalls, so we review labels against the product specification before shipment.

7. Traceability and recalls

• Every shipment must be traceable to its supplier, lot or batch, production date and point of loading.
• We keep the records needed to identify one step back (supplier) and one step forward (buyer) for every lot we trade.
• If a product we traded is subject to a recall, market withdrawal or safety alert, we notify the affected buyers and authorities as required, and cooperate fully to remove the product from the market.

8. Sanctions and export controls

• We screen suppliers, buyers, consignees and, where relevant, banks and vessels against the U.S. Treasury OFAC Specially Designated Nationals list and other U.S. government restricted-party lists.
• We do not trade with sanctioned persons, or with countries and regions subject to comprehensive U.S. sanctions, unless the transaction is authorized under U.S. law.
• Most food products are not subject to export licensing, but we review each transaction for any applicable export control or end-use restriction.

9. Know your customer and payments

• We verify the identity and legal existence of the companies we trade with and may request company registration documents and references.
• We accept payments only through the banking channels agreed in the contract, from accounts in the name of the contracting party.
• We do not accept cash, unexplained third-party payments or requests to split, disguise or misdescribe invoices.

10. Anti-corruption

We comply with the U.S. Foreign Corrupt Practices Act and the anti-corruption laws of the countries where we operate. We do not offer, pay or accept bribes, kickbacks or facilitation payments to obtain business, permits, inspections or customs clearance, directly or through agents. Gifts and hospitality must be modest, infrequent and never linked to a business decision.

11. Forced labor and ethical sourcing

U.S. law prohibits imports of goods produced with forced labor. We expect our suppliers to respect human rights and labor laws, prohibit forced and child labor, and allow us to verify where products come from. We will not source from suppliers or regions where we cannot obtain reasonable assurance on these points.

12. Right to refuse

We may decline or stop any transaction that does not meet this policy, where documentation is incomplete or inconsistent, or where we have reasonable concerns about food safety, legality or the identity of a party. We are not obliged to explain the specific reason when the law restricts disclosure.

13. Reporting a concern

If you have a food safety concern about a product we traded, or believe someone has acted against this policy, write to info@ghamatrade.us with the subject "Compliance". Include the product, lot number and shipment details if you have them. We review every report and will not retaliate against anyone who reports in good faith.