2013 saw the formation of the Global Compliance Group, the primary goal at that time was the delivery of independent third-party services to the Australian Live exporters throughout South East Asia.
At that time, the deliverable included:
- Facility and supply chain Risk assessments
- Training and Education of work methods and Animal Welfare Practices.
- Overseeing discharges and the transportation of livestock
- Data management of livestock in market through the Track & Trace system
- Independent third-party audit services to ensure compliance with ESCAS requirements.
After the delivery of these services commenced a significant question coupled with a high level of uncertainty arose questioning the structure of the business as to a potential conflict of interest.
These questions arose as both control and traceability services and audit services were provided.
Whilst the business believed that it was truly independent it was concluded to restructure the delivery of services and ownership was the best course of action. To that end Global Compliance Group retained all of those services addressing Control and Traceability through the entities listed in the following:
- Global Compliance Limited
- Global Compliance Asia
- Conception to Consumption
- Global Compliance Service company (Vietnam)
- PT Global Compliance Asia (Indonesia)
- Track and Trace
- Big Brother (BB)
- Big Brother Next Edition System (BBNE)
Global Compliance Group ceased providing any audit services at that time; also, at that time the ownership of the GloblCompliance Group altered with Warwick Ashby surrendering his equity in Global Compliance Group and incorporating the Company Livestock Audit services Pty Limited.
Livestock Audit Services Pty Limited is an ASIC Registered Audit Company with Warwick Ashby as its sole shareholder and director; given that he is a Registered Company Auditor; this structure is required amongst many other compliance issues to ensure the ongoing registration with ASIC in the delivery of Assurance Audits pursuant to Global Audit Standards and ESCAS.
Livestock Audit Services Pty Limited continues to provide Assurance Audits to the livestock industry throughout South East Asia and Australia.
The restructure of the Global Compliance Group occurred with the guidance and concurrence of the Department at that time and continues to this day.
Global Compliance Group is immensely proud of what is has achieved, what it has delivered, what it currently delivers and what it will deliver in the future.
It has been a continuing evolution with a never ending client centric focus which not only provides the delivery to a level of ESCAS and the 6 Point Plan; which importantly since their inceptions has contributed at the highest level to the welfare of Australian Livestock exports and the sustainability of the industry.
These outcomes have been achieved and continue attainment on a purely commercial platform; with not one cent of taxpayer or industry funding having ever been received.
From Track & Trace to Big Brother to Big Brother Next Edition
The implementation of ESCAS required for the first time that Exporters implement Control & Traceability processes throughout their overseas supply chains.
The implementation of ESCAS outside of Australia has been a complex and difficult task.
By in large we see that the financial burden of ESCAS and it follows animal welfare has been borne by the participants in the Live Export Industry. It is also true to say that this has led to demonstrable significant positive enduring outcomes.; some examples are
- The upgrading of facilities - borne by exporters
- The provision of additional onsite staff working as Animal Welfare Officers (AWO)
- The investment in technology also borne by exporters
At times it is difficult to comprehend that ESCAS its requirements and other plans is the implementation of a regulatory framework that impinges directly on the sovereignty of another nation; the management of this alone has been and continues to be a significant challenge.
Global Compliance Group is proud of the contribution it has made and continues to make in all those areas that underpin a compliant and successful Live Export Industry.
ESCAS & 6 Point Plan
The Exporter Supply Chain Assurance System (“ESCAS”) is an industry requirement set by Industry and the Australian Government and administered through the Department of Agriculture water and Environment (DAWE). Its scope covers all feeder and slaughter livestock exported from Australia through the importing country’s supply chain until the point of slaughter. ESCAS was introduced into the Indonesian market in 2011 and, in 2013 was applied to all exports of cattle into Vietnam.
The four principles of ESCAS are animal welfare, control, traceability, and independent auditing.
In 2015 the industry implemented a 6-Point Plan (“6PP”) for Vietnam supply chains to reflect the risk profile of that market and to ensure ESCAS is consistently applied.
The six principles of the plan include:
- Access Standard (unrestricted access to in-market facilities within an exporter’s supply chain).
- Traceability and reporting standard (electronic and visual traceability of animals in the supply chain).
- Equipment standard (traceability equipment must be maintained in good order).
- SOP documentation standard (facility-level display and understanding of SOPs).
- Human resource standard (trained and dedicated staff at each critical control point).
- CCTV monitoring standard (real-time CCTV at key control points with remote monitoring and recording capability)
In 2017, LiveCorp contracted MRAG Asia Pacific (“MRAG”) to undertake a review of the control and traceability arrangements underpinning the Vietnamese live cattle trade. Additionally, MRAG undertook a review of the control and traceability systems of Global Compliance. Both reports were released in October 2017.
Inherent Risk: The risk that an activity would pose if no controls or other mitigating factors were in place (the gross risk or risk before controls).
Residual risk: is also known as your “vulnerability” or “exposure” the risk that remains after you have attempted to mitigate the inherent risk. Companies can only understand residual risk if they have first addressed inherent risk.
Our strategy takes the information from the auditing and risk assessment process and develops systems and procedures to minimise the likelihood of occurrence.
Our staff are trained in risk management and have experience in implementing risk mitigation procedures.
Risk assessments are implemented to identify residual risk critical to the Live Export Industry by doing so we assists importers and exporters identify critical control points throughout the supply chain. Creating solutions and risk mitigation strategies with the outcome of a reduced risk profile
Risk is real and dynamic – we must identify and respond.
Risk Mitigation and Management
- Ensuring Management Structure is implemented.
- Ensuring a clear chain of responsibility is implemented.
- Education and training.
- Monitoring reviewing / internal auditing.
- External Audits.
- Continued improvement Strategies.
Critical Control Points
Risk assessments should be conducted throughout the whole supply chain.
- Animal Welfare
- Point of slaughter.
The BBNE system comprises both software and hardware that is overlaid on internet technology that enables the trackability and traceability of cattle distribution in the supply chain.
Quality Management System
The Global Compliance Group delivers a Quality Management System (QMS) that has been developed to ensure that the compliance requirements of the Exporter Supply Chain Assurance System (ESCAS) are met and surpassed. To ensure compliance and traceability the “Big Brother Next Edition” system has been upgraded to include. Automatic scanners that capture cattle in real-time throughout the supply chain with no human intervention required.
PT Global Compliance Asia is an independent, ISO, KAN certified business.
Collective Standards for Animal Welfare
In April 2018, four Australian exporters to Vietnam agreed to pursue a collective approach to ESCAS, 6PP and animal welfare more broadly in Vietnam, known as the Collective Standards for Animal Welfare (“CSAW”). CSAW members have agreed to be signatories to four core documents
1) Code of Conduct
2) Collective Standards
3) Standard Service Agreement (with an independent service provider)
4) Administrative Charter
A key feature of CSAW is the transparency across the collective supply chain of CSAW members with all notifiable events related to animal welfare published via a shared Notice Board. In conjunction with the standards agreed to the Notice Board allows all members to work collectively and transparently to raise the standard of animal welfare in the market.
Global Compliance (“GC”) a business unit of Global Compliance Group, has been selected as the common service provider of the Control and Traceability (“C&T”) system including the management of the Notice Board on behalf of CSAW exporters. GC owns and operates the intellectual property for the C&T system known as Big Brother Next Edition (“BBNE”). This system comprises infrastructure, processes and inputs that provide for monitoring and reporting associated with ESCAS compliance and in meeting requirements of the 6PP.
The CSAW initiative goes beyond the regulated requirements of ESCAS and the 6PP by introducing the principles of transparency and collective responsibility across the supply chains of the member exporters.