Very warm welcome to everyone, and thank you for joining this webinar. I'm László Győrfi, Global Product Manager for IFS at SGS. As you may know, SGS is the world's leading certification body in IFS certification. Today, I'm going to guide you through the key changes in IFS Food Version 7. This webinar consists of two parts. First, there is a presentation followed by a Q&A session. Please submit your questions through the Q&A chat box. You can submit your questions anytime during the presentation. We are going to discover the background of the changes, the most important changes in the certification protocol, and in the assessment requirements. We will also talk about the obligatory use of the Global Location Numbers, which is a key change in the new version. As I mentioned earlier, we will have a Q&A session at the end of this webinar for any specific questions. I hope you will receive useful information that you can apply in the certification process against the IFS Food Version 7. The review process for Version 7 started back in 2019. During this review, there were several rounds of consultation with the IFS working groups, accreditation bodies, and other interested parties, and test audits were carried out in different countries. The review process continued with a wide public consultation on the draft version of the standard. After reviewing the feedback, IFS's International Technical Committee validated the final version, and the new standard version was published in October 2020. According to the general rules, the new version may be applied to IFS food assessments from 1st of March, and it's obligatory from 1st of July 2021. However, there may be specific conditions, for example, for unannounced assessments and for multi-location arrangements where there are different deadlines which we have to apply. The certification body of SGS International Certification Services has developed a transition plan which has been distributed to our IFS Food certified clients through our local SGS offices. Please contact your local SGS office if you have any questions about the transition process. Let's have a look on the key objectives of the review. One of the main objectives was to make the standard more user-friendly from the company's point of view. Therefore, the certification protocol part of the standard follows the steps of the certification process. The requirements part of the standard has also undergone some revision. More focus has been put on the process and product approach. The new requirements of the GFSI benchmarking document have been integrated. Additionally, some of the requirements have been aligned with the requirements in the Codex, the FISMA, and in the EU regulations. The assessment report is also updated, giving more comprehensive and standardized information to the readers. This slide shows the summary of the key changes. In the certification protocol, the key changes concern the scoring system, the requirements for the outsource processes, the rules for the unannounced assessments, as well as an update to the exclusion decision tree. In the requirements part, several requirements have been merged, and there are also some new requirements introduced. The assessment reporting has been updated with new requirements, formats, and standardized structures. Unfortunately, we have no time to discuss the requirements for the auditors and certification bodies in detail during this presentation. This is the structure of the new standard. The four key parts are the same as they were in Version 6.1. However, the content of each section has been updated. There are several annexes giving details and explanations on the different certification process steps. I would like to draw your attention to the glossary. This is often omitted. However, it is important that both auditors and assessed companies learn the definitions in order to be able to fully understand the terminology used during assessments and throughout the whole certification process. Besides the standard, IFS has issued several other documents. Please note that the IFS Doctrine is also a normative document. Therefore, the rules set in the Doctrine must be applied during the assessments and throughout the whole certification process. There are also guidelines available on the IFS web page, which may help in the interpretation and in the application of the standard. There is also a document which compares the old and the new versions, highlighting the differences. It is worth remembering that the English version is the mother version. If there are any interpretation doubts of the translated versions, we must always use the English version. You may have noticed that I'm using the word "assessment" instead of "audit." This is because this term is used in connection with IFS Food Version 7. IFS assessment is more than just an audit. IFS assessments are performed by using a combination of inspection and auditing tools. There is a greater importance put on product and process conformity and fulfilling customers' requirements. Later in the presentation, we will see that the scoring system has been adjusted to meet the ISO 17065 requirements with regards to the closing out of the deviations and non-conformities before the certification can be granted. After this introductory information, let's start discussing some details. First, let's see what the key changes are in the certification protocol. As you may remember, part one of the standard describes the steps of the certification process. This part gives important rules not only for the certification bodies but also for the companies wishing to be IFS Food certified. One of the changes in IFS Food Version 7 is about rules for handling outsourced processes. This slide gives examples for three different types of outsourcing. In the first example, a winery doesn't have a bottling line, so the bulk wine is transported to a nearby bottling plant. This is a typical example when a part of a process is outsourced. In the second example, there is a fully outsourced product described when a meat company fully outsources the production of the meat burgers. In this example, the full production of a product is outsourced. In the third example, the company produces biscuits, and in order to extend the product portfolio, they also trade donuts from another manufacturer under a brand of the other company. There are different rules for these types of outsourcing activities. The scope of the IFS Food Version 7 assessment may cover partly outsourced processes only. Such partly outsourced processes may be production steps done by another company or by a sister site, and these may cover primary packaging and labeling activities too. Such partly outsourced processes may cover company-branded or customer-branded products. Do not forget, storage and transport carried out by contracted service providers are not considered as outsourced processes, but these are rather purchased services. When an IFS certified site has partly outsourced process, during the IFS Food assessment of this site, the auditor shall evaluate how the assessed site manages the partly outsourced process. There shall be a contract between the two sides detailing the in-process controls, sampling, and testing as a minimum. The other company or site that carries out the outsourced process shall be IFS Food certified or certified against a GFSI-recognized equivalent standard. If there is no certification, the site shall carry out a documented supplier assessment at the other site which carries out the outsourced process. When there is a partly outsourced process, on the IFS Food certificate of the site, beneath the assessment scope, we have to include the statement that besides own production, the company has partly outsourced processes. Furthermore, details about the outsourced process or processes shall be given in the relevant section of the audit report. Fully outsourced products are not in the scope of IFS Food Version 7. It is recommended that the site which has fully outsourced products gets these products certified through an IFS Broker certification for an equivalent standard which is GFSI accepted and accredited according to ISO 17065. It is possible to conduct an IFS Food and an IFS Broker combined assessment. If the IFS Food assessed site has fully outsourced products, we have to indicate on the IFS Food certificate that the site has such activity and whether this brokering activity is certified or not. Similar requirements apply to traded goods as for the fully outsourced products. These are also not included in the scope of IFS Food Version 7. If the IFS Food assessed site has traded products, we have to indicate on the IFS Food certificate that the site has such activity and whether this brokering activity is certified or not. With regards to unannounced assessments, there are some new rules. One of the new rules is based on a GFSI requirement, and it is not only applicable for Version 7 but also for Version 6.1 starting from 2021. According to this GFSI requirement, an unannounced assessment option shall be chosen at least once in every third certification assessment. This rule also applies when a certification cycle is interrupted or when a company is changing certification bodies. For tracing the last unannounced assessment easily, the IFS Food certificates will contain the date of the last assessment conducted unannounced. It is the responsibility of the companies to register for an unannounced assessment. On the IFS web page, there is a useful calculator which calculates the registration deadline as well as the time window for the unannounced assessment. If a company misses the registration deadline, it is still possible to make a registration. However, in this case, the registration will be made as an initial unannounced assessment, and there is a risk that the company will have a period when their certificated status will not be continuous. In IFS Food Version 7, there is clarification relating to different company structures and how these companies may be certified. The simplest structure is the single site company which has one COID, one assessment, and one certificate. There may be companies which have several production sites, and these sites are organized in a multi-location certification arrangement. In this arrangement, each site has its own COID, assessment, and certificate. However, the central processes are assessed only once at the central managing site or in the headquarters office. One remark: the headquarters office which has no production cannot get its own certificate. A special arrangement may exist when several legal entities are operated on the same site. For example, there is a site which packs fruits and vegetables. The site is shared by two sister companies. Company A supplies retailer A, and Company B supplies retailer B. Company A and B are considered as multi-legal entities operating on the same site. Some companies may have decentralized structures. For example, when there is an off-site storage or when there is a production workshop at a close location to the main site, and this workshop belongs to the same process of the main site. In such situations, the additional storage site or the additional workshop may be included in the assessment of the main production site. Now let's discuss the new scoring system. One of the key changes is that the B scoring does not mean a deviation anymore, but a point of attention. C and D remain deviations. The other key change is that the deviations must be corrected and closed out before the certificate may be issued. Let's see the B Scoring a little bit more in detail. When a situation is scored with a B, this situation is still in full compliance with the relevant requirements. However, it needs attention from the company because this may lead to a future deviation or non-conformity. A situation scored with a B does not need correction or corrective action. As a summary, a B point of attention could be an observation which could lead to a future deviation or non-conformity, but at the time of the assessment, the situation complies with the requirements. Obviously, a B scored situation cannot have a risk on the product. The B scoring cannot be an opportunity of improvement, cannot be a deviation or non-conformity, cannot be used for soft grading, and cannot be used to recommend solutions for a discovered problem. Let's have an example. Let's suppose that we are in a dry powder mixing area. The auditor observes that there are some plastic holders displaying instructions. These plastic document holders are not included in the cleaning instructions. The auditor also observes that these holders and the surrounding walls are kept clean and tidy. The question is how you would score this situation. Is this a B point of attention or a C deviation? Well, this situation may be scored as a B point of attention. The situation at the time of the assessment complies with the cleaning requirements. However, in the future, this may be a deviation if the cleaning of the holders is missed because the holders are not included in the cleaning schedule. The C and D scorings have not been changed. However, there is a major difference between Version 7 and Version 6.1. From the new version, the deviations need to be corrected with supporting evidence before the certificate may be issued, and further corrective actions shall be defined to avoid further reoccurrence of the deviations. Corrections shall be implemented before the certificate may be issued. The corrective actions shall be implemented before the next pre-certification assessment at the latest. The evidences for correction shall be submitted to the certification body initially to the auditor within four weeks following the receipt of the provisional action plan. The action plan shall be completed by the assessed company and shall be sent to the auditor together with the supporting evidences. These evidences may include training records, updated documents or procedures, before and after pictures, evidence of communication of documents to relevant parties, invoices of completed works. Please note, offers are not accepted as these are not proving completed works. The evidences submitted shall be checked and validated by the auditors and by the certification body before issuing the certificate. This slide shows some acceptable corrections and corrective actions. Let's take the second example where the correction cannot be done within the four-week deadline because the supplier cannot supply the necessary spare part within the deadline. In such cases, the company shall carry out a temporary measure. In this example, the cracked plastic cover cannot be replaced. Therefore, the company introduced a checklist with which they can keep the status of this cracked cover under control. Coming back to the scoring system, there are not many changes regarding the KO and major non-conformities. For KO requirements, B scoring is not possible as B is for a point of attention. A KO requirement may be scored with an A, C, or D. Handling the situation when a KO is scored with a D has not been changed in Version 7 compared to Version 6.1. There is no change in scoring of a major non-conformity. However, there is a clearer description when a situation may be or shall be scored as a major non-conformity. We have finished discussing the main changes in the certification protocol. Now let's see the key changes in the requirements. The six main chapters of the requirement sections are the same as they were in Version 6.1. However, some of them have been renamed. The KO requirements are the same as they were in Version 6.1. Several requirements have been merged or deleted, and there are some new requirements as well. The new requirements are related to the food safety culture, informing and notifying the certification body. As we discussed, there are new requirements for outsourced processes, new requirements for using plastic curtains, updated requirements for cleaning and disinfection, foreign body management, and pest control. There is a new requirement for traceability tests. Responsibilities for food fraud assessment shall be defined. Several changes and updates have been made in food defense requirements. This is just a quick summary of the KO requirements. As I mentioned, these have not been changed. However, the numbering of some of the KO requirements was shifted within the sub clauses because some of the requirements have been merged or deleted, or some new requirements have been inserted. IFS strengthens the requirements related to transparency of information and communication throughout the whole supply chain. There is a new requirement 1.2.6 about obligation to inform the certification body within three working days about any changes that may have an effect on the ability of the certified company to conform to the certification requirements. This requirement was already in the protocol section in Version 6.1. However, it is now placed in the requirement section of the standard. Furthermore, there is a clear guidance in which situation the certified company must inform its certification body. 5.8.1 is a requirement about managing complaints as well as notifications from competent authorities when they are ordering actions to be done after an identified non-compliance. There is one more additional measure which may increase the transparency, namely the achieved percentage shall be indicated on the IFS certificates, not only the achieved level. Food safety culture is now included in all GFSI-recognized standards and now in IFS Food Version 7 as well. IFS has developed a useful guidance document about food safety culture, which is available on the IFS web page. Actually, food safety culture-related elements were already included in the previous versions. However, they were not referred to specifically as food safety culture. Senior management shall drive the food safety culture throughout the whole organization, and this shall include as a minimum communication about food safety policies and responsibilities, training activities, employee feedback on food safety-related issues, and performance measurements. SGS has recently launched a new service called Realize Winning Food Safety Culture. This program gives added value by measuring culture maturity and improving morale within the company. This is an online service available in more than 25 languages. Employees of a company from different levels shall answer questions developed by various experts from different areas. The questions are chosen by the system from a pool of questions intended for different levels within the company. This is fully anonymous and can be done on laptops, tablets, or even on smartphones. The company will receive a comprehensive report and can have access to analytics in order to benchmark performance. If you would be interested in this service, please visit the SGS website or contact your local SGS office. Continuing with the requirements, let's see what has been changed in the HACCP section. There are no significant changes in this section. However, it has been aligned with the Codex and FISMA requirements. The HACCP system is now called as HACCP Plan. No CCPs are mentioned anymore as these are now called control measures. More descriptive provisions are included relating to the hazard types that shall be addressed in the HACCP Plan. CCP records to be verified by a responsible person within the company. This originates from FISMA. It specifies specific competency requirements for those individuals. Specific training is not only required for operational personnel who carry out CCP monitoring, but also who monitor other control measures. Corrective actions shall address also the root cause for the loss of control. We have already talked about outsourced processes. 4.4.6, 7, and 8 describe the requirements about managing partly outsourced processes. 4.4.6 requires to identify such processes and to document the control measures. 4.4.7 requires a written agreement between the parties. 4.4.8 describes the certification requirements, or if there is no certification, the need of a documented supplier audit. The requirements for packaging have been strengthened. Please also note that by definition, a food product comprises packaging. In other words, packaging is an integral part of the food product. Therefore, the requirements for the packaging are as important as the requirements for the food product itself, which is packed into the packaging material. Requirements 4.5.1, 4.5.2, and 4.5.3 are not new. There are other requirements where packaging is mentioned. 4.2.1.3 is a KO Requirement, and it includes packaging material specifications. According to 4.3.2 and 4.3.3, packaging requirements shall be defined as part of the product development process. Please note, 4.3 is not only for new products, but also for modifications to existing products. 5.6.1 says the testing plan shall cover packaging materials as well. In 5.7.1, product release procedure shall include packaging materials. 4.8.3 sets requirements for sensitive areas. Besides microbiologically sensitive areas, this requirement now also covers areas with chemical and physical risks. For example, different GMP or cleaning requirements may be needed for areas handling specific allergens. Also, specific measures may be needed for areas with less packaging or for areas where wooden pallets or tools may be allowed. 4.9.6.3 is a new requirement for plastic strip curtains. This requires that such curtains, used for internal separation, shall be maintained in good condition. This is a simple and straightforward requirement. The requirements for cleaning and disinfection are set in 11 individual requirements, showing the importance of this subject. 4.10.3 is dedicated to monitoring records. It is not enough to record the cleaning, but there shall be separate records for monitoring as well. Auditors now have more freedom to give lower scores to the sites that are performing poorly in cleaning and disinfection. Separate deviations or even non-conformities may be raised for the cleaning schedules, for the cleaning practices, and for the monitoring records of cleaning and disinfection activities. In Foreign Body Management, 4.12.1 gives more detailed guidance and requirements for protecting the products from physical contamination sources. It clearly names areas which shall be considered, such as factory environment, oils and dripping liquids, dust spills, equipment and utensils, as well as walkways, platforms, and ladders. 4.5.4 covers filters, sieves, magnets, and all types of other methods which are not considered as detectors, like metal detectors and X-ray detectors. The Pest Monitoring and Control chapter has been increased from six to seven requirements. 4.13.1 relates to the infrastructure. The infrastructure shall be designed and built to prevent pest infestation. 4.13.2 gives additional considerations to pest control measures implemented. 4.13.3 is a very important requirement. It defines that even if the pest control is subcontracted, the responsibility still remains with the company for monitoring and carrying out actions when needed. 4.15.6 gives more descriptive provisions for the design and for the operation of loading areas. The IFS Food Doctrine gives additional requirements when a company uses parcel services to deliver its product to customers or consumers. The company shall conduct risk assessment, considering the worst-case scenario, and shall implement controls for identified risks. Traceability is still a KO requirement. 4.18.1 is more descriptive with bullet points, including rework clearly mentioned. 4.18.3 is a new requirement for traceability tests. Test results, including the time frame for obtaining the information, shall be recorded. Actions shall be taken when the test results identify discrepancies or non-compliances. Time frame objectives shall be set, taking into consideration any customer requirements. 4.18.2 requires that traceability tests shall be done in a way that the tests represent the complexity of the company's product range. The whole 4.9 chapter has been deleted. All product-related claims have been moved to the requirement 4.2.1.5. This includes free-form claims, for example, allergen-free claims, or similar declarations on the product labels, or any claims regarding special methods of treatment, including GMO status, or organic claims. Since 4.19 has been deleted, requirements for allergen control have been shifted from 4.20 to 4.19. 4.19.2 is now more descriptive with bullet points describing the main allergen cross-contamination sources, such as the factory environment, transport, storage, or raw materials. Once again, the free-form claims now covered in 4.2.1.5. The standard also gives more detailed guidance for the auditors on how to report correctly the allergens used on the assessed site. Regarding food fraud, there is a new requirement about responsibilities for food fraud assessment. The responsible person or persons shall have appropriate knowledge. Also, full commitment from the management shall be in place. The rest of the requirements have not been changed for food fraud. Food Defense chapter has been revised. Several individual and explicit requirements have been removed, such as testing alert system, identification of loading and delivery staff, etc. However, this does not mean that the company should not control these, but the introduced control measures shall be based on the threat assessment. 6.1 requires the commitment from the senior management. 6.2 requires that the company develop a food safety plan based on the assessment of the threats. This shall include legal requirements, identification of critical areas, visitors, contractors, and any other appropriate control measures. According to 6.3, the test of the effectiveness of the control measures and the food defense plan shall be included in the internal audit and inspection plan. Now we have covered the key changes in the requirement section. Finally, we have another new item regarding the certification process. IFS has decided to introduce the use of global location numbers, GLNs, on the IFS Food Certificates. It allows better identification of the production locations. This was initiated by the retailers to ease traceability of the certified sites. GLNs must be indicated on IFS Food reports and on IFS Food Certificates. This is obligatory for sites located in the European Economic Area and in the U.K. For other sites, it is not obligatory. During the assessments, auditors shall check the GLNs of the assessed sites. Without a valid GLN, the certification body cannot issue a certificate against IFS Food Version 7. The global location numbers can be purchased from the GS1 organization. More details can be found on IFS web page. There is a special link which gives a step-by-step description for companies wishing to be IFS Food certified, how they can purchase GLNs, or if they have one, how those can be checked in the database. I would like to thank you for your attention. I hope you received some useful information that can be used in practice. Please visit our website or contact us on the indicated contact details. You can also contact our colleagues at the local SGS offices, who are always there to help you. Now let's see the questions you submitted during this webinar. I will try to answer as many as I can. Please be assured that all questions have been recorded, and if any of the questions cannot be answered now, we will get back to you later. Thank you, László, for that very informative webinar. We do have the Q&A session coming up now. Just a quick reminder that the recording of this webinar will be available, and the link will be sent to you within the day after the webinar has concluded. Okay, so if you can see on screen, you have a Q&A widget box, so if you wish to enter any questions, please do so. We already have some questions coming in, so László, I'll start with some of those. Firstly, the first question is, as the total number of clauses has been reduced within IFS Version 7, does this mean each deviation will have a bigger impact on the final score? Thank you, Géraldine. Well, yes, it will have, as each deviation will have a greater effect on the final scoring. As we have less requirements, less number of requirements, then each deviation will have a greater effect on the final result. On the other hand, there is a bigger effect as well, namely the change in the scoring system. So all B deviations, which were scored, for example, in Version 6.1, now have to be scored as C deviations because B is not anymore a deviation but point of attention. So this is another factor which will affect the final result or may affect the final result. Just a quick information, as I mentioned at the beginning of the webinar, there were some trial audit assessments before the final version was published. And if I remember well, there were 10 companies tested against the new version. All of them were having Higher Level against Version 6.1. And out of these 10, five kept the Higher Level, but five dropped to Foundation Level. So yeah, it's possible that levels will change according to the new scoring system. But I always say that you cannot really compare the Version 6.1 score with the Version 7 score. It's like, yeah, like comparing an apple to a pear, or if it's not even so big difference, but like golden apple with a Stark apple, something like that. Okay, thank you, László. We have another question here, and it's about mobile bottling. Can a mobile bottling service be certified under IFS Food 7? This question can be answered based on the doctrine. In the IFS Food doctrine, there is a clause about mobile bottling, and it says that mobile bottling service providers cannot be certified as an entity. However, if a company is using mobile bottling service, a winery, for example, is using mobile bottling service, then it can be included, but the mobile bottling must be operating on site of the winery, which is being audited. If during the audit, the mobile bottling operation can be seen, then it can be included in the certificate of the winery. It's also possible that the mobile bottling is not present during, for example, an unannounced audit. But if the company wants to include this into the certificate, then an extension audit must be done when the mobile bottling is running. Okay, thank you, László. We have another question here. If I have a completely outsourced product with my brand, must I have to declare it on the certificate? Well, according to the new rules, it must be indicated on the certificate that the company has such activity. And we also have to put whether this activity is IFS broker or equivalent certified or not. So actually, the fully outsourced or traded products are not appearing in the scope of the certification, but we have to put the additional sentence that the company has brokering activities, which is or which is not broker certified. Okay, thank you, László. We have another question about traded product. And this one's a bit long. Okay, so in our plant, they produce frozen pastry, which is in storage in their on-site warehouse. The other part of frozen finished product is transferred to an external warehouse for distribution. Is this considered an outsourced process? To transfer to an external warehouse for distribution? No, this is not. External warehousing is considered as a purchase service. So if the external warehouse only stores frozen products and does not do a freezing process, then it's not an outsourced process. It's a purchase service. Okay, thank you very much, László. We've got a question from someone who's not that familiar with the IFS standard and was wondering what the KO stood for. Well, out of the 200-plus requirements, there are 10 requirements marked as KO requirements. And these are essential requirements addressing key topics like CCP monitoring or internal audits or raw material specifications, corrective actions. So these are the essential requirements which a company has to fulfill in order to get IFS certification. If any of these requirements are scored not compliant, which means scored with a D, then it means that the company or the site hits a KO non-conformity. And with a KO non-conformity, the company must have a full new audit before it can be certified. So with a KO, the company fully fails the certification, a nd it has to start from scratch with a new audit. Okay, thank you, László. We have another question. This one, please, can you clarify the requirement for the responsible person verifying the CCP or control measure records? Does it have to be a PCQI, or can it be also, for example, a plant manager or another member of the food safety team? Yeah, this requirement has been aligned with the FISMA requirements. So obviously, if the site is operated in the U.S., then they have to fulfill the FISMA requirements. So as far as I know, in the U.S., there should be a PCQI competent person or equivalent competency with that one. For the other parts of the world where, for example, this site is not supplying to the U.S., there are no FISMA requirements applicable for them, then it could be another responsible person, yeah, like a product manager or another member of the food safety team, yes. But it must be defined in the company's own HACCP system. And obviously, it has to have, or this person has to have certain training to do this verification, yeah. Okay, thank you, László. Another question. What deadline is applicable for an unannounced assessment for a version change? Yeah, it's an interesting question. Again, we have to go back to the doctrine, which gives additional explanation. The doctrine says that if the unannounced audit time window starts with 1st of May or later, then the assessment must be done according to version 7, independently or irrespectively, whether it is done in May, June, or in August. So practically, if the unannounced time window, so minimum half of the unannounced time window falls after 1st of July, then the company must expect that the assessment will take place according to version 7, irrespectively, when the actual assessment is done before July or after July. Okay, great. Thank you, László. We have a question here about trial audits. So are sites permitted to have a trial audit before they actually have their first real audit against IFS version 7? Yes, it is possible to have a pre-assessment, I would say. This is the correct term for that. However, the rule is that for a pre-assessment, there should be a separate contract with the certification body, and it is not allowed to convert a normal assessment into a pre-assessment. So for example, if during a three-day audit, the result after the first day is that we have two majors and three KOs, the company cannot ask to convert this assessment into a pre-assessment and just walk away without any consequences. So yes, it's possible to have a pre-assessment, but it has to be agreed before starting a pre-assessment or a complete assessment, yeah. Okay, thank you. I've got a follow-up question about critical control point monitoring. So for example, if production runs for 24 hours a day and the CCP is verified by trained operators, is this still acceptable, or would this now be a deviation? The standard says it's designated responsible within the company. So if they are really designated in the HACCP system, that these individuals, not just general like operators, but let's say certain names, certain operators have been designated to this function, then it can be I would accept, yes. Okay. Another question for you, László Győrfi. Which version should be used in a multi-site or, sorry, a multi-location arrangement covering several sites? Yes, it's another interesting question. The basic rule is that if there is a multi-location arrangement and the calculation is done according to multi-location, so there is a central managing site or a headquarters office where the central processes are audited, and then for the related production sites, reductions were given. Then the key rule is that the version according to which the central managing site was audited must be applied for the other related sites, so the subsequent sites, because generally, we cannot change versions between sites in a Multi-location Arrangement. So yeah, Version 6.1 is still applicable after July. If the central managing site was assessed against Version 6.1, then all related sites must be also assessed against 6.1 independently or irrespectively, whether the actual assessment takes place before or after July. Okay, thank you. We have a question about unannounced audits around the three-year rule. So for example, if in the first three years they have an unannounced audit in the two years, then should I have another unannounced audit in the fifth year, or could I have it in four years? I think it's just a question of timing. Yeah, it's a question of timing. So it says that every third assessment shall be unannounced, irrespectively of the number of unannounced assessments previously. So we always have to take the last unannounced assessment and calculate from the last unannounced assessment the next three years, practi cally, yeah. Okay, László. I think we're just coming up to the end of the questions. So for all people, please remember to complete the survey when the webinar finishes. And a link to the recording will be sent over to you within 24 hours. And finally, László, are there any final words you'd like to say as you wrap up and leave? Thank you very much for your attention. Hope this is very useful. And don't forget that you can always contact local SGS offices or even ourselves in the global IFS team. Okay, thank you, László.