Non-Conformity and Non-Compliance Procedure

Document Owner	The Sustainable Restaurant Association (The SRA)	Version	1.0
Effective Date	9th September 2026	Review Date	1st September 2026
Regulatory Basis	ECGT Directive (EU) 2024/825; ISEAL Code of Good Practice v1.1	Status	Active

1. Purpose and scope

This procedure sets out how The Sustainable Restaurant Association (The SRA) identifies, investigates, and resolves non-conformities with the FMG Standard and non-compliance with scheme rules by certified and applicant businesses. It covers all stages of the certification journey, from application through to renewal.

2. Classification of non-conformities

All non-conformities are classified into one of three levels. The level determines the urgency, investigation process, and consequences. This classification is applied consistently by both The SRA and the independent audit body.

Level	Classification	Definition	Consequence
1 MINOR	Minor non-conformity	Does not materially affect the integrity of the certification. Correctable without lasting impact on certification status.	Corrective action required within three months. Certification status unchanged.
2 MAJOR	Major non-conformity	Undermines the validity of a scoring area or claim. May be inadvertent but has material impact on scheme integrity.	Corrective action with deadline. Certification suspended if not remediated within three months.
3 CRITICAL	Critical non-conformity	Invalidates the certification. Includes deliberate falsification, fraud, or serious breach of scheme rules.	Immediate suspension. Certification withdrawn following investigation.

Where a non-conformity is identified during audit, that is, where information available to the auditor does not support an answer given by the business, the audit body provides the business with a written report detailing:

the specific question(s) where a non-conformity has been found,
the information reviewed and the basis for the finding,
the additional information required to substantiate the original answer, if any, and
the timeframe within which the business may respond.

This applies equally where assessment is conducted by The SRA Delivery Team auditors for non-EU businesses.

DISQUALIFYING CRITERIA

Where a matter under investigation relates to a Disqualifying Criterion as set out in the Terms and Conditions, the classification and evidence thresholds set out in the Terms and Conditions apply. A confirmed Disqualifying Criterion is treated as a Level 3 (Critical) non-compliance under this Procedure, resulting in immediate suspension and withdrawal following investigation. Where a Disqualifying Criterion is the subject of a pending investigation or unresolved allegation, it is handled in accordance with the Pending Investigations clause in the Terms and Conditions.

3. Investigation triggers

An investigation of a non-conformity, or of a breach of compliance with The SRA rules, may be initiated through any of the following:

An audit identifies a non-conformity during assessment
A formal complaint from a consumer, competitor, regulator, or other third party
Information coming to The SRA's attention suggesting that a business's operations have changed materially since its last assessment, such that the current certification may no longer accurately reflect its practices
Identification of potential logo or claims misuse, whether reported by a third party or identified by The SRA
A third party, such as a supplier or partner, referencing a business's FMG certification in a way that may be misleading or that uses the FMG logo without authorisation

Any person or organisation may report a suspected non-conformity or non-compliance via hello@thesra.org, including reports of logo or claims misuse. Complainant confidentiality is protected where requested.

4. Non-conformity and non-compliance along the certification journey

The following sets out what non-conformity and non-compliance looks like at each stage of the certification journey, how it is classified, and the immediate consequence.

4.1. APPLICATION AND ONBOARDING

Level	Classification	Examples	Consequence
1. MINOR	Administrative error	Incomplete application form Minor inaccuracy in contact or site information that does not affect eligibility	Business asked to correct and resubmit, or correction made by The SRA. No further action taken.
2. MAJOR	Misleading application	Misrepresenting the nature or scale of the business, for example describing a non-qualifying operation as a restaurant, or understating turnover to qualify for a lower fee band. Applying for certification for one site but using, or intending to use, the FMG logo across other sites or a wider brand not covered by the assessment.	Application suspended. Written notice issued. Business must respond within 10 working days.
3. CRITICAL	Fraudulent application	Applying under false ownership or identity. Failing to disclose that certification was previously withdrawn.	Application immediately rejected. Business may not reapply for 12 months.

4.2. ASSESSMENT RESPONSES AND EVIDENCE

Level	Classification	Examples	Consequence
1. MINOR	Insufficient or unclear information	Evidence or information provided does not fully support the answer given but is not misleading Out-of-date document submitted where a current one exists Answers are vague or lack sufficient detail to verify the claim	Evidence or information query raised with the business. Business has 10 working days to respond. Non-conformity recorded and corrective action verified before certification is confirmed.
2. MAJOR	Materially misleading information	Evidence or information from a different site or period submitted as current and applicable Answers based on aspirational rather than current practice Inconsistencies between answers that suggest the information given does not accurately reflect operations Use of generic AI-generated content submitted as evidence of specific practices, where it is clear the content does not reflect the business's actual operations	The business is notified in writing of the non-conformity Business has 10 working days to respond with additional information or clarification, or to revise their answer to accurately reflect current practice.
3. CRITICAL	Fabricated or false information	Submitting documents that have been altered, falsified, or created specifically to support an answer rather than reflecting actual organisational practice Deliberately misrepresenting operational practice to achieve a higher score Making a false declaration of legal or food safety compliance in the mandatory declarations	Immediate suspension of certification or application. Critical non-conformity investigation initiated. Certification withdrawn if confirmed.

4.3. POST-CERTIFICATION: USE OF THE FMG LOGO AND CLAIMS

Businesses may state that they are in the process of FMG certification while their assessment is ongoing. They may not use the FMG logo or make any claim to FMG certification status until certification has been formally awarded.

Level	Classification	Examples	Consequence
1. MINOR	Inadvertent misuse	FMG logo used in a modified form or in colours, proportions, or formats not permitted under the FMG Brand Guidelines	Business notified. Required to correct within 5 working days and confirm this in writing with The SRA.
2. MAJOR	Significant misuse	Making claims about FMG certification that are misleading, unauthorised, or not in line with approved wording Using the FMG logo after certification has lapsed Displaying the logo or making certification claims in relation to a location, brand, activity or channel not covered by the certification Using the logo to imply endorsement of a specific product, supplier or activity Using the FMG logo or claims in relation to operations that have materially changed since the last assessment	Non-Compliance Notice issued. Business required to cease incorrect use of the FMG logo and any associated claims immediately. Investigation initiated; outcome may include suspension or withdrawal of certification.
3. CRITICAL	Deliberate prohibited claims	Using the FMG logo or claiming FMG certified status before certification has been awarded Making prohibited claims as set out in the Terms and Conditions Using a star rating higher than the one awarded Continuing to use logo or claims after receiving written notice to cease	Immediate suspension. Investigation initiated; certification withdrawn if confirmed.

4.4. RESUBMISSION AND RENEWAL

Non-conformities identified during a resubmission assessment are handled under Section 4.2.

Where an already certified business notifies The SRA of their intention to resubmit shortly before their certification renewal deadline, their certification is extended by three months from the renewal deadline to allow time to complete the resubmission and assessment process. During this period, the previous certification remains valid, and the business may continue to use the FMG logo and associated claims. If new certification is not confirmed within the three-month grace period, the previous certification lapses at that point and the business must cease use of the FMG logo and associated claims until the new assessment is complete and certification confirmed. Where a business has not notified The SRA of their intention to resubmit before the renewal deadline, certification lapses immediately at the renewal deadline.

Where a business chooses not to resubmit, certification lapses automatically. This does not constitute a non-conformity or non-compliance. The business is removed from the public register and must cease use of the FMG logo and associated claims. It may reapply at any time as a new applicant.

5. Investigation process

5.1 NON-CONFORMITIES IDENTIFIED DURING ASSESSMENT OR AUDIT

Where a non-conformity is identified during assessment or audit, it is handled within the assessment process as follows:

Stage	Action
1. Identification	The assessor or audit body identifies a non-conformity and logs it in the assessment record.
2. Query	The audit body issues a preliminary report to the business detailing any non-conformities identified. The business has 10 working days to respond, either providing additional information or clarification to substantiate the original answer or revising their answer to accurately reflect current practice.
3. Determination	The assessor or audit body reviews the response and makes a determination. Where the additional information substantiates the original answer, the score is confirmed. Where it does not, the score is adjusted to accurately reflect the evidence available. Where no response is received, the score is adjusted accordingly.
4. Escalation	Where the non-conformity suggests deliberate misrepresentation or fabrication, the assessor or audit body escalates to the Head of Certification, who initiates a formal investigation under Section 5.2.
5. Record	All non-conformities identified during assessment, and their outcomes, are recorded in the assessment record and retained for a minimum of 5 years.

5.2. NON-COMPLIANCE IDENTIFIED OUTSIDE OF ASSESSMENT

Where a potential non-compliance is identified outside of the assessment process, for example through logo monitoring, a third-party complaint, or information coming to The SRA's attention about a business's operations or claims, a formal investigation is initiated as follows:

Stage	Detail
1. Log	Case logged in the Non-Compliance Register within 2 working days of identification. Initial classification level assigned by the Head of Certification.
2. Notice	Written notice issued to the business within 10 working days confirming that an investigation has been initiated. The notice includes: a description of the issue; the classification level; the relevant Terms and Conditions clause; the response required; the response deadline; and the potential consequences if the non-compliance is confirmed. Where the case is Level 3 (Critical), the notice requires the business to cease use of the FMG logo and any associated claims immediately and for the duration of the investigation. Continued use after receipt of the notice will be treated as a further non-compliance. For Level 3 cases, the business is also temporarily removed from The SRA's public directory of certified businesses for the duration of the investigation. No public statement will be made by The SRA about the investigation or its subject while it is ongoing.
3. Response	Level 1: business required to correct promptly and confirm by email. Level 2: business has 10 working days to respond in writing. Level 3: business has 5 working days to respond in writing.
4. Determination	The Head of Certification reviews the response and makes a determination within 15 working days of the response deadline. For Level 2 cases where the determination results in suspension, CEO sign-off is required before the determination is issued to the business. For Level 3 cases, the determination is made jointly with the CEO before being issued. Where the Level 3 case involves suspected fraud or deliberate misrepresentation, the determination is also reported to the SRA Board.
5. Outcome	Written determination issued to the business. Outcomes: No non-compliance confirmed: case closed Level 1 confirmed: business required to correct, no change to certification status Level 2 confirmed: certification suspended if not remediated Level 3 confirmed: certification withdrawn Where certification is withdrawn, the business must cease use of the FMG logo and any associated claims immediately. The business is removed from the public directory and may not reapply for a minimum of 12 months from the date of withdrawal.
6. Appeal	Business may appeal the determination within 10 working days of receipt. See Section 7 for information about the Appeals process.

6. Suspension and withdrawal of FMG certification

6.1. SUSPENSION

Suspension is applied in the following circumstances:

A Level 3 non-compliance is confirmed following investigation, or, where credible evidence indicates a serious and immediate risk to scheme integrity, on issue of a Level 3 Notice pending investigation
A Level 2 corrective action is not completed and verified within the required timeframe

During suspension the business must cease all use of the FMG logo, star rating, and any associated claims across all public-facing materials. The SRA will remove the business from the public directory of certified businesses and cease any associated communications or promotional activity relating to the business for the duration of the suspension.

Suspension is lifted once the investigation is concluded and The SRA is satisfied that the non-compliance has been resolved.

6.2. WITHDRAWAL

Withdrawal is applied where a Level 3 non-conformity or non-compliance is confirmed following investigation, or where a suspended business fails to complete required corrective actions within the agreed timeframe.

Upon withdrawal:

The business must immediately cease all use of the FMG logo, star rating, and any claims to FMG certification status.
The business is removed from the public directory of certified businesses for a minimum of 12 months.
Outstanding fees remain payable.
The business may reapply as a new applicant after a minimum of 12 months from the date of withdrawal.

7. Appeals

A certified or applicant business may appeal any formal written outcome issued by The SRA within 10 working days of receipt. This includes non-compliance findings made by The SRA following investigation. Certification determinations made by the independent audit body under Schedule 1 are final and are not subject to appeal to The SRA, in accordance with the Terms and Conditions. Where a business disputes an audit body determination, it must raise this with The SRA, who will liaise with the audit body on the business's behalf in accordance with the audit body's own review process, where one exists.

The appeal must identify at least one of the following grounds:

Procedural error in how the assessment, audit, or investigation was conducted
New material evidence or information not available at the time of the original decision
Error of fact in the decision

Element	Detail
Appeal panel	Where the original determination was made by the Head of Certification, the appeal is reviewed by the CEO Where the original determination involved the CEO, the appeal is reviewed by the Board Chair or another Board member not involved in the original decision This panel structure applies to non-compliance findings made by The SRA. Certification determinations made by the independent audit body are not reviewed by this panel (see the introduction to Section 7 above).
Timeframe	The SRA issues a written decision within 20 working days of receiving the appeal.
Possible outcomes	The SRA may uphold the original decision, modify it, or overturn it. The decision is final and binding.
Status during appeal	Where certification has been suspended, it remains suspended during the appeal. Where certification has been withdrawn, it remains withdrawn during the appeal unless The SRA directs otherwise.
Disclosure	The outcome is disclosed in writing to the business. Anonymised aggregate appeal data is included in the annual Board governance report.

8. Non-compliance register

The SRA maintains two records relating to non-conformities and non-compliance. Non-conformities identified during assessment or audit are recorded in the assessment record (see Section 5.1). Non-compliance cases identified outside of assessment are recorded in the Non-Compliance Register as set out below.

The SRA record the following in the Non-Compliance Register:

Case reference number and date opened
Business name, certification reference, and stage at which the issue arose
Classification level and description of the issue
Trigger source
All correspondence, evidence reviewed, and audit body findings
Determination, reasoning, corrective actions required, and verification outcome
Appeal outcome where applicable
Date case closed

Records are retained for a minimum of 5 years from case closure and are available to the independent audit body and, where required, to competent national authorities in EU Member States. A summary of cases and outcomes is reported to the Board annually as part of scheme governance oversight.

9. Document control

Version	Date	Author	Summary
1.0	1st September 2026	The SRA Head of Certification	Initial issue

This procedure is reviewed annually by the Head of Certification and updated as required to reflect changes in the FMG Standard, applicable regulation, or operational practice.