Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Compliance Program Overview As part of the Master Licensing Agreement (MLA), licensees make a commitment to follow all Starbucks standards. Each licensee, in every store is responsible for modeling Starbucks customer service commitment, ensuring the delivery of high-quality products, and maintaining a clean, safe and welcoming store that creates the Starbucks Experience. When standards are not met, and coaching or consulting provided by the Starbucks district manager does not yield sustainable results, the licensee has failed to comply with the licensing agreement. If this occurs, Starbucks has a responsibility to escalate appropriately using the Compliance process. Intent: This guide is used by licensees to understand the Compliance program, including types of compliance notices, your role in navigating the process and what to expect from Starbucks. © 2023 Starbucks Corporation. All rights reserved. For internal use only 1 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Table of Contents When does Starbucks Leverage Compliance 3 Compliance Escalation Paths 4 Understanding Your Role 5 Compliance Categories, Issues and Action Steps 6 Notice of Action Required Process Flow 7 Critical Notice of Action Required Process Flow 8 Immediate Notice of Default Process Flow 9 Navigating the Compliance Process 10 Appendix Compliance Categories, Issues, Details and Action Steps © 2023 Starbucks Corporation. All rights reserved. For internal use only 12-20 2 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE When does Starbucks Leverage Compliance? Coaching, consulting and compliance Guidance for immediate compliance As a World Class Licensor, Starbucks provides ongoing consulting and coaching to licensees. However, when a licensee is not adhering to Starbucks operational standards and has failed to act on coaching and consulting guidance provided by the Starbucks district manager, the Compliance Program may be leveraged. This escalation protects the Starbucks Experience and demonstrates Starbucks commitment to closing gaps that hinder licensee success. When the Starbucks Experience is imminently at risk, there may be instances when it is necessary for a Starbucks district manager (DM) to issue compliance immediately without first utilizing coaching and consulting. See issues below that may result in an immediate compliance notice. Note: If you identify any of these issues when self-assessing operations, proactively consult with your Starbucks DM to inform them of your plan to close the standards gaps. IMMEDIATE COMPLIANCE ISSUES • Store is closed during normal business hours or is left unattended during breaks and/or lunches. This could result from a customer complaint, observation by other Starbucks partners, or any other reliable source Consulting • Uncertified baristas are working without the support of a certified barista or Barista Trainer • Store does not have Licensed Store (LS) Leader certified lead Coaching Compliance • Selling unapproved food, Ready-to-Drink (RTD), or other product offering • Food Safety Critical - Directly contributes to foodborne illness; immediate action must be taken Note: See full list of Critical Compliance Issues in the Appendix © 2023 Starbucks Corporation. All rights reserved. For internal use only 3 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Compliance Escalation Paths There are two main escalation paths for compliance depending on the severity, urgency and potential impact to the Starbucks brand: Notice of Action Required (NAR) and a Critical Notice of Action Required (Critical NAR). Use this guide to learn about different compliance paths and your role in navigating the process. Below is a brief description of each type of notice; additional details are provided throughout this program guide. Starbucks reserves the right to take appropriate action, as permitted by law and contractual rights, to ensure the safe and working operation of all stores. Note: Starbucks reserves the right to require immediate temporary closure of a store in the event of an immediate and material threat to the health or safety of customers or employees. Notice of Action Required (NAR) Critical Notice of Action Required (Critical NAR) • A written notice issued by Starbucks to a Licensed Store documenting operational standards gaps • The store has 30 days to remedy documented issues and demonstrate sustainable change A written notice issued by Starbucks to a Licensed Store documenting operational standards gaps • Failure to fully resolve will result in a 30-day remedy date extension escalation • Used for a limited number of critical food safety issues that pose an immediate threat to customer safety and the Starbucks brand (see full list on page 20) • • • If there is a reoccurrence within 90 days, indicating issues were resolved but not sustained, this will escalate to Notice of Default immediately Note: Extensions are only leveraged when substantial progress has been made but additional time is needed to fully resolve Notice of Default • • • • A written notice issued by the Starbucks legal department to the Licensee corporate contact Issued as an escalation when a licensee fails to remedy an NAR or immediately due to the severity of a store’s operational gaps Once issued the store has 30 days to remedy outstanding issues and demonstrate sustainable change Failure to resolve will result in escalation Notice of Failure to Cure • A written notice issued by the Starbucks legal department to the Starbucks Licensee corporate contact • • Issued as an escalation when a licensee fails to remedy a Notice of Default • Failure to resolve will result in temporary or permanent store closure Once issued the store has 30 days to remedy outstanding issues and demonstrate sustainable change Temporary or Permanent Store Closure • In the event of a compliance related store closure, additional details will be provided by COMPLIANCE ESCALATION • Once issued the store has 5 days to take immediate action, remedy outstanding issues and demonstrate sustainable change • • • A Critical NAR cannot be extended Failure to resolve will result in escalation If there is a reoccurrence within 90 days, indicating issues were resolved but not sustained, this will escalate to Critical Notice of Default immediately Critical Notice of Default • • • • A written notice issued by the Starbucks legal department to the Licensee corporate contact Issued as an escalation when a licensee fails to remedy a Critical NAR Once issued the store has 30 days to remedy outstanding issues and demonstrate sustainable change Failure to resolve will result in temporary or permanent store closure Temporary or Permanent Store Closure • In the event of a compliance related store closure, additional details will be provided by your Starbucks DM or RD Note: Subject to the opportunities identified, it may be necessary for Starbucks to simultaneously issue a NAR and a Critical NAR. This ensures severe food safety issues are resolved immediately. At the same time, it provides adequate time for licensees to develop and implement an action plan for other important standards gaps that require additional time to resolve and demonstrate sustainable change. your Starbucks DM or regional director (RD) © 2023 Starbucks Corporation. All rights reserved. For internal use only 4 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Understanding Your Role The success of Starbucks depends on the entire store team working together to create the Starbucks Experience for customers and each other. As a licensee, you are responsible for the experiences created in your Starbucks location and operating to Starbucks standard. To ensure that happens, you have support and partnership from Starbucks representatives to help set you up for success and achieve business goals. Below is an overview of roles and responsibilities when navigating the Starbucks Compliance process and operating with excellence. LICENSEE Role Barista STARBUCKS • • • Barista Trainer/ Daily Operations Leader Starbucks Manager/ Brand Standards Leader Role Responsibility • • • Uses operational tools and training to follow Starbucks standards and create the Starbucks Experience for customers Executes licensee action plans Responsibility District Manager Identifies teachable moments and provides feedback and coaching as needed to close gaps outlined in licensee action plans • Provides ongoing support, utilizing current tools and resources to coach, consult and issue compliance to ensure standards are met • Delivers compliance notices to key store level contact • Main point of contact during the compliance process Serves as a role model in following standards and creating the Starbucks Experience Creates and communicates action plans to close standards gaps Identifies barriers to creating the Starbucks Experience and acts quickly to provide coaching or support • Regional Director • Supports district manager in the delivery of all Default and Failure to Cure notices Consults with licensee leaders to solve complex compliance issues Supporting Resources When assessing the operational health of your store or navigating the compliance process there are many existing tools and resources available to support sustainable resolution and operational excellence. Below are just some of the operational tools and resources found on LS STAR. • • • • System Checks Deep Dive Observations Store Action Plan Period Planning Materials © 2023 Starbucks Corporation. All rights reserved. For internal use only • • Licensed Stores Operations Manual • Beverage Resource Manual Store Cleanliness and Equipment Maintenance Manual • • • Ops Excellence Field Guide – Licensed Stores Food Safety Self-Assessment Starbucks Training Materials 5 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Compliance Categories Issue, Detail & Action Compliance categories are broken down into four operational areas: Within each category, standards are listed as “Issues” with the ability to indicate one or more specific “Details” and corresponding recommended “Actions” to take. Food safety issues and details are aligned with the Food Safety Assessment and grouped into minor, major and critical categories. STAFFING & SCHEDULING TEACHING & TRAINING SALES & INVENTORY OPS STANDARDS & CONTINUOUS IMPROVEMENT Example A Starbucks DM arrives at 3pm for an unannounced Observe and Coach Visit (OCV) to follow up on the stores inventory action plan. Upon arrival the DM finds the store closed for the day, although according to the posted hours of operation, it should be open until 8pm. After connecting with the licensee, the DM learns that due to a barista callout and no backup baristas available, the store closed at noon. In this case the DM would select the Issue “Store is not adhering to posted hours of operation” and in the Detail & Action section choose “Store closing early” and “Failure to notify Starbucks DM of store closure.” ISSUE DETAIL & ACTION Store closing early - Properly schedule adequate staff to stay open until posted closing time ☐ Store is not adhering to posted hours of operation Store opening late - Properly schedule adequate staff to open at the posted opening time Store left unattended - Properly schedule adequate staff including back up support so the store is never left unattended Store closed for breaks - Schedule barista shifts to provide adequate coverage for all necessary breaks Store hours not posted - Ensure accurate store hours of operation are clearly posted and followed Failure to notify Starbucks DM of changes to posted hours - Notify Starbucks immediately if there are any changes in store hours of operation Failure to notify Starbucks DM of store closure - Notify Starbucks immediately if there is a planned or unplanned store closure Note: A full list of compliance Issues with related Details & Actions is available in the Appendix (see pages 11-20) © 2023 Starbucks Corporation. All rights reserved. For internal use only 6 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Notice of Action Required (NAR) Process Flow This process flow outlines potential escalation paths after being issued a NAR. During each phase, the Starbucks DM will conduct follow up visits to assess progress and consult on next steps and expectations. Starbucks reserves the right to take appropriate action, as permitted by law and contractual rights, to ensure the safe and working operation of all stores. Note: In the event of a compliance-related store closure, additional details will be provided by your Starbucks DM or RD. This is not a step that is taken lightly and will be weighed against the negative impact to the customer experience by not operating to standard. Start Notice of Action Required (NAR) *Starbucks Follow-Up Visit 30 Days RESOLVED EXTENSION *Starbucks Follow-Up Visit 60 Days *Starbucks Follow-Up Visit 90 Days *Starbucks DMs will conduct one or more Follow-Up Visits to assess progress or confirm complete resolution. These visits may be announced or unannounced depending on the issues and the best way to validate sustainable change. If the same issue reoccurs if within 90 days resolution, the store will be placed in Default © 2023 Starbucks Corporation. All rights reserved. For internal use only 120 Days RESOLVED DEFAULT RESOLVED RESOLVED NOTICE OF FAILURE TO CURE STORE CLOSURE STORE CLOSURE DEFAULT Starbucks Follow-Up Visit RESOLVED (Temporary or Permanent) NOTICE OF FAILURE TO CURE RESOLVED STORE CLOSURE STORE CLOSURE (Temporary or Permanent) (Temporary or Permanent) (Temporary or Permanent) 7 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Critical Notice of Action Required (Critical NAR) Process Flow When certain Food Safety Critical* issues are observed that can directly contribute to foodborne illness, a Critical NAR is issued, and immediate action must be taken by the licensee. Licensees have 5 days to remedy the Critical NAR before it is escalated to a Critical Default. This process is only leveraged for a small set of critical food safety issues, listed below. Starbucks reserves the right to take appropriate action, as permitted by law and contractual rights, to ensure the safe and working operation of all stores. Note: In the event of a compliance-related store closure, additional details will be provided by your Starbucks DM or RD. This is not a step that is taken lightly and will be weighed against the negative impact to the customer experience by not operating to standard. Starbucks reserves the right to require immediate temporary closure of a store in the event of an immediate and material threat to the health or safety of customers or employees. Start 5 Days *Starbucks Follow-Up Visit 35 Days *Starbucks Follow-Up Visit Critical NAR Issues* 90 Days ☐ 1.1a - Working while ill, improper bandage ☐ 2.1a - Inadequate refrigeration for Time/Temperature Control for Safety (TCS) foods (complete lack of refrigeration) ☐ 2.1g - Improper internal cooking temperatures (tea brewed with ambient or cold water) RESOLVED CRITICAL NOTICE OF ACTION REQUIRED REPEAT of INITIAL VIOLATION CRITICAL DEFAULT *Starbucks DMs will conduct one or more Follow-Up Visits to assess progress or confirm complete resolution. These visits may be announced or unannounced depending on the issues and the best way to validate sustainable change. If there is a reoccurrence within 90 days, indicating issues were resolved, but not sustained, this will escalate to Critical Default immediately. RESOLVED* STORE CLOSURE (Temporary or Permanent) CRITICAL DEFAULT STORE CLOSURE (Temporary or Permanent) ☐ 3.1a - Critical pest activity observed (any presence, or evidence of rodents or cockroaches (live or dead), and any presence of fruit flies or house flies in multiple areas of the store and/or on food) ☐ 4.1a - Biohazard event present ☐ 4.1b - Sewage backup present in facility ☐ 4.1c - Water service interruption (store is without drinking water) ☐ 4.1d - Operating under hazardous/dangerous public health safety conditions on store premises (fire/flood/other natural disaster) ☐ 4.1f - Hot water unavailable Note: Due to the expedited 5-day remedy period a follow up will only be conducted if escalated to Critical Default 8 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Immediate Notice of Default Process Flow The compliance process usually begins with issuing a NAR or a Critical NAR. However, in some cases it may be necessary to issue a Notice of Default immediately, bypassing the NAR or Critical NAR step. Starbucks reserves the right to take appropriate action, as permitted by law and contractual rights, to ensure the safe and working operation of all stores. Note: In the event of a compliance-related store closure, additional details will be provided by the Starbucks DM or Regional Director (RD). This is not a step that is taken lightly and will be weighed against the negative impact to the customer experience by not operating to standard. Starbucks reserves the right to require immediate temporary closure of a store in the event of an immediate and material threat to the health or safety of customers or employees. Start *Starbucks FollowUp Visit 30 Days *Starbucks Follow-Up Visit Immediate Default 60 Days • • RESOLVED DEFAULT RESOLVED NOTICE OF FAILURE TO CURE • • STORE CLOSURE The same compliance issues from a previously closed NAR or Critical NAR reoccur within a 90-day period, indicating the issues were resolved but not sustained If the same compliance issues resulting in a compliance-related temporary store closure reoccur within a 90-day period after reopening, indicating the issues were resolved but not sustained When the onsite conditions are so severe that they put the customers or baristas at risk Other considerations for immediate default may include, store history, previous coaching and documentation, and the severity of the issues (Temporary or Permanent) STORE CLOSURE (Temporary or Permanent) *Starbucks DMs will conduct one or more Follow-Up Visits to assess progress or confirm complete resolution. These visits may be announced or unannounced depending on the issues. © 2023 Starbucks Corporation. All rights reserved. For internal use only 9 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Navigating the Compliance Process Phase Starbucks Role Licensee Expectations Documentation and Delivery • • • • • • • Ensure all appropriate leaders are present and engaged • Within the first 2-3 business days after compliance has been issued, you, the licensee, should provide the Starbucks DM a written plan to close gaps Licensee Store Action Plan • • Starbucks DM will document observations and standards gaps to provide a Compliance Notice Starbucks DM will set up time (in person or virtually) to align on expectations, timelines and next steps. The Starbucks DM will review and provide consultation on action plan and reference during Follow-Up visits • • • • Assessing Progress/Follow-up visit(s) Resolving Compliance and Sustainability • • • The Starbucks DM will conduct one or more follow-up visits to assess progress. These may be announced or unannounced. © 2023 Starbucks Corporation. All rights reserved. For internal use only Inform the Starbucks DM when to expect an action plan with key dates Ask when follow up visit(s) will occur to assess progress? Will they be announced or unannounced? Ask questions to understand the escalation path if there is failure to resolve issues Determine what additional coaching and consulting support may be needed from the Starbucks DM You may choose to leverage the Store Action Plan form on LS STAR or other preferred licensee forms Plans should be specific and include detailed action(s) to be taken to address root causes, by whom, and by when. Ensure the plan is cascaded appropriately to all key leaders and baristas Leverage the plan regularly when assessing progress in closing gaps and check and adjust as needed You should follow your organizations protocols to communicate compliance issues to leaders and identify where internal escalation may be needed if additional support or resources are needed to execute the plan • • Refer to your existing action plan and share progress and/or next steps with the Starbucks DM • Maintaining a long-term Store Action Plan to sustain operational standards is highly recommended to ensure the root cause of issues has been sustainably resolved and efforts were not a short-term fix. The Starbucks DM will assess progress and provide feedback whether the store is trending towards resolution, escalation or is neutral At the end of the remedy period if the store has successfully resolved all standards gaps the compliance record will be closed by the Starbucks DM. Ask questions to understand compliance issues and what is required for resolution Discuss any challenges or barriers and identify where you may need to check and adjust the plan 10 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE APPENDIX © 2023 Starbucks Corporation. All rights reserved. For internal use only 11 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Staffing & Scheduling - Compliance Issues, Details and Actions Issue ☐ Baristas are not working together and/or not following roles and routines Detail & Action ☐ Baristas not in assigned positions - Plan and communicate to baristas their assigned positions through out all-day parts ☐ Baristas not working together - Ensure baristas work together and flex or reassign their position to meet customer demand ☐ Baristas not following routines - Review routines, coach to standards and follow up with baristas to ensure sustainability ☐ Store closing early - Properly schedule adequate staff to stay open until posted closing time ☐ Store opening late - Properly schedule adequate staff to open at the posted opening time ☐ Store left unattended - Properly schedule adequate staff including back up support so the store is never left unattended ☐ Store is not adhering to posted hours of operation ☐ Store closed for breaks - Schedule barista shifts to provide adequate coverage for all necessary breaks ☐ Store hours not posted - Ensure accurate store hours of operation are clearly posted and followed ☐ Failure to notify Starbucks DM of changes to posted hours - Notify Starbucks immediately if there are any changes in store hours of operation ☐ Failure to notify Starbucks DM of store closure - Notify Starbucks immediately if there is a planned or unplanned store closure ☐ Store does not have the optimal number of baristas hired and trained on staff to meet customer demand ☐ Understaffed and unable to build a schedule - Hire and train the optimal number of baristas to build effective schedules to meet forecasted business needs ☐ Lack of barista availability to cover all day parts - Hire and train baristas with the necessary availability to cover gaps ☐ No certified baristas or LS Leaders available to provide back up support - Hire, train, and/or schedule baristas or LS Leaders to provide back up coverage as needed and ensure back up baristas work enough shifts to be proficient ☐ Effective scheduling is not in place to meet customer demand ☐ Schedules are not accurate or effective - Write schedules to meet the forecasted needs of the business ☐ Incomplete coverage throughout all dayparts - Write schedules with adequate staffing across all dayparts ☐ Not scheduling training time required for the learner and trainer - Schedule dedicated training time for learner and trainer as outlined in training programs © 2023 Starbucks Corporation. 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For internal use only 12 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Teaching & Training– Compliance Issues, Details and Actions Issue Detail & Action ☐ Uncertified baristas working unassisted - Review and adjust schedule to ensure uncertified baristas are working with a certified barista or barista trainer ☐ Training requirements and standards have not been met ☐ No certified LS Leader - Identify, train and certify at least one LS Leader ☐ Less than 2 certified barista trainers - Identify, train and certify a minimum of 2 barista trainers and schedule them to complete all new hire training ☐ Training is not completed and/or documented using program materials - Execute training programs and certifications as outlined for each ☐ Training programs are not being executed as outlined role using training materials and ensuring all documentation is properly completed ☐ Training documentation is not maintained and/or available - Complete documentation for all training as outlined for each role ensuring documentation is maintained, updated, and available on site for review by the District Manager ☐ Baristas not trained by certified barista trainer - Review and adjust schedule to ensure all new baristas are trained by certified barista trainers ☐ Baristas are not meeting Starbucks customer service expectations ☐ Baristas are not making genuine connections with customers - Review and coach baristas on the Starbucks Customer Service Commitment: Smile, Offer a friendly greeting, Learn customers names and orders, Assume the best in others, and Say thank you ☐ Customer feedback program not being utilized - Enroll and start participating in the Starbucks Customer Experience Program ☐ Customer feedback systems are not in place - Order "Share Your Thoughts with Us" comment cards and place in an easily accessible location for customers © 2023 Starbucks Corporation. 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For internal use only 13 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Sales & Inventory - Compliance Issues, Details and Actions Issue Detail & Action ☐ Insufficient product inventory levels - Place orders to ensure sufficient levels of inventory and safety stock; adjusting par levels as needed to reflect seasonality and business fluctuations ☐ Store does not have adequate product availability ☐ Core and/or promotional beverage components unavailable - Place orders to ensure all core and/or promotional beverage components are available during all hours of operation ☐ Pre-prepared beverage components unavailable - Prepare enough beverage components in advance to meet store demand and ensure availability throughout all dayparts ☐ Store is not set up and ready to execute all elements of the current retail promotion at open on the launch date ☐ Using or selling unapproved products ☐ Baristas are not fully trained using promotional tools - For each planning period ensure all baristas complete required training utilizing the training tools provided ☐ Not following Siren's Eye - Review the current Siren's Eye and ensure all elements are set to standard for food, lobby and beverage ☐ Store is displaying unapproved signage or marketing content - Review and follow licensed store marketing guidelines ☐ Store is substituting unapproved beverage components - Immediately discontinue using unapproved beverage components and check and adjust inventory pars to ensure there are sufficient levels of approved products to meet business needs ☐ Store is selling unapproved RTD or other products - Immediately discontinue selling unapproved products and review and adhere to Starbucks approved assortments © 2023 Starbucks Corporation. 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For internal use only 14 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Ops Standards & Continuous Improvement – Compliance Issues, Details and Actions Issue Detail & Action ☐ Not meeting espresso shot standards - Ensure bean hopper is full, calibrate machine to correct espresso shot standard, and if the machine still cannot meet standard call for service ☐ Not meeting brewed coffee quality standards - Follow brewed coffee routine, ensuring brewed coffee timer is in place and active ☐ Not meeting product quality standards ☐ Using unapproved ice - Stores must use a Starbucks approved ice machine and all ice should meet the ice standards to ensure proper consistency and beverage quality ☐ Product not properly dated - Communicate and coach proper dating procedures including shelf life and/or hold times for all products to ensure freshness ☐ Not meeting sampling guidelines - Follow sampling standards by actively sampling fresh food or beverages at the ☐ Baristas are not adhering to Starbucks and Licensee approved dress code ☐ Store is not well maintained in 'like new' condition and/or appearance ☐ Weekly Sales are not reported or are inaccurately submitted ☐ Failure to take action to fix inoperable equipment ☐ Failure to complete proper preventative maintenance ☐ Food Safety Minor - Generally related to cleanliness, documentation correct temperature, portion size, and build ☐ Not adhering to dress code - Review and communicate dress code requirements and follow up to ensure sustainability ☐ Store has broken, missing, or damaged fixtures or items - Make necessary repairs to ensure store appearance is well maintained ☐ Weekly sales are not reported - Ensure weekly sales are submitted using the reporting template on time each week by Monday at 9 a.m. Pacific Time ☐ Weekly sales are inaccurately reported - Ensure sales are accurately submitted each week using the reporting template ☐ Equipment not functioning - Take immediate action to repair or replace any equipment that is not functioning properly ☐ Mastrena I - Ensure you complete two preventative maintenance visits annually ☐ Mastrena II - Ensure you complete one preventative maintenance visit annually or every 150,000- cycle count ☐ Other Equipment - Complete recommended preventative maintenance or condition and could lead to major finding ☐ Details align with Starbucks Food Safety Assessment (refer to page 18 for full list) leads to critical findings ☐ Details align with Starbucks Food Safety Assessment (refer to page 19 for full list) immediate action must be taken ☐ Details align with Starbucks Food Safety Assessment (refer to page 20 for full list) ☐ Food Safety Major - Indirectly contributes to foodborne illness, likely ☐ Food Safety Critical - Directly contributes to foodborne illness, © 2023 Starbucks Corporation. 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For internal use only 15 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Ops Standards & Continuous Improvement – Compliance Issues, Details and Actions Issue Detail & Action ☐ 1.3a - Barista aprons are not clean - Ensure aprons are clean and free from spills ☐ 1.3b - Barista's non-food personal belongings stored improperly - Store all personal belongings in a dedicated space away from food and smallwares ☐ 1.3c - Food safety training/certification not present/valid where required - Ensure all applicable certifications are valid and available for review ☐ 1.3d - Health Department reports and permit not on file - Ensure all applicable documentation is on file and available for review ☐ 1.3e - Food safety signage not present - All signage must be current and clearly visible to the customer ☐ 2.3a - Frozen product not held solidly frozen - All frozen product must be held continuously in a frozen state to maintain food safety standards ☐ 2.3b - Internal thermometer not present and/or not working properly - Repair or replace thermometer to ensure availability and in good working order ☐ Food Safety Minor - Generally related to cleanliness, documentation or condition and could lead to major finding (continued next page) ☐ 2.3c - Gaskets not in good repair - All gaskets must be free of any damage and repair or replace any gaskets showing signs of tears or cracks ☐ 2.3d - Refrigeration ventilation not maintained - All condenser coil fins must be clean and free from dust and debris ☐ 3.3a - Minor pest activity observed (ants observed in one area but not on food) - Take action to resolve pest activity and prevent future pest activity ☐ 3.3b - Pest harborage not prevented - Take action to clean or repair any area(s) that could attract pests and promote harborage ☐ 3.3c - Floors, walls, ceilings not clean and/or not cleanable - Review cleaning procedures and schedules to ensure all areas of the store are able to be wiped clean of dust and debris regularly ☐ 3.3d - Air curtain off and/or not working properly, if present - Properly maintain air curtain to ensure continuous operation ☐ 3.3e - Pest reports not on file - All applicable pest reports must be on file and available for review ☐ 3.3f - Mop area not maintained - Ensure mop area and all mop supplies are properly cleaned and stored ☐ 3.3g - Plumbing not maintained - Properly maintain all plumbing including preventing any water leaks ☐ 4.3a - Equipment/utensils/smallwares not air-dried before stacking - All smallwares must be completely air dried before stacking ☐ 4.3b - Unapproved scouring pads in use - Discontinue using any unapproved scouring pads, only approved cleaning supplies are permitted © 2023 Starbucks Corporation. 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For internal use only 16 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Ops Standards & Continuous Improvement – Compliance Issues, Details and Actions Issue Detail & Action ☐ Food Safety Minor - Generally ☐ 4.3e - Sinks and dish areas are not maintained clean - Properly clean all sinks and dish areas ☐ 4.3f - Cabinetry/countertop not maintained clean - Properly clean all countertops and cabinetry ☐ 4.3c - Non-TCS foods expired - All food must have an expiration date clearly labeled and be within that date ☐ 4.3d - Refrigeration units not clean and/or not cleanable - All refrigerator components must be clean including gaskets, shelves, fan guards, interiors and exteriors related to cleanliness, documentation or condition and could lead to major finding (continued from previous page) ☐ 4.3g - Other equipment not clean and/or not cleanable - Ensure all equipment is clean and in good repair ☐ 4.3h - Condiment bar not maintained clean - Properly clean interior and exterior of the condiment bar ensuring there is no encrusted build up ☐ 4.3i - Lighting not maintained and/or not properly shielded - Ensure all lighting is clean, working, and properly shielded ☐ 4.3j - Restrooms not clean and/or not cleanable - Properly clean entire restroom including all fixtures ☐ 4.3k - Produce not washed as required, if present - Ensure all produce is properly washed prior to use ☐ 1.2a - Hand sinks not accessible, stocked and/or used properly - Ensure hand sink is not blocked or used for anything other than hand washing and that it is properly stocked ☐ 1.2b - Fingernails/hair/jewelry not to standard - Tie back all long hair, trim nails and keep them free from polish, and keep wrists free from jewelry ☐ 1.2d - Barista food/beverage not stored properly - Store all barista food/beverage in a designated and labeled container on the bottom shelf of the back of house refrigerator away from all food and smallwares ☐ Food Safety Major - Indirectly contributes to foodborne illness, likely leads to critical findings (continued next page) ☐ 1.2e - Baristas are eating, drinking and/or smoking - Ensure all eating, drinking, and/or smoking is only done is designated areas ☐ 2.2a - Refrigeration units out of required temperature - Ensure all refrigerators are below 41°F / 40°F CAN ☐ 2.2b - Product thermometer not present and/or not working properly - Repair or replace as needed to ensure store has a properly functioning and calibrated product thermometer ☐ 2.2c - Stores using TPHC do not have proper written procedures available - If using time as a control there must be documented written procedures available ☐ 2.3d - Temperature logs not completed - Fill out temperature logs completely everyday for all day parts including any action taken and relevant notes ☐ 3.2a - Major pest activity observed (fruit or house flies in one area but not on food, ants observed in multiple areas and/or on food) - Take action to resolve pest activity and prevent future pest activity ☐ 3.2b - Pest entry not prevented - Take action to prevent all possible points of pest entry ☐ 3.2c - Pest control devices placed improperly, if present - Ensure devices are not placed above a food prep areas © 2023 Starbucks Corporation. All rights reserved. For internal use only 17 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Ops Standards & Continuous Improvement – Compliance Issues, Details and Actions Issue Detail & Action ☐ 4.2a - Equipment drain lines placed improperly - Consult with a professional as needed to ensure all drain lines are properly placed ☐ 4.2b - Food items stored unprotected - Store all food items protected in a proper food safe location or container ☐ 4.2c - Food contact items stored unprotected - Food contact items should be clean, free from damage, and stored protected in a proper food safe location ☐ 4.2d - In use food contact items not approved, clean and/or cleanable - Ensure all food contact items are clean, free from damage, and stored protected in a proper food safe location ☐ 4.2e - In use contact items not washed, rinsed, and sanitized every 4 hours - Ensure the 4 hour smallwares timer is present, running, and properly utilized to clean all food contact items ☐ 4.2f - Food packages damaged and/or damaged product not segregated - Ensure all packaged food is free from damage/tampering and any damaged products are stored separately and properly labeled ☐ Food Safety Major - Indirectly contributes to foodborne illness, likely leads to critical findings (continued from previous page) ☐ 4.2g - Prepped, ready-to-eat, or refrigerated foods improperly labeled - Properly label all foods/beverages with name and any other required labeling ☐ 4.2h - TCS product out of quality use-by date - Ensure all products are within manufacturers use-by date and any barista written date code ☐ 4.2i - Ice stored unprotected - Close all ice bins/ice machine lids when not in use and properly label and store all buckets and scoops (if applicable, ice machines accessible to customers are to be locked when not in use to prevent contamination) ☐ 4.2j - Ice equipment not maintained clean - Properly clean ice bins and ice machine ensuring they are free from mold or slime build up ☐ 4.2k - Ice equipment not in good repair - Ensure all ice equipment is free from chips, cracks, or other damage ☐ 4.2l - Chemicals improperly labeled and/or stored - Properly label, seal, and store all chemicals away from food and food prep areas ☐ 4.2m - Dishwashing machine/three compartment sink used/set up improperly - Follow all procedures to properly set up and use the dishwashing machine and three compartment sink ☐ 4.2n - Sanitizer test strips unavailable - Proper type of strips must be available, free from damage, and within use-by date ☐ 4.2o - Improper wiping cloth storage - Ensure all in use wiping cloths are completely submerged in sanitizer solution ☐ 4.3k - Produce not washed as required, if present - Ensure all produce is properly washed prior to use © 2023 Starbucks Corporation. All rights reserved. For internal use only 18 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Ops Standards & Continuous Improvement – CRITICAL Compliance Issues, Details and Actions Issue Detail & Action ☐ 1.1b - Bare hand contact with food - Train all baristas on proper food handling procedures ☐ 1.1c - Proper hand washing not taking place at appropriate times - Train all baristas on proper hand washing procedures ☐ 1.1d - Proper handwashing procedures not followed - Train all baristas on proper hand washing procedures ☐ 2.1b - Critical temperature abuse (condiment bar carafes or TCS foods out of refrigeration above 42°F/41°F CAN) - Immediately discard all product out of temperature and take actions to prevent temperature abuse ☐ 2.1c - Stores using time as public health control (TPHC) not following proper procedures - Monitor product with time removed or time of expiration and never exceed the 4-hour limit ☐ Food Safety Critical - Directly contributes to foodborne illness, immediate action must be taken. ☐ 2.1d - Proper reheating/hot holding procedures not followed - Follow all proper procedures for reheating/hot holding ☐ 2.1e - Proper cooling procedures not followed - Follow all proper procedures for cooling ☐ 2.1f - Proper thawing/slacking procedures not followed for TCS - Follow all proper procedures for thawing/slacking ☐ 4.1e - Employee restroom unavailable (employees have no access to a restroom) - Ensure there is a properly functioning restroom accessible to all baristas ☐ 4.1g - Improper conditions/procedures for warewashing - Follow all proper procedures for warewashing based on the type of machine/conditions ☐ 4.1h - Improper wiping cloth sanitizer solution concentration - Immediately change the sanitizer solution and test to ensure the proper concentration it met ☐ 4.1i - Direct contamination of food observed - Ensure there are no direct chemical, physical or biological contaminations of food/beverage/ice ☐ 4.1j - Food from unapproved sources (health or safety risk) - Immediately discontinue selling unapproved products and review and adhere to Starbucks approved products © 2023 Starbucks Corporation. All rights reserved. For internal use only 19 Starbucks Licensed Stores LICENSEE COMPLIANCE PROGRAM GUIDE Ops Standards & Continuous Improvement – CRITICAL NAR Compliance Issues, Details and Actions Issue Detail & Action ☐ 1.1a - Working while ill, improper bandage - Immediately send home baristas showing any symptoms of illness; properly cover all lesions with a bandage and if necessary, a single use glove ☐ 2.1a - Inadequate refrigeration for TCS foods (complete lack of refrigeration) - Immediate actions should be taken to provide proper refrigeration ☐ 2.1g - Improper internal cooking temperatures (tea brewed with ambient or cold water) - Follow all proper procedures and temperatures for internal cooking ☐ 3.1a - Critical pest activity observed (any presence, or evidence of rodents or cockroaches (live or dead), and any presence of fruit flies or house flies in multiple areas of the store and/or on food) - Immediately take actions to resolve critical pest activity and there should be a substantial reduction seen within 5 days ☐ Food Safety Critical - Directly contributes to foodborne illness, immediate action must be taken. ☐ 4.1a - Biohazard event present - Immediately and properly contain and clean any biohazard event ☐ 4.1b - Sewage backup present in facility - Immediately and properly contain and clean any sewage backup ☐ 4.1c - Water service interruption (store is without drinking water) - Immediately close store and contact your district manager if there is a water service interruption and do not reopen until water service issues have been resolved, all open stores must have safe drinking water available at all times ☐ 4.1d - Operating under hazardous/dangerous public health safety conditions on store premises (fire/flood/other natural disaster) Immediately close store and contact your district manager and do not reopen until hazard has been resolved ☐ 4.1f - Hot water unavailable - Immediately close store and contact your district manager until there is an adequate supply of hot water available © 2023 Starbucks Corporation. All rights reserved. For internal use only 20
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