Hi Richard
As you describe, there is a scenario with high level of compliance isn FS Culture. A BRC AA permit supposes that several dimensions of the GFSI FS Culture are met.
In order to assure compliance with 1.1.2 clause may be required a Pre Assessment against the GFSI document. in order to determine which of the 5 levels of development are in each position of the organizational chart and other intended parties. This could minimize the amount of actions/costs.
If you are interested I would offer the referred service in a remote mode.
Mi contact is
Ana Domenech
BRC & FSSC 22000 Leader Auditor
AIB Food Safety Professional
Have a nice day
Regards
Ana