AWRS DUE DILIGENCE POLICY
AWRS DUE DILIGENCE POLICY
As part of the Alcohol Wholesaler Registration Scheme (AWRS) DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. are required to conduct due diligence checks on both customers and suppliers involved in the supply chain for alcoholic drinks.
Due diligence is important for our business to minimise exposure to commercial risk, reduce the risk of being exposed to fraudulent transaction chains and reduce the risk of being exposed to significant financial losses.
Making due diligence an obligation for all businesses involved in alcohol will help drive fraudsters from the market place, increase consumer confidence in the sector, boost legitimate businesses by restoring a level playing field and help maintain confidence and reputation.
We carry out extensive due diligence checks following the guidelines from HMRC and the ‘FITTED’ checks as a structure to establish potential risk within supply chains. We ensure we “know our customer and supplier”.
STATEMENT OF POLICY
DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. are committed to trading in full compliance with all relevant national, EU and international laws. We will:
- Objectively assess the risks of alcohol duty fraud within the supply chains in which we operate;
- Put in place reasonable and proportionate checks, in our day to day trading, to identify transactions that may lead to fraud
- or involve goods on which duty may have been evaded;
- Have procedures in place to take timely and effective mitigating action where a risk of fraud is identified; and
- Document the checks we intend to carry out and have governance in place to ensure that these are, and continue to be, carried out as intended or customer or other trading partner where we think there is a possibility that this could involve a fraudulent transaction.
We have close regard to “know your customer” requirements as set out in 2017 Money Laundering Regulations as amended from time to time. If we suspect fraud, HMRC will be notified through our Lead Contact – NAME.
All customers who do not pass the internal checks will be notified that their account will not be opened and customers with suspicious behaviour will be reported to HMRC in a timely manner. We will not inform you when or in what manner or to whom we report suspicious behaviour.
CONSEQUENCE OF NON-COMPLIANCE
Failure to demonstrate due diligence may lead HMRC to conclude that a business is a risk to the revenue and not “fit and proper” for the purpose of excise legislation. This may lead to restrictions or conditions being imposed and, ultimately, to the withdrawal of authorizations, financial penalties, prosecutions and the seizure of stock.
Any customers or suppliers identified as high risk will undergo further questioning before we decide if we will begin to trade. Due diligence will be evaluated every 6 months for high risk customers/suppliers, annually for all others, with regular reviews to highlight any changes in activity so the appropriate actions can be taken.
All customers and suppliers must provide the required list of documents and completed questions for DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. to undertake risk assessment before any account is opened. DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. will only trade with a customer or supplier that has passed the assessment checks.
Any customers or suppliers who don’t pass our internal checks will be notified that we are unable to open an account and unable to trade. Any business with suspicious behaviour will be reported to HMRC in a timely manner.
Information submitted will be reviewed on a case-by-case basis and the company directors will conduct final sign off.
All initial checks and further reviews will be documented in the customer or supplier file electronically. Reminders for checks should be logged into CRM software and Google calendar reminders.
Day-to-day checks will be carried out to identify any potential transactions that may lead to fraud or involve goods on which duty may have been evaded. These checks are made on both supplier purchase ordering and customer sales orders.
DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. has adopted and documented processes that will:
- Check the identity of trading partners;
- Check the financial health of trading partners;
- Check the contract terms;
- Check the existence and provenance of goods that we buy and sell;
- Assess the credibility of the deal being contemplated
It is integral to those processes that in each case we will assess (having regard to said 2017 Regulations) how much information we need in order to justify the relationship or specific transaction. When we receive information, we will, as far as possible, cross-check it with independent sources.
This policy will be reviewed by the Business owners as required.
DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd.
DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. are committed to tackling alcohol fraud on a national level. We work to eliminate risk and aim to ensure DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. complies with the Excise Due Diligence and AWRC and insists that our customers and suppliers alike perform these checks on us in return.
HMRC deems checks to be risk based, however we appreciate that for many of our customers it is impossible to risk assess all their suppliers with this in mind the following information is provided to help meet due diligence obligations.
Trading Name: DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd
Trading Address: 45 Easter Park, Benyon Rd, Reading RG7 2PQ, United Kingdom.
Trading Activity: Wholesaler and retailer of Wine, Beer & Spirits & direct delivery to customers through online website
Company number: 13443538
Date of Incorporation: TBC
VAT Number: TBC
HMRC Deferment Number: NA
AWRS application number: TBC
WOWGR Excise ID: NA
EORI : TBC
Email: firstname.lastname@example.org / email@example.com
- Logistics and fulfilment: FUTURE PRO LOGISTICS LTD
- Website: https://www.futureprologistics.com/
Company Information: Company Registration: Incorporated in England Number 8756627
VAT Registration Number: 176 9861 46
- Warehouse Address: FuturePro Logistics Ltd, 40 and 45 Easter Park, Benyon Road, Reading, Berks RG7 2PQ
With this information, checks can be carried out on the identity and financial health of the companies through Companies House in the UK.
DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. are limited companies and are registered and incorporated through Companies House in the UK. The details of our current board of directors, our registered address and annual accounts are verifiable through their online service.
DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. Supply Chain
DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. only source products from reputable businesses. Duty has been paid on all stock, prior to its delivery at DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. Warehousing at FUTUREPRO LOGISTICS or delivered directly to the retailer.
Evidence of Duty Payment
DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. supply all our stock duty paid. We do not provide evidence of duty payment to customers. We will only supply this information and such evidence directly to the HMRC upon their request. Relevant invoices include our Alcohol Wholesaler Registration Scheme number.
Documents that We are Unable to Supply
The following is a list of documents which we cannot provide to customers as in the wrong hands they present a considerable potential for fraud to be conducted against DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd., our employees and the Exchequer: Blank invoices / Blank letterheads / Copies of companies Directors passports / Copies of Directors private address details / Bank statements / Utility bills
All orders are raised through official purchase orders for approved suppliers via TBCCCC. The orders are emailed across to the supplier directly with the full details of the product and price. Once the goods are received into the warehouse the goods are booked in onto TBCCCC which will highlight any error in quantity. If any delivery hasn’t been received within the required window, we will raise a query with the supplier or haulier.
For any new sales, we will first check that the customer’s due diligence file is up to date by checking Active Campaign and reviewing the due date. Customer orders are received in writing by email. Orders are then assessed alongside the due diligence provided on a case-by-case basis.
Documentation required to open a customer account:
1. DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. due diligence questionnaire (completed online).
2. Company incorporation certificate.
3. VAT certificate.
4. Company owner / director’s photo ID.
5. Copy of business utility bill (less than 3 months old).
6. AWRS number
7. Signed letter of introduction on headed letter paper?
8. Company Bank Details.
9. Copy of Lease agreement or proof of Freehold of the business premises.
Once the relevant information has been gathered, we will review the information provided and carry out risk assessment. Payment method is Card only. We do not accept third party card payments.
Documentation required in order to consider opening a Supplier account:
As a part of the Alcohol Wholesaler Registration Scheme (AWRS), DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks. DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. will require the following documents for a wholesaler to open an account to start trading:
1. DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. due diligence questionnaire (completed online).
2. Copy of Incorporation Certificate.
3. Copy of VAT Certificate.
4. Copy of company’s last filed set of accounts.
5. Copy of Money Laundering Certificate, if applicable.
6. Owner/Director’s/ Proprietor’s photo ID.
7. Company Bank Details.
8. AWRS number.
9. Copy of Business Utility Bill (Less than 3 months old).
10. Headed paper complete with Director’s Signature.
11. Proof of Due Diligence the company carries out.
12. Copy of company’s term.
13. If you are a UK duty paid supplier, please provide us with copies of form W-5 (or similar document) showing evidence of duty payment.
Once the supplier has sent the above information, the appointed accounts officer or another trained member of the team will review it. The overall risk of the supplier will be established. If the business is identified as a high risk supplier, further questions will be asked and site visits will be conducted as appropriate. Any suspicious retail pricing at uneconomic levels or improper trading patterns will be reported to HMRC in a timely manner. All high risk suppliers will be reviewed every three months; all other suppliers will be reviewed on an annual basis.
DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd. OVERVIEW
Due Diligence Code of Conduct (DDCOC) sets out the basic rules we will follow and the values that guide our decisions! It also points us to a more detailed processes and procedures relating to the purchase and supply of alcoholic products.
The DDCOC is built on the premise of ‘knowing your customer or supplier and the commercial transactions that will be involved. Supply chains are only as strong as the weakest link and the purpose of DRAFT PRODUCTS and DRAFT PRODUCTS IMPORT Ltd DDCOC is to prevent entering into commercial transactions with any illicit customer or supplier. The policy will aid in ensuring all customers and suppliers are regularly reviewed so any changes of activities are identified and the appropriate action taken.
The DDCOC will be implemented and maintained by the designated Accounts officer. All training of the DDCOC must be authorised by Accounts officer or Directors and any changes in staff will undergo full training on the DDCOC. Part of the DDCOC is to ensure day-to-day checks are in place to identify transactions that may lead to fraud or involve goods on which duty may have been evaded. Checks in purchase order processing and customer orders are two areas where daily checks are performed.
We have applied for an AWRS licence and await confirmation of the same to update this section ASAP.