Due Diligence Policy

Version 1 – Issued July 2020

Due for review – February 2021

Written by: Kevin Fox

Approved by: Peter Sullivan

Contents:

Due Diligence Policy

As part of the Alcohol Wholesaler Registration Scheme (AWRS) Gin Genie Distillery Limited 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 to establish potential risk within supply chains. We ensure we “know our customer and supplier”.

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.

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 with them. Any business with suspicious behaviour will be reported to HMRC in a timely manner.

All customers and suppliers must provide the required list of documents and completed questions for Gin Genie Distillery Ltd to undertake risk assessment before any account is opened. Gin Genie Distillery Ltd will only trade with a customer or supplier that has passed the assessment checks.

Information submitted will be reviewed on a case-by-case basis by the company directors.

All initial checks and further reviews will be documented in the ‘Due Diligence Checklist’ File both electronically and in paperwork formats. 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.

Due Diligence Pack

The following information has been prepared to support and confirm Gin Genie Distillery Limited to be classified as “fit and proper” in compliance with HMRC regulations:

Gin Genie Distillery Ltd.

Registered address: 8 Columbine way, Littlehampton, West Sussex. BN17 6UX

These addresses are not open to the public.

Gin Genie Distillery Ltd is registered in the UK:

Company Number: 12239925

Nature of business: 11010 - Distilling, rectifying and blending of spirits

Date of incorporation: 2ND Oct 2019

VAT Number: GB335919085

Rectifier & Compounder: NRU/REC/238/19 & 245/19

AWRS URN: XTAW000 000 0011 4747

Gin Genie Distillery is a limited company 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.

Company Directors:

Kevin Fox

Peter Sullivan

Contact via email: info@gingeniedistillery.com

CUSTOMER DUE DILIGENCE POLICY

For a retailer (Off License) or online account through Shopify or company website. 

In order for a business to register for trade, Gin Genie Distillery will require the following documents:

• Copy of Incorporation Certificate
• Copy of VAT Certificate
• Company Bank Details
• Owner Photo ID details such as Passport or Driving License
• Copy of Business Utility Bill (Less than 3 months old)

Once Gin Genie Distillery has collated this information, the necessary checks will be conducted before opening the account. Payment methods are Card or Bank Transfer only (Gin Genie Distillery preferred method is bank transfers and Cards for online sale). Gin Genie Distillery does not accept cheques.

For a wholesaler

In order for a business to register as a wholesaler, Gin Genie Distillery will require the following documents:

• Copy of Incorporation Certificate
• Copy of VAT Certificate
• Company Bank Details
• Owner Photo ID details such as Passport or Driving License
• Copy of Business Utility Bill (Less than 3 months old)
• AWRS URN

Once the information has been gathered, the appointed officer or another qualified member of staff will complete a risk assessment. Any customers identified as high risk will undergo further questioning. High risk customers that are accepted will be evaluated every three months; all other customers will be reviewed on an annual basis.

All customers who do not pass the internal check will be notified that their account will not be opened and customers with suspicious behaviour will be reported to HMRC in a timely manner.

GIN GENIE DISTILLERY DISTRIBUTORS – SUPPLIER DUE DILIGENCE POLICY

As a part of the Alcohol Wholesaler Registration Scheme (AWRS), Gin Genie Distillery is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks. 

Gin Genie Distillery will require the following documents for a wholesaler to open an account to start trading:

• Company Introduction stating nature of business and products available
• Copy of Incorporation Certificate
• Copy of VAT Certificate
• Copy of company’s last filed set of accounts
• Copy of Money Laundering Certificate, if applicable
• Owner/Director’s/ Proprietor’s ID Details
• Company Bank Details
• AWRS number
• Copy of Business Utility Bill (less than 3 months old)
• Headed paper complete with Director’s Signature
• Proof of Due Diligence the company carries out
• Copy of company’s term
• 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.

Existing suppliers who are already supplying Gin Genie Distillery at the date of this policy will need to provide the relevant documents (as above) to continue as a supplier. As with new suppliers, each supplier's risk will be established. Regular visits to the supplier’s premises will also be made by Gin Genie Distillery representatives to verify business records.

Gin Genie Distillery’s’ Due Diligence Code of Conduct (DDCOC) sets out the basic rules we will follow and the values that will 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 Gin Genie Distillery’s’ 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.

Specific guidelines have been developed for customers and suppliers. All customers and suppliers must provide the required list of documents and completed questions for Gin Genie Distillery to undertake a risk assessment before any account is open. Gin Genie Distillery will only trade with a customer or supplier if they have passed the necessary risk assessment checks. Gin Genie Distillery will only work with suppliers in the alcohol industry who accept payment by bank transfer. Cash payments are not permitted.

Designated Accounts officer or another authorised member of the team will review the submitted information on a case-by-case basis and Kevin Fox will conduct the final sign off. Any customer or supplier who fails to pass the risk assessment will immediately have all transactions ceased pending review. If the review is unsatisfactory, the account will be closed indefinitely.

Regular reviews of customer and supplier information will be conducted by Accounts officer or another authorised member of the team and the final sign off will be conducted by Kevin Fox.

All initial checks and further reviews will be documented in the customer or supplier file and maintained on an ongoing basis. Reminders for checks will be logged onto the accounting software and Outlook calendars.