AWRS Due Diligence Policy | Market Harborough Honey Co.

Statement of Policy

As part of the Alcohol Wholesaler Registration Scheme (AWRS) Market Harborough Honey Co. 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 and the ‘FITTED’ checks as a structure to establish potential risk within supply chains. We ensure we “know our customer and supplier”.

Market Harborough Honey Co. Limited 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.
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 Market Harborough Honey Co. Limited to undertake risk assessment before any account is opened. Market Harborough Honey Co. Limited 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.

Processes

Market Harborough Honey Co. Limited 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.

Document Review

This policy will be reviewed by the business owners as and when required or every 12 months, whichever comes first.

MHHC Company Information

Market Harborough Honey Co. Limited are committed to tackling alcohol fraud on a national level. We work to eliminate risk and aim to ensure Market Harborough Honey Co. Limited complies with the Excise Due Diligence and AWRC and insist 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:
Market Harborough Honey Co. Limited

Director’s Name:
Thomas Lamble-Dun

Registered Office:
Union House, 111 New Union Street, Coventry, Warwickshire, CV1 2NT

Company Activity:
Honey Production & Bee Farming
Wholesaler and retailer of honey
Wholesaler and retailer of spirits
Honey packing and processing

Telephone Number:
01858 220210

Email Address:
info@harborough-honey.co.uk

Company number:
12355158

VAT Number:
GB 378 6301 71

AWRS Number:
Provided on request

Website Address:
http://www.harborough-honey.co.uk

With this information, checks can be carried out on the identity and financial health of the companies through Companies House in the UK.

Company Structure

Market Harborough Honey Co. Limited is a limited company 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.

Supply Chain

Market Harborough Honey Co. Limited only source products from reputable businesses. Duty has been paid on all stock, prior to its delivery to Market Harborough Honey Co. Limited. from the distillers.

Evidence of Duty Payment

The distillers 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 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 Market Harborough Honey Co. Limited our employees and the Exchequer:

Blank invoices
Blank letterheads
Copies of companies Directors passports
Copies of Directors private address details
Bank statements
Utility bills

Ordering

Purchase ordering
All orders are raised through official purchase orders for approved suppliers via SliQ. 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 SliQ 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.

Customer ordering
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:

Market Harborough Honey Co. Limited due diligence questionnaire
Company incorporation certificate
VAT certificate
Company owner / director’s photo ID
Copy of business utility bill (less than 3 months old)
AWRS number
Signed letter of introduction on headed letter paper
Company Bank Details
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 by Bank Transfer or Card Payment Only. We do not accept third party card payments. Card Payments incur an additional processing fee of 2.5%.

Documentation required in order to consider opening a Supplier account:
As a part of the Alcohol Wholesaler Registration Scheme (AWRS), Market Harborough Honey Co. Limited is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks. Market Harborough Honey Co. Limited will require the following documents for a wholesaler to open an account to start trading:

Market Harborough Honey Co. Limited due diligence questionnaire
Copy of Incorporation Certificate
Copy of VAT Certificate
Copy of company’s last filed set of accounts (if applicable)
Copy of Money Laundering Certificate (if applicable)
Owner/Director’s/ Proprietor’s photo ID
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 terms
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.

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 Market Harborough Honey Co. Limited 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.

Retailer On-Boarding Process

MHHC On-Boarding process as follows:
MHHC will speak with the customer on the telephone and organise a Teams meeting or face-to-face meeting if not possible. We will then discuss their reasons for wanting to supply our products and finding out the history about their business.

We will then request the following list of documentation.

Copy of incorporation certificate or equivalent
AWRS and or WOWGR registration numbers will be required if applicable
Copy of VAT registration certificate
Company Bank Details

(If a company has not been operational for more than 1 year, we will require bank statements showing trading activity and cash resources for invoice payments. If the company has a trading history and substantial tax returns that are visible online this may not be necessary.)

Owner/Director Photo ID details such as Passport or Driving License
Company structure document showing ownership and whether the company is a subsidiary of a parent company.
Company address proof for trading and registered address if different, Utility Bill and/or Bank Statement (Less than 3 months old)
Copy of Lease agreement or proof of Freehold of the business premises
Confirmation of payment method will be ascertained as to how bills will be settled, whether it be by Card or Bank transfer. These will be the only methods for payment of invoices. Payments by card will incur a surcharge of 2.5% of the invoice total. Our preference is for a bank transfer.
Trade references will be requested for a minimum of 2 other suppliers. We will contact the supplier and check there has been no unpaid invoices or payment related issues.
Signed letter of introduction to MHHC on headed letter paper
Completed in full, a “MHHC Retailer Registration Form”

Statement of Policy

As part of the Alcohol Wholesaler Registration Scheme (AWRS) Market Harborough Honey Co. 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 and the ‘FITTED’ checks as a structure to establish potential risk within supply chains. We ensure we “know our customer and supplier”.

Market Harborough Honey Co. Limited 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.

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

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.

Processes

Market Harborough Honey Co. Limited 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.

Document Review

This policy will be reviewed by the business owners as and when required or every 12 months, whichever comes first.

MHHC Company Information

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: Market Harborough Honey Co. Limited

Director’s Name: Thomas Lamble-Dun

Registered Office: Union House, 111 New Union Street, Coventry, Warwickshire, CV1 2NT

Company Activity: Honey Production & Bee Farming Wholesaler and retailer of honey Wholesaler and retailer of spirits Honey packing and processing

Telephone Number: 01858 220210

Email Address: info@harborough-honey.co.uk

Company number: 12355158

VAT Number: GB 378 6301 71

AWRS Number: Provided on request

Website Address: http://www.harborough-honey.co.uk

With this information, checks can be carried out on the identity and financial health of the companies through Companies House in the UK.

Company Structure

Market Harborough Honey Co. Limited is a limited company 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.

Supply Chain

Market Harborough Honey Co. Limited only source products from reputable businesses. Duty has been paid on all stock, prior to its delivery to Market Harborough Honey Co. Limited. from the distillers.

Evidence of Duty Payment

The distillers 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 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 Market Harborough Honey Co. Limited our employees and the Exchequer:

Blank invoices

Blank letterheads

Copies of companies Directors passports

Copies of Directors private address details

Bank statements

Utility bills

Ordering

Documentation required to open a customer account:

Market Harborough Honey Co. Limited due diligence questionnaire

Company incorporation certificate

VAT certificate

Company owner / director’s photo ID

Copy of business utility bill (less than 3 months old)

AWRS number

Signed letter of introduction on headed letter paper

Company Bank Details

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 by Bank Transfer or Card Payment Only. We do not accept third party card payments. Card Payments incur an additional processing fee of 2.5%.

Market Harborough Honey Co. Limited due diligence questionnaire

Copy of Incorporation Certificate

Copy of VAT Certificate

Copy of company’s last filed set of accounts (if applicable)

Copy of Money Laundering Certificate (if applicable)

Owner/Director’s/ Proprietor’s photo ID

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 terms

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

Trading Name:
Market Harborough Honey Co. Limited

Director’s Name:
Thomas Lamble-Dun

Registered Office:
Union House, 111 New Union Street, Coventry, Warwickshire, CV1 2NT

Company Activity:
Honey Production & Bee Farming
Wholesaler and retailer of honey
Wholesaler and retailer of spirits
Honey packing and processing

Telephone Number:
01858 220210

Email Address:
info@harborough-honey.co.uk

Company number:
12355158

VAT Number:
GB 378 6301 71

AWRS Number:
Provided on request

Website Address:
http://www.harborough-honey.co.uk

MHHC On-Boarding process as follows:
MHHC will speak with the customer on the telephone and organise a Teams meeting or face-to-face meeting if not possible. We will then discuss their reasons for wanting to supply our products and finding out the history about their business.