DUE DILIGENCE
Island Goods Ltd is committed to tackling alcohol fraud in the United Kingdom, the EU
and/or recognised international tax authorities. We will work to eliminate risk and aim to
ensure that we comply with all requirements and regulations as set out by HMRC under
the Excise Notice 2002. ( Excise Notice 2002: Alcohol Wholesaler Registration Scheme
– GOV.UK (www.gov.uk) )
The following information has been prepared to support and confirm Island Goods Ltd to
be classified as ‘fit and proper’ in compliance with these regulations.
Company Details:
Company Name: Island Goods Ltd
Registered Address: 3 Durlock House, Gosling Way, London SW9 6LS
Company Registered Number in England and Wales: 16148497
VAT Number: 494 7742 38
EORI Number: GB494774238000
AWRS Unique Reference Number (URN): XZAW00000122511
Due Diligence Code of Conduct (DDCOC)
Island Goods Ltd – Due Diligence Code of Conduct (DDC
OC) sets out the basic rules
we will follow and the values that will guide our decisions. It gives us a more detailed
process and procedure 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 Island Goods Ltd - DDCOC is to prevent entering
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 Island
Goods Ltd to undertake a risk assessment before any account is open. Island Goods Ltd
will only trade with a customer or supplier if they have passed the necessary risk
assessment checks. Island Goods Ltd will only work with suppliers in the alcohol
industry who accept payment by cheque or bank transfer. Cash payments are not
permitted and will only be accepted on the discretion of the Director.
Trade Customers Due Diligence Checks:
In order for a customer to register for trade, the Company will require the following
documents:
− Photographic proof of identity and age for business owner (e.g., passport or driving
license).
− For sales to AWRS-registered wholesalers: AWRS registration number.
− For sales to licensed businesses: Copy of club premises certificate, premises licence,
or Temporary
Event Notice (TEN).
− Name and Company Number of any company registered with Companies House.
− Copy of VAT Certificate (if business is VAT registered).
− Business bank details in the name of the potential customer.
− Proof of address, for example copy of business utility bill (less than 3 months old).
Suppliers Due Diligence Checks:
All potential UK suppliers will be subject to a site visit during which the following
business records will be
requested for inspection and copies taken:
− Photographic proof of identity of business owner (e.g., passport or driving license).
− Proof of address, for example copy of business utility bill (less than 3 months old).
− Company bank details in the name of the supplier.
− Company Incorporation Certificate and the latest filed accounts.
− VAT Certificate.
− AWRS registration number.
− Supply chain AWRS due-diligence policy.
− If relevant: WOWGR certificate; or trade facility warehouse approval; or HMRC
approval to hold excise duty suspended alcohol at another facility.
Where suppliers are located outside of the UK, equivalent checks to those detailed
above will, as far as is possible, be carried out in the relevant jurisdiction.
The Director or an authorised member of Island Goods Ltd will review the submitted
information on a case-by-case basis and the Director 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.
Regular reviews of customer and supplier information will be conducted by the Director
or an authorised member of Island Goods Ltd and the final sign off will be conducted by
a Director.
All initial checks and further reviews will be documented in the customer or supplier file
and maintained on an ongoing basis. Reminders for checks should be logged onto the
accounting software and cloud-based calendars. The DDCOC will be implemented and
maintained by the Director. All training and signoff’s of the DDCOC will be authorised by
a director and 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
Company number 16148497 www.islandgoods.ltd
purchase order processing and customer orders are two areas where daily checks are
performed.
Once the trade customer or supplier has sent the above information, the Director or the
authorised member of Island Goods Ltd will review it. The overall risk of the trade
customer or supplier will be established. If the individual or business is identified as
high-risk, further questions will be requested, 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 trade customer or suppliers will be reviewed every three months; all other
trade customers or suppliers will be reviewed on an annual basis.