POLICY – DUE DILIGENCE

BACKGROUND

To comply with requirements of the AWRS (Alcohol Wholesaler Registration Scheme), D & F McCarthy Ltd (McCarthys) must carry out due diligence checks of the supply chain of alcohol both for supply to and from McCarthys.

PURPOSE

The due diligence policy is in place to prevent alcohol duty fraud whereby businesses or individuals may attempt to evade excise duty. This policy will ensure D & F McCarthy Ltd is satisfies all requirements from HMRC and does not trade with any companies without sufficient registrations in place.

GENERAL

For all suppliers of alcohol, supplier forms must be filled out before any trading commences. These supplier forms request the business names and AWRS numbers of any companies involved within the supply chain, which will subsequently be checked online with HMRC. The companies will be checked to be active by means of companies house, websites, social media etc. McCarthys will aim to buy all alcoholic beverages directly from Producers within the local area, thus having a direct supply chain to minimise the exposure to illegitimate parties. Only once all information for a supplier is identified as accurate will trading commence.

For all customers buying alcohol from D & F McCarthy Ltd, customers must provide proof of AWRS number/premises licence/personal licence holder, as required with the type of establishment they are. As well as this, customer account forms insist that customers detail the type of their business (sole trader, LLP, limited company etc.) and name of a responsible party (owner, director etc.) so that McCarthys are able to conduct a credit search prior to any sale of goods.

The ERP system used by D & F McCarthy Ltd, De Facto, is able to track stock movement from purchase to sale. This allows McCarthys to monitor exactly which customers/suppliers are buying/supplying goods, cross referencing this with relevant customer/supplier forms. It also allows full forward and backward product recalls.