DUE DILIGENCE


 

Oct ‘18

WEE HEMP SPIRITS LTD – DUE DILIGENCE

INTRODUCTION

Wee Hemp Spirits Ltd are committed to tackling alcohol fraud on a national level. Wee work to eliminate risk and aim to ensure Wee comply with all requirements and regulations and insist that our customers and suppliers perform due diligence checks on us in return.

OVERVIEW

As part of the Due Diligence requirement in the various excise regimes (Alcohol Wholesaler Registration Scheme, WOWGR, excise warehousing) it is necessary for Wee Hemp Spirits Ltd to carry out due diligence checks on existing and proposed customers, UK suppliers where applicable, and contractors. This is also important from anti-money laundering, anti-excise duty fraud and normal commercial perspectives.

PURPOSE & AUDIENCE

The purpose of this policy is to set out our, Wee Hemp Spirits Ltd, approach to due diligence. Alcohol duty fraud is a serious problem that harms not only the UK taxpayer but also legitimate businesses, communities and the wider economy. Without effective safeguards in place, there are considerable risks to all businesses along alcohol supply chains of becoming implicated in illicit trading. The due diligence condition requires that all excise registered businesses operating in the alcohol sector consider the risk of excise duty evasion as well as any commercial and other risks when they are trading. Doing so will help to drive illicit trading out of alcohol supply chains and reduce the risk to businesses of financial liabilities associated with goods on which duty has been evaded. This policy should be read by all members of staff, and especially by Directors, Buyers, Account Managers and Sales Teams.

STATEMENT OF POLICY

Wee Hemp Spirits Ltd is committed to trading in full compliance with all relevant national, EU and international laws. We will:

a) Objectively assess the risks of alcohol duty fraud within the supply chains in which we operate;

b) 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;

c) Have procedures in place to take timely and effective mitigating action where a risk of fraud is identified; and

d) 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 will 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 - Calum Napier, (Business owner).

All customers who do not pass the internal checks will be notified that their account will not be opened and customers with suspicious behavior 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.

PROCESSES

Wee Hemp Spirits Ltd has adopted and documented processes that will:

1. Check the identity of trading partners;

2. Check the financial health of trading partners;

3. Check the contract terms;

4. Check the existence and provenance of goods that we buy and sell;

5. 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.

 

REVIEW

This policy will be reviewed by the Business owners as required.

The following information has been prepared to support and confirm Wee Hemp Spirits Ltd to be classified as “fit and proper” in compliance with HMRC regulations:

 

Trading Name: Wee Hemp Spirits Ltd

Trading Address: 3 Eday Road, Aberdeen, AB15 6JH

Trading Activity: Wholesaler of Spirits & direct delivery to customers through online website

Company number: SC616502

Date of Incorporation: 19/12/2018

VAT Number: N/A

HMRC Deferment Number: N/A

AWRS application number: 077000014508

 

Phone: 07521340410

Email:info@weehempspirits.com

 

BUSINESS STRUCTURE

Wee Hemp Spirits Ltd is the trading name of a Scottish Partnership based in Aberdeen, Scotland. The details of our owners, our business address and our accounts will be provided where required by entities with whom we enter into commercial arrangements.

Partner: Calum Napier

Partner: Rebecca Napier

IMPORTANT NOTE:

The company registered at Companies House named Wee Hemp Company Ltd is presently not trading & is not currently involved with this partnership or any of its activities.

SUPPLY CHAIN

Wee Hemp Spirits Ltd only source products from reputable businesses within the EU. 

STORAGE

All products from start to finish are stored at contracted Brewery’s warehouse facilities.

With the exception of sensitive documents, such as blank invoices, letterheads, utility bills and banks statements Wee are fully open and transparent and welcome any and all checks you wish to make, if Wee can be of any assistance, Wee surely will.

WEE HEMP SPIRITS LTD AWRS SUPPLIER/TRADE CUSTOMER FORM

Please request this document or download & return this one to us. This document should contain details sensitive to YOUR business.

 

Once the supplier or customer has sent the above information, a partner or another trained member of the team will review it. The overall risk of the supplier or customer will be established. If the business is identified as a high-risk supplier or customer, 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. Wee reserve the right to carry out reviews for which Wee may require updated or additional information and may require further site visits or personal interviews.