// BEER & CIDER WHOLESALE
Due Diligence Policy
1. Introduction
As an approved alcohol wholesaler, Thunder Panda Ltd is committed to upholding the highest standards of integrity and compliance with all relevant regulations, including those outlined by Her Majesty’s Revenue and Customs (HMRC). This Due Diligence Policy establishes the framework within which Thunder Panda Ltd will objectively assess and mitigate the risks of alcohol duty fraud within its supply chains.
2. Objective Assessment of Risks
Thunder Panda Ltd recognises that the risks of alcohol duty fraud are inherent within the alcohol sector supply chains. To effectively mitigate these risks, we will objectively assess the likelihood of our trading activities contributing to fraud. This assessment will encompass all trading relationships established by Thunder Panda Ltd, considering factors such as the credibility of suppliers and the provenance of goods.
3. Risk Indicators
Possible indicators of risk, as outlined by HMRC, include but are not limited to:
- Unusually complex or uneconomic supply routes.
- Lack of transparency or credibility of suppliers.
- High-value goods sourced from unconventional locations.
- Suspicious payment or credit arrangements.
- Lack of proper documentation or evidence of duty payment.
4. Due Diligence Checks
Thunder Panda Ltd will implement reasonable and proportionate due diligence checks tailored to the nature and complexity of our transactions. These checks will focus on areas such as:
- Financial health and creditworthiness of trading partners.
- Verification of the identity and legitimacy of businesses.
- Scrutiny of contract terms, payment arrangements, and credit agreements.
- Examination of transport details and logistics arrangements.
- Confirmation of the existence and provenance of goods.
- Evaluation of the nature and viability of trading deals.
5. Responses to Identified Risks
Where due diligence checks indicate real concerns regarding the risk of fraud, Thunder Panda Ltd will take timely and effective mitigating action. This may include revising supply chain arrangements or refraining from engaging in high-risk transactions. However, the decision to trade with another party remains a commercial one for Thunder Panda Ltd.
6. Review of Due Diligence Procedures
HMRC will periodically review the effectiveness of Thunder Panda Ltd’s due diligence procedures to ensure they adequately address fraud risks. Thunder Panda Ltd must demonstrate that it has objectively assessed supply chain risks and implemented reasonable checks and procedures to respond to fraud risks effectively. Failure to maintain sufficient due diligence may result in sanctions or the revocation of AWRS approval.
7. Conclusion
Thunder Panda Ltd is committed to maintaining robust due diligence procedures to combat the risks of alcohol duty fraud within its supply chains. By adhering to this policy and continuously monitoring and refining our processes, we aim to uphold the highest standards of compliance and integrity in our operations.