Customer Due Diligence Policy

Customer Due Diligence Policy

Customer Due Diligence Policy

April 2016

CellarVino is open for trade only. We only serve to registered trade members.

For a retailer to open an account:

In order for a business to register for trade, CellarVino will require the following documents:

  • Copy of Incorporation Certificate
  • Copy of VAT Certificate
  • Company Bank Details
  • Owner Photo ID Details such as Passport & Driving License
  • Copy of Business Utility Bill (Less than 3 months old)
  • Copy of Lease agreement or proof of Freehold of the business premises

Once CellarVino has collated this information, the necessary checks will be conducted before opening the account. Payment methods are Cash or Card only. CellarVino does not accept cheques. Cash payments can only be accepted under the Money Laundering Regulations. Note that photo ID may be requested for card payment at the time of payment. There is also a charge of 1.5% on any credit card payments over £1,000. Third party card payments will not be accepted. CellarVino trade membership card must be shown when purchasing goods.

For a wholesaler to open an account: In order for a business to register as a wholesaler, CellarVino will require the following documents:

  • Copy of Incorporation Certificate
  • Copy of VAT Certificate
  • Company Bank Details
  • Owner Photo ID Details such as Passport & Driving License
  • Copy of Business Utility Bill (Less than 3 months old)
  • Copy of Lease agreement or proof of Freehold of the business premises
  • Signed account forms
  • Picture of business address, if applicable

Once the information has been gathered, the appointed officer Rachelle Dalgarno or another qualified member of staff will complete a risk assessment. Any customers identified as high risk will undergo further questioning. High risk customers that are accepted will be evaluated every three months, all other customers will be reviewed on an annual basis.

All customers who do not pass the internal check will be notified that their account will not be opened and customers with suspicious behaviour will be reported to HMRC in a timely manner.

CellarVino Supplier Due Diligence Policy

April 2016 For a supplier to open an account:

As a part of the new Alcohol Wholesaler Registration Scheme (AWRS), CellarVino is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks. CellarVino will require the following documents for a wholesaler to open an account to start trading:

  • Company Introduction stating nature of business and products available
  • Completion of Know Your Supplier Questionnaire
  • Copy of Incorporation Certificate
  • Copy of VAT Certificate
  • Copy of company’s last filed set of accounts
  • Copy of Money Laundering Certificate, if applicable
  • Owner/Director’s/ Proprietor’s ID Details
  • Company Bank Details
  • AWRS number, if this has been issued and UK based supplier
  • 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 term
  • 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, Rachelle Dalgarno 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.

Existing suppliers who are already supplying CellarVino at the date of this policy will need to provide CellarVino with the relevant documents (as above) to continue as a supplier. As with new suppliers, each supplier's risk will be established. Regular visits to the supplier’s premises will also be made by CellarVino representatives to verify business records.

CellarVino Due Diligence Code of Conduct Our Due Diligence Code of Conduct (DDCOC) sets out the basic rules we will follow and the values that will 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 CellarVino’s 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.

Specific guidelines have been developed for customers and suppliers. All customers and suppliers must provide the required list of documents and completed questions for CellarVino to undertake a risk assessment before any account is open. CellarVino will only trade with a customer or supplier if they have passed the necessary risk assessment checks. CellarVino will only work with suppliers in the alcohol industry who accept payment by cheque or bank transfer. Cash payments are not permitted.

Rachelle Dalgarno or another authorised member of the team will review the submitted information on a case-by-case basis and Amrik Binning 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 indefinitely.

Regular reviews of customer and supplier information will a be conducted by Rachelle Dalgarno or another authorised member of the team and the final sign off will be conducted by Amrik Binning.

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 Sage accounting software and Outlook calendars.

The DDCOC will be implemented and maintained by Rachelle Dalgarno who has several years experience working with CellarVino’s customers, suppliers and methods of business. Christina Deberik and Shahbaz Malik are the other authorised officers who will assist Rachelle Dalgarno in enforcing the code. All training of the DDCOC must be authorised by Rachelle Dalgarno 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.

Purchase Order Process for Nominated Suppliers

The purchase order process we currently use will help assist in ensuring fraud does not take place. All orders are raised through official purchase orders for approved suppliers on Sage. The orders are emailed across directly to the supplier with the full details of product and price. Once the goods are received into our warehouse or bonded warehouse, the goods are booked into the Sage system. This process highlights any errors in quantity and costings.

If any order has not been received in the expected delivery window, we will raise a query with the supplier, haulier if we have instructed them and destination warehouse. If anything fraudulent has been identified we take the necessary actions.

An area of higher risk of fraud is duty suspended goods CellarVino import from Europe. As policy, all purchase orders must include the haulier and all orders must be sent to the nominated bonded warehouse and sent through the EMCS system. Currently the preferred haulier is Wineflow and the preferred bonded warehouse is Edwards’s Bond.

Customer Orders

Customer orders are placed in writing by email, fax or through a CellarVino sales representative. If the order has not been sent through the appointed manner from when the account was opened, the order will be placed on hold.

The same principle applies to the delivery address requested on the customer's purchase order. CellarVino ensure copies of delivery notes for each order are received to help prove delivery to the requested delivery address.

Any changes to the form of ordering or delivery address have to be made in writing by the customer on company letterhead or company email.

HMRC Alcohol Wholesaler Registration Scheme (AWRS)

Supplier Registration Form Please can you answer the questions below and provide copies of the required documents:

  • Company Introduction stating nature of business and products available
  • Copy of Incorporation Certificate
  • Copy of VAT Certificate
  • Copy of company’s last filed set of accounts
  • Copy of Money Laundering Certificate, if applicable
  • Owner/Director’s/ Proprietor’s ID Details
  • 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 term
  • 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

NAME OF SUPPLIER: 1. How long has the company been operating for?

  1. Please provide the name, address and contact details of 2 references.

     Refer 1 Name __________________________________________________
    
              Address__________________________________________________
    
              ________________________________________________________
    
              ________________________________________________________
    
              Contact__________________________________________________
    
              Telephone________________________________________________
    
              Email____________________________________________________
    

Refer 2 Name __________________________________________________

              Address__________________________________________________

              ________________________________________________________

              ________________________________________________________

              Contact__________________________________________________

              Telephone________________________________________________

              Email____________________________________________________
  1. Please state below and provide copies of certifications for the company, i.e. Health and Safety Policy, IFS, ISO or any other accreditation.

    1. Which countries/ tax jurisdictions does the company currently operate in? If you are a UK based wholesaler please provide your AWS URN, if received or your application reference number.
  2. What credit terms does the company normally offer suppliers?

    1. Please provide the company’s bank details into which payment should be made.

      Bank Name___________________________________________________

      Bank Address__________________________________________________


      Sort Code_____________________________________________________

      Account Number_______________________________________________

  3. Is there a company website? If so, please provide details.

  4. Do you attend any trade exhibitions on behalf of the company? If yes, please provide details.

  5. Do you advertise in any media on behalf of the company? If yes, please provide details.

    1. Are you involved in any trade associations on behalf of the company? If yes, please provide details.
    2. What is the company's current returns policy?
  6. What insurance provisions are there on the company’s goods?

  7. On what provisions are the goods sold, i.e. ex-cellars, FOB, delivered, etc?

  8. If you are a non-UK based supplier, do you provide any goods that originate from the UK? If yes, please provide detail

Please return to CellarVino’s office with copies of the required documents so the relevant checks can be carried out in keeping with HMRC Alcohol Wholesaler Registration Scheme.

Completed by:

Position in company

Signature:

Date:

Company Stamp:

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CellarVino is one of the largest drinks company solely dedicated to the independent drinks industry.

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CellarVino Limited, Auction House, Crescent Road, Luton, Bedfordshire, LU2 0AH

+44 (0) 1582 457 799

sales@cellarvino.com