Alcohol Wholesaler Registration Scheme ( AWRS )
AWRS Policy – Artigiano Limited T/A Hammersmith Brewery
EXCISE DUE DILIGENCE POLICY - AWRS URN XCAW 000 0011 5107
October 2024
Summary
Artigiano Ltd is fully aware of its obligations under the Alcohol Wholesaler Registration Scheme (AWRS). A due diligence process is in place which considers the likelihood of excise duty evasion as well as other commercial/criminal risks when undertaking trading activities. Artigiano Ltd fully supports any action to drive out illicit trade in alcohol and reduce the risk to businesses. It is for this reason that you as a supplier/retailer will have to accept the terms set out in this policy below.
Background
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. Any business in the supply chain which trades in alcohol is potentially at risk of becoming implicated in the illicit alcohol trade unless it undertakes due diligence checks as set out by HMRC in Excise Notice 2002. The AWRS is designed to reduce fraud and under the scheme, any business which falls within the definitions in the Notice as being required to register, must do so. From March 2017, it will be an offence to purchase alcohol from an unregistered wholesaler.
Artigiano Ltd may ask for your Unique Reference Number (URN) or AWRS application reference number in addition to any other questions that may be pertinent in order to document and satisfy the requirements of due diligence as set out by HMRC. Artigiano Ltd will not deal with any customers or suppliers where it is felt that there is a possibility that such trade will involve fraud. If Artigiano Ltd suspect fraud, HMRC will be notified.
Artigiano Ltd maintains its obligation to:
· Objectively assess the risk of alcohol duty fraud within the supply chain
· Establish reasonable and proportionate checks in day-to-day trading in order to ensure that transactions do not lead to fraud and do not involve duty-evaded goods
· Establish processes and procedures to take timely and effective action where the risk of fraud has been identified
· Put in place audit and governance procedures to ensure that due diligence processes are, and continue to be, carried out
For the purposes of AWRS, suppliers or customers may need to document their own due diligence regarding Artigiano Limited.
The Unique Reference Number (URN) for Artigiano Ltd will be placed on all invoices for reference.
Artigiano Ltd is committed to trading in full compliance with all relevant national, EU and International laws, although we only source products from reputable businesses within the UK. We do not import alcohol-based products from the EU and non-EU countries. All products we supply will have had its appropriate duty paid.
Requirements to open an account with Artigiano Ltd
1. FOR A RETAILER TO OPEN AN ACCOUNT:
In order for a business to register for trade, Artigiano Ltd will require the following documents:
A completed account application form which is available online at https://www.hammersmithbrewery.co.uk/due-diligence
or which can be posted on request.
Copy of Incorporation Certificate (if Applicable)
Copy of VAT Certificate (If applicable)
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 (Proof of contract if using third party distribution hub)
Once Artigiano Ltd has collated this information, the necessary checks will be conducted before opening the account. Payment methods are card, bank transfer or direct debit only. Artigiano Ltd does not accept cheques or cash. Note that photo ID may be requested for card payment at the time of payment. Third party card payments will not be accepted.
2. FOR A WHOLESALER TO OPEN AN ACCOUNT:
In order for a business to register as a wholesaler, Artigiano Ltd will require the following documents:
A Completed account trade application form which is either filled online or filled in by hand
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 (Proof of contract if using third party distribution hub)
Signed account forms
Picture of business address, if applicable
Once the information has been gathered, the appointed officer Giovanni Palermo (Managing Director) or another qualified member of staff will complete a risk assessment. Any customers identified as high risk will undergo further questioning. Higher 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 within 5 working days.
3. FOR A SUPPLIER TO OPEN AN ACCOUNT:
As a part of the Alcohol Wholesaler Registration Scheme (AWRS), Artigiano Ltd is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks. Artigiano Ltd will require the following documents for a supplier to open an account to start trading:
Company Introduction stating nature of business and products available
Copy of Incorporation Certificate
Copy of VAT Certificate
Owner/Director’s/ Proprietor’s ID Details
Company Bank Details
AWRS number if this has been issued and UK based supplier
Headed paper or business card
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, Giovanni Palermo 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 within 5 working days.
All higher risk suppliers will be reviewed every three months; all other suppliers will be reviewed on an annual basis.
4. DUE DILIGENCE CODE OF CONDUCT (DDCOC):
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 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 the Artigiano Ltd 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 Artigiano Ltd to undertake a risk assessment before any account is open. Artigiano Ltd will only trade with a customer or supplier if they have passed the necessary risk assessment checks.
Giovanni Palermo will review the submitted information on a case-by-case basis and 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 be conducted by Giovanni Palermo and the final sign off will be conducted by Giovanni Palermo.
All initial checks and further reviews will be documented in the customer or supplier file and maintained on an ongoing basis.
The DDCOC will be implemented and maintained by Giovanni Palermo who has experience working with Artigiano Ltd customers, suppliers and methods of business.
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.
5. 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 Breww. 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 Breww 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.
The same principle applies to the delivery address requested on the customer’s purchase order. Artigiano Ltd ensures 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.
Existing suppliers who are already supplying Artigiano Ltd at the date of this policy will need to provide Artigiano Ltd 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 may also be made by Artigiano Ltd representatives to verify business records.
Existing Customers who are already purchasing from Artigiano Ltd at the date of this policy will need to provide Artigiano Ltd with the relevant documents (as above) to continue as a customer. As with new customers, each customer’s risk will be established. Regular visits to the supplier’s premises may also be made by Artigiano Ltd representatives to verify business records.