AWRS Due Diligence Policy

1. FOR A RETAILER TO OPEN AN ACCOUNT:

In order for a business to register for trade, The Origin Beer Company will require
the following documents:

● Copy of Incorporation Certificate
● Copy of VAT Certificate (If applicable)
● Company Bank Details
● Trade References
● Premises Licence Code (If Applicable)

Once The Origin Beer Company has collated this information, the necessary checks will be conducted before opening the account. Payment methods are Card or bank transfer only. The Origin Beer Company 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. The Origin Beer

2. FOR A WHOLESALER TO OPEN AN ACCOUNT:

In order for a business to register as a wholesaler, The Origin Beer Company 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 (Proof of contract if using third party distribution hub)
● AWRS Number

Once the information has been gathered, the appointed officer Finlay Heslop 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 within 5 working days.

3. FOR A SUPPLIER TO OPEN AN ACCOUNT:

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

● Company Introduction stating nature of business and products available
● Completion of ‘FITTED’ online questionnaire
● 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

The FITTED questionnaire, includes all information that is required for our checks as well as points to upload evidence. This will be sent directly to a new supplier prior to an initial order being placed.

Once the supplier has sent the above information, Finlay Heslop 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 within 5 working days.

All high 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 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  The Origin Beer Company 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 The Origin Beer Company to undertake a risk assessment before any account is open. The Origin Beer Company will only trade with a customer or supplier if they have passed the necessary risk assessment checks. The Origin Beer Company will only work with suppliers in the alcohol industry who accept payment by bank transfer. Cash and cheque payments are not permitted.

Finlay Heslop or another authorised member of the team will review the submitted information on a case-by-case basis and Finlay Heslop 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 Finlay Heslop or another authorised member of the team and the final sign off will be conducted by Finlay Heslop. In the rare occasion Finlay Heslop is unable to complete the final sign off, Wesley Hall will work on his behalf and cross check with Finlay Heslop on his return.

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 Xero accounting software and internal cloud-based calendars.

The DDCOC will be implemented and maintained by Finlay Heslop who has experience working with The Origin Beer Company customers, suppliers and methods of business. In the rare occasion Finlay Heslop is unable to complete any checks, David Heslop will work on his behalf and cross check with Finlay Heslop on his return.

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 XERO. 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 XERO 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.

6. CUSTOMER ORDERS:

Customer orders are placed in writing by email (sales@moonwakebeer.com) or the B2B Trade Store. 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. The Origin Beer Company 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.