AWRS Due Diligence Policy

Statement of Policy

Shimla Gin Ltd is committed to trading in full compliance with all relevant national, EU and international laws. We will:
  • Objectively assess the risks of alcohol duty fraud within the supply chains in which we operate
  • Put in place reasonable and proportionate checks in our day to day operations to identify transactions that may lead to fraud or involve goods on which duty may have been evaded
  • Have procedures in place to take timely and effective mitigating action where a risk of fraud is identified
  • 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 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 – Talwinder Patara, Director. All customers who do not pass the internal checks will be notified that their account will not be opened and customers with suspicious behaviour 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

Shimla Gin Ltd has adopted and documented processes that will:
  • Check the identity of trading partners
  • Check the financial health of trading partners
  • Check the contract terms
  • Check the existence and provenance of goods that we buy and sell
  • 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 Money Laundering 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. This policy will be reviewed by the Business owners as required.

Shimla Gin Ltd

Shimla Gin Ltd is committed to tackling alcohol fraud on a national level. We work to eliminate risk and aim to ensure Shimla Gin complies with the Excise Due Diligence and AWRC, and we insist that our customers and suppliers alike perform these checks on us in return. HMRC deems checks to be risk based. We appreciate that for many of our customers it is impossible to risk assess all their suppliers with this in mind the following information is provided to help you meet your due diligence obligations. Trading Name: Shimla Gin Ltd Trading Address:  352 Bearwood Road, Bearwood B66 4ET, England Trading Activity: Producer, Wholesaler and Retailer of Spirits, including direct sales and delivery through our website Company number: 09063366 Date of Incorporation: 30 May 2014 VAT Number: 350788870 HMRC Deferment Number: N/A AWRS application number: XPAW0000114387 WOWGR Excise ID: N/A EORI : N/A Phone: 07754 325786 Email: info@shimlagin.com Website: https://shimlagin.com With this information, checks can be carried out on the identity and financial health of the company through Companies House in the UK (https://find-and-update.company-information.service.gov.uk/company/09063366)

Company Structure

Shimla Gin Ltd is a limited company, registered and incorporated through Companies House in the UK. The details of our current board of directors, our registered address and annual accounts are verifiable through their online service.

Supply Chain

Shimla Gin source products only from reputable businesses. Duty has been paid on all stock before delivery at Shimla Gin warehousing.

Evidence of Duty Payment

Shimla Gin supplies all our stock duty paid. We do not provide evidence of duty payment to customers. We will only supply this information and such evidence directly to the HMRC upon their request. Relevant invoices include our Alcohol Wholesaler Registration Scheme number.

Documents we do not supply

The following is a list of documents which we do not provide to customers, as in the wrong hands they present a considerable potential for fraud to be conducted against Shimla Gin, our employees and the Exchequer. Blank invoices Blank letterheads Copies of companies Directors passports Copies of Directors private address details Bank statements Utility bills We trust that this information provides all you require to satisfy your Excise Due Diligence requirements. Should you have any questions with regards to this matter then please do not hesitate to contact us.

Customer Due Diligence Policy

As a part of the Alcohol Wholesaler Registration Scheme (AWRS), Shimla Gin is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks. For Shimla Gin to trade with a business, whether physical (e.g. Off Licence) or online (e.g. online retailer), we require the following information: Trading Name Trading Address Phone Email Website Trading Activity Company Registration number Date of Incorporation VAT Number AWRS application number (URN) HMRC Deferment Number (if applicable) WOWGR Excise ID (if applicable) EORI (if applicable) Company Bank Details Excise Registration Number Warehouse Address Payment terms, including returns policy, insurance provisions, details on what provisions are the goods sold, i.e. ex-cellars, FOB, delivered, etc We will also need scanned digital copies of the following documents:
  • Certificate of Incorporation
  • VAT Certificate
  • Company Bank Details
Once Shimla Gin has received this information, all necessary checks will be conducted before opening the account. The appointed accounts officer 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 high risk, we will ask for more information. will undergo further questioning. All businesses who do not pass internal checks will be notified that their account will not be opened. High risk customers that are accepted will be evaluated every three months, all other customers will be reviewed on an annual basis. Any suspicious behaviour, retail pricing at uneconomic levels or improper trading patterns will be reported to HMRC in a timely manner. Payment methods are Bank Transfer only, Shimla Gin does not accept cheques.

Shimla Gin Due Diligence Code of Conduct

Shimla Gin’s internal Due Diligence Code of Conduct sets out the basic rules we will follow and the values that will guide our decisions. It is built on the premise of ‘knowing your customer or supplier and the commercial transactions that will be involved. You can read our Code of Conduct online here.