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AWRS Due Diligence Policy

DUE DILIGENCE POLICY – FELIX MAX LTD T/A LUNUN GIN



All Felix Max Due Diligence checks are carried out in line with the Alcohol Wholesaler Registration Scheme (AWRS). The company is registered under the scheme, holding the AWRS Unique Reference Number of XZAW00000116432.



Felix Max Ltd is fully aware of its obligations under the AWRS and processes are in place that consider the likelihood of excise duty evasion as well as other commercial/criminal risks when undertaking criminal activities.



To comply with the AWRS, Felix Max will:

Thoroughly and objectively assess the risk of fraud within the supply chain

Implement and maintain reasonable checks to identify potentially fraudulent transactions or transactions that involve goods on which duty may have been evaded

Have procedures in place where a risk of fraud is identified to mitigate impact in a timely manner

Keep records of all checks and procedures with supporting evidence (if applicable).



Suspected fraud is to be reported to Ross McGregor, Director. Should fraud be suspected, trading with the supplier/customer in question will cease immediately and the incident reported to HMRC.



Details checked throughout the supply chain may include (but are not limited to):

Trading and registered address

Point of contact & contact details

Certificate of Incorporation

Company owner proof of identification

AWRS & company registration numbers

Banking details

Credit check

Product country of origin

Ad hoc site visits



Felix Max Ltd reserves the right to deny sale to any companies that fail to pass checks on the above.



To protect against potentially fraudulent behaviour, certain documents may not be issued to customers, such as: blank invoices/headed paper; proof of identification of employees/Directors; bank statements; utility bills. Any requests for such documentation may be reported to HMRC.



Felix Max Ltd stands against fraudulent activity of any kind. For further information, enquiries may be submitted in writing to 4 Islay Place, Perth, PH1 3FU.



Policy Drafted: June 2021

Policy Updated: February 2023