Due Diligence Policy

POLICY STATEMENT

HF Drinks Limited is committed to conducting all trading activity in accordance with UK law and HMRC Excise Due Diligence requirements, including those applicable under the Alcohol Wholesaler Registration Scheme (AWRS).

We work exclusively with international suppliers and producers outside the United Kingdom, and take particular care to ensure that all goods entering our supply chain are legitimately produced, correctly documented, and compliant with UK import and excise requirements.

Our approach is designed to reduce the risk of involvement in alcohol duty fraud, tax evasion, or other financial crime. We maintain full visibility of our supply chain from origin to UK distribution, ensuring that all products are sourced through reputable and verifiable businesses.

We adopt a risk-based due diligence process across all trading relationships, including suppliers, logistics providers, warehouse partners, and customers. As part of this, we verify key business information and assess whether the commercial relationship is consistent with legitimate international trade.

We also monitor transactions and supply chain activity to ensure they remain consistent with expected commercial behaviour. Where concerns arise, additional checks are carried out before trading proceeds.

HF Drinks Limited maintains a “Know Your Customer” and “Know Your Supplier” approach aligned with HMRC guidance. Where we identify suspected fraud, duty evasion, or other suspicious activity, we reserve the right to suspend trading immediately and notify HMRC where appropriate.

CONSEQUENCES OF NON-COMPLIANCE

Failure to maintain adequate due diligence standards may result in HM Revenue & Customs determining that a business is not fit and proper for the purposes of excise regulation. This could lead to regulatory action including withdrawal of AWRS approval, financial penalties, seizure of goods, suspension of trading activity, and in serious cases, criminal investigation or prosecution. HF Drinks Limited therefore treats compliance with this policy as a core requirement of doing business, and expects the same standard from all parties within its supply chain.

DUE DILIGENCE APPROACH

Our due diligence process is designed to ensure we only enter into trading relationships with legitimate and reputable overseas producers and suppliers. Before establishing or continuing a trading relationship, we assess the identity, legal status, and commercial credibility of each counterparty, including verification of their business registration and operating legitimacy in their country of origin where appropriate.

We also review the commercial rationale of transactions, including pricing, payment structure, logistics arrangements, and supply chain transparency. Given that goods originate outside the United Kingdom, particular attention is given to documentation supporting origin, transport, and import compliance into the UK.

In addition to initial checks, we maintain ongoing monitoring of trading activity. Transactions may be reviewed where necessary to ensure they remain consistent with normal commercial expectations. Where concerns arise, we may request additional information or pause trading until satisfactory clarification is received.

REQUIRED DOCUMENTS

Customers (Trade Account Setup)

Company registration number
VAT registration certificate
AWRS registration number (where applicable)
Trading and registered address
Company website
Bank account details
Details of authorised representative(s)

Overseas Suppliers

Company registration details in country of origin
VAT or equivalent tax registration (if applicable)
Export registration details (where applicable)
Warehouse or production address
Commercial terms of trade
Bank account details
Proof of authority to distribute products (where applicable)
Export documentation supporting movement of goods
Evidence of product origin and supply chain legitimacy
Transport and logistics documentation (where applicable)

RECORD KEEPING

HF Drinks Limited maintains appropriate records of due diligence checks and related trading documentation. These records are stored securely and retained for a minimum of six years in line with HMRC requirements. They are made available to HMRC upon request where required.

SUPPLY CHAIN INTEGRITY

We work exclusively with reputable overseas producers and suppliers who can demonstrate legitimate production, ownership, and export of alcoholic beverages.

All goods entering our supply chain are expected to be fully traceable from origin through to UK import and distribution, with appropriate supporting documentation at each stage.

CONFIDENTIALITY AND DOCUMENT CONTROL

For security and fraud prevention purposes, HF Drinks Limited does not routinely provide sensitive internal documents such as director identification documents, bank statements, internal financial records, or confidential commercial agreements.

REVIEW

This policy is reviewed periodically by the Directors of HF Drinks Limited and updated where necessary to reflect changes in legislation, HMRC guidance, or business operations.

Last Updated: June 2026