1. POLICY STATEMENT
Grecian Artisan Wine Co. Ltd is firmly committed to conducting its business activities in strict accordance with applicable national, EU, and international legal frameworks. Our approach entails the following key aspects:
i. Thoroughly assessing the potential risks associated with alcohol duty fraud across our operational supply chains.

ii. Implementing reasonable and proportionate measures within our daily trading operations to detect transactions that may present a risk of fraud or involve goods on which duty might have been evaded.

iii. Establishing well-defined protocols for taking prompt and effective corrective actions in cases where the risk of fraud is identified.

iv. Documenting the comprehensive checks that we intend to carry out and instituting a robust governance framework to ensure their consistent and accurate execution.

v. Being attuned to the “know your customer” obligations outlined in the 2017 Money Laundering Regulations, as they may be revised over time.

In the event of suspected fraud, we are committed to notifying the appropriate authority, HMRC, through our designated Lead Contact, Miss M. Theologou, who serves as our Director. It is important to note that customers/suppliers not meeting our internal verification standards will be duly informed that their account opening request cannot be accommodated. Furthermore, instances of suspicious behavior will be promptly communicated to HMRC, adhering to established timelines. For transparency purposes, please be aware that we are not able to provide specifics regarding the timing, nature, or recipients of the reports we submit concerning suspicious behaviour. Your trust and our commitment to integrity are of paramount importance to us.

2. CONSEQUENCES OF NON-COMPLIANCE
The absence of a diligent approach in showcasing due care and attention could potentially lead HMRC to form the view that a business poses a risk to revenue and lacks the necessary credentials to be deemed “fit and proper” in accordance with excise legislation. Such an assessment could result in the imposition of restrictions or conditions, ultimately culminating in the revocation of authorisations, imposition of financial penalties, initiation of legal proceedings, and even the seizure of stock.

3. PROCESSES
Grecian Artisan Wine Co. Ltd has thoughtfully formulated and recorded a series of processes designed to ensure the highest standards of operational integrity. These procedures encompass:
i. Verification of the identity of our trading partners.

ii. Scrutiny of contractual terms to ensure alignment with our principles.

iii. Thorough assessment of the origin and authenticity of goods involved in our transactions.

iv. Evaluation of the financial stability of our trading counterparts.

v. Careful evaluation of the viability and credibility of the contemplated business deals.

Central to the execution of these processes is a judicious evaluation, always mindful of the 2017 Regulations. In each instance, we determine the requisite amount of information essential for validating the business relationship or specific transaction. Upon receiving information, we diligently undertake efforts to corroborate it through reference to credible independent sources whenever feasible.

4. CUSTOMER DUE DILIGENCE POLICY
Grecian Artisan Wine Co. Ltd holds a steadfast dedication to combating alcohol fraud on a national scale. Our primary focus is on eradicating risk, and we maintain an unwavering commitment to upholding compliance with the Excise Due Diligence and AWRS regulations. To facilitate the registration process for trading, Grecian Artisan Wine Co. Ltd will require the following documents from businesses:

i. Company bank details

ii. Photo ID details of the owner, such as Passport or Driving License

iii. A copy of a business utility bill (dated within the last three months).

Once these essential documents have been gathered, Grecian Artisan Wine Co. Ltd will initiate the necessary verification procedures before finalising the account setup. Customers identified as posing a high risk will undergo additional inquiries. High-risk customers who are approved will undergo evaluations every three months, while all other customers will be subject to annual reviews. For the convenience of our customers, we only accept payment through bank transfers. Please note that we do not accept cheques as a mode of payment. Customers who do not meet our internal verification standards will be promptly informed that their account cannot be opened. Additionally, customers displaying suspicious behaviour will be promptly reported to HMRC, ensuring compliance with regulatory obligations.