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Due Diligence Policy

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Nippitaty Liquor Merchants Limited – CUSTOMER DUE DILIGENCE POLICY

For a retailer or online account through to open an account:

In order for a business to register for trade, NIPPITATY will require the following documents:

  •  Copy of Incorporation Certificate
  •  Copy of VAT Certificate
  •  Company Bank Details
  •  Owner Photo ID details such as Passport or Driving License
  •  Copy of Business Utility Bill (Less than 3 months old)

Once NIPPITATY has collated this information, the necessary checks will be conducted before opening the account. Payment methods are Cash or Card or Bank Transfer only (NIPPITATY preferred method is bank transfers and Cards for online sale). NIPPITATY does not accept cheques. Cash payments have a cap of £250/month and are only applicable to onsite sale and can only be accepted under the Money Laundering Regulations.

For a wholesaler or online account through to open an account:

In order for a business to register as a wholesaler, NIPPITATY will require the following documents:

  • Copy of Incorporation Certificate
  • Copy of VAT Certificate
  • Company Bank Details
  • Owner Photo ID details such as Passport or Driving License
  • Copy of Business Utility Bill (Less than 3 months old)
  • Picture of business address, if applicable

Once the information has been gathered, the appointed officer will complete a risk assessment. The appointed officer completing risk assessments will be utilising the services of Equifax Limited. 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 in a timely manner.

For individuals through only:

An account must be opened online at by providing following documents:

  • Photo ID details such as Passport or Driving License

Delivery of products will only be done to Card’s registered name and address. Individual must be of the age of 18+.


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

  • Company Introduction stating nature of business and products available
  • Completion of ‘Supplier Registration’ Form and Questionnaire
  • Copy of Incorporation Certificate
  • Copy of VAT Certificate or equivalent 
  • Copy of company’s last filed set of accounts
  • Copy of Money Laundering Certificate, if applicable
  • Owner/Director’s/ Proprietor’s ID Details
  • Company Bank Details
  • AWRS number, if this has been issued and UK based supplier
  • Copy of Business Utility Bill (less than 3 months old)
  • Headed paper complete with Director’s Signature
  • Proof of Due Diligence the company carries out
  • Copy of company’s terms
  • 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

Once the supplier has sent the above information, the appointed accounts officer will review it and complete checks by using the services of Equifax Limited. 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 in a timely manner.

All high-risk suppliers will be reviewed every three months; all other suppliers will be reviewed on an annual basis. Visits to the supplier’s premises, where possible, will also be made by NIPPITATY representatives to verify business records.

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

The Director, William McCartin will review the submitted information on a case-by-case basis and 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 be conducted by the Director with the final sign off.

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 business Outlook calendar.

The DDCOC will be implemented and maintained by the Director. Part of the DDCOC is to ensure day-to-day checks are in place to identify transactions that may lead to fraud or involve goods on which duty may have been evaded. Checks in purchase order processing and customer orders are two areas where daily checks are performed.

NIPPITATY LIQUOR MERCHANTS (NIPPITATY) LIMITED – Purchase Order Process for Nominated Suppliers

The purchase order process used will help assist in ensuring fraud does not take place. All orders are raised through official purchase orders for approved suppliers. The orders are emailed across directly to the supplier with the full details of product, price and freight costs. Once the goods are received into the bonded warehouse, the goods are counted and receipted into their system. Through their website we can access stock reports, proof of delivery information, Duty & VAT payments and Goods received information. When an outgoing order is placed the order is then compiled and booked for dispatch through the bonded warehouse delivery service. 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 and destination warehouse. If anything fraudulent has been identified we will take the necessary actions.

As policy, all purchase orders must include the haulier and all orders must be sent to the nominated bonded warehouse. Currently the preferred haulier is Albatrans UK Ltd and the preferred bonded warehouse is LCB (London City Bond).


Customer orders are placed in writing by email or through a NIPPITATY sales representative. 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. NIPPITATY 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 must be made in writing by the customer on company letterhead or company email.