Blue Sky South Goa Limited trading as A G Caravela is committed to tackling alcohol fraud in the United Kingdom, the EU and/or recognised international tax authorities. We will work to eliminate risk and aim to ensure that we comply with all requirements and regulations as set out by HMRC under the Excise Notice 2002. ( Excise Notice 2002: Alcohol Wholesaler Registration Scheme – GOV.UK (www.gov.uk) )

The following information has been prepared to support and confirm Blue Sky South Goa Limited to be classified as ‘fit and proper’ in compliance with these regulations.

Company Details

Company Name: Blue Sky South Goa Limited

Trading Name: A G Caravela

Registered Address: c/o KBN Accountants Limited, 12A Castle Street, Reading. RG1 7RD. United Kingdom.

Company Registered Number in England and Wales: 13842899

VAT Number: GB 400124572

EORI Number: GB400124572000

AWRS Number: XXAW00000117852

Due Diligence Code of Conduct (DDCOC)

Blue Sky South Goa Limited – Due Diligence Code of Conduct (DDCOC) sets out the basic rules we will follow and the values that will guide our decisions. It also enables Blue Sky South Goa Limited with  more detailed process and procedure 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 Blue Sky South Goa Limited- DDCOC is to prevent entering 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 Blue Sky South Goa Limited to undertake a risk assessment before any account is open. Blue Sky South Goa Limited will only trade with a customer or supplier if they have passed the necessary risk assessment checks. Blue Sky South Goa Limited will only work with suppliers in the alcohol industry who accept payment by cheque or bank transfer. Cash payments are not permitted and will only be accepted on the discretion of the Director.

Trade Customers Due Diligence Checks:

In order for a customer to register for trade, the Company will require the following documents:
− Photographic proof of identity and age for business owner (e.g., passport or driving license).
− For sales to AWRS-registered wholesalers: AWRS registration number.
− For sales to licensed businesses: Copy of club premises certificate, premises licence, or Temporary
Event Notice (TEN).
− Name and Company Number of any company registered with Companies House.
− Copy of VAT Certificate (if business is VAT registered).
− Business bank details in the name of the potential customer.
− Proof of address, for example copy of business utility bill (less than 3 months old).

Suppliers Due Diligence Checks:

All potential UK suppliers will be subject to a site visit during which the following business records will be
requested for inspection and copies taken:
− Photographic proof of identity of business owner (e.g., passport or driving license).
− Proof of address, for example copy of business utility bill (less than 3 months old).
− Company bank details in the name of the supplier.
− Company Incorporation Certificate and the latest filed accounts.
− VAT Certificate.
− AWRS registration number.
− Supply chain AWRS due-diligence policy.
− If relevant: WOWGR certificate; or trade facility warehouse approval; or HMRC approval to hold     excise duty suspended alcohol at another facility.

Where suppliers are located outside of the UK, equivalent checks to those detailed above will, as far as is possible, be carried out in the relevant jurisdiction.

The Director or an authorised member of Blue Sky South Goa will review the submitted information on a case-by-case basis and the Director 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 or an authorised member of Blue Sky South Goa Limited and the final sign off will be conducted by the Director.

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 accounting software and cloud-based calendars. The DDCOC will be implemented and maintained by the Director. All training and signoff’s of the DDCOC must be authorised by him and any changes in staff will undergo full training on the DDCOC. 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.

Once the trade customer or supplier has sent the above information, the Director or the authorised member of Blue Sky South Goa Limited will review it. The overall risk of the trade customer or supplier will be established. If the individual or business is identified as high-risk, further questions will be requested, 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 trade customer or suppliers will be reviewed every three months; all other trade customers or suppliers will be reviewed on an annual basis.

Please Contact – AG Caravela for any further details.