Due Diligence Policy Statement

This Due Diligence Policy sets out our company’s commitment to conducting through and proportionate checks on al customers and suppliers in line with HMRC guidance. Our aim is to ensure that we trade only with legitimate businesses and avoid any involvement, whether knowingly or unknowingly, in tax fraud, VAT evasion, labour exploitation, or other illegal activities within our supply chains.

Objectives

• Verify the identity and legitimacy of all customers and suppliers.
• Ensure compliance with HMRC requirements, including VAT, PAYE, and tax obligations.
• Maintain transparent and lawful trading practices.
• Keep detailed records of all due diligence checks as evidence of compliance.

Responsibilities

All employees involved in purchasing, sales, or account management are responsible for carrying out due diligence checks before engaging inbusiness with new customers or suppliers. Management will review the due diligence process periodically to ensure ir remains effective and up to date.

Due Diligence Process

Our due diligence process includes, but is not limited to:

• Confirming company registration and VAT details.
• Checking commercial legitimacy and reasonableness of transactions.
• Verifying tax compliance and reviewing invoices for accuracy.
• Maintaining awareness of supply chain risks, particularly in high-risk sectors.
• Keeping records of all checks for audit purposes.

Review and Approval

This policy will be reviewed annually or sooner if HMRC guidance changes. It haws been approved by senior management and is effective immediately.