Due Diligence Policy

1. Purpose and scope

This policy applies to LOVEGATE directors, employees and people acting on our behalf, and to new and continuing relationships with customers, suppliers, brand owners, manufacturers, advisory clients, logistics and warehouse providers, agents and other business partners. It supports the management of fraud, sanctions, product, credit, customs and regulatory risk, including excise risk where applicable.

Checks must reflect the activity, goods, country, duty status and risk. A completed form or uploaded certificate is evidence to assess, not automatic verification or approval.

2. Manual onboarding and required evidence

LOVEGATE currently carries out due diligence manually. Our team identifies the counterparty’s role and activity, requests the appropriate information and supporting evidence, reviews it and records the approval decision. We will explain the documents needed and agree a private route for submitting sensitive material. There is currently no LOVEGATE online account-application or identity-document upload service.

Obtain company registration and status, registered and trading addresses, relevant ownership and authorised contacts, VAT registration where applicable, and evidence proportionate to the legal form, activity, geography and risk. Where a registration does not apply, record and assess the explanation.

Request identity documents, bank-account ownership evidence, licences, insurance or other certificates only where necessary and proportionate to the check. This policy does not impose a universal passport requirement on every director or a blanket bank-proof requirement on every applicant. Explain any personal-document request and its purpose before collection.

Allow irrelevant balances or transactions on bank evidence to be redacted where account ownership and essential details remain verifiable. Do not send passports or bank evidence through the public website enquiry form. If an evidence requirement cannot reasonably be met, ask the team to agree an alternative before proceeding.

3. Separate approvals

Due diligence clearance, account opening and credit approval are separate recorded decisions. Supplying documents, receiving an account reference or paying in advance does not by itself authorise trading. Required compliance checks must be satisfied before trading is authorised.

A prepayment account can be approved without granting credit. Credit terms, limits and any credit-insurance requirement must be separately decided by the Managing Director or expressly authorised management and communicated in writing. Higher-risk cases and material exceptions must be escalated.

4. Review and evidence

Authorised reviewers check completeness, compare legal identity, addresses and ownership or authorised contacts across the information and evidence, verify relevant official registrations, review credit evidence and record discrepancies. Record the source, check date, reviewer, result, evidence and any follow-up action.

Differences, missing documents and expired approvals remain visible until resolved. A high-risk credit score is a flag for a management decision, not an automatic approval or rejection. Any automated extraction or summary must be checked against the original evidence; it does not verify a register or replace human judgement.

Access to passports, banking evidence and credit reports is restricted to authorised people with a business need. Routine operational access must not automatically confer access to these documents.

5. Company, identity and bank checks

Verify legal identity, company status, relevant directors/ownership and registered and trading addresses using appropriate official registers and reliable evidence. Resolve differences between registered offices and actual trading premises without treating every address difference as fraud.

Verify the account holder and payment instructions. Changes to bank details require independent confirmation using an established contact route, rather than relying on an email or document alone. Consider third-party payments and unusual payment arrangements as risk indicators.

6. Customs logistics and alcohol where applicable

Check EORI details where relevant to cross-border activity. LOVEGATE’s EORI number is GB231395128000. An EORI number identifies an economic operator for relevant customs activity; it does not itself establish permission to handle duty-suspended stock.

Where a transaction involves alcohol, check the approvals and duty arrangements required for that transaction. Check applicable UK alcohol wholesalers against HMRC’s AWRS service, including suppliers from whom alcohol is bought for resale, and record the check. Do not represent another company’s AWRS number as LOVEGATE’s approval. AWRS does not replace premises licensing or an excise warehouse approval.

For goods under duty suspension or customs arrangements, verify the specific warehouse, warehousekeeper, owner or consignee and movement authorisations applicable to the transaction.

For logistics and warehouse partners, establish the actual sites and goods they may handle, storage conditions, traceability, relevant insurance, and applicable transport, food or feed registrations and approvals. LOVEGATE coordinates warehousing and distribution through partners in the UK and Europe. Food, pet food/feed, household cleaning and alcohol requirements differ; do not assume one certificate covers every activity or location.

7. Credit and specialist support

LOVEGATE uses Creditsafe for business checks and credit information, Allianz Trade for credit insurance, Sovos for VAT/tax compliance and PKF Francis Clark for accounting support where relevant. Staff must distinguish an external report from an independently verified fact.

Personal credit searches must be necessary for the person's role and the decision, have an appropriate lawful basis and be explained to the person beforehand, including relevant agency information. Signing a company form is not blanket permission for unnecessary personal searches.

Management records the decision on credit terms, limits, insurance and exceptions. Reviewers may request evidence and recommend an outcome but may not grant credit unless separately authorised.

8. Sanctions and supply-chain risk

Do not proceed with a transaction prohibited by applicable sanctions or law. Apply appropriate checks to the parties, ownership/control, goods, destinations and relevant intermediaries before the transaction, escalating concerns for specialist advice.

Establish that suppliers are entitled to supply the goods. Check product source, authenticity, traceability, duty status, labelling and destination requirements as relevant. Obtain movement and export documents required for the transaction.

For advisory assignments, identify the client and authorised decision-makers, agree the purpose and scope, consider conflicts and establish the business purpose of any proposed intermediary or commission. Record any authority to act for the client and resolve concerns before starting work.

9. Red flags and escalation

Stop and seek advice if there is pressure to dispatch before clearance, an unusually urgent first order, unexplained low prices, unexpected delivery destinations, inconsistent identity or regulatory information, third-party payments, unusual cash requests, bank-detail changes or reluctance to provide evidence.

Refer unresolved or high-risk issues to the Managing Director or expressly authorised management. Do not bypass a legal prohibition through a commercial exception. Where reporting is legally required, obtain appropriate advice and report to the relevant authority without prejudicing an investigation.

10. Records, review and responsibility

Keep information requests, evidence, check results, decisions and relevant transaction records securely, with an audit trail and controlled access. Observe applicable VAT and other statutory retention requirements. Where AWRS obligations apply to an activity, keep the prescribed records for the required six-year period.

A statutory period for transaction records is not a blanket instruction to retain every passport or bank document for the same period. Review identity evidence and other personal records against their purpose, risk, outstanding legal needs and the Privacy Notice; securely delete what is no longer needed.

Review relationships on a risk basis and when ownership, payment behaviour, insurance, registrations, activity, sites or other material information changes. The Managing Director owns this policy and arranges annual review and staff guidance. Questions: info@lovegatemarketing.com.