Due Diligence Policy for A Grape Pairing Ltd.

Last Amended: 06/09/2024

1. Introduction

A Grape Pairing Ltd (“we”, “us”, “our”) is committed to conducting business ethically, responsibly, and in compliance with all applicable laws and regulations. This Due Diligence Policy outlines the procedures and practices we follow to assess and manage risks related to our suppliers, partners, and operations. Our aim is to ensure that all aspects of our business, including product sourcing and event management, meet high standards of quality, legality, and integrity.

We are proud to hold a 5-star food hygiene certification from the Food Business Operator (FBO) at Halton Council, which reflects our commitment to high food safety standards.

2. Purpose

The purpose of this Due Diligence Policy is to:

  • Ensure compliance with applicable laws, regulations, and industry standards.
  • Assess and manage risks associated with suppliers, partners, and other third parties.
  • Safeguard our reputation by preventing unethical, illegal, or unsafe practices.
  • Ensure the quality, safety, and legality of the products we offer and the services we provide.

3. Scope

This policy applies to all areas of A Grape Pairing Ltd’s business, including:

  • Supplier Selection and Management: Ensuring all wines and other products sourced from third parties meet legal and quality standards.
  • Event Management: Ensuring events are planned and executed in compliance with safety, health, and legal regulations.
  • Third-Party Relationships: Vetting partners and service providers involved in the supply chain, event organization, and other business functions.

4. Supplier Due Diligence

We ensure that all suppliers and products, particularly wines imported from Italy, meet the following criteria:

4.1 Legal Compliance

  • All suppliers must comply with local and international laws, including but not limited to labor laws, environmental regulations, and food safety standards.
  • We verify the legal status of suppliers by requesting necessary licenses, certifications, and permits relevant to wine production and distribution.

4.2 Product Quality

  • We assess and maintain records of the quality of wines and products supplied, including certifications (such as DOCG, DOC, IGT for Italian wines) and compliance with EU and UK food safety standards.
  • Regular quality checks and supplier audits are conducted to ensure that products consistently meet our quality requirements.

4.3 Supplier Integrity and Ethical Practices

  • We engage only with suppliers who demonstrate ethical business practices, including non-involvement in human rights abuses, child labor, or exploitation of workers.
  • Suppliers are required to follow best practices in environmental sustainability, responsible sourcing, and ethical treatment of workers.

4.4 Risk Assessment

  • We assess potential risks posed by our suppliers, including financial stability, geopolitical risks (in relation to importing goods), and compliance with quality standards.
  • High-risk suppliers are subject to more frequent monitoring and review.

5. Event Due Diligence

For our wine tasting events, we adhere to strict due diligence protocols to ensure the safety and satisfaction of all participants.

5.1 Venue and Health & Safety Compliance

  • All venues are inspected to ensure compliance with health and safety regulations, fire codes, and food hygiene standards.
  • Event staff and service providers are vetted to ensure they have the required licenses, insurance, and training (e.g., in handling allergens and alcohol service).

5.2 Allergen Management

  • We ensure that accurate allergen information is provided for all wines and food items served at events. Where there are risks related to specific allergens, participants are informed in advance.

5.3 Participant Safety

  • We implement measures to ensure the safety of all participants, including crowd control, responsible alcohol service, and provisions for medical emergencies.
  • In the case of force majeure events, such as pandemics or natural disasters, we have contingency plans in place, including event cancellations, refunds, and rescheduling protocols.

6. Partner and Third-Party Due Diligence

We partner with third-party service providers (e.g., payment processors, marketing agencies) to support our operations. Due diligence is performed to ensure they align with our values and comply with legal obligations.

6.1 Financial and Legal Checks

  • We conduct background checks and creditworthiness assessments of potential partners to mitigate financial risk.
  • Partners must provide proof of compliance with all relevant legal and regulatory requirements.

6.2 Data Protection and Privacy

  • Any third-party service providers who handle customer data must comply with GDPR and other applicable data protection laws. We require them to sign data processing agreements where necessary.
  • Regular audits are conducted to ensure data security practices are maintained to our standards.

6.3 Contractual Agreements

  • We have clear contractual agreements with all third-party partners, outlining their obligations, including compliance with our code of conduct, data protection standards, and ethical sourcing requirements.

7. Ongoing Monitoring and Review

We continuously monitor and review our suppliers, partners, and business processes to ensure ongoing compliance and adherence to our standards.

7.1 Supplier and Partner Audits

  • Regular audits are conducted on suppliers and partners to ensure compliance with legal, quality, and ethical standards.
  • Any non-compliance identified during audits is addressed promptly, with corrective action plans implemented and monitored.

7.2 Internal Review

  • We regularly review our internal processes and this Due Diligence Policy to ensure alignment with evolving laws, regulations, and industry best practices.
  • Employees involved in procurement, event management, and third-party relationships are trained on due diligence procedures and compliance requirements.

8. Reporting Non-Compliance

If any supplier, partner, or employee is found to be in violation of this Due Diligence Policy, we will take immediate action. This may include:

  • Termination of contracts with suppliers or partners.
  • Legal action if necessary.
  • Internal investigations and disciplinary actions for employees who fail to adhere to the policy.

9. Compliance with the Modern Slavery Act

We are committed to upholding the principles of the Modern Slavery Act. We conduct thorough checks to ensure that none of our suppliers or partners are involved in forced labor, human trafficking, or modern slavery practices. Any evidence of such practices will result in immediate termination of the business relationship and notification to the relevant authorities.

10. Policy Updates and Changes

We reserve the right to update this Due Diligence Policy as necessary to reflect changes in legislation, business practices, or our operational needs. Any updates will be communicated to all relevant stakeholders and made available on our website.

11. Contact Information

If you have any questions about this Due Diligence Policy or would like to report a potential issue, please contact us at:

  • Email: info@agrapepairing.com
  • Postal Address: A, R. T. Centre, Tan House Ln, Widnes WA8 0RR

By engaging with A Grape Pairing Ltd, suppliers, partners, and employees acknowledge that they have read, understood, and agree to comply with this Due Diligence Policy.