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HMRC internal manual

Hydrocarbon Oils Strategy

Registered Dealers in Controlled Oils (RDCO): duty of care: interviewing the trader

Ensure you interview a responsible person, preferably the person who has control of the business.

Establish and record on the EX465B how the trader exercises their duty of care. The following basic information should be gathered:

  • Establish what controls (if any) the trader has to ensure the legitimacy of supplies of rebated oil they make. Are these controls recorded in any internal Code of Practice, or ISO 9000 assessment?
  • Establish what checks (if any) the trader makes on new customers, eg relating to declared use of the oil, methods of payment, credit worthiness.
  • Establish what training staff are given when dealing with supplies of rebated fuel.
  • Establish whether or not there have been any sales where the trader has had suspicions about the customer.
  • Establish whether there have been any potential customers who failed any of the checks and were refused.
  • Were the suspicions reported, and to whom?
  • Establish the delivery arrangements.
  • Have they any customers who move address regularly, or request delivery to different delivery addresses?
  • Have any customers ‘gone missing’ between buying the oil and the invoice being issued?

The information recorded on the EX465B should be reviewed periodically and updated.