Audit & Compliance Framework

The Code sets out a thorough and robust audit framework of Signatories’ online sale and delivery practices through independent mystery shopping and investigatory powers on alleged breaches.

The purpose of this framework is twofold: to support Signatories to improve compliance where deficiencies are found, and to ensure there is a robust disciplinary process for complaint handling. 

Audit Process

The Code sets out a thorough and robust audit framework of Signatories’ online sale and delivery practices to support continued compliance by Signatories.

  1. As a first step, all Code Signatories can conduct their own internal audits to ensure that their online sale and delivery practices comply with the Code.  

  2. In addition, all Code Signatories will at some point be mystery-shopped by an external company as part of a random audit process. This mystery-shop will involve carrying out a transaction on the Code Signatory’s website which will then be monitored through to the delivery’s completion to determine the Signatory’s compliance with the Code.   

These self and randomised audits exist separately to the Code’s complaint management framework which is also used to ensure Code Signatories’ ongoing compliance. At any time, a customer, retailer or delivery agent may lodge a complaint with Retail Drinks if they believe that a breach of the Code has occurred. All complaints automatically trigger an investigation by Retail Drinks to determine whether any Code non-compliance has occurred. Following this, Retail Drinks may contact a Code Signatory to discuss this non-compliance and the actions required to rectify it. Should a Code Signatory fail to respond in a timely and satisfactory manner, disciplinary action may then be taken against that Code Signatory.

Disciplinary Process

If Code Signatories are found to have deliberately and repeatedly breached the Code as a result of either the audit or complaints process, disciplinary action may be taken against them.

Prior to this however, Code Signatories will be given the opportunity to address their non-compliance internally. If the Signatory is again found to be non-compliant, there will be a formal process to decide what disciplinary action should be taken which may include suspending or permanently revoking their status as a Code Signatory. If the Code Signatory is also a Member of Retail Drinks, their Membership may also be terminated.

The decision about what disciplinary action to be taken will occur at a meeting of the CAC with the Code Signatory able to present verbally to CAC members or provide them with a written statement regarding their non-compliance. Should the CAC decide to pursue disciplinary action, the affected Code Signatory will be given the opportunity to appeal this decision in writing.   

The full disciplinary mechanisms established by the Code will come into effect as of 1 January 2020, six months after the Code’s official start date. Please see The Code of Conduct.