Our commitment to fair, transparent and honest business
Last updated: 23 January 2026
EEW Design Limited (“EEW Design”, “we”, “us”) is committed to conducting business fairly, honestly and transparently. We have zero tolerance for bribery or corruption in any form.
This Anti-Bribery and Corruption (ABC) Policy sets out the standards we expect from our employees, contractors, suppliers and any third parties acting on our behalf.
This policy is designed to:
Prevent bribery and corruption in connection with our business activities.
Provide clear guidance on acceptable and unacceptable behaviour.
Support compliance with applicable anti-bribery and anti-corruption laws and regulations.
It applies to:
All EEW Design employees, directors and officers.
Freelancers, consultants and contractors engaged by EEW Design.
Third parties acting on our behalf, including agents, intermediaries and key suppliers.
For the purposes of this policy:
Bribery is offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage with the intention of improperly influencing a decision or securing an improper advantage.
Corruption is the abuse of entrusted power for private gain, which may include bribery, conflicts of interest, fraud, embezzlement or similar behaviour.
Bribery and corruption can involve public officials, private-sector individuals or organisations, and can occur in any country.
You must not, either directly or indirectly:
Offer, promise, give, request or accept a bribe of any kind.
Make facilitation payments (small unofficial payments made to secure or speed up routine actions).
Offer or receive kickbacks or secret commissions.
Use third parties to do anything that EEW Design is not permitted to do directly.
Falsify records or disguise the true nature of any payment or benefit.
If you are unsure whether something may constitute a bribe or improper advantage, you must seek guidance before proceeding.
Reasonable, proportionate and transparent hospitality or business gifts may sometimes be appropriate to build legitimate business relationships. However:
Gifts and hospitality must never be offered or accepted with the intention of improperly influencing a decision or securing an improper advantage.
Gifts and hospitality should be modest, infrequent and appropriate to the context and relationship.
Cash or cash-equivalent gifts (such as vouchers) must not be offered or accepted.
Any hospitality offered in connection with public officials or public-sector procurement must be treated with extra caution and may require prior approval.
Where there is any doubt, the safest course is to decline or seek guidance.
Bribery and corruption risks often arise through third parties. When we engage agents, intermediaries, suppliers or partners who may act on our behalf, we will:
Take reasonable steps to understand who they are, what they will do and how they are paid.
Make it clear that we expect them to comply with this policy and all applicable anti-bribery laws.
Avoid working with third parties who are unwilling to support appropriate anti-bribery standards.
We may include anti-bribery clauses in our contracts and in our Supplier Code of Conduct.
As a business:
EEW Design does not make political donations.
Any support for charities, community initiatives or sponsorships must be transparent, proportionate and not used as a vehicle for bribery or undue influence.
Individual employees and contractors remain free to engage in lawful political or charitable activities in a personal capacity, provided this is clearly separate from EEW Design’s business.
We are committed to maintaining accurate and complete books and records that properly document all business transactions. In particular:
All invoices, expenses and payments must be supported by appropriate documentation and approvals.
No undisclosed or unrecorded accounts or funds may be created.
Descriptions of services, fees and benefits must be clear, accurate and not misleading.
These controls help us demonstrate that payments are for genuine services and not for improper purposes.
Everyone working with or for EEW Design is encouraged to speak up if they:
Are asked to do something that may breach this policy or applicable anti-bribery laws.
Suspect that bribery or corruption may have occurred, is occurring or is likely to occur.
Concerns can be raised by:
Speaking directly with the Director.
Emailing policy@eew-design.com with relevant details.
Concerns raised in good faith will be taken seriously, and we will not tolerate retaliation against anyone who raises a genuine concern.
Breaches of this policy are treated seriously. Where bribery or corruption is suspected:
We may investigate the circumstances and seek legal advice where appropriate.
We may report matters to law-enforcement, regulatory or other competent authorities where required.
Employees found to have breached this policy may face disciplinary action, up to and including dismissal.
Contractors, suppliers or third parties may have their contracts terminated and be removed from our approved supplier list.
This policy will be reviewed periodically to ensure it remains appropriate for our size, services and risk profile, and to reflect changes in law or guidance.
Questions about this policy, or any concerns about potential bribery or corruption, can be directed to:
Emile Wendling
Director, EEW Design Limited
policy@eew-design.com