Last updated: 28 April 2026

1. Introduction

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 Policy sets out the standards we expect from our directors, employees, freelancers, contractors, suppliers and any third parties acting on our behalf.

2. Purpose and scope

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, including the Bribery Act 2010 where relevant; and

• protect EEW Design, our clients and our suppliers from improper conduct.

It applies to:

• all EEW Design directors, employees and officers;

• freelancers, consultants and contractors engaged by EEW Design;

• suppliers and production partners working with or for EEW Design; and

• any third party acting on our behalf.

3. What we mean by bribery and corruption

For the purposes of this policy:

• Bribery means 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 means the abuse of entrusted power for private gain, which may include bribery, conflicts of interest, fraud, embezzlement or similar conduct.

Bribery and corruption can involve public officials, private-sector individuals or organisations, and can occur in any country.

4. Prohibited conduct

No person working with or for EEW Design must, directly or indirectly:

• offer, promise, give, request or accept a bribe of any kind;

• make facilitation payments, meaning unofficial payments made to secure or speed up routine actions;

• offer or receive kickbacks or secret commissions;

• use a third party to do anything that EEW Design is not permitted to do directly;

• falsify records or disguise the true nature of any payment, expense or benefit; or

• offer or accept anything of value where doing so could create an appearance of impropriety or a conflict of interest.

If there is any doubt about whether something may constitute a bribe or improper advantage, guidance should be sought before proceeding.

5. Gifts, hospitality and expenses

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;

• gifts and hospitality should be modest, infrequent and appropriate to the context;

• cash or cash-equivalent gifts should not be offered or accepted;

• hospitality connected with public officials, regulated entities or public-sector procurement must be treated with particular caution; and

• all expenses must be properly recorded and supported by appropriate documentation.

Where there is any doubt, the safest course is to decline the gift or hospitality, or seek guidance before accepting or offering it.

6. Third parties and suppliers

Bribery and corruption risks can arise through third parties. When we engage freelancers, suppliers, agents, intermediaries or production partners, we will take proportionate steps to understand:

• who they are;

• what services they are providing;

• how they are paid; and

• whether there are any warning signs of improper conduct.

We expect third parties working with or for EEW Design to comply with this policy, applicable anti-bribery laws and our Supplier Code of Conduct where relevant.

7. Political and charitable activity

EEW Design does not make political donations.

Any charitable support, sponsorship or community activity connected with EEW Design must be transparent, proportionate and not used as a way to secure an improper business advantage.

Individuals remain free to engage in lawful political or charitable activity in a personal capacity, provided this is clearly separate from EEW Design’s business and does not create a conflict of interest.

8. Record-keeping and controls

We maintain accurate and complete business records. In particular:

• invoices, expenses and payments must be supported by appropriate documentation;

• no undisclosed or unrecorded accounts or funds may be created;

• descriptions of services, fees and benefits must be clear and not misleading; and

• any concerns about improper payments or inaccurate records must be raised promptly.

9. Raising concerns

Anyone working with or for EEW Design is encouraged to raise concerns if they suspect bribery, corruption or any conduct that may breach this policy.

Concerns can be raised by:

• speaking directly with the Director; or

• emailing policy@eew-design.com.

Concerns raised in good faith will be treated seriously. EEW Design will not tolerate retaliation against anyone who raises a genuine concern.

10. Breaches and consequences

Breaches of this policy are treated seriously. Where bribery or corruption is suspected, EEW Design may:

• investigate the circumstances;

• pause or terminate work with a relevant third party;

• seek legal or professional advice where appropriate;

• report matters to law-enforcement, regulatory or other competent authorities where required; and

• take disciplinary or contractual action where applicable.

11. Review and contact

This policy is reviewed periodically to ensure it remains appropriate for our size, services and risk profile, and to reflect changes in law, guidance or client requirements.
‍
Questions about this policy, or concerns about potential bribery or corruption, can be directed to:
‍
Emile Wendling
Director, EEW Design Limited
‍policy@eew-design.com