Last updated: 28 April 2026
1. Introduction
EEW Design Limited (“EEW Design”, “we”, “us”) is committed to conducting business with integrity and in compliance with applicable tax laws. We have zero tolerance for tax evasion or the criminal facilitation of tax evasion by anyone acting for or on behalf of EEW Design.
This Anti-Tax Evasion Policy explains our approach to preventing tax evasion facilitation risk in our business, in line with the Criminal Finances Act 2017 where relevant.
2. Purpose and scope
This policy applies to:
directors, employees and officers of EEW Design;
freelancers, contractors, consultants and suppliers working with us;
agents, intermediaries or other third parties acting on our behalf; and
anyone involved in our invoicing, payment, procurement, accounting or financial administration processes.
The purpose of this policy is to:
prohibit tax evasion and the facilitation of tax evasion;
ensure that our financial records and invoices are accurate;
help identify and manage tax-related red flags; and
support lawful, transparent and ethical business relationships.
3. What we mean by tax evasion and facilitation
For the purposes of this policy:
Tax evasion means the illegal non-payment or underpayment of tax.
Facilitation of tax evasion means knowingly helping, enabling or encouraging another person or business to evade tax.
Tax evasion is different from lawful tax planning. EEW Design may take professional advice on tax matters, but we will not participate in arrangements intended to evade tax.
4. Policy statement
EEW Design will not:
knowingly assist a client, supplier or other third party to evade tax;
create false invoices or misleading records;
accept or make payments designed to disguise the true nature of a transaction;
knowingly misdescribe goods or services to reduce tax liabilities unlawfully;
make payments to bank accounts or jurisdictions without a legitimate commercial reason; or
ignore warning signs that a transaction may be connected with tax evasion
5. Risk areas for our business
As a creative studio, the main tax-evasion facilitation risks we monitor include:
requests for inaccurate invoice descriptions;
requests to invoice a different entity without a clear commercial reason;
requests to omit VAT or tax information where it is legally required;
unusual payment routing, including unexplained third-party payments;
cash payment requests for business services;
pressure to alter records after services have been provided; and
suppliers who appear unwilling to provide normal business, tax or payment details.
6. Due diligence and controls
We apply proportionate checks and controls, including:
issuing invoices that accurately describe the services provided;
keeping records of estimates, approvals, purchase orders, invoices and payments;
checking supplier and client details where needed;
asking for clarification where payment or invoicing instructions appear unusual;
using professional accountancy support where appropriate; and
refusing requests that appear designed to evade tax or misrepresent a transaction.
7. Working with clients and suppliers
We expect clients, suppliers and business partners to:
comply with all applicable tax laws;
provide accurate information for invoicing and payment;
avoid asking EEW Design to participate in tax evasion or misleading record keeping;
notify us promptly if information previously supplied is inaccurate; and
cooperate with reasonable compliance questions where relevant.
8. Reporting concerns
Concerns can be raised by:
Concerns raised in good faith will be treated seriously and handled sensitively.
9. Breaches and consequences
Breaches of this policy may result in disciplinary action, termination of a supplier or contractor relationship, refusal to proceed with a project, or referral to appropriate authorities where required.
10. Review and contact
This policy is reviewed periodically and updated where needed to reflect changes in law, guidance, our business activities or client requirements.
Questions about this policy can be directed to:
Emile Wendling
Director, EEW Design Limited
policy@eew-design.com
