This Modern Slavery and Human Trafficking Statement is made by EEW Design Limited for the financial year ending 31 March 2025. It was approved by the Board of Directors on 9 December 2025.
EEW Design Limited (“EEW Design”) provides professional services including graphic and digital design (encompassing print management), video and motion graphics, brand and identity consultation, and creative content creation.
Our registered office is 1 Hill Crescent, Surbiton, Surrey, KT5 8DP, England and we operate from 15 Bourne Drive, Mitcham, Surrey, CR4.
We value human rights and are committed to conducting all business according to ethical, professional and legal standards in a fair, honest and open manner. We recognise that modern slavery can occur in any sector and we are committed to continually improving the way we identify and manage modern slavery risks in our operations and supply chains.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, secondees, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
It also sets out our expectations of our suppliers and other organisations in our supply chain.
Zero tolerance – We have a zero-tolerance approach to modern slavery and human trafficking in all forms.
Transparency – We are committed to being transparent about how we tackle modern slavery, in line with the UK Modern Slavery Act 2015.
High standards for suppliers – We expect the same high standards from all suppliers and business partners. Our contracts and purchase terms prohibit the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.
EEW Design and its suppliers are expected to meet, as a minimum, the following standards:
Compliance with all applicable local and national laws on labour, employment and health and safety.
No use of forced, bonded or involuntary labour of any kind.
Freedom to terminate employment in line with legal or contractual notice periods, without penalties designed to trap workers.
Freedom of movement – workers must not be physically confined or have movement unreasonably restricted.
Freedom of association and collective bargaining – workers must be free to join or form trade unions and bargain collectively, in accordance with local law, without fear of reprisal.
A working environment free from threats of violence, harassment, intimidation or abuse.
No worker-paid recruitment fees or similar charges which could result in debt bondage.
No compulsory overtime – overtime must be voluntary and paid in line with legal requirements.
No child labour – no employment of workers below the minimum legal working age.
No discrimination on the basis of race, colour, nationality, ethnic origin, religion or belief, gender, sexual orientation, disability, age, union membership, pregnancy or any other protected characteristic.
No confiscation of original identity documents (such as passports or work permits) as a condition of work.
Access to effective remedies – workers must have access to grievance mechanisms and remedial action where their rights have been infringed.
Board of Directors – The Board has overall responsibility for this policy and for ensuring we comply with our legal and ethical obligations.
Director (Emile Wendling) – Has day-to-day responsibility for implementation, monitoring effectiveness and reporting to the Board.
Managers and supervisors – Must ensure that those reporting to them understand this policy and receive appropriate training.
All workers – Are responsible for familiarising themselves with this policy and reporting any concerns.
Our supply chain is relatively simple and mainly consists of:
freelance designers and other creative professionals
print and production partners
software, IT, hosting and cloud-service providers
professional advisers and other service suppliers
Most of our direct (Tier 1) suppliers are based in the UK or other low-risk jurisdictions, and we do not procure goods in high-volume manufacturing or agricultural sectors. However, we recognise that some services (for example print or digital services) may involve overseas production, which we treat as relatively higher risk.
We assess modern slavery risk in our supply chains by:
Maintaining a Tier 1 supplier register that records the type of service, country of operation and a simple risk rating (e.g. low/medium).
Considering higher risk where services involve lower-wage sectors, complex subcontracting, or operations in countries with weaker labour protections.
Reviewing the supplier register at least annually, or when we enter new categories of spend.
Where a supplier or category is assessed as higher risk, we may:
request further information (e.g. policies, statements, or responses to due-diligence questions)
include strengthened contractual clauses
decide not to enter into or renew the relationship if adequate safeguards cannot be demonstrated.
We recognise that our own purchasing practices can influence working conditions in our supply chain. We therefore aim to:
avoid aggressive pricing that is incompatible with paying fair wages and maintaining safe conditions
agree realistic deadlines and avoid last-minute changes that could create excessive pressure on suppliers or their workers
use fair payment terms and pay suppliers on time
avoid imposing unfair penalties that could push suppliers into unsustainable practices.
We consider modern slavery risks at appropriate pointsof the procurement process, including:
Needs and requirements – considering whether the work may involve higher-risk sectors or countries.
Supplier selection – favouring suppliers who can demonstrate strong labour and human rights standards.
Contract award – including modern slavery and labour-standards clauses in contracts and purchase terms where proportionate.
In-life management – monitoring for any warning signs (e.g. repeated complaints, concerning media coverage) and following up as needed.
Our due diligence processes include:
requiring new suppliers, where proportionate, to confirm compliance with our Modern Slavery Policy and relevant laws
asking higher-risk suppliers to answer targeted questions on labour practices, including whether workers pay recruitment fees or are subject to debt-related deductions
reserving the right to request supporting evidence, such as policies or statements.
We explicitly prohibit worker-paid recruitment fees and any form of debt bondage. Where we use recruitment agencies or labour providers (for example for temporary staff), we will:
only use reputable agencies that commit to ethical recruitment
seek confirmation that workers are not charged recruitment fees or deposits
require agencies to comply with all applicable employment and immigration laws.
If we identify credible concerns, we will engage with the supplier or agency to understand the issue and agree corrective actions. Where a supplier is unwilling or unable to address concerns, we may ultimately reconsider or terminate the relationship.
We want anyone connected to our business to feel able to raise concerns about modern slavery safely and without fear of retaliation.
Workers, contractors, freelancers and suppliers can raise concerns by:
speaking to their line manager or main EEW Design contact
contacting the Director directly at policy@eew-design.com
using our confidential whistleblowing route, which allows concerns to be raised anonymously.
All reports will be:
Acknowledged within a reasonable timeframe.
Assessed for urgency and potential risk to individuals.
Investigated proportionately, which may involve speaking to the reporter (where possible), reviewing documents, and engaging with relevant suppliers.
Addressed through appropriate action, which may include remediation for affected workers, changes to our processes, engagement with the supplier or, where necessary, ending the relationship.
Recorded so that we can monitor themes and improvement actions.
No one who raises a concern in good faith will sufferany detrimental treatment as a result.
We provide training and guidance on modern slavery torelevant staff, including:
an overview of modern slavery and human trafficking
common indicators of forced labour and exploitation (with reference to ILO indicators)
how to consider modern slavery risk in our service-based supply chain
how to report concerns and where to find this policy.
Training is:
provided at induction for new employees
refreshed at least annually and when this policy is materially updated.
We share key expectations and red flags with relevant freelancers and suppliers as part of onboarding or contract discussions, and we encourage them to raise any concerns they become aware of.
We have a Supplier Code of Conduct which sets out our expectations in more detail, including:
compliance with this policy and with applicable labour, human rights and anti-slavery laws
respect for workers’ freedom of association, health and safety, working hours and wages
prohibition of child labour, forced labour, discrimination and harassment
cooperation with reasonable information requests from EEW Design in relation to modern slavery risks.
The Code is provided to suppliers and forms part of our contracting and ongoing relationship with them.
As a small business, we make use of publicly available guidance from government bodies and specialist organisations that work to combat modern slavery. Where proportionate, we may:
participate in relevant industry or multi-stakeholder initiatives
attend webinars or training organised by external bodies
share good practice with other businesses in our network.
We use simple key performance indicators (KPIs) to monitor the effectiveness of our approach, such as:
percentage of relevant policies reviewed and approved annually
proportion of Tier 1 suppliers recorded in our supplier register and assessed for modern slavery risk
proportion of new suppliers who have confirmed compliance with this policy and relevant clauses
completion rates for modern slavery training among relevant staff
number and outcome of any modern slavery-related concerns raised.
These indicators help us identify trends and areas for improvement.
This policy and statement are reviewed at least annually by the Board of Directors, or sooner if there are significant changes in our business or in relevant legislation or guidance.
We are committed to continually improving our approach to preventing modern slavery and human trafficking, and to reporting transparently on our progress
Signed,
Emile Wendling
Director, EEW Design Limited
Date: 9 December 2025