Last updated: 28 April 2026
1. Introduction
EEW Design Limited (“EEW Design”, “we”, “us”) is committed to complying with applicable sanctions laws and regulations in the UK and any other jurisdiction relevant to our work.
This Sanctions Policy explains how we identify and manage sanctions risk in our business and supply chain, and how we support clients in meeting their own compliance expectations.
2. Purpose and scope
The aims of this policy are to:
ensure that EEW Design does not knowingly enter into business relationships or transactions that breach applicable sanctions laws;
help us identify, assess and manage sanctions risk in relation to clients, suppliers and projects;
provide clear guidance to anyone working with or for EEW Design; and
support our clients’ own sanctions, compliance and risk-management frameworks.
This policy applies to all work carried out by EEW Design, including projects delivered by employees, contractors, freelancers and approved suppliers acting on our behalf.
3. Legal and regulatory framework
EEW Design will comply with applicable sanctions laws and regulations, including where relevant:
UK sanctions regimes administered and enforced by HM Treasury and the Office of Financial Sanctions Implementation;
relevant United Nations sanctions adopted into UK law; and
other sanctions regimes that may apply because of a client, project, supplier, location or transaction.
Where there is a conflict between applicable regimes, the stricter relevant requirement will normally be followed.
4. Restricted countries, parties and activities
EEW Design will not knowingly:
Work with individuals or entities that are subject to applicable asset freezes or other financial sanctions.
Provide services that directly support prohibited sectors, activities or transactions under applicable sanctions laws.
Structure work, relationships or invoicing in a way that is intended to circumvent sanctions.
If a client project or potential engagement involves higher-risk jurisdictions or sectors, additional checks and approvals may be required before we proceed.
5. Screening and due diligence
We carry out proportionate checks on new and existing clients and, where relevant, suppliers. These may include:
reviewing publicly available information;
considering ownership, control and location;
asking whether the project relates to sanctioned countries, sectors or activities;
requesting confirmations from clients or suppliers; and
seeking external advice where the risk is unclear or elevated.
6. Working with clients and suppliers
We expect clients and suppliers to:
comply with applicable sanctions laws and regulations;
use our services only for lawful purposes;
avoid using EEW Design services to support sanctioned activities, individuals or entities;
inform us promptly if they become subject to sanctions; and
raise any sanctions-related concern relevant to work we are doing together.
We may include sanctions clauses in contracts and may ask for written confirmations where appropriate.
7. Escalation and reporting concerns
Anyone working with or for EEW Design who becomes aware of a potential sanctions issue must raise it promptly.
Concerns can be raised by:
We would rather a potential issue be raised early and ruled out than risk an inadvertent breach.
8. Breaches and non-compliance
If we believe that a sanctions breach may have occurred, or that there is a significant risk of breach, we may:
pause or terminate the relevant work or relationship;
seek external legal or compliance advice;
withhold services or deliverables where legally required;
cooperate with competent authorities where required; and
take disciplinary or contractual action where applicable.
9. Review and contact
This policy is reviewed periodically and updated where needed to reflect changes in law, guidance, our services, our client base or our risk profile.
Questions about this policy can be directed to:
Emile Wendling
Director, EEW Design Limited
policy@eew-design.com
