How we avoid doing business where we legally or ethically shouldn’t
Last updated: 23 January 2026
EEW Design Limited (“EEW Design”, “we”, “us”) is committed to complying with all applicable sanctions laws and regulations in the UK and any other jurisdictions relevant to our work. This policy explains how we identify and manage sanctions risk in our business and supply chain, and how we support clients in meeting their own obligations.
This policy applies to all work carried out under the EEW Design brand, including projects delivered by employees, contractors and approved suppliers acting on our behalf.
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 on what is expected of them.
Support our clients’ own sanctions, compliance and risk-management frameworks.
This policy sits alongside our Anti-Bribery and Corruption Policy, Modern Slavery Policy, Supplier Code of Conduct and other legal and compliance policies.
EEW Design will comply with all applicable sanctions laws and regulations, including (where relevant):
UK sanctions regimes administered and enforced by HM Treasury and the Office of Financial Sanctions Implementation (OFSI).
Relevant United Nations sanctions adopted into UK law.
Other sanctions regimes that may apply to our activities through our clients, projects or locations.
Where there is a conflict between regimes, the strictest applicable requirement will normally be followed.
We 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.
We carry out proportionate checks on new and existing clients and, where relevant, suppliers. These may include:
Reviewing publicly available information on the client or supplier and their ownership or control.
Considering whether the work relates to sanctioned countries, sectors or activities.
Asking clients or suppliers to confirm that they are not subject to sanctions and will not use our services in a way that breaches sanctions laws.
Where a higher level of risk is identified, we may seek additional information or external advice before taking on or continuing work.
We expect our clients and suppliers to:
Comply with all applicable sanctions laws and regulations.
Use our services only for lawful purposes and not to support sanctioned activities, individuals or entities.
Inform us promptly if they become subject to sanctions or if any sanctions-related concern arises that is relevant to work we are doing together.
We may include sanctions clauses in contracts and our Supplier Code of Conduct, and we may ask for written confirmations where appropriate.
Anyone working for or with EEW Design who becomes aware of, or has concerns about, a potential sanctions issue must raise it promptly. Concerns can be raised by:
Speaking directly with the Director.
Emailing policy@eew-design.com with relevant details.
We would rather have a potential issue raised early and ruled out than risk an inadvertent breach.
If we believe that a sanctions breach may have occurred, or that there is a significant risk of a breach:
We may pause or terminate the relevant work or relationship while we investigate.
We may seek external legal or compliance advice where appropriate.
We will co-operate with competent authorities if required.
Deliberate or reckless disregard of this policy by anyone working for EEW Design may result in disciplinary action or termination of engagement.
We review this policy periodically and update it as needed to reflect changes in:
Legal and regulatory requirements.
Industry standards and best practice.
Our services, technology and internal processes.
Our client base, markets and risk profile.
Feedback from clients, suppliers or other stakeholders.
This policy may be updated from time to time. The most recent version is always available in the Legal section of our website.
Questions about this policy, or sanctions risk more generally, can be sent to:
Emile Wendling
Director, EEW Design Limited
policy@eew-design.com