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 business is registered at 1 Hill Crescent, Surbiton, Surrey, England, KT5 8DP, and operates from 15 Bourne Drive, Mitcham, Surrey, CR4. We value human rights and are committed to ensuring that all business is conducted according to ethical, professional, and legal standards in a fair, honest, and open manner.
We are committed to preventing modern slavery and human trafficking in all our business activities and ensuring that our supply chains are free from such practices. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labor, and human trafficking, all of which involve the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
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, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
Zero Tolerance: We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships.
Transparency: We are committed to ensuring transparency in our business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the UK Modern Slavery Act 2015.
High Standards: We expect the same high standards from all our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labor, or anyone held in slavery or servitude, whether adults or children.
Board of Directors: The board has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
HR Manager: The HR manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Director: The Director of EEW Design, Mr. Emile Wendling, has overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply with it. All persons are responsible for ensuring those reporting to them understand and comply with this policy and are given appropriate training on it and the issue of modern slavery and human trafficking in supply chains.
We have established due diligence processes to:
Identify and assess potential risk areas in our supply chains.
Mitigate the risk of slavery and human trafficking occurring in our supply chains.
Monitor potential risk areas in our supply chains.
Protect whistleblowers.
We conduct regular risk assessments to identify and evaluate the risk of modern slavery and human trafficking in our operations and supply chains. This includes:
Mapping Supply Chains: Identifying suppliers and assessing their risk levels based on factors such as location, industry, and the nature of their operations.
Supplier Audits: Conducting audits and assessments of high-risk suppliers to ensure compliance with our anti-slavery policies.
Risk Mitigation: Implementing measures to mitigate identified risks, including supplier training, contract clauses, and corrective action plans.
Continuous Monitoring: Regularly reviewing and updating our risk assessment processes to address emerging risks and ensure ongoing compliance.
We conduct thorough audits of our suppliers to ensure adherence to our anti-slavery and human trafficking policies. These audits include:
Scheduled Audits: Regularly planned audits to review supplier practices and compliance.
Unannounced Audits: Surprise audits to ensure ongoing compliance and identify any hidden issues.
Audit Criteria: Evaluating suppliers based on their labor practices, working conditions, and adherence to our ethical standards.
Corrective Actions: Requiring suppliers to implement corrective actions if any non-compliance is found, with follow-up audits to ensure issues are resolved.
Termination of Contracts: Ending relationships with suppliers who fail to comply with our anti-slavery policies after being given the opportunity to rectify issues.
When non-compliance with our anti-slavery and human trafficking policies is identified, we take the following corrective actions:
Immediate Response: Address the issue promptly with the supplier, outlining the specific areas of non-compliance.
Action Plan: Develop a detailed corrective action plan in collaboration with the supplier, specifying the steps needed to rectify the issues and a timeline for implementation.
Support and Training: Provide necessary support and training to the supplier to help them understand and meet our compliance requirements.
Follow-Up Audits: Conduct follow-up audits to ensure that the corrective actions have been implemented effectively and that compliance is maintained.
Escalation: If the supplier fails to implement the corrective actions within the agreed timeframe, escalate the issue to senior management for further action.
Contract Termination: As a last resort, terminate the contract with the supplier if they consistently fail to comply with our anti-slavery policies, despite being given opportunities to rectify the issues.
We provide training to ensure that our staff understand the risks of modern slavery and human trafficking in our business and supply chains. This training is mandatory for all employees and is refreshed regularly. We also provide training programs for our suppliers to ensure they understand and comply with our anti-slavery policies.
Any concerns about modern slavery or human trafficking should be reported to the HR manager or through our confidential whistleblowing hotline. All reports will be taken seriously and investigated appropriately. We have established a clear grievance mechanism for employees and suppliers to report concerns related to modern slavery and human trafficking, including anonymous reporting options.
This policy will be reviewed annually by the board of directors to ensure its continuing suitability, adequacy, and effectiveness. We commit to publishing an annual report on our anti-slavery and human trafficking efforts, including any incidents, actions taken, and progress made.
We have developed a detailed Supplier Code of Conduct that outlines our expectations regarding anti-slavery and human trafficking. This code is a separate document referenced in this policy and is provided to all suppliers.
We have defined key performance indicators (KPIs) to measure the effectiveness of our anti-slavery initiatives. These KPIs help us track progress and identify areas for improvement.
We collaborate with non-governmental organisations (NGOs) and industry groups that focus on combating modern slavery. These partnerships enhance our efforts and provide additional resources.
If you have any questions about this policy, please contact the appropriate person:
Emile Wendling, Founder and Creative Director: policy@eew-design.com