ENI-JR286, Inc. is committed to the prevention of human trafficking and slavery and ensuring human rights are upheld for all workers in our supply chain.  We require our suppliers and their subsidiaries, affiliates, and subcontractors to conduct business in accordance with our Supplier Code of Conduct (the “Code of Conduct”) and we do not conduct business with any supplier who engages in human trafficking or uses any form of slave, forced, bonded, indentured, or prison labor.

Verification of product supply chains to evaluate and address risks of human trafficking and slavery.  We assess our suppliers’ compliance with the Code of Conduct and local laws, and any violations may jeopardize the supplier’s business relationship with us, up to and including termination.  Our suppliers are required to permit us and/or a third party to periodically evaluate a supplier’s facilities and operations and those of its subcontractors and next-tier suppliers, to the extent they are providing goods or services to us, for our benefit or for use in our products.

Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains.

In addition to our own audits, we periodically engage third parties to conduct on-site audits to evaluate the supplier’s compliance with laws, including the eradication of human trafficking and slavery and compliance with fair wage and health and safety requirements.

Requires direct suppliers to certify that materials incorporated into products comply with laws regarding slavery and human trafficking of the country or countries in which they are doing business.

The Code of Conduct requires our suppliers to comply with applicable laws regarding slavery and human trafficking.

Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

We maintain internal accountability standards and procedures applicable to both employees and contractors and we hold accountable those who fail to meet company standards.  If compliance issues are discovered with a supplier, a plan of action is put into place to bring that facility into compliance.  Violations of the Code of Conduct or any other policy or procedure may result in disciplinary action, including termination of employment or of a supplier contract.

Provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

We provide compliance training to employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chains of products.  Such compliance training includes supplier summits, periodic updates on policy changes and additional training for our employees and management.