California Transparency in Supply Chains Act Disclosure
Ecliptic Enterprises, LLC and its affiliates (“Ecliptic” or “the Company”) are committed to conducting business ethically, responsibly, and in full compliance with all applicable laws. We oppose all forms of human trafficking, including slavery, sex trafficking, involuntary servitude, forced or compulsory labor, child labor, and any related exploitative practices. As stated in our Anti‑Trafficking Compliance Plan, “No employee, agent, subcontractor, vendor, or supplier is permitted to solicit, participate in, or benefit from such activities.”
The Company fully supports U.S. Government policies prohibiting trafficking in persons and strictly prohibits employees, agents, and subcontractors from engaging in any form of trafficking; procuring commercial sex acts; or using forced labor during the performance of a contract. The Company also prohibits destroying, concealing, or confiscating identity or immigration documents such as passports or driver’s licenses. Misleading or fraudulent recruitment practices are strictly forbidden, including failing to disclose key terms and conditions of employment in a language the worker understands, misrepresenting wages or benefits, failing to explain living conditions or associated costs, or failing to disclose the hazardous nature of work when applicable. Recruiters used by the Company must comply with all local labor laws, and employees or potential employees may not be charged recruitment fees under any circumstances.
Verification
Ecliptic does not operate a formal third‑party verification program dedicated solely to identifying human trafficking or slavery risks in our supply chain. We have assessed our supplier base and business model and determined that based on the industries in which they are involved and the type of products and services provided that they present a low‑risk profile, and we rely on established supplier selection processes, commercial due diligence, and ongoing business relationships to assess supplier integrity.
Our anti‑trafficking standards prohibit misleading or fraudulent recruitment practices, including failing to disclose employment terms in a language the worker understands, misrepresenting wages or benefits, or failing to explain living conditions or associated costs. Recruiters engaged by Ecliptic must comply with all applicable labor laws, and employees or candidates may not be charged recruitment fees. We endeavor, wherever possible, to ensure that our suppliers comply with relevant laws and regulations. In addition, because we are a supplier to various government programs, as described below we have an obligation to comply to strict standards and, in many cases, to pass along these standards to our own suppliers.
Audits
Ecliptic does not currently conduct independent or unannounced audits specifically focused on human trafficking or slavery. However, we reserve the right to review supplier performance, business practices, and compliance obligations as part of our general supplier management activities.
Our Anti‑Trafficking Compliance Plan requires all agents and subcontractors—at any tier and at any dollar value—to comply with all applicable laws and regulations related to combating trafficking in persons. When concerns arise, we may request documentation, seek clarification, or take corrective action.
Certifications
Where appropriate, Ecliptic includes contractual provisions requiring suppliers to comply with all applicable laws relating to human trafficking, forced labor, and slavery. These provisions may require suppliers to certify that their operations and labor practices meet legal and ethical standards.
Our policy prohibits the use of forced labor, the procurement of commercial sex acts, and the destruction or confiscation of identity documents. We also prohibit providing or arranging housing that does not meet host‑country safety standards and require that written employment contracts or recruitment agreements be provided in a language the employee understands.
Accountability
Ecliptic maintains internal policies and standards of conduct that apply to employees, agents, and subcontractors. Violations of these policies may result in disciplinary action, including termination of employment or business relationships. As stated in our Anti‑Trafficking Compliance Plan, “Any individual or entity found to have engaged in trafficking‑related conduct will face appropriate corrective action, up to and including termination of employment, removal from a contract, or termination of a subcontract or business relationship.”
All personnel working on behalf of the Company are required to report any activity inconsistent with this policy or with FAR 52.222‑50. Reports may be made confidentially through our website, by phone, or through the Global Human Trafficking Hotline. Retaliation against individuals who report concerns in good faith is strictly prohibited.
Training
Ecliptic provides employees and management personnel with policies, guidance, and awareness related to ethical business conduct and supply chain responsibilities. We periodically update internal policies and procedures to reinforce compliance with laws relating to human trafficking and slavery.
Our Anti‑Trafficking Compliance Plan is posted on the Company intranet and “informs all personnel of the prohibitions outlined in FAR 52.222‑50(b), the consequences of violating Company policy, and the methods available for reporting concerns.”
Our Commitment
Ecliptic is committed to maintaining a responsible, transparent, and ethical supply chain. We will continue to evaluate our practices and strengthen our efforts to prevent human trafficking and forced labor in all aspects of our operations.
All employees, agents, and subcontractors working on behalf of the Company are required to report any activity inconsistent with FAR 52.222‑50 or this policy. Reports may be made without fear of retaliation to a Manager or Human Resources and may be submitted confidentially through the Company’s website at www.eclipticenterprises.com, by phone at 626‑798‑2436, or via the contact page at https://www.eclipticenterprises.com/contact. Individuals may also report concerns to the Global Human Trafficking Hotline at 1‑844‑888‑FREE or help@befree.org. Retaliation against anyone who reports a concern in good faith is strictly prohibited.