The California Transparency in Supply Chains Act of 2010 (SB 657) and the United Kingdom Modern Slavery Act of 2015 require certain businesses to provide disclosures and take other actions concerning their efforts, if any, to address the issues of slavery and human trafficking in their supply chains. Similarly, the Federal Acquisition Regulation (FAR) 52.222-50 (‘‘Combating Trafficking in Persons”) and FAR provision 52.222-56 (‘‘Certification Regarding Trafficking in Persons Compliance Plan”) prohibits trafficking persons. This Anti-Slavery and Human Trafficking Statement (“Statement”) addresses these statutes and regulations and covers all of Neeco Industries, Inc. and its divisions (“Neeco”).
Neeco is a leading manufacturer and aftermarket service provider of comprehensive pressure control, flow control and related systems. Neeco’s product portfolio of valves, manifolds, wellhead, automation and aftermarket services supports global infrastructure industries, including oil and gas, chemical, power generation (including nuclear, fossil and renewable) geothermal, and marine/defense, as well as certain general industrial markets. Neeco conducts operations through three business segments: Engineered Product Division, Industrial Product Division and Pressure Control Division.
Neeco’s supply chain supports its manufacturing facilities and sources raw materials, components and services from around the globe. Neeco’s suppliers play a critical role in the business, and supplier relationships are based on achieving best performance, product delivery, service and total cost in an ethical and sustainable manner.
Neeco is committed to conducting its worldwide business operations in a manner that complies with applicable laws and regulations and according to the highest ethical standards.
Neeco prohibits slavery and human trafficking and is committed to taking steps to ensure that slavery and human trafficking are not taking place in any part of our supply chain or business.
Neeco’s Code of Conduct requires all employees to comply with the laws and regulations of all countries in which we operate. Similarly, Neeco requires each of its suppliers to adhere to a Supplier Code of Business Conduct, which requires compliance with all local and country laws and regulations. The Supplier Code of Business Conduct specifically prohibits forced labor, child labor and human rights abuses. Neeco contractually reserves the right to terminate any supply chain contract for violation of its Supplier Code of Business Conduct. Likewise, Neeco’s Standard Terms & Conditions of Purchase require compliance with human trafficking laws. Further, Neeco requires compensation practices to comply with applicable wage laws, including minimum wage requirements, overtime compensation and legally mandated benefits. Neeco also respects the rights of workers to associate freely and seek representation in accordance with local law.
Neeco takes steps to evaluate, assess and verify risks of slavery and human trafficking in our supply chains through our Supplier onboarding and ongoing management processes, conducting regular audits of our suppliers and potential suppliers to confirm adherence to Neeco’s Supplier Code of Business Conduct. In addition to the regular audits, Neeco also maintains an Ethics Hotline where ethical concerns or alleged wrongdoing can be reported, including violations of the law, Code of Conduct and/or Neeco policies. The Ethics Hotline is available globally, with multilingual capabilities, 24 hours a day, seven days a week. Reports made through the Ethics Hotline are promptly and thoroughly investigated.
Neeco reinforces its ethics and compliance requirements through annual training for all employees. Neeco also has mandatory employee training that details its commitments to treating employees fairly, respecting human rights, promoting a healthy and safe workplace, and treating employees with respect. Neeco will continue to benchmark its standards and audit its approach against regulatory requirements and available guidance.
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