Modern Slavery & Human Rights Statement

1.1 Voluntary publication. The Company falls below the thresholds that make such a statement mandatory in the jurisdictions it sells into: s.54 of the UK Modern Slavery Act 2015 applies to commercial organisations with a global turnover of £36 million or more; the Australian Modern Slavery Act 2018 applies above AUD $100 million consolidated revenue; the California Transparency in Supply Chains Act applies to retail sellers and manufacturers above US$100 million in worldwide gross receipts; and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act applies to entities meeting prescribed size tests. The Company is below each. It publishes this statement voluntarily and does not claim statutory compliance it is not subject to.

1.2 Obligations that apply regardless of size. Two do. Section 307 of the Tariff Act of 1930 (19 U.S.C. §1307) prohibits the importation of goods made wholly or in part with convict, forced or indentured labour, with no de minimis exception. The Uyghur Forced Labor Prevention Act (Pub. L. 117-78) creates a rebuttable presumption that goods mined, produced or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or by an entity on the UFLPA Entity List, are made with forced labour and are barred from entry into the United States unless the importer rebuts that presumption by clear and convincing evidence. These apply to any importer of any size, and are directly relevant to the Company’s merchandise line.

1.3 Standards referenced. This statement is written against the ILO core conventions on forced labour (Nos. 29 and 105) and child labour (Nos. 138 and 182), the UN Guiding Principles on Business and Human Rights, and the sustainable-procurement framework of ISO 20400:2017 as applied in the Sustainable Procurement Policy.

2.1 Entity. ERIANUX, LLC is a limited liability company organised under the Wyoming Limited Liability Company Act, W.S. 17-29-101 et seq. It has no subsidiaries.

2.2 What we sell. Charting indicators, order-flow tools and drawing tools for the NinjaTrader 8 platform, licensed digitally to independent traders; subscription access to Company services; and a small range of branded merchandise — apparel, drinkware and desk mats — produced by third-party print and fulfilment partners. See About.

2.3 Our workforce. The Company has no employees at the date of this statement. Work is performed by the Managing Member and, where required, by professional contractors engaged directly for software, accounting and legal services. The Company does not use labour agencies, recruitment intermediaries or seasonal labour, which removes the two mechanisms — recruitment fees and agency debt bondage — through which forced labour most commonly enters a workforce.

The Company’s supply chain divides into three tiers with materially different risk profiles. Naming them is what makes the rest of this statement checkable.

The software business has no manufacturing supply chain: a licence key is written, not made. The merchandise line is where a genuine sourcing decision exists, and where this statement does its work. The Company does not own a factory, does not commission bulk manufacturing, and does not hold manufacturing inventory.

• 4.1 Zero tolerance. The Company prohibits, in its own operations and in any supply chain it relies on, forced or compulsory labour; bonded, indentured or debt-bonded labour; involuntary prison labour; human trafficking; child labour below the applicable minimum working age; and any hazardous work performed by a person under eighteen.
• 4.2 Freedom of movement and documents. No worker in a supplier’s facility should have identity documents, passports or wages withheld as a means of retaining them, be required to pay a recruitment fee or deposit, or be restricted in leaving the workplace or terminating employment on reasonable notice.
• 4.3 Wages, hours and association. Workers should be paid at least the legal minimum for their region and, where the Company has a choice between comparable partners, it prefers the one paying above it; hours should comply with local law, with overtime voluntary and not used as a substitute for hiring; and freedom of association should be respected where local law permits it.
• 4.4 Flow-down. This standard applies to any manufacturing, print or fulfilment partner the Company uses, and to that partner’s own suppliers to the extent the Company has visibility into them. A partner that cannot say where its greige goods, cotton or components originate is a partner that cannot demonstrate compliance with clause 4.1.
• 4.5 Consistency with other policies. This statement operates alongside the Sustainable Procurement Policy and the Code of Conduct, clause 5.3 of which imposes the same obligation on every person acting for the Company.

5.1 Overall. The Company assesses its risk as low in absolute exposure but not negligible in category. The risk lives in the product category and its upstream tiers, not in company revenue, which is precisely why this statement exists at the Company’s size.

5.2 Apparel and textiles — the principal risk. Cotton is the Company’s highest-risk input. A substantial share of the world’s cotton is grown in a region subject to the UFLPA rebuttable presumption, and finished garments cut and sewn outside China may still contain that fibre. Under the UFLPA the country of assembly is not determinative; the origin of the raw material is. Apparel and textiles remain a priority enforcement sector for U.S. Customs and Border Protection, and there is no de minimis threshold below which an input is disregarded.

5.3 Dropship and wholesale marketplaces. Sourcing through a marketplace shortens the contractual chain but lengthens the visibility gap: the platform is the counterparty, the manufacturer several tiers behind it. Where a supplier ships from a jurisdiction with elevated forced-labour risk, the Company treats the absence of traceability as a risk in itself rather than as an absence of evidence.

5.4 Drinkware, desk mats and promotional goods. Moderate risk. These categories involve metals, polymers and electronics-adjacent inputs sourced through opaque tiers, and are subject to periodic enforcement attention.

5.5 Digital and financial suppliers. Low risk. These are established, professionally staffed technology and financial businesses in jurisdictions with functioning labour enforcement. The Company does not treat them as risk-free, but does not apply apparel-grade diligence to them.

5.6 Mitigating structure. Print-on-demand production, rather than commissioned bulk manufacturing, means no volume commitment and no pressure to hit a unit cost that only forced labour can deliver; the Company can change partner without stranding inventory. The small scale of the merchandise line relative to software revenue removes the commercial incentive to tolerate a supplier it has doubts about.

6.1 Partner selection. The Company selects established print and fulfilment operators that publish their own labour standards and carry a track record other sellers can verify, in preference to an unverified supplier offering a lower unit price. Price alone does not win a sourcing decision.

6.2 Screening at onboarding. Before a physical-goods partner is used, the Company checks the entity’s identity and ownership, reviews its published labour and sourcing policies, and screens the entity and its principals against the UFLPA Entity List, CBP withhold-release orders and findings, and the sanctions lists identified in the Anti-Money Laundering & Sanctions Policy.

6.3 Commercial terms that do not create the risk. The Company does not negotiate prices or turnaround times that could only be met by cutting corners on labour, does not impose penalty-backed deadlines on a print partner, and pays its own suppliers on the agreed terms.

6.4 Contractual requirements. New and renewed physical-goods agreements require the partner to comply with applicable labour law and with clause 4 of this statement; to refrain from unapproved subcontracting of production; to disclose the country of manufacture on request; to notify the Company of any forced-labour allegation, detention or withhold-release order affecting its supply chain; and to accept termination for breach.

6.5 Traceability expectations. For apparel, the Company asks its partner to identify the country of manufacture and, where the partner can provide it, the origin of the fabric. Where a partner cannot or will not answer, that is recorded and weighed against continuing the relationship.

6.6 The limits of our oversight, stated plainly. The Company does not commission its own factory audits, does not employ a supply-chain auditor, and does not hold tier-three traceability documentation. It relies on its partners’ certifications, published standards and standing, together with the screening at clause 6.2. It says so rather than implying a level of assurance it does not have — and it will change partners where it has credible reason to doubt either the certification or the partner.

6.7 What we do not claim. No audited supply chain, no certified forced-labour-free rating, and no verified tier-three visibility. An unverified assurance is not one the Company publishes.

7.1 On credible information. Where the Company receives credible information of forced or child labour in a supplier it uses, it will suspend new orders with that supplier, seek an explanation and evidence, and consult the partner’s published grievance mechanism where one exists.

7.2 Remedy before exit. Immediate disengagement can leave affected workers worse off. Where a partner is willing and able to remediate — repaying recruitment fees, returning withheld documents, correcting underage employment with the welfare of the worker in mind — the Company will support that course and verify the outcome before resuming orders. Where the partner is unwilling, or the conduct is egregious, the Company terminates.

7.3 Escalation. Credible evidence of trafficking or child labour is reported to the appropriate authority, and any potentially affected inbound goods are withdrawn from sale pending resolution.

8.1 How we measure effectiveness. The Company does not publish a performance percentage it has not measured. It tracks four process indicators instead: the proportion of physical-goods partners screened before first order; the proportion of physical-goods agreements carrying the clause 6.4 terms; the number of concerns received and their outcomes; and the number of partners changed or declined on labour grounds. These are recorded at each annual review.

8.2 Training. The Company has no employees, so formal staff training does not yet apply. Any person given responsibility for selecting or managing a physical-goods supplier will be briefed on this statement and the clause 5 risk assessment before that responsibility is transferred, and the briefing recorded.

8.3 Grievance channel. Workers in a supplier’s facility, customers, and members of the public may raise a concern directly at legal@erianux.com. The Company will not disclose the identity of a worker who raises a concern to their employer.

8.4 Approval and review. This statement is approved by the Managing Member, who holds accountability for it. It is reviewed annually and additionally whenever the merchandise supplier base changes materially, a new product category is introduced, a partner is named in an enforcement action, or the Company crosses a statutory reporting threshold — at which point it will publish a statutory statement in the required form.

9.1 Inputs treated as higher risk. Cotton and cotton-blend fabric; viscose, rayon and other cellulosic fibres; garment dyeing and finishing; stainless steel and aluminium components in drinkware; polymer and rubber sheet in desk mats; and packaging produced in the same facilities as the goods. Each is sourced, at some tier, through markets with documented labour-exploitation risk.

9.2 Indicators at the supplier level. A price materially below the market for the specification; unwillingness to identify the production facility; production capacity inconsistent with the stated workforce; a certificate provided as an image that cannot be verified against the issuing body; a sudden change of factory or bank details; and any reference to a labour-transfer, placement or state-sponsored recruitment programme.

9.3 Indicators at the worker level. Recruitment fees charged to workers; retention of identity documents or wages; accommodation tied to employment with movement restricted; wage deductions for equipment, transport or training; overtime that is compulsory in practice; and the presence of workers who appear to be under the applicable minimum age.

9.4 How an indicator is treated. One indicator is a question. Two is a decision point at which orders are held until the question is answered. Refusal to answer is treated as an adverse answer.

10.1 Position. Where goods are dropshipped directly to a customer by an overseas partner, the Company is nonetheless the party whose commercial decision caused the importation and treats itself as accountable for it. It does not treat the partner’s shipping label as a transfer of responsibility.

10.2 If goods are detained. The Company will not attempt to rebut a forced-labour presumption with documentation it does not genuinely hold. Where a shipment is detained and the Company cannot evidence a clean chain of custody, the goods are withdrawn from sale, the product line is suspended, and the supplier relationship is reassessed rather than re-routed through a different port or a different intermediary.

10.3 Country-of-origin accuracy. The Company does not mislabel origin, ask a supplier to mislabel it, or accept a supplier’s offer to do so in order to clear customs more easily.

These requirements are incorporated into physical-goods agreements and apply to the supplier and to any facility it uses.