Anti-Slavery & Anti-Trafficking

08 Dec, 2025

ANTI-SLAVERY AND ANTI-TRAFFICKING STATEMENT

Marmont Encore Limited operates www.theFANBANK.com ("theFANBANK" or "the Company"),

a subscription-based social platform that is transforming how creators and fans connect. The

platform welcomes content creators across all genres, empowering them to reach their full

potential in line with the Company’s values and objectives.

theFANBANK is dedicated to fighting modern slavery. We strive to build the safest digital media

platform globally and have zero tolerance for modern slavery or human trafficking on our site,

within our business partnerships, or in our supply chain.

This statement reflects our Company’s values and objectives and adheres to the UK Modern

Slavery Act, Australia Modern Slavery Act, and the California Transparency in Supply Chains

Act. It outlines the measures theFANBANK has implemented to prevent modern slavery and

human trafficking within our operations, partnerships, and supply chains.

Our Commitment

theFANBANK firmly opposes all forms of modern slavery and human trafficking. These acts are

criminal offenses and serious violations of basic human rights. They include, but are not limited

to, slavery, servitude, forced labor, and human trafficking—all of which involve depriving

someone of their freedom for exploitation.

We are devoted to conducting ourselves with integrity and actively reducing the risk of modern

slavery and human trafficking in our business relationships and interactions with creators and

fans. We also commit to treating every employee, partner, and vendor with dignity and respect,

ensuring safe workplaces, and upholding ethical, environmentally responsible practices.

Measures to Prevent, Detect, and Address Risks of Modern Slavery and Human Trafficking

During this financial period, we have:

• Continued mandatory company-wide training on modern slavery and human trafficking;

• Distributed policies and procedures covering acceptable business practices and ethical

standards;

• Assessed our supply chain for risks related to modern slavery and human trafficking and

taken action to reduce these risks;

• Made significant investments to strengthen our content moderation processes, including

hiring additional specialists;

• Appointed an independent monitor to review and improve our safety controls and

compliance initiatives; and

• Increased collaboration with third-party organisations dedicated to combating modern

slavery and human trafficking.

Our Policies

theFANBANK takes steps to prevent modern slavery and human trafficking in our business,

platform, and supply chain.

Merchandise:

1We source promotional merchandise for creators and fans, acknowledging the garment

industry’s risks of exploitation. We monitor for issues such as forced labor, underage workers,

working conditions, pay, and worker rights.

Risk Mitigation Efforts

We address risks identified in prior statements and remain committed to further actions.

Creator Verification:

We carefully verify each creator’s identity and payment details to ensure accounts are genuine

and payments reach the rightful owner. In higher-risk cases, additional “selfie” checks are

required at intervals.

Content Moderation:

We screen all uploaded media using advanced technology and trained moderators, removing

and reporting any material linked to exploitation, modern slavery, or trafficking. All content is

reviewed before appearing on theFANBANK, and we do not use end-to-end encryption—

everything is visible for moderation.

Contractor or Agency Staff:

Agencies and temporary staff must follow laws and policies against modern slavery and

trafficking. All employees undergo annual online training regarding these issues.

Merchandise:

Commercial agreements with manufacturers require adherence to our Code of Conduct, Terms

of Service, and Acceptable Use Policy.

Policy and this Anti-Slavery & Anti-Trafficking Statement are maintained to ensure alignment

with our organisational standards opposing modern slavery and human trafficking.

Community Reporting: We have continued to enhance our support functions to address

concerns or complaints from both users and the broader community. A report button is

available on every post and account on theFANBANK; any reports escalated via our platform are

thoroughly reviewed by our internal moderation team. Furthermore, we encourage anyone who

encounters material suggesting that someone is in immediate physical danger related to human

trafficking to promptly contact us at compliance@thefanbank.com

Support for Law Enforcement: When theFANBANK identifies content indicative of modern

slavery or human trafficking, we immediately suspend the associated account and relay this

information to law enforcement and relevant non-governmental organisations to facilitate the

identification of those responsible.

Investments and Partnerships: We continue to invest significantly in our technical and

operational teams to improve the detection of content linked to human exploitation. Our

increased investments focus on identifying and disrupting illicit actors, networks, organisations,

and businesses engaged in these activities, both on our platforms and through external

partnerships. We collaborate with a range of NGOs, helplines, and charities in line with our

rigorous safeguarding policies for creators, fans, and staff. This includes active participation in

the reporting systems of the National Center for Missing & Exploited Children (NCMEC) and

other recognised NGOs.

2Transparency & Reporting: theFANBANK is committed to establishing the safest social media

platform globally. We uphold accountability and routinely publish data verifying our efforts,

which can be accessed in our Transparency Reports available here. Moreover, we have

appointed an independent third-party monitor to audit our safety controls and compliance

programme.

Our Reporting Mechanisms

We nurture a culture grounded in transparency, integrity, and accountability, encouraging

employees to report concerns or misconduct, including violations related to human rights,

modern slavery, and human trafficking.

If you have concerns or suspect legal violations involving the Company—by employees,

contractors, agency staff, or any third party acting on the Company’s behalf—please report

such matters via email to compliance@ theFANBANK.com.

Should a concern arise regarding a supplier or contractor, we will collaborate with appropriate

stakeholders to investigate and resolve the situation. Substantiated concerns will result in

corrective measures, up to and including contract termination.

Our Ongoing Commitment to Continuous Improvement

Modern slavery and human trafficking present intricate challenges for organizations globally.

theFANBANK is dedicated to ongoing efforts aimed at addressing and preventing these

practices, and our strategies are regularly reviewed and enhanced. We maintain open

communication regarding our approach both internally and with suppliers, from the

commencement of business relationships and at intervals thereafter.

We remain committed to upholding and strengthening our measures to prevent modern slavery

and human trafficking. To that end, we will continue to evaluate and implement actions that are

suitable in relation to the risk profile of Marmont Encore Limited and theFANBANK, including:

• Identifying and evaluating further potential risks within our operations and supply chain;

• Mitigating the likelihood of modern slavery and human trafficking occurring within our

organization or among suppliers;

• Protecting whistleblowers and taking remedial action as necessary;

• Keeping abreast of legislative developments related to the UK Modern Slavery Act,

Australian Modern Slavery Act, and other relevant statutes;

• Monitoring risk areas and developing effective solutions to ensure the safety of

employees, users, and third parties from exploitation.

Responsibility for this Statement

The Executive Leadership team holds overall responsibility for ensuring compliance with this

statement and all related policies. Managers at every level must ensure their teams understand

and adhere to our anti-slavery and anti-trafficking protocols. The Legal team is chiefly

responsible for overseeing the implementation of this statement, responding to related

enquiries, and assessing internal controls to guarantee their effectiveness in combatting

modern slavery and human trafficking.

This statement has been approved by the Board of Marmont Encore Limited.


Signed by

Malcolm Hogg


Director and CEO of Marmont Encore Limited (operator of theFANBANK.com)