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)