1. About Us

TrueFanz is a membership management platform that is revolutionizing the connection between creators and their biggest supporters. The site is inclusive of artists and content creators from all genres and allows them to develop authentic relationships with their fan base. TrueFanz gives creators the opportunity to monetize the content they want to share. TrueFanz LLC is committed to providing a secure environment with full compliance with relevant laws, rules, and various regulations.

2. Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and, taking into account our creator/fan platform structure to implement and enforce effective systems to ensure modern slavery never takes place anywhere inside or outside our business infrastructure.

3.Our Policies

We are committed to ensuring that there are no modern slavery or human trafficking activities taking place on our platform or via our third-party suppliers. Our Anti-Slavery and Anti-Trafficking Policies, along with our deep learning security monitoring systems reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place within the TrueFanz community.

The prevention, detection and reporting of modern slavery in any part of our business or throughout our supply chain is the responsibility of ALL those working for us, with us, or under contract.

Our employees are required to avoid any activity that might lead to, or suggest, a breach of this statement. 

All employees, users, and contractors are encouraged to read, understand and comply in full with our Anti-Slavery and Anti-Trafficking Policy.

Internally we brief and encourage our members to report any concerns or wrongdoings which extends to any human rights violations like modern slavery.

All reports will be fully investigated and appropriate remedial action taken both internally and externally.

For our users we have several community reporting processes which allows all users to report any breaches of policy and regulations and law.

This can be done in several ways. Contacting support@truefanz.com, or submitting a detailed support ticket to our team directly at TrueFanz.com. A user can also flag/report content in real-time during their usage of the platform.

We have a policy which encourages our staff to report any concerns or wrongdoings which extends to human rights violations like modern slavery.

All reports are investigated, and appropriate action taken. If any employee or user or third party raises a genuine concern, they will not suffer any detriment as a result of doing so even if they turn out to be wrong.

4. Areas of Risk

We understand that our biggest exposure to modern slavery is within our own business model. We are committed to report on key points of action that we intend to take going forward.

The areas that we operate in could contain high risk regions and we are conscious of this.

• There are risks relating to uploading the content by our creators and the risk of material being used that is exploitative and in breach of the TOS. In order to disrupt and prevent harm we monitor all media uploaded to the platform and remove, and report where necessary, any content that facilitates or coordinates the exploitation of humans, including human trafficking.
  
  We define human trafficking as the business of depriving someone of liberty for profit. It is exploitation of humans in order to force them to engage in commercial sex, labor or other activities against their will. It relies on deceptive force or coercion. Please see our Human Rights Sources publication.
• Our recruitment of staff.
  
  Our contracts with suppliers regularly specify the Act as a contractual obligation for them to comply with and we will promote a requirement that any suppliers confirm their compliance with the Act. That said we have a limited number of suppliers because of the nature of our industry. We are implementing companywide training on modern slavery to new customer facing staff and existing workers and an annual refresher for all employees and/or [contractors] the training is mandatory and is provided via an online training environment.

5. Responding to Areas of Risk

• 1. Security. We have a robust onboarding and Know-Your-Customer (KYC) process when new users join the platform to become a creator. This is a critical part of our zero-tolerance policy against modern slavery. In 2021, we have added user verification methods that require user presence.
• 2. Content Moderation. We have continued to develop the depth and sophistication of our content moderation to ensure compliance with our TOS. This has included the addition of hiring many customer service agents to review content in addition to our automated “AWS Recognition” services.
  
• 3. We monitor to make sure that only a creator is allowed to make an account on their own behalf. We further enforce this rule throughout their usage of the platform. We review any discrepancies between ID’s added and the Payout legal name provided.
  
• 4. Community Reporting. In 2021, we have significantly expanded our Support functions to deal with any concerns or complaints from our users and from the wider global communities. Any reports escalated from our platform are reviewed internally by our admins and platform Moderators.
• 5. We will continue to consider and take the following actions which are appropriate and proportionate to the risk profile for TrueFanz LLC and our users.
  
  a. Identify and assess any further risk areas within our business or technology chains.
  b.    Mitigate the risk of slavery and human trafficking occurring in our business or technology chains.
  c.    Protect whistleblowers within our business and take appropriate remedial or legal action as warranted.
  d.    Stay up to date with any recognized changes to related legislation. We are committed to transparency in our business and in our approach to tackling modern slavery throughout that business consistent with our obligations under the law. We expect and welcome very high standards within our business and from our users, contractors, and other suppliers and we include specific prohibition against the use of force, compulsory or trafficking labor or any held in slavery or servitude whether adults or minors.
  e. Manually and technologically monitoring all avenues of potential risk areas and solutions to ensure employees, users and any third party are safe from the risk of slavery and human trafficking.
  
• 6. We encourage anyone encountering content on TrueFanz that indicates someone is in immediate physical danger relating to human trafficking to immediately report the content to us at support@TrueFanz.com.

6. Responsibility for the statement

Our Executive Management have overall responsibility for ensuring that all those under our control comply with this statement and our related policies.

Management and team-members at all levels are responsible for ensuring their personnel understand this statement and comply with our Anti-Slavery and Anti-Trafficking Policy.

The TrueFanz LLC Legal Team have primary and day to day responsibility for dealing with this statement and any queries about it and considering internal control systems and procedures to ensure they are effective in countering modern slavery.

7. Training

Training on the risks TrueFanz LLC faces from modern slavery in our business and if appropriate our technology chains are mandatory for all key individuals who work for TrueFanz LLC and is provided annually both in person and digitally.

Our approach to modern slavery will continue to be communicated throughout our business and to any suppliers at the outset of any business relationship with them and shall be reinforced as appropriate thereafter.

We are committed to maintaining and improving our practices to combat slavery and human trafficking.

This statement has been approved by managers at TrueFanz LLC.