Anti-Slavery and Human Trafficking Policy


Modern slavery and human trafficking are a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour 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.

Factor fully supports the elimination of human trafficking and slavery from all businesses and supply chains.

This Ppolicy establishes:

  • Our commitment to conducting business with integrity and standing against human trafficking, forced, and slave labor;
  • The actions we have taken to understand potential modern slavery risks related to our business and to ensure these events do not occur in any part of our business; and
  • Our compliance with the California Transparency in Supply Chains Act of 2010 and the United Kingdom’s Modern Slavery Act of 2015.

Factor has a zero-tolerance approach to any form of slavery and human trafficking, and is committed to acting ethically, with integrity and transparency, by putting effective controls in place to safeguard against any form of such an events taking place within our business or our supply chain.


This policy applies to all the activities conducted by Factor, and it governs all our business dealings and the conduct of all persons or organisations with whom we contract directly, or whom we appoint to act on our behalf.

We expect that our suppliers will hold their own suppliers to the same high standards.


The Executive Team has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Quality Risk & Compliance have primary responsibility for implementing this policy, monitoring its use and effectiveness.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

Guidance on the policy can be obtained from the Quality Risk & Compliance.


Our core business philosophy is to conduct business with uncompromising integrity and professionalism.

Our Business, Supply Chains, and Evaluation of Risk

We believe that the nature of our business and the regulatory environment in which we operate mitigate the risk of human trafficking and slavery taking place within our business and our supply chain.

Despite our low risk, we have published an anti-slavery and human trafficking statement at, and obliged suppliers they to meet or exceed the standards set forth in our Ppolicy.

Our Commitments

We maintain the following policies and guidelines that support the identification and prevention of slavery and human trafficking in our operations:

Code of Conduct:

The Code of Conduct serves as a compass for our employees, directors, and business partners to consistently act with uncompromising integrity as we build trusted relationships around the world. We will not tolerate and we work to prevent any practices involving human trafficking, forced, and slave labor in our operations and supply chain.


This policy establishes procedures for the receipt and treatment of complaints received by Factor regarding behavior in violation of the law, our Code of Conduct or any company policy.

Anti-Slavery and Human Trafficking Policy:

This policy supports our commitment to human rights and discloses the actions we have taken to ensure human trafficking and slavery are not taking place in our supply chain or in any part of our business.

Vendor Management Policy:

This policy sets out the basis for the due diligence on our suppliers and a risk -based assessment.

Should this approach fail to live up to our commitment, beliefs, or compliance on this topic, we will explore implementing additional governance and corrective measures including but not limited to in-depth monitoring of our supply chain.


The prevention, detection and reporting of modern slavery and human trafficking in any part of our business or supply chains is the responsibility of all those working for us or under our control.

  • You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
  • You must notify your manager as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.
  • You are encouraged to raise concerns about any issue or suspicion of modern slavery and human trafficking in any parts of our business or supply chains or any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager as soon as possible.

Communication and Awareness of this Policy

Guidance on this policy forms part of the annual attestation process for all individuals who work for us and will be provided otherwise as necessary.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working for us or on our behalf (including suppliers) if they breach this policy.

Reporting Violations and/or Concerns and non-retaliation

We expect and encourage our employees and business partners to raise any concerns regarding violations of law, regulations, or our standards of business conduct.

You can report any concerns to EthicsPoint - Factor.

Reports made on the Ethics Hotline may be made on a confidential and anonymous basis. If you make an anonymous report, please provide as much detail as possible, including copies of documents you believe are relevant to the matter.

We do not tolerate retaliation against anyone for asking questions or making good faith reports of possible violations of law, regulation, the Code of Conduct, or other company guidelines.