Policy Against Forced Labor


Policy Summary

GF Health Products, Inc., and its wholly owned subsidiary, Intensa, Inc. (“GFHP”) is committed to a work environment that is free from human trafficking and slavery, which for purposes of this policy, includes forced labor and unlawful child labor (“this Policy”). GFHP will not tolerate or condone human trafficking or slavery in any part of our organization. This policy is consistent with GFHP’s Ethics Policy and Code of Conduct and our core values to protect and advance human dignity and human rights in our global business practices. This Policy applies to all GFHP employees, contractors, subcontractors, suppliers, and others through whom GFHP conducts business. Each of these individuals/entities is advised of the Policy.

Policy statement

GFHP prohibits trafficking in persons and slavery. GFHP employees, contractors, subcontractors, suppliers, and others through whom GFHP conducts business must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:

  • Engaging in any form of trafficking in persons;
  • Procuring commercial sex acts;
  • Using forced labor in the performance of any work;
  • Destroying, concealing, confiscating, or otherwise denying access by an individual to the individual’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
  • Using misleading or fraudulent practices during the recruitment of candidates or offering of employment/contract positions; such as failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if provided by the employer), any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work;
  • Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
  • Charging applicants/candidates recruitment fees;
  • If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment;
  • If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards; or
  • If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.

GFHP is committed to maintaining and improving its systems and processes, to eradicate human trafficking and slavery in its own facilities and in its supply chain. GFHP requires its suppliers to observe all applicable laws and conduct business in an ethical and responsible manner. GFHP continues to verify, evaluate, and address risks associated with forced labor and human trafficking in its facilities and in its supply chain. Examples of actions undertaken include the following:

Evaluating and addressing supply chain risks

GFHP has incorporated requirements for supply chain compliance to applicable state, federal and international laws in supplier agreements.

Supplier certification

GFHP ensures that suppliers certify to the best of their knowledge that the materials they incorporate into products were generated in compliance with applicable anti- slavery and human trafficking laws.

Auditing suppliers

GFHP audits its suppliers based on risk and reviews the audit results for these suppliers.


GFHP provides training on human trafficking and slavery issues to employees that directly manage the supply chain and to employees that recruit, hire and manage applicants and employees.

Investigations and audits

GFHP performs investigations and audits to verify that business is being conducted in compliance with this Policy. All GFHP employees and third parties through whom GFHP conducts business are required to cooperate with GFHP’s internal and external auditors and investigators fully and promptly, and must respond fully and truthfully to their questions, requests for information, and documents. Failure to comply may be grounds for immediate termination of the relationship.

Policy compliance

Any shipment of goods by any Third Party is deemed a certification by such third party that it has obtained and will retain for a period of no less than two years from the date of such shipment, all required documentation demonstrating that no finished product or any component material included in such shipment was sourced (1) through any means in violation of any applicable law, including without limitation the Uyghur Forced Labor Prevention Act or any replacement or similar law or regulations (“Forced Labor Laws”); (2) from any person or entity identified on any Forced Labor Law entity list; (3) from any person or entity located within the Xinjiang region or any other region identified by any Forced Labor Law from time to time as suspect or highly suspected for the use of any forced, child or indentured labor; or (4) through “forced” labor as that term is defined in 19 U.S.C. 1307.

Any GFHP employee or partner who suspects a violation of this Policy, must immediately report to the GFHP Quality/Regulatory team or to the GFHP Human Resources team. Reports may also be made through GFHP’s toll free number 888-974-4347, which allows anonymous reporting as permitted by applicable law.

Failure of Third-Party Partners to Comply with the Policy

By agreeing to GFHP’s Purchase Order Terms and Conditions, as may be amended from time to time, third party contractors, subcontractors and suppliers each agrees to be bound by this Policy and each of these third parties agrees to indemnify GFHP against all claims, demands, judgments, awards, fines, penalties, losses, damages, costs, suits and expenses arising from the third party’s non-compliance with this Policy, including without limitation the cost of any investigation and all costs related to the shipment of goods and return of such goods if necessary.