Modern Slavery Policy

1. Purpose and Scope

(“the Company”) is fully committed to combatting modern slavery, human trafficking, forced labour, and any form of exploitation across its operations and digital platforms. This policy outlines our approach to identifying and mitigating such risks, especially within the context of our role in the adult online business sector.

This policy applies to all employees, contractors, business partners, users, content providers, and advertisers associated with the Company.

2. Legal Framework

This Policy aligns with the following international and national standards:

• UK Modern Slavery Act 2015
• UN Guiding Principles on Business and Human Rights
• ILO Conventions No. 29 and 105
• German Supply Chain Due Diligence Act (LkSG), where applicable
• EU Charter of Fundamental Rights
• Other national anti-trafficking and labour laws in jurisdictions where the Company operates.

3. Definition of Modern Slavery

Modern slavery refers to practices such as:

• Human trafficking
• Forced or compulsory labour
• Debt bondage
• Child labour
• Servitude
• Sexual exploitation involving coercion or threat

The Company enforces a zero-tolerance policy on all such conduct throughout its business and supply chain.

4. Our Commitment

• We prohibit all forms of modern slavery in our operations, content platforms, and partner relationships.
• We require all parties we work with, users, including content creators and advertisers, to comply with this policy and relevant legal standards.
• We actively assess risks and implement control mechanisms in high-risk areas.
• We terminate relationships with any party found in breach of these standards.

5. Due Diligence & Risk Management

a. Verification of Suppliers and Partners

All content creators and users submitting adult material must:

• Verify identity using a valid government-issued ID
• Confirm legal age (18 years or older)
• Provide consent for content publication
• Affirm that participation is voluntary, with no coercion or duress

b. Platforms Monitoring and Escalation

We use both automated and manual tools to detect:

• Suspicious or flagged content
• Unusual or coercive behaviour
• Fake documentation or identity misuse

Where risks are identified, immediate internal investigation is triggered.

6. Training and Awareness

All employees and relevant contractors receive regular training on:

• Identifying signs of modern slavery
• Proper documentation and reporting procedures
• Legal responsibilities and platform-specific risks

New joiners complete this training during onboarding, with annual refresher courses.

7. Reporting and Whistleblowing

Any person, internal or external, may report suspected violations confidentially via:

• Email:
• Anonymous whistleblower may report through the website own contact form.
• In writing to the General Manager

Reports are handled sensitively, and retaliation against whistleblowers is prohibited.

8. Corrective Action and Enforcement

When a violation is confirmed, the Company:

• Affected accounts or services are immediately suspended
• The matter is referred to appropriate law enforcement if required
• Contracts may be terminated for cause
• Support is extended to any identified victim where feasible

9. Transparency and Disclosure

The Company publishes an Annual Modern Slavery Statement including:

• Summary of due diligence actions
• Detected incidents (if any) and response
• Risk reassessment processes
• Planned policy updates

This statement is approved by senior management and publicly available on our website.

10. Governance and Review

This policy is approved by the General Manager of the Company and is subject to annual review. Any updates reflecting legal or operational changes will be made promptly.

The General Manager is responsible for:

• Overseeing implementation of this policy
• Ensuring staff compliance
• Coordinating investigations and remedial actions when necessary

Effective Date: January 1st, 2025

Date of latest review: May 30th, 2025