Standard contract between fan and creator

ANTI-SLAVERY AND ANTI-TRAFFICKING STATEMENT 2024

WildGirlsProductions Limited owns and operates the website BBWPlayHouse ("BBWPlayHouse" or the "Company"), a subscription based social platform revolutionizing creator and fan connections. The site is inclusive of content creators from all genres and empowers creators to own their full potential in accordance with the Company’s values and goals.

WildGirlsProductions fights to combat modern slavery. We are committed to building the safest digital media platform in the world and we do not tolerate modern slavery or human trafficking in any form including on our platform, in our partnerships or in our supply chain.

This statement is made pursuant to our Company values and goals, and in line with the USC 2257, UK Modern Slavery Act, Australia Modern Slavery Act, and the California Transparency in Supply Chains Act. It sets out the steps taken by WildGirlsProductions to ensure that modern slavery and human trafficking is not taking place in our business operations, partnerships and supply chains.

Our Commitment

BBWPlayHouse stands against all forms of modern slavery and human trafficking. Modern slavery is 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.

We are committed to acting with integrity and mitigating the risk of modern slavery and human trafficking in our business dealings and relationships with our creators and fans. We are also committed to treating all employees, partners and vendors with respect and dignity, ensuring safe working conditions, and conducting environmentally responsible and ethical operations.

Steps Taken to Prevent, Detect and Report Modern Slavery and Human Trafficking Risks

In this financial period we have:

  • Continued to roll out company wide mandatory modern slavery and trafficking training.
  • Issued company-wide policies and procedures as to acceptable business practices and ethical conduct;
  • Reviewed our supply chain to identify and mitigate risks of modern slavery and human trafficking;
  • Invested heavily in enhancing our approach to content moderation including hiring additional specialist resources;
  • Appointed an independent monitor to review our safety controls and compliance program to continue to enhance the safety of our platform; and Increased our engagement with third-parties that seek to combat modern slavery and human trafficking.

    Our Policies

    BBWPlayHouse is committed to taking all reasonable and appropriate steps to ensure that there are no modern slavery or human trafficking activities taking place on our platform, in our business, or in our supply chain.

  • We have a Code of Conduct & Business Ethics in place which sets out our expectation that all employees act with integrity and to exercise good judgment and common sense in their efforts to comply with all applicable laws, rules, and regulations, including in relation to modern slavery and human trafficking. This Code is also shared with key suppliers and contractors.
  • This Anti-Slavery and Anti-Trafficking Statement sets out our overarching commitment to combating modern slavery and human trafficking. The Statement also describes the concrete actions the Company takes to mitigate the risk of modern slavery and human trafficking and provides reporting channels for suspected instances of modern slavery or human trafficking.
  • Our Terms of Service and Acceptable Use Policy specifically prohibit the uploading, posting, displaying, or publishing of content on BBWPlayHouse that: shows, includes or refers to any other individual unless written consent is obtained from each individual to use their name or images (or both) in the Content; or shows, promotes, advertises or refers to escort services, sex trafficking, or prostitution.
  • We also strive to hold our employees and suppliers to high standards. Any violation of our standards by an employee can result in disciplinary action, including termination of employment. Any violation by a supplier can result in contract termination.

    Our Risk Assessment

  • We continually assess modern slavery and human trafficking risks in our business environment through identifying and analyzing higher-risk areas of our business. Our assessment is based on external reports and standards, and country and sector risk profiles, and we adjust our processes and controls, as appropriate, based on changing risks.
  • Our Direct Business Operations We consider the risks of modern slavery and human trafficking to be relatively low in our direct business operations as our direct workforce is largely comprised of professionally qualified or skilled personnel. We recognise that in areas where we employ contractors outside the United Kingdom and United States of America, there is a slightly higher risk of modern slavery and human trafficking. We ensure that our entire workforce is aware of these risks and our views toward these issues, and that they can report any instances of suspected modern slavery or human trafficking.
  • Our Platform and Supply Chain Creator Content. As with all social media platforms, there are risks related to creators’ content, including the risk of material being uploaded that is exploitative and in breach of various laws and our policies.

    Contractors and Third Parties. We use contractors and temporary staff for our platform services, and third-party suppliers to assist with, among other tasks, user verification and content moderation processes. These contractors and third parties may violate relevant laws or our policies.

  • Merchandise. We procure promotional merchandise, which is provided to creators and fans for marketing purposes and is available for sale on the BBWPlayHouse store. These items may be manufactured by a workforce that is at more risk of exploitation. We understand the garment manufacturing industry has the potential for modern slavery and human trafficking, including in such areas as freely chosen employment, young workers, working hours, wages and benefits, humane treatment, non-discrimination/non-harassment, and freedom of association.

    Our Risk Mitigation Efforts

  • We have continued to work to mitigate risks identified in our previous modern slavery and human trafficking statements and we are committed to report on key points of action that we intend to take going forward.
  • Creator Verification. We carefully check all identity and payment details for each creator account application to ensure that individuals can only make an account on their own behalf. We specifically check for any discrepancies between identity documents and the legal name provided on payment methods, and employ technological safeguards to prevent creator payment details from being changed by the user. This is to ensure the creator is receiving payments directly from BBWPlayHouse. In certain high-risk jurisdictions or where an account has been flagged for additional security after our initial verification process has been completed, we require an additional "selfie" identification process to log into a creator account at specific intervals (which can include every log in).
  • Content Moderation. In order to prevent and detect harm, we monitor all media uploaded to the platform and remove, and report where necessary, any content that facilitates or coordinates the exploitation of people, including modern slavery and human trafficking. We have continued to enhance the depth and sophistication of our content moderation to ensure compliance with our Terms of Service and Acceptable Use Policy. All our content moderators are trained to identify and swiftly report any suspected modern slavery including trafficking. Before content can appear on a newsfeed, we inspect it with state-of-the-art digital technologies to check whether the content is allowed on the platform. All content which attempted to be uploaded to BBWPlayHouse is compared against databases and tools used by law enforcement to prevent modern slavery and human trafficking. All content that passes this initial review is then manually reviewed by our trained human moderators within 24 hours. Our trained moderators identify, and immediately escalate, any content which they suspect may be an indicator of modern slavery or human trafficking. We can review and remove any image or video shared on BBWPlayHouse at any time, including in all direct messages. BBWPlayHouse does not use end-to-end encryption and everything on the site is visible to our team of trained reviewers. There are no “hidden” posts, “secret” areas, or disappearing messages on BBWPlayHouse.
  • Contractor or Agency Staff. We regularly include a contractual obligation for agencies and temporary staff to comply with various laws and our policies to combat modern slavery and human trafficking. We have also implemented company wide training on modern slavery and human trafficking for all employees. The training is required annually and provided via an online training provider.
  • Merchandise. When entering into commercial agreements with manufacturers we consider the relevant provisions of our Code of Conduct & Business Ethics, Terms of Service, Acceptable Use Policy and this Anti-Slavery & Anti-Trafficking Statement to ensure these agreements align with our policies against modern slavery and human trafficking.
  • Community Reporting. We continued to expand our support functions to deal with any concerns or complaints from our users and from the wider community. Each post and account on BBWPlayHouse has a report button. Any reports escalated from our platform are reviewed internally by our moderators. In addition, we encourage anyone encountering content on BBWPlayHouse that indicates someone is in immediate physical danger relating to human trafficking to immediately report the content to us at compliance@WildGirlsProductions.com.

    Assist Law Enforcement. If BBWPlayHouse identifies content which contains indicators of modern slavery or human trafficking, we immediately suspend the associated account and pass this information to law enforcement and non-governmental organizations to help identify the perpetrators.

  • Investments and Partnerships. We also continue to invest in our ability to detect content related to human exploitation through major investments by our technical and operational teams. We are increasing our investments and ability to identify the illicit actors, networks, organizations, and businesses that perpetrate these activities and disrupt them accordingly. We look to enact counter measures - both on our platforms and via our external partnerships to stop actors and businesses from using our services to commit crimes, and in all stages of the exploitation lifecycle. We work with a range NGOs, helplines and charities in order to support our strict policies on safeguarding our creators, fans and workforce, including working with, and participating in the reporting systems of, the National Center for Missing & Exploited Children (NCMEC) and other well-known NGOs.
  • Transparency & Reporting. BBWPlayHouse is committed to building the safest social media platform in the world. We take responsibility for our actions, and we regularly publish data which verifies the steps we say we are taking. This data is found in our Transparency Reports which you can find here. We have also put in place an independent third party monitor to audit our safety controls and compliance program compliance@WildGirlsProductions.com.

    Our Reporting Mechanisms

  • We foster a culture of transparency, honesty and accountability, which encourages our employees to report any concerns or wrongdoings, including human rights violations, modern slavery and human trafficking.
  • If you have any concerns or suspect a violation of any law by the Company, whether by its employees, contractors, agency staff or any third party doing business on the Company’s behalf, please report the matter by email to compliance@WildGirlsProductions.com.
  • If a concern is raised regarding a supplier or contractor, we will coordinate with appropriate stakeholders to investigate and address the issue. If a reported concern is substantiated, corrective action will be taken, up to and including termination.

    Our Ongoing Commitment to Continuous Improvement

  • Modern slavery and human trafficking are complex challenge s for all businesses. BBWPlayHouse efforts to combat these practices are ongoing, evolving, and continually improving. Our approach to modern slavery and human trafficking will continue to be communicated throughout our business and to any suppliers, both at the outset and periodically throughout the business relationship.
  • We are committed to maintaining and improving our practices to combat modern slavery and human trafficking. We will continue to consider and take the following actions which are appropriate and proportionate to the risk profile for WildGirlsProductions and BBWPlayHouse :

    Identify and assess any further risk areas within our business or supply chain.

  • Mitigate the risk of modern slavery and human trafficking occurring in our business or supply chain.
  • Protect whistleblowers and take appropriate remedial action as needed.
  • Stay up to date with any recognised changes to the UK Modern Slavery Act, Australian Modern Slavery Act and any other laws we noted above or related legislation.
  • Monitor potential risk areas and possible solutions to ensure employees, users and any third parties are safe from the risk of modern slavery and human trafficking.

    Responsibility for this Statement

  • Our Executive Leadership have overall responsibility for ensuring that all those under our control comply with this statement and our related policies.
  • Management at all levels are responsible for ensuring their teams understand this statement and comply with our anti- slavery and anti-trafficking policies and procedures. Our Legal team have primary and day-to- day responsibility for overseeing the principles in this statement, addressing any queries about the statement, and considering internal control systems and procedures to ensure they are effective in countering modern slavery and human trafficking.

    This statement has been approved by the Board of WildGirlsProductions Limited

    Signed by

    lenard blanks