Anti-slavery and anti-trafficking statement

Introduction

Fluffy Stone Media Gmbh is the owner and operator of the website SoulCams (www.soulcams.com) ("SoulCams" or the "Company"). The platform is open to webcam models as well as content creators from all genres, empowering them to fully realize their potential in alignment with the Company's values and objectives.

SoulCams is dedicated to combatting modern slavery. We are unwavering in our commitment to create the world's safest digital media platform, and we categorically reject any form of modern slavery or human trafficking, whether on our platform, within our partnerships, or within our supply chain.

Our Commitment

We take a strong stance against all manifestations of modern slavery and human trafficking. These practices represent both crimes and gross violations of fundamental human rights. They manifest in various forms such as slavery, servitude, forced labor, and human trafficking, all of which involve the deprivation of a person's freedom for the purpose of exploitation, whether for personal or commercial gain.

We are committed to conducting our business with integrity and to mitigating the risk of modern slavery and human trafficking in our interactions with creators, fans, and all stakeholders. Our commitment also extends to treating all employees, partners, and suppliers with respect and dignity, ensuring safe working conditions, and conducting operations that are both environmentally responsible and ethically sound.

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

During this fiscal period, we have:

• Continued the implementation of company-wide mandatory training on modern slavery and trafficking.
• Issued comprehensive company-wide policies and procedures to guide acceptable business practices and ethical conduct.
• Conducted reviews of our supply chain to identify and mitigate risks associated with modern slavery and human trafficking.
• Made significant investments to enhance our content moderation approach, including the recruitment of additional specialized resources.
• Engaged an independent monitor to review and enhance our safety controls and compliance program, with the aim of fortifying the security of our platform.
• Strengthened our collaboration with third-party entities dedicated to combating modern slavery and human trafficking.

Our Policies

SoulCams is fully committed to taking all reasonable and appropriate measures to ensure that modern slavery and human trafficking have no presence on our platform, within our business operations, or throughout our supply chain.

Our Code of Conduct & Business Ethics is in place to set clear expectations for the integrity of all employees and to guide their decision-making. It emphasizes compliance with all relevant laws, rules, and regulations, including those pertaining to modern slavery and human trafficking. This Code is also shared with key suppliers and contractors.

This Anti-Slavery and Anti-Trafficking Statement underscores our overarching commitment to combat modern slavery and human trafficking. It delineates the concrete actions undertaken by the Company to mitigate the risks and provides channels for reporting suspected instances of these heinous practices.

Our Terms of Service and Acceptable Use Policy explicitly prohibit the upload, posting, display, or publication of content on SoulCams that includes, refers to, or promotes any individual without the appropriate written consent, or any content related to escort services, sex trafficking, or prostitution.

We also hold our employees and suppliers to high standards. Employee violations can result in disciplinary action, including termination, while supplier violations can lead to contract termination.

Risk Assessment

We continually assess the risks of modern slavery and human trafficking in our business environment by identifying and analyzing high-risk areas. Our assessment is informed by external reports, standards, country profiles, and sector risk assessments. We adjust our processes and controls accordingly in response to evolving risks.

Direct Business Operations

We perceive the risks of modern slavery and human trafficking to be relatively low in our direct business operations, as the majority of our workforce consists of qualified and skilled professionals. Nevertheless, we acknowledge that employing contractors beyond the United Kingdom and United States entails a slightly higher risk. We ensure that our entire workforce is educated about these risks and our stance on these issues, empowering them to report any suspected incidents.

Platform and Supply Chain

Creator Content: Like all social media platforms, SoulCams is exposed to risks related to creators' content. This includes the risk of exploitative material being uploaded in violation of laws and our policies.

Contractors and Third Parties: We engage contractors and temporary staff for platform services and enlist third-party suppliers for tasks such as user verification and content moderation. These entities may potentially violate applicable laws or our policies.

Merchandise: We procure promotional merchandise that is distributed to creators and fans for marketing purposes and is available for purchase on the SoulCams store. These items could be produced by a workforce vulnerable to exploitation. Given the potential for modern slavery and human trafficking in the garment manufacturing industry, we consider aspects such as employment conditions, worker age, working hours, wages, humane treatment, and freedom of association.

Mitigation Efforts

We continue to work diligently to mitigate the risks identified in previous statements related to modern slavery and human trafficking. Our commitment to improvement remains steadfast, and we intend to implement key actions in the future.

• Creator Verification: We diligently verify the identity and payment details of each creator account application to ensure that accounts are created only by the intended individuals. We specifically scrutinize identity documents and cross-reference them with the legal name associated with payment methods. Technological safeguards prevent unauthorized changes to creator payment details, guaranteeing that payments are made directly to creators.

• Content Moderation: To prevent and detect harm, we closely monitor all media uploaded to the platform. We promptly remove and report content that facilitates or coordinates the exploitation of individuals, including modern slavery and human trafficking. We have continually enhanced the sophistication of our content moderation to align with our Terms of Service and Acceptable Use Policy. Our content moderators receive training to recognize and promptly report suspected instances of modern slavery and trafficking. Before content is displayed on users' newsfeeds, it undergoes evaluation using cutting-edge digital technologies to determine its compliance. Content is cross-referenced against law enforcement databases and tools to detect modern slavery and human trafficking indicators. Content passing this initial review is manually assessed by our trained human moderators within 24 hours. Any content hinting at modern slavery or human trafficking is immediately escalated. We retain the ability to review and remove images or videos shared on SoulCams, including in direct messages. Notably, our platform does not employ end-to-end encryption, making all content visible to our trained reviewers. There are no hidden or secret areas on SoulCams.

• Contractor and Agency Staff: We consistently stipulate contractual obligations for agencies and temporary staff to comply with laws and policies related to modern slavery and human trafficking. Additionally, we offer company-wide training on these topics, which is mandatory and provided via an online platform.

Merchandise: When entering into commercial agreements with manufacturers, we ensure alignment with our Code of Conduct & Business Ethics, Terms of Service, Acceptable Use Policy, and this Anti-Slavery & Anti-Trafficking Statement to uphold our anti-modern slavery and anti-human trafficking policies.

• 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 OnlyFans has a report button. Any reports escalated from our platform are reviewed internally by our moderators. In addition, we encourage anyone encountering content on OnlyFans that indicates someone is in immediate physical danger relating to human trafficking to immediately report the content to us at compliance@onlyfans.com.

   Assist Law Enforcement. If OnlyFans 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. OnlyFans 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.

   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@onlyfans.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. OnlyFans 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 Fenix International Limited and OnlyFans:
       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 Fenix International Limited

Signed by

Lee Taylor

Director and CFO of Fenix International Limited (operator of OnlyFans.com)