Introductionand Purpose

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.

This Policy is necessary due to the unfortunate fact that Modern Slavery is a vast, worldwide problem. The UK is estimated that:

·         10,000 – 122,000 people in the UK are in modern slavery

·         50 million people worldwide are in modern slavery (Unseen)

The consequences of Modern Slavery are often serious mental and physical health issues. For this reason, Elhuevo Worldwide Ltd. (the parent company of More Than Fanz) is morally and ethically committed to helping those affected by Modern Slavery and is committed to combatting such practices as a whole business approach.

Our Modern Slavery Policy demonstrates our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery, and human trafficking are not taking place anywhere in our organisation or on our platform.

In addition, Elhuevo Worldwide Ltd. is also committed to reporting to the appropriate authorities any individual, organisation or group we suspect of taking part in or organising modern slavery or human trafficking.

Who and what this policy applies to

This policy applies to all employees and, in part, also applies to our subcontractors, partners, suppliers, and creators.

Definitions

Modern slavery is defined as the recruitment, movement, harbouring or receiving of people using force, coercion, abuse of vulnerability, deception, or other means for exploitation. It includes holding a person in a position of slavery, servitude, forced or compulsory labour, or facilitating their travel to exploit them soon after.

Policy

The Law

Section 3 of the Modern Slavery Act 2015 defines a person as a victim of exploitation if one or more of the following apply to them:

• slavery, servitude and forced or compulsory labour
• sexual exploitation
• removal of organs
• securing services and such like by force, threats or deception
• securing services and such like from children and vulnerable persons

The Modern Slavery Act 2015 consolidated existing criminal offences and increased sentences for these offences from 14 years to maximum sentences of life imprisonment. The act also introduced a statutory defence for slavery or trafficking victims who are compelled (in the case of an adult) or forced (in the case of a child) to commit certain criminal offences.

How the law applies to our business

Quite simply, every business faces risks from modern slavery. However, Elhuevo worldwide is most at risk from:

1.        Procuring

Despite our procurement being very limited, we recognise that there is always a risk that modern slavery, human trafficking, or exploitation could occur within our supply chain or business relationships, and we remain committed to taking proactive steps to identify and mitigate such risks.

2.       Criminals using our platform

"In cases of sexual exploitation, adult services websites often unwittingly play a key role in expanding offenders' client bases." (National Crime Agency)

Therefore, minimising the opportunities for these criminals, identifying victims, and following up with a report to the respective authorities is a key focus.

Our Commitment

We are committed to:

• Operating a zero-tolerance approach to modern slavery and human trafficking.
• Ensuring that all individuals who use our platform to create and share content are participating of their own free will.
• Raising awareness within our team to spot potential signs of exploitation and take appropriate action.

Procurement

Our Expectations

Quite simply, we expect the same high standards from all Elhuevo Worldwide Ltd. suppliers and partners in that they both oppose the use of forced, compulsory or trafficked labour or anyone held in slavery or servitude and hold their own suppliers and partners to the same high standards.

Our zero-tolerance approach to modern slavery willbe communicated to all suppliers and partners at the outset of our business relationship and reinforced as appropriate after that.

Our Terms

Suppliers and partners must agree to abide by our terms as follows:

ü  Suppliers and partners must adhere to a zero-tolerance policy for modern slavery and comply with all local and international laws relating to anti-slavery and human trafficking, including the UK Modern Slavery Act 2015.

ü  Suppliers and partners must be transparent about their manufacturing processes, sourcing, and labour practices.

ü  Suppliers and partners must ensure that any sub-contractors they engage are also compliant with these terms and the principles of the Modern Slavery Act.

ü  Elhuevo Worldwide Ltd. reserves the right to audit suppliers and partners for compliance with the terms of the contract, including unannounced audits by independent third parties.

ü  Suppliers and partners must have in place effective mechanisms for their workers to report instances of modern slavery without fear of retaliation.

ü  In the case where modern slavery practices are identified, suppliers and partners must have a remediation plan that aligns with international best practices to address and rectify the issue.

In addition, all suppliers and partners will ensure that their workers are provided with working conditions that are safe, comfortable, fair, and legal in line with UK health and safety laws.

Due Diligence

Elhuevo Worldwide Ltd. is committed to maintaining responsible relationships with our suppliers and partners and will not knowingly engage with organisations or entities that use or condone modern slavery and/or poor labour practices.

Elhuevo Worldwide Ltd. will also seek to ensure that no slavery has been used in the procurement of the goods we use or supply to others. To do this, we will seek to procure all goods from reputable suppliers with a solid reputation and will require all major suppliers to provide evidence of legal compliance and supporting policies and procedures during a tendering/onboarding process.

Ongoing Monitoring

Elhuevo Worldwide Ltd. will undertake regular supplier and partner audits and will terminate, without delay, any contract or agreement with any supplier or partner who is suspected of promoting or aiding or has been convicted of or otherwise sanctioned for:

• Human Trafficking.
• Modern Slavery – including Child, Bonded and Forced Labour.
• Human Rights Violations.

Our Platform

Identifying and Preventing Risks

Given the nature of our platform, our primary focus is on preventing the exploitation of content creators/models. Steps we take include:

• Requiring robust age and identity verification for all creators/models through a trusted third-party verification service.
• Monitoring platform activity for signs of coercion, control, or exploitation.
• Providing creators with clear, accessible information about their rights and the voluntary nature of their work.
• Offering a confidential reporting mechanism for concerns related to exploitation or coercion. Where concerns are raised, we act promptly, sensitively, and in accordance with safeguarding best practice.

Staff Training and Awareness

All staff involved in creator relations, content moderation, and compliance are trained to:

• Recognise signs of modern slavery and human trafficking.
• Understand the procedures for escalating and responding to concerns.
• Uphold our zero-tolerance approach.

Reporting and Action

Any suspicions or reports of modern slavery or exploitation must be reported immediately to the Director, who will:

• Investigate concerns thoroughly and sensitively.
• Suspend any accounts under investigation, where appropriate.
• Report confirmed and/or suspected cases of modern slavery/trafficking to the relevant authorities.
• Cooperate fully with law enforcement agencies as required.

Continuous Improvement

We are committed to continually improving our practices to combat modern slavery. We will:

• Regularly review and update this policy.
• Assess the effectiveness of our procedures.
• Engage with industry initiatives to strengthen our approach to safeguarding and anti-slavery.

Monitoring and Reviewing

Elhuevo Worldwide is committed to ensuring our policies are effective and up-to-date.

The Director is responsible for this process and will review this policy at least once a year or more frequently if needed due to changes in laws, regulatory guidance, or best practice.

Appendix A: Spotting Modern Slaevry in Adult Entertainment

Live-Streamed Content

Potential warning signs include:

·         High frequency of content with little variation

·         Extreme control over creators' behaviour by third parties

·         Suspicious viewer-performer interactions

·         Manipulation through gifts or payments

·         Sexualised interactions with minors

·         Performers displaying distress, addiction, or fear

Spotting Trafficking Victims

A person may be a human trafficking victim if they show signs of limited personal autonomy, such as not wanting to commit to basic requests without consulting a handler.

Visual indicators might include tattoos used as branding or signs of physical abuse, like cuts, burns, and bruises.

Note that women and girls account for 99% of modern slavery victims in the commercial sex industry. (Unseen)

Spotting Child Sex Trafficking/Abuse

A sexual creator may be a child if they look younger than their listed age, especially if the filmmakers have made significant efforts to age the creator's appearance.

Such cases may appear on videos that mention the creator's youth with terms like "barely legal."

Reference: https://humantraffickingfront.org/trafficking-in-adult-entertainment/