Anti-trafficking statement

Last Updated: September 3, 2024

Eros Therapy (“we”, “us”, “our”) operates as a leading subscription-based social platform that fosters inclusive, safe environments for creators and fans. We are firmly committed to preventing modern slavery and human trafficking, ensuring that these unethical practices have no place within our platform, partnerships, or supply chains. Our commitment to combat modern slavery aligns with global standards, including the UK Modern Slavery Act, Australia Modern Slavery Act, and the California Transparency in Supply Chains Act.

Our Commitment to Eradicating Modern SlaveryModern slavery encompasses various forms of exploitation such as forced labor, servitude, human trafficking, and all forms of coerced work that deprive individuals of their freedom for the personal or commercial gain of others. These practices are clear violations of human rights and have no place in our business or supply chains. We are dedicated to acting with integrity in all our business dealings, whether it is with employees, creators, fans, partners, or vendors. Our focus is on ensuring that all individuals associated with our platform are treated fairly, with dignity, and without the risk of exploitation. We aim to uphold the highest standards in terms of ethical operations, working conditions, and environmental responsibility.

Our Efforts and AchievementsThroughout the past year, we have taken significant steps to prevent, detect, and address the risks of modern slavery and human trafficking across our business. Some of the major actions we have undertaken include: Training and Awareness: We implemented mandatory training on modern slavery for all our employees. This training covers how to identify signs of exploitation and provides guidance on reporting mechanisms for suspected instances of trafficking or forced labor. We continuously update this training material to align with the latest global standards and ensure that employees remain vigilant against potential risks. Policies and Ethical Practices: We issued company-wide policies detailing acceptable business practices and ethical conduct to help prevent modern slavery within our operations and supply chains. These policies are shared with employees, contractors, and key partners to ensure that all parties understand and adhere to the same ethical principles. Supply Chain Review: We conducted a thorough review of our supply chains to assess and mitigate any risks related to forced labor or trafficking. As part of this process, we examined the sectors and geographical regions most susceptible to these issues and adjusted our risk management strategies accordingly. Content Moderation and Safety Enhancements: We significantly increased investments in content moderation, hiring additional specialist resources to bolster our efforts in identifying and removing harmful content. Our commitment to creating the safest possible platform for users led to the appointment of an independent monitor to review and improve our safety controls and compliance program. Partnerships to Combat Modern Slavery: We expanded our engagement with third-party organizations, including NGOs and law enforcement agencies, that focus on combating human trafficking and modern slavery. Through these partnerships, we have enhanced our ability to detect and disrupt exploitation on our platform.

Policies to Prevent Modern Slavery and Human TraffickingWe have a comprehensive set of policies designed to uphold our commitment to preventing modern slavery and trafficking. These policies serve as the foundation of our efforts and guide the conduct of employees, suppliers, contractors, and all other stakeholders. Code of Conduct & Business Ethics: Our Code of Conduct clearly outlines expectations for all employees and partners, emphasizing integrity, good judgment, and compliance with all applicable laws. The Code specifically prohibits any form of modern slavery or trafficking, and we ensure that all employees and suppliers are familiar with these guidelines. Anti-Slavery and Anti-Trafficking Statement: This statement underscores our overall commitment to fighting modern slavery, detailing the steps we take to mitigate risks across our operations. We also provide clear reporting channels for any suspected instances of exploitation or trafficking, encouraging transparency and accountability. Terms of Service and Acceptable Use Policy: These policies explicitly prohibit content that refers to or promotes escort services, sex trafficking, or prostitution. Creators are required to obtain consent from any individual featured in their content, ensuring that no one is exploited or featured without their knowledge and agreement. Supplier and Contractor Agreements: We hold suppliers and contractors to the same high standards as our direct employees. Contracts with suppliers include clauses related to ethical conduct and anti-slavery provisions, ensuring that all third-party partners adhere to relevant laws and our internal policies. Any violation of these standards may result in the termination of the business relationship.

Risk Assessment and ManagementWe continually assess the risks of modern slavery and human trafficking across various areas of our business, focusing on identifying and addressing vulnerabilities in high-risk sectors. Our assessments consider a variety of factors, including external reports, industry standards, and the risk profiles of specific countries or regions. We use these insights to guide our risk mitigation efforts, adjusting our processes and controls as needed to address emerging risks.

Direct Business OperationsThe risk of modern slavery in our direct business operations is relatively low, given that most of our workforce consists of highly skilled professionals working in technical, administrative, and creative roles. However, we remain vigilant in regions where we employ contractors or temporary staff, particularly outside of the UK and the US, as these areas may present a higher risk. We ensure that all staff, regardless of their role or location, are aware of our policies and the mechanisms in place to report any concerns related to modern slavery or trafficking.

Platform and Supply Chain RisksAs a social media platform, we face unique risks related to user-generated content. There is always the potential for exploitative material to be uploaded, which is why we have implemented a robust content moderation system. This system combines advanced digital tools with human reviewers to monitor and remove any content that violates our policies or national laws. In addition to risks related to content, our supply chain also presents areas of concern, particularly in relation to the procurement of promotional merchandise. We recognize that the garment manufacturing industry, in particular, has a higher risk of modern slavery, and we have implemented measures to ensure that our suppliers meet high ethical standards. These measures include reviewing labor practices, ensuring the use of fair wages, and monitoring working conditions.

Mitigating Risks Through Verification and ModerationWe have developed several key processes to mitigate the risks of modern slavery and human trafficking within our platform and supply chain: Creator Verification: We conduct thorough identity and payment verification for all creators to ensure that accounts are only created by individuals acting on their own behalf. This includes cross-referencing identity documents with payment information to detect discrepancies. In certain high-risk areas, we require creators to verify their identity through an additional “selfie” process at regular intervals. Content Moderation: We use a combination of automated digital technologies and manual reviews to monitor all content uploaded to the platform. Our trained content moderators are skilled at identifying potential signs of exploitation and trafficking, and they escalate any suspicious content for further investigation. Content flagged for suspected modern slavery is promptly removed, and we collaborate with law enforcement as necessary. Contractor and Temporary Staff Management: We include specific clauses in our agreements with contractors and temporary staff, requiring them to comply with our policies against modern slavery. We also provide modern slavery training for all employees and contractors, ensuring that everyone involved in our platform understands their responsibilities. Merchandise Supply Chain: We carefully review all suppliers involved in the production of our promotional merchandise, ensuring that they comply with our ethical standards. We prioritize transparency and accountability in our supply chain, conducting regular audits to assess labor practices and ensure that workers are not at risk of exploitation.

Reporting and Response MechanismsWe encourage anyone who encounters suspicious content or behavior related to modern slavery to report their concerns through our platform’s reporting channels. Each post and account on our platform has a dedicated “report” button, allowing users to easily flag content for review. Reports are reviewed by our team of moderators, who take immediate action when necessary. In addition to internal reporting mechanisms, we also encourage users to contact us directly via email at support@erostherapy.org, especially in cases where immediate action is needed. We take all reports seriously and are committed to addressing any concerns related to modern slavery or trafficking in a timely manner. When instances of modern slavery or trafficking are detected, we suspend the associated accounts and report the findings to law enforcement agencies. We work closely with these agencies and NGOs to assist in identifying perpetrators and supporting victims of exploitation.
Investment in Partnerships and Technology We continue to invest in technology and partnerships aimed at preventing modern slavery and human trafficking. This includes developing more sophisticated tools for detecting illicit content and expanding our network of partnerships with organizations focused on anti-trafficking efforts. By working with external experts, we aim to stay at the forefront of efforts to disrupt trafficking networks and prevent exploitation on our platform.
Transparency and Independent Monitoring Transparency is at the core of our approach to modern slavery prevention. We regularly publish transparency reports that outline the steps we’ve taken to combat modern slavery and trafficking. These reports include data on content moderation efforts, user reports, and any actions taken in response to suspected instances of trafficking. To further ensure accountability, we have appointed an independent third-party monitor to audit our safety controls and compliance programs. This monitor reviews our internal processes and provides recommendations for improving our anti-slavery efforts.

Ongoing Commitment to Improvement We recognize that the fight against modern slavery and human trafficking is an ongoing challenge that requires continuous improvement. Our commitment to combating these issues remains strong, and we are dedicated to refining our practices, enhancing our policies, and staying informed of emerging risks. Looking forward, we plan to: Continue identifying and assessing risk areas within our business and supply chain. Implement additional measures to mitigate these risks, as appropriate. Protect whistleblowers who report suspected violations of our policies or relevant laws. Remain informed about changes to anti-slavery legislation, including updates to the UK Modern Slavery Act and related laws. The Anti-Slavery and Anti-Trafficking Statement for 2022 outlines the company’s dedication to preventing modern slavery and human trafficking across its operations and supply chain. It emphasizes a zero-tolerance approach towards these practices, implementing rigorous policies, creator verification processes, content moderation, and partnerships with NGOs and law enforcement. Training is mandatory for employees to detect risks, while suppliers are also held to strict ethical standards. Reporting mechanisms are in place, and independent audits ensure transparency and continuous improvement in anti-slavery efforts.

Contact UsIf you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at: Email: support@erostherapy.org