Anti-Slavery & Human Trafficking Statement

1. Our Commitment

OpenFans is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chain. This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and the California Transparency in Supply Chains Act of 2010 (SB 657).

We recognize that modern slavery is a serious crime and a grave violation of fundamental human rights. It takes various forms, including servitude, forced and compulsory labor, and human trafficking, all of which involve the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

OpenFans has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our business or in any part of our supply chain.

2. Our Business & Supply Chain

OpenFans operates a digital platform that enables content creators to monetize their work through paid subscriptions and direct support from fans. Our supply chain primarily consists of:

• Technology infrastructure providers (cloud hosting, databases, blockchain services)
• Payment processing services and blockchain networks
• Identity verification and compliance service providers
• Professional service providers (legal, accounting, consulting)
• Content creators who use our Platform as independent contractors

3. Due Diligence Processes

OpenFans has implemented the following due diligence processes to identify and mitigate the risk of modern slavery and human trafficking:

• Creator Verification: All Creators must complete mandatory identity verification, including government-issued ID verification and live selfie matching, before they can publish content. This helps ensure that all individuals producing content on the Platform are doing so voluntarily and are of legal age.
• Content Moderation: We employ a combination of automated detection tools and human review to monitor content uploaded to the Platform. Our moderation team is trained to identify indicators of coercion, exploitation, or trafficking.
• Supplier Assessment: We evaluate our technology and service providers for their own anti-slavery and human rights commitments, giving preference to partners with robust compliance programs.
• Risk Assessment: We conduct periodic risk assessments of our business operations and supply chain to identify areas where modern slavery risks may be elevated.

4. Reporting Mechanisms

OpenFans provides multiple channels for reporting suspected modern slavery, human trafficking, or exploitation:

• In-Platform Reporting: Users can report suspicious content or activity directly through the Platform's reporting tools available on every content page and user profile.
• Email: Reports can be submitted to complaints@openfans.online at any time.
• Anonymous Reporting: We accept anonymous reports and will investigate all credible allegations regardless of the source.

All reports are treated confidentially and are investigated promptly by our compliance team. Where appropriate, findings are referred to law enforcement authorities without delay.

5. Training & Awareness

OpenFans ensures that all employees and contractors involved in content moderation, creator onboarding, customer support, and compliance functions receive regular training on:

• Recognizing the signs and indicators of modern slavery and human trafficking
• Understanding the legal and regulatory framework surrounding modern slavery
• Proper procedures for reporting and escalating suspected cases
• Trauma-informed approaches when interacting with potential victims
• Platform-specific risks and red flags in the creator economy context

Training is provided during onboarding and refreshed at least annually. Additional training is provided when new risks or trends are identified.

6. Zero-Tolerance Policy

OpenFans maintains a strict zero-tolerance policy toward modern slavery and human trafficking. Any Creator, user, employee, or contractor found to be involved in or facilitating modern slavery or human trafficking will be subject to:

• Immediate suspension and permanent termination of their account or employment
• Removal of all associated content from the Platform
• Referral to the relevant law enforcement and regulatory authorities
• Full cooperation with any subsequent criminal investigation
• Termination of any contractual relationship without notice or compensation

7. Annual Review

This statement and the effectiveness of the measures described herein are reviewed and updated at least annually by the OpenFans leadership team. We are committed to continuous improvement of our practices to combat modern slavery and human trafficking.

As part of our annual review, we assess the effectiveness of our due diligence processes, evaluate new risks, incorporate lessons learned from any reports or investigations, and update our training programs accordingly.

8. Contact

If you have any questions about this statement or wish to report a concern, please contact us at complaints@openfans.online or legal@openfans.online.