Anti-Slavery and Anti-Trafficking Statement

Anti-Slavery and Anti-Trafficking Statement

ANTI-SLAVERY, ANTI-TRAFFICKING, AND EXPLOITATION PREVENTION POLICIES

SWAG maintains a robust framework to prevent any form of human exploitation on our platform. We have a zero-tolerance policy for slavery, human trafficking, coercion or any kind of forced participation in content creation. These policies apply to all platform participants – creators, members, and any third parties – and are enforced through strict onboarding checks, continuous monitoring, user reporting mechanisms, and collaboration with law enforcement. We recognize our responsibility to ensure that all content on SWAG is produced consensually by adults and that our platform is not used to facilitate or profit from human trafficking or exploitation in any way.

ZERO-TOLERANCE POLICY STATEMENT

SWAG unequivocally does not tolerate modern slavery, sex trafficking, or exploitation. We explicitly prohibit any content that features individuals who are forced, coerced, or unable to consent. Any account engaging in or promoting such activity will be immediately banned. This zero-tolerance stance is communicated clearly to all users and staff: SWAG does not accept or condone any form of modern slavery, whether forced, compulsory, or trafficked labor. All creators must certify during onboarding that their content involves only consenting adults and that no one is acting under coercion or duress.

Similarly, members are reminded that any attempt to exploit others or solicit illegal services on the platform will lead to expulsion and reporting to authorities. Our policy aligns with global ethical standards and laws – for example, U.S. law (FOSTA-SESTA) makes it illegal for online platforms to knowingly assist or facilitate sex trafficking, and SWAG goes beyond mere compliance by actively preventing and rooting out any such misconduct. In practical terms, “zero tolerance” means that when we discover evidence of trafficking or exploitation, we act immediately and decisively (as detailed below) – there are no warnings or second chances for offenders in this realm. We want to foster a safe environment where creators produce content of their own free will and members engage respectfully, free from any association with human rights abuses.

Prohibition on Third-Party Exploitation and Debt Bondage

• Vetting of Agents & Managers
We strictly prohibit individuals, agencies, or "talent managers" from managing Creator accounts unless they can prove legitimate business registration and provide verified authorization from the Creator.
• No Debt Bondage
We maintain a zero-tolerance policy for debt bondage. It is prohibited to use financial debts, recruitment fees, or other financial obligations to coerce a Creator into producing content or remaining on the platform.
• Direct Access
Regardless of agency representation, Creators must always retain direct access to their SWAG account settings and withdrawal options to ensure their financial autonomy.

CREATOR ONBOARDING & EXPLOITATION DETECTION MECHANISMS

• Enhanced Manual Review During Onboarding
SWAG’s creator verification process is augmented with specific checks aimed at detecting signs of coercion or trafficking from the very start. In addition to verifying age and identity, our compliance team is trained to look for red flags that might indicate a person is not participating of their own free will. During the ID verification selfie/video, reviewers observe the creator’s demeanor and environment. Indicators such as a person appearing extremely nervous, fearful, or as if they are being instructed by someone off-camera (e.g., eyes frequently darting aside for approval) will trigger additional scrutiny. We may ask the creator a few direct questions in a live video call (e.g., confirming they are joining voluntarily, and that they understand our policies) – reluctance or inability to answer could suggest coercion. We also compare the creator’s submitted information for inconsistencies: if, for example, the ID shows one name but the bank account for payouts is in a completely different name, that could indicate the creator is not in control of their finances, a possible sign of trafficking. Such inconsistencies would lead us to pause activation of the account and investigate further (potentially requesting proof of account ownership or the presence of a manager).
• Device and IP Monitoring
Our team also checks if the same device or IP address is associated with multiple creator sign-ups – a scenario possibly indicating one person (a trafficker) trying to register several victims. If that is detected, all related accounts are flagged for a deep review. In markets or communities with known higher risk of organized exploitation, we apply additional verification steps (such as requiring a second form of ID or a personal reference). All creators, as a condition of account approval, must digitally sign our Creator Code of Conduct, which includes statements affirming that: “I am creating content of my own free will, I am not being forced or defrauded into appearing, and no one else is controlling my account.” This affirmation is more than symbolic; it becomes a record that we can later use if any question of consent arises. In sum, our onboarding isn’t just about identity – it’s about ensuring each creator is a willing participant.
• Strict Investigation Standards
Any hint of possible trafficking or unwillingness results in the account being held back or rejected, pending thorough investigation. We would much rather err on the side of caution and require more proof from a legitimate creator than to inadvertently approve someone in a harmful situation.
• Ongoing Monitoring of Creator Content and Behavior
Verification at sign-up alone is not enough, so SWAG employs continuous monitoring mechanisms (both automated and human) to detect exploitation over time. Our platform analysis to scan videos, images, and text for potential signs of trafficking or abuse.
• Content Red Flags
For instance, the SWAG may flag content where a creator has visible injuries or bruises that could indicate abuse (which a moderator would then review closely). We require that all individuals who appear in any content be age-verified and documented as well – this doubles as an anti-trafficking measure because it prevents a situation where a trafficker could force an unverified person (possibly a minor or a victim) into a video. If any unverified person is detected in a creator’s content, that content is immediately taken down and the creator is contacted for an explanation (and blocked from posting further until resolved).
• Creator Support Resources
We also encourage creators to privately reach out to us if their situation changes – for example, if at any point they feel unsafe or coerced by someone (manager, partner, etc.), we provide a discreet channel for them to get help. To facilitate this, SWAG supplies resources on our Creator Help Center about organizations that assist trafficking victims and a one-click “Report a Safety Issue” button that goes directly to our safety team. In effect, SWAG deploys a multi-layer defense: initial vetting, continuous content scanning, community vigilance (user reports, see below), and periodic human audits.

REPORTING AND ENFORCEMENT ACTIONS

• Account Removal and Suspension Procedures
The moment SWAG has credible reason to believe an account (creator or member) is involved in trafficking, coercion, or any exploitation, we take immediate action prior to full investigation to ensure no further harm can occur via our platform. This typically means an instant suspension of the account – the account is locked so that no new content can be posted, and the user is logged out.
• Investigation Protocols
For a creator, their content will be hidden from public view pending investigation (to prevent continued distribution of potentially exploitative material). We preserve all data from the account (as it may become evidence) but freeze financial transactions – for instance, any pending payouts to the creator are put on hold. Our team then urgently reviews the case with top priority. If evidence confirms involvement in trafficking or forced content, the account is terminated (banned) and any related accounts (aliases, alternate accounts found) are also terminated. We remove all content that violates our policy (e.g., videos identified as non-consensual or exploitative are deleted) and, where appropriate, will notify users who may have viewed that content in the past that it was removed for a policy violation without exposing sensitive details. In cases where a creator might be a victim rather than a perpetrator (for example, if a creator reaches out to say they are being forced by someone), we will work with them to ensure their safety – that might include immediately disabling access to the suspected controller, and possibly transferring the account to the creator alone if that’s a safe option. However, if any user is confirmed to be actively engaged in trafficking others, we will ban them permanently and share information with law enforcement. There is no route to reinstatement for anyone found to be involved in exploitation. We document the entire process and outcome. These swift enforcement measures underscore that SWAG will not allow our platform to be used for such abuses – even one incident is too many, and we act decisively to shut it down.
• Rapid Response & Escalation to Authorities
SWAG has a rapid-response protocol for potential trafficking situations: as soon as an account is flagged with plausible evidence, we escalate it to a specialized internal task force trained in handling such incidents. In the U.S., we will promptly report credible trafficking cases to federal law enforcement agencies or the CyberTipline (for any minor exploitation) and provide them with the preserved data they need (user info, content, IP logs) under the allowances of law.
• Cooperation with Victim Support
We will also reach out to organizations like the National Human Trafficking Hotline to ensure the case is flagged to victim support networks. In the EU or UK, we similarly contact local police units or national trafficking hotlines. Our policy is to cooperate fully with investigations – complying with lawful requests for information (such as subpoenas) swiftly to aid in the rescue of victims and prosecution of offenders. We understand that under laws like the U.S. Trafficking Victims Protection Act, knowingly benefitting from a venture that engages in trafficking is a serious offense; thus, we act as soon as we suspect such activity, not waiting for absolute proof, thereby meeting the “knowingly assist” threshold head-on with action. Additionally, SWAG may proactively refer cases: if our monitoring discovers something egregious (e.g., content that appears to show someone in distress and we cannot immediately verify their wellbeing), we may initiate contact with authorities even before a formal report is made to us. We have a crisis management plan so that if a large-scale issue were ever discovered (say an organized group attempted to use the platform), we can mobilize resources quickly, including shutting down sections of the site if needed while the issue is addressed.
• Legal Compliance and Global Regulations
SWAG’s anti-trafficking efforts are designed to ensure compliance with all relevant laws, including U.S. laws like SESTA/FOSTA, which removed certain liability protections and require platforms to actively fight sex trafficking online , and international laws like the UK Modern Slavery Act and Australia’s Modern Slavery legislation, which mandate businesses to take action and be transparent about combating slavery. We align our policies with the intent of these laws. In the U.S., the Trafficking Victims Protection Act (TVPA) provides tools for law enforcement and victims to take action against facilitators of trafficking; SWAG’s strict monitoring and reporting are structured so that we never knowingly facilitate or turn a blind eye to trafficking, thereby upholding the principles of the TVPA. We also comply with Section 230 carve-outs (as modified by FOSTA/SESTA) – meaning if we are notified of any content or activity that might be trafficking, we treat it as a non-negotiable removal and report scenario. In Canada and EU nations, where laws against sexual exploitation and human trafficking are vigorously enforced, we similarly ensure our moderation practices meet the highest standard. Should SWAG operate in countries with additional requirements (for example, some jurisdictions require suspected trafficking to be reported within 24 hours), we will incorporate those timelines and protocols as needed. Our Terms of Service explicitly forbid use of the platform for any exploitative purposes, which contractually binds users under our rules in addition to the law.
• User-Generated Reporting Mechanisms
We believe our user community can be an important partner in identifying and stopping exploitation. To facilitate this, SWAG provides easy and anonymous reporting tools for anyone to flag suspected trafficking or exploitation. Every piece of content and each profile has a “Report” button. When selected, one of the categories a user can choose is “Possible coercion or trafficking”. We also have a dedicated email support@swag.live and an online form in our Help Center for more detailed reports – users can submit concerns even if they just have a suspicion (they don’t need proof). Reports of this nature are escalated above normal content flags: they are marked as urgent and reviewed by our Trust & Safety team 24/7. We allow anonymous reporting so that users need not fear retaliation or involvement; however, we encourage them to provide contact info if they are comfortable, so we can follow up if we need more details. When a report comes in, the team immediately investigates the account or content in question (similar to the processes described earlier) – if the report seems credible, we will suspend the account right away as a precaution. Users who report will receive a confirmation that we’ve received their report and a notice once the investigation is concluded (though for privacy and legal reasons we might not be able to share extensive details, we at least inform them if action was taken). Overall, we aim to empower everyone – from creators, to subscribers, to employees – to speak up if they see something concerning. SWAG ensures those reports are taken seriously and acted on without delay. By building a culture of vigilance where the community knows “if you suspect it, report it” and making reporting straightforward, we multiply the eyes and ears.

Non-Retaliation Guarantee for Victims

If a Creator is identified as a victim of trafficking or coercion:

• No Penalty
Their account will be closed securely without penalty, and their content will be permanently removed.
• Support, Not Blame
Victims will never be blamed, retaliated against, or treated as offenders by SWAG. We prioritize their safety and will provide referrals to appropriate support organizations.