Anti Slavery Statement

Last updated: 13th Feb 2024

 

 

Anti-Slavery And Anti-Trafficking Statement

Owner and operator of the subscription-based social platform TheQueerly (www.thequeerly.com), which is changing connections between creators and fans, is NAUGHTY NETWORKS SRL . The website welcomes content creators from all genres and gives them the tools they need to realize their full potential in line with the company’s principles and objectives. TheQueerly campaigns against contemporary slavery. We’re dedicated to creating the safest digital media platform in the world, and we don’t accept modern slavery or human trafficking in any of its manifestations, whether it occurs on our platform, through our relationships, or in our supply chain. This declaration is made in accordance with the principles and objectives of our company and with the California Transparency in Supply Chains Act, the Modern Slavery Act of Australia, and the UK Modern Slavery Act. It outlines the measures TheQueerly has made to ensure that neither modern slavery nor human trafficking is occurring within our supplier chains, commercial partnerships, or internal processes.


 

We’re Committed

TheQueerly opposes human trafficking and modern slavery in all their forms. A crime and a violation of fundamental human rights, modern slavery. Slavery, servitude, forced labor, and human trafficking are some of the several names for it, but they all involve depriving someone of their freedom so that they might be used for another person’s benefit or for their own.
In our business dealings and interactions with our creators and fans, we are dedicated to upholding ethical standards and reducing the possibility of modern slavery and human trafficking. Steps taken to reduce the risk of modern slavery and human trafficking include providing safe working conditions, ensuring that all employees, partners, and vendors are treated with respect and dignity, and implementing ethical and ecologically responsible business practices.


 

We have

Continued to implement company-wide, required training on modern slavery and trafficking.
Published principles and guidelines for appropriate corporate conduct and ethical behavior across the entire organization;
Reviewed our supply chain to find and reduce risks of human trafficking and modern slavery;
Invested a lot of money into improving our approach to content moderation, which included recruiting more specialized staff;
Appointed an independent monitor to examine our safety measures and compliance procedures in order to keep our platform as safe as possible; and
Substantially up our cooperation with organizations fighting human trafficking and modern slavery.


 

Our Principles

TheQueerly is committed to making every effort to prevent modern slavery and human trafficking from occurring on our platform, in our company, or elsewhere in our supply chain.
We have a Code of Conduct & Business Ethics in place that outlines our expectations for all employees, including how they should act with regard to modern slavery and human trafficking. We also expect them to use good judgment and common sense in their efforts to comply with all applicable laws, rules, and regulations. Important contractors and suppliers are also informed of this Code.
This Anti-Slavery and Anti-Trafficking Statement outlines our broad commitment to preventing human trafficking and contemporary slavery. In addition, the Statement outlines the specific steps the Company takes to reduce the danger of modern slavery and human trafficking and offers reporting options for any suspected cases.
We work hard to uphold excellent standards for both our suppliers and workers. Any employee who violates our standards may face disciplinary action, including termination of employment. A supplier’s contract may be terminated for any infraction.


 

Our Risk Analysis

We identify and analyze our business’s higher-risk sectors in order to continuously examine the hazards of modern slavery and human trafficking. Based on shifting risks, we adapt our processes and controls as necessary. Our assessment is based on external reports and standards, as well as country and sector risk profiles.


 

Direct Business Operations we Conduct

We believe that the risks of modern slavery and human trafficking are minimal in our direct business activities because the majority of our direct workforce is made up of professionals. We acknowledge that there is a somewhat increased risk of modern slavery and human trafficking in regions where we hire contractors from countries other than the United Kingdom and the United States of America. We make sure that every member of our staff is aware of these hazards, our stance on these matters, and that they know how to report any suspected cases of modern slavery or human trafficking.
Creator Content on Our Platform and Supply Chain. Similar to other social media sites, there are hazards associated with user-generated content, such as the possibility that exploitative or otherwise illegal material will be uploaded.
Third parties and contractors. Our platform services are provided by independent contractors and temporary employees, and third-party vendors help with processes like user identification and content moderation, among other things. These subcontractors and other parties might transgress the law or our rules.
Merchandise. We source promotional goods that are sold on the TheQueerly shop and given to creators and fans for marketing purposes. These goods might be produced by a workforce that is more vulnerable to exploitation. We are aware that there is a chance for modern slavery and human trafficking in the clothing manufacturing sector, particularly in regards to areas like young workers, freely chosen employment, working conditions, wages and benefits, humane treatment, non-discrimination/non-harassment, and freedom of association.


 

Our Efforts to Reduce Risk

We have continued to take steps to reduce the dangers mentioned in our earlier comments on modern slavery and human trafficking, and we have vowed to report on the most important steps we plan to take moving forward.
Creator Authentication. We thoroughly verify each creator account application’s identification and financial information to make sure that people can only create accounts on their own behalf. We take care to look for any differences between identity documents and the legal name listed on payment methods, and we apply technological precautions to stop users from changing the creator payment information. This is to guarantee that TheQueerly is paying the creator directly. We demand an additional “selfie” identification step to log into a creator account at particular periods in high-risk regions or when an account has been marked for further security after our initial verification process has been finished (which can include every log in).
Content control. We keep an eye on every content posted to the platform in order to prevent and identify harm. We take down any materials that encourage or organize the exploitation of individuals, such as modern slavery and human trafficking, and report them when appropriate. To ensure adherence to our Terms of Service and Acceptable Use Policy, we have continued to deepen and expand our content moderation. All of our content moderators have received training in spotting and reporting any possible cases of modern slavery, including human trafficking. We use cutting-edge digital technology to examine information before it may appear on a newsfeed to determine whether it is permitted on the site. All uploaded content to TheQueerly is checked against databases and other resources used by law enforcement to thwart modern slavery and human trafficking. Within 24 hours, our skilled human moderators manually examine all content that passes this initial inspection. Any content that our skilled moderators feel may be a sign of contemporary slavery or human trafficking is instantly escalated. Any image or video shared on TheQueerly, including in all direct conversations, is subject to review and removal at any moment. TheQueerly does not use end-to-end encryption, and our team of qualified reviewers can see everything on the website. On TheQueerly, there are no “secret” regions, “hidden” entries, or communications that vanish.
Contractor or agency personnel. We typically include a clause in our contracts requiring temporary employees and agencies to abide by our anti-human trafficking and modern slavery policies. Additionally, all staff now receive company-wide training on human trafficking and modern slavery. Each year, this training must be completed, and it is delivered online.
Merchandise. To ensure that our commercial agreements with manufacturers are in line with our policies against modern slavery and human trafficking, we take into account the pertinent provisions of our Code of Conduct & Business Ethics, Terms of Service, Acceptable Use Policy, and this Anti-Slavery & Anti-Trafficking Statement.
Public reporting. We kept developing our customer service capabilities so that we could address any issues or grievances raised by both our users and the larger community. There is a report button next to each post and account on TheQueerly. Our moderators internally analyze any reports that have been escalated from our site. Additionally, we urge anyone who comes across TheQueerly content connected to human trafficking that suggests someone is in urgent physical risk to report the content to us right away at [email protected].
Support law enforcement TheQueerly promptly suspends the related account and notifies law enforcement and non-governmental groups of content that exhibits signs of modern slavery or human trafficking so they can help identify the culprits.
Investing and joint ventures. Through significant investments made by our technical and operational teams, we also keep enhancing our capacity to identify content related to human exploitation. We are stepping up our efforts to pinpoint the illegal individuals, groups, networks, and companies that carry out these crimes and destroy them as necessary. We want to implement countermeasures – both on our platforms and through our external relationships – to prevent individuals and organizations from utilizing our services to conduct crimes at all times during the lifecycle of exploitation. In order to support our stringent policies on protecting our creators, fans, and workforce, we collaborate with a variety of NGOs, helplines, and charities. This includes working with the National Center for Missing & Exploited Children (NCMEC) and other well-known NGOs, as well as taking part in their reporting systems.
Reporting & Transparency. TheQueerly is dedicated to creating the world’s safest social media platform. We accept accountability for our actions, and we frequently release information that attests to the actions we claim to be taking. You may discover this information in our Transparency Reports, which are available here. As part of our compliance program and safety controls audit, we have also hired a neutral third party monitor.


 

Our Reporting Procedures

Our staff are encouraged to report any issues or wrongdoings, including human rights violations, modern slavery, and human trafficking since we cultivate a culture of transparency, honesty, and responsibility.
Please report the situation by email to [email protected] if you have any worries or suspect that the Company, including any of its employees, contractors, agency personnel, or other third parties conducting business on the Company’s behalf, has broken any laws.
If a supplier or contractor is the subject of a complaint, we will work with the relevant parties to look into and resolve the situation. Corrective action, up to and including termination, will be implemented if a stated concern is confirmed.


 

Our Consistent Commitment to Improvement

For many enterprises, modern slavery and human trafficking present difficult challenges. TheQueerly’s attempts to stop these behaviors are ongoing, changing, and getting better all the time. Our company’s stance on modern slavery and human trafficking will continue to be explained to any suppliers at the beginning of the business relationship and on a regular basis thereafter.

We are dedicated to upholding and enhancing our procedures to stop human trafficking and modern slavery. The following initiatives, which are suitable and proportionate to NAUGHTY NETWORKS SRL and TheQueerly’s risk profile, will continue to be taken into consideration:

Find and evaluate any additional risk areas in our company or supply chain. Reduce the likelihood that modern slavery and human trafficking will take place in our company or supply chain. Whistleblowers must be protected, and any necessary corrective action must be taken. Keep abreast of any modifications to the Australian Modern Slavery Act, the UK Modern Slavery Act, or any other laws we mentioned above or comparable legislation. To guarantee that workers, users, and any other third parties are secure from the risk of modern slavery and human trafficking, keep an eye on potential risk areas and viable remedies.


 

Ownership of this Statement

The overall responsibility for ensuring that this statement and our related policies are followed by everyone under our control rests with our Executive Leadership. It is the responsibility of management at all levels to ensure that teams are aware of this statement and follow our anti-slavery and anti-trafficking policies and procedures. In order to ensure that internal control systems and procedures are effective in preventing modern slavery and human trafficking, our Legal team has the primary and ongoing responsibility for overseeing the principles in this statement, responding to any questions about it, and considering internal control systems and procedures.

The members of NAUGHTY NETWORKS SRL  have given their consent to this statement.