Anti-Slavery & Anti-Trafficking Policy

1. Introduction & Commitment

Velvet ("Velvet," "we," "us," or "our"), operator of the platform accessible at velvet.fans, is firmly committed to combating modern slavery, human trafficking, forced labor, and all forms of exploitation. This policy applies to all users of the Platform (including Creators, Fans, Agencies, and Chatters) as well as to our own employees, contractors, and business partners.

Velvet provides a content monetization platform where adult creators may sell exclusive digital content. We recognize that platforms operating in this space bear a heightened responsibility to prevent exploitation. We take this responsibility seriously.

2. Legal Framework

This policy is informed by and aligns with:

• UK Modern Slavery Act 2015: transparency in supply chains
• EU Anti-Trafficking Directive (2011/36/EU): prevention, prosecution, and victim protection
• French Penal Code, Articles 225-4-1 to 225-4-9: trafficking in human beings
• US Trafficking Victims Protection Act (TVPA): combating trafficking and protecting victims
• ILO Forced Labour Convention (No. 29) and Protocol of 2014
• UN Guiding Principles on Business and Human Rights
• EU Digital Services Act (DSA): obligations regarding illegal content

3. Definitions

For the purposes of this policy:

• Modern slavery encompasses slavery, servitude, forced or compulsory labor, and human trafficking.
• Human trafficking is the recruitment, transportation, transfer, harboring, or receipt of persons by means of threat, force, coercion, fraud, deception, abuse of power, or exploitation of a position of vulnerability, for the purpose of exploitation.
• Forced labor is all work or service exacted under the menace of any penalty and for which the person has not offered themselves voluntarily.
• Sexual exploitation includes forcing, coercing, or deceiving an individual into creating, distributing, or appearing in sexual content without their free, informed, and ongoing consent.
• CSAM(Child Sexual Abuse Material) refers to any content that depicts or appears to depict a minor in a sexual context.

4. Zero-Tolerance Policy

Velvet maintains an absolute zero-tolerance policy toward:

• Content depicting, promoting, or facilitating human trafficking or modern slavery
• Content produced through forced labor, coercion, or exploitation of any kind
• Child Sexual Abuse Material (CSAM): any sexual content involving minors
• Non-consensual intimate imagery (NCII), including revenge pornography
• Content that promotes or facilitates prostitution or sex trafficking
• Deepfake pornography or AI-generated intimate imagery of real persons without consent
• Content depicting sexual violence, except where clearly fictional, consensual, and legally compliant
• Any use of the Platform to recruit, advertise, or organize trafficking of persons

Violation of this policy will result inimmediate account termination, forfeiture of all pending earnings, preservation of evidence, and referral to law enforcement authorities.

5. Age Verification & Identity Requirements

5.1 Minimum Age

All users must be at least eighteen (18) years of age and have reached the age of majority in their jurisdiction. No exceptions.

5.2 Creator Verification

All Creators must:

• Provide a valid government-issued photo identification document confirming their age and identity
• Verify their identity through our onboarding process, which may include cross-referencing social media profiles (e.g., Instagram verification)
• Provide accurate and up-to-date personal information, including their legal name and banking details for payouts

5.3 Third-Party Depicted Persons

If any content depicts identifiable persons other than the uploading Creator:

• The Creator must obtain and retain written consent from every depicted individual
• Each depicted individual must provide proof of age (18+)
• Consent records must be produced to Velvet upon request within 48 hours
• Failure to produce records will result in immediate content removal and potential account suspension

6. Content Moderation & Detection

6.1 Proactive Measures

Velvet employs the following measures to detect and prevent exploitation:

• Automated scanning of uploaded content using industry-standard hash-matching technology (e.g., PhotoDNA, CSAI Match) to detect known CSAM
• Metadata analysis and behavioral pattern detection to identify suspicious account activity
• Monitoring for indicators of trafficking, including accounts managed by third parties without consent, unusual geographic patterns, or signs of coercion in communications
• Regular audits of high-risk content categories

6.2 Indicators of Exploitation

Our team is trained to recognize indicators of exploitation, including but not limited to:

• Multiple creator accounts controlled from a single device or IP address without agency designation
• Creators who appear to be under duress in their content or communications
• Evidence that a third party is controlling a creator's account, communications, or earnings without proper agency authorization
• Content that appears to depict individuals who are underage, intoxicated, or unable to consent
• Patterns of financial control, such as earnings being directed to a third party not identified as an authorized agency
• Rapid creation of multiple creator profiles with similar content from the same location

6.3 Reporting Mechanisms

We provide multiple channels for reporting suspected exploitation:

• In-platform reporting: Every piece of content and every user profile includes a report function
• Email: contact@velvet.fans
• Email: support@velvet.fans

All reports are treated as confidential. We do not disclose the identity of reporters to the reported party. Reports involving minors or trafficking are escalated immediately.

7. Agency & Chatter Accountability

7.1 Agency Obligations

Agencies managing creator profiles on Velvet must:

• Verify the identity and age of every creator they manage
• Ensure that every managed creator participates voluntarily and retains the right to withdraw from the platform at any time
• Maintain transparent and fair revenue-sharing agreements with creators
• Never restrict a creator's access to their own account settings, earnings information, or withdrawal capabilities
• Report any suspicion of exploitation to Velvet immediately

7.2 Chatter Obligations

Chatters (team members authorized to manage conversations on behalf of creators) must:

• Never impersonate a creator in a manner that could deceive fans into believing they are communicating directly with the creator when they are not
• Never facilitate, promote, or engage in any conversation that solicits illegal services or exploitation
• Report any communication from fans or creators that indicates exploitation, trafficking, or abuse of minors

8. Cooperation with Law Enforcement

Velvet will cooperate fully with law enforcement agencies investigating modern slavery, trafficking, child exploitation, or related crimes. This includes:

• Preserving relevant account data, content, and communications upon receipt of a valid legal request
• Voluntarily reporting suspected CSAM to the National Center for Missing & Exploited Children (NCMEC) and the relevant national authority (e.g., PHAROS in France)
• Proactively referring credible reports of trafficking to the appropriate authorities
• Providing data and evidence in response to lawful requests, warrants, or court orders

9. Victim Support

If you are a victim of trafficking, forced labor, or exploitation, or if you suspect that someone on this platform is being exploited, please contact:

• Velvet Safety Team: contact@velvet.fans
• France: 0 800 05 95 95 (National helpline against trafficking, free & anonymous)
• UK: Modern Slavery Helpline: 08000 121 700
• US: National Human Trafficking Hotline: 1-888-373-7888
• EU: Anti-Trafficking Coordination:ec.europa.eu/anti-trafficking
• International: IOM Counter-Trafficking:iom.int/counter-trafficking

Velvet will never penalize a user who, in good faith, reports suspected exploitation, even if the report does not result in a confirmed violation.

10. Internal Governance

10.1 Training

All Velvet employees and contractors involved in content moderation, trust & safety, customer support, or creator onboarding receive mandatory training on:

• Recognizing indicators of modern slavery and trafficking
• Handling reports of exploitation with appropriate urgency and sensitivity
• Applicable legal obligations, including mandatory reporting requirements

10.2 Due Diligence

We conduct due diligence on our business partners, payment processors, and service partners to ensure they share our commitment to ethical practices and compliance with anti-slavery legislation.

10.3 Policy Review

This policy is reviewed and updated at least annually, or more frequently as required by changes in legislation, industry best practices, or our operational scope.

11. Prohibited Content: Adult Content Guidelines

While Velvet allows adult content from verified, consenting creators aged 18+, the following is strictly prohibited:

• Any sexual or suggestive content involving minors (real or fictional depictions)
• Non-consensual sexual acts, real or staged without clear indication of consent
• Content depicting or glorifying sexual violence, rape, or assault
• Bestiality or zoophilia
• Necrophilia
• Content promoting incest
• Escort services, prostitution, or solicitation of sexual services for payment outside the Platform
• "Meet-up" content or any content facilitating in-person sexual encounters
• Content that fetishizes or sexualizes race, ethnicity, disability, or other protected characteristics in a dehumanizing manner
• Deepfake or AI-generated pornographic content depicting real persons without their explicit consent

12. Enforcement & Consequences

Violations of this policy may result in any or all of the following:

1. Immediate content removal
2. Temporary account suspension pending investigation
3. Permanent account termination
4. Forfeiture of pending earnings: funds may be held pending investigation
5. Reporting to law enforcement, including providing all relevant account data
6. Civil and criminal liability: users may be held personally liable for violations

Velvet reserves the right to take enforcement action at its sole discretion and without prior notice when there is reasonable suspicion of exploitation, trafficking, or abuse.

13. Contact

For questions about this policy, or to report a concern:

• Email: contact@velvet.fans
• Email: support@velvet.fans
• DMCA & content removal: /dmca

Velvet
13 Place Jean Jaurès
59292 Saint-Hilaire-lez-Cambrai, France
SIREN: 898 251 384