ANTI-SLAVERY AND ANTI-TRAFFICKING STATEMENT

By using our website, you agree to this policy – please read it carefully.

ZVN Digital Limited operates the website JustFans – a subscription-based social platform that redefines the connection between creators and fans. JustFans is open to content creators from all fields and supports them in reaching their full potential – in line with our values and goals.

JustFans is actively committed to combating modern slavery. Our goal is to create the safest digital media platform in the world. We do not tolerate any form of modern slavery or human trafficking – neither on our platform nor in our partnerships or supply chains.

This statement is based on our corporate values as well as the requirements of the UK Modern Slavery Act, the Australia Modern Slavery Act, and the California Transparency in Supply Chains Act. It outlines the measures JustFans takes to ensure that modern slavery and human trafficking have no place in our company, our partnerships, or our supply chain.

1. Our Commitment

JustFans takes a clear stand against all forms of modern slavery and human trafficking. Modern slavery is a crime and a violation of fundamental human rights. It can take many forms – including slavery, forced labor, exploitation, and human trafficking. What they have in common is that a person's freedom is taken away in order to exploit them for private or commercial purposes.

We are committed to acting with integrity in all our business activities and in our interactions with creators and fans, and to actively preventing all forms of modern slavery. We are also dedicated to ensuring that all employees, partners, and service providers are treated with respect and dignity, work in safe conditions, and that all our actions are ethical and environmentally conscious.

2. Measures to Prevent, Detect, and Report Risks of Modern Slavery and Human Trafficking

In the current financial year, we have taken the following measures:

• We have continued to roll out the mandatory training on modern slavery and human trafficking company-wide
• We have published internal policies and codes of conduct that set clear standards for ethical behavior and responsible business practices.
• We have reviewed our supply chains to identify and minimize risks related to modern slavery and human trafficking.
• We have made significant investments in the further development of our content moderation – including hiring additional specialized professionals.
• We have commissioned an independent audit body to review and further improve our security measures and compliance program.
• We have strengthened our collaboration with organizations and third-party providers that are actively committed to combating modern slavery and human trafficking.

3. Our Commitment Against Modern Slavery and Human Trafficking

JustFans is committed to taking all reasonable and appropriate measures to ensure that neither on our platform, nor within our company or our supply chain, do modern slavery or human trafficking occur.

We have a Code of Conduct for Integrity and Business Ethics that obligates all employees to act in compliance with the law, responsibly, and with common sense – including with regard to modern slavery and human trafficking.

This code is also shared with key partners, suppliers, and service providers. This anti-slavery and anti-human trafficking statement reflects our fundamental commitment to combating modern slavery and outlines concrete measures we take to identify and reduce risks and provide reporting channels in cases of suspected violations.

Our Terms of Service and Acceptable Use Policy expressly prohibit uploading, posting, displaying, or publishing content on JustFans that:

• depicts or refers to other individuals without having their written consent to use their name or image (or both);
• depicts, promotes, or references escort services, human trafficking, or prostitution.

We also set high standards for our employees and suppliers. Violations by employees may result in disciplinary actions up to and including termination. Violations by suppliers may lead to the immediate termination of the business relationship.

4. Our Risk Assessment

We continuously assess the risks related to modern slavery and human trafficking in our business environment. In doing so, we identify and analyze areas of elevated risk within our company. Our assessment is based on external reports and standards, as well as country and industry risk profiles. Depending on the risk level, we adjust our internal processes and control mechanisms accordingly to identify and minimize potential threats at an early stage.

Our Direct Business Operations

We assess the risk of modern slavery and human trafficking within our direct business operations as relatively low, as our direct workforce primarily consists of qualified professionals. However, we acknowledge that there may be a slightly elevated risk when engaging contractors outside the United Kingdom and the United States. Therefore, we ensure that all employees and contractors are informed about these risks and our position on the matter. In addition, we make sure that everyone in the company has the opportunity to report suspected cases of modern slavery or human trafficking – confidentially and without fear of retaliation.

As with all social media platforms, there are risks on JustFans related to the content uploaded by creators. This includes the risk that exploitative material may be published that violates laws or our policies.

We work with freelancers, external staff, and third-party providers, for example for user verification and content moderation. There is a risk that individual contractors or providers may violate legal regulations or our standards

We produce promotional merchandise that is made available to creators and fans for marketing purposes – in some cases also sold through the JustFans shop. These products are often manufactured in the textile industry – a sector particularly vulnerable to modern slavery and exploitation

In doing so, we pay attention to risks related to:

• Voluntary employment relationships
• Age-appropriate employment
• Working hours, wages, and social benefits
• Humane and fair treatment
• Protection from discrimination and harassment
• Freedom of association

Our Measures to Minimize Risk

We carefully review all identity and payout information for each creator registration. This ensures that only the actual person can create a creator account.

In particular, we match identity documents with the legal name on the specified payment methods and use technical safeguards to prevent payout information from being altered independently. This ensures that creator payments are made directly and securely from JustFans to the authorized individual

In certain cases – e.g., in high-risk areas or in the event of suspicious activity after the initial verification – we additionally require selfie verification at login. This may be required at regular intervals or at every login to ensure the security of the creator account.

To prevent and detect harm early, we monitor all media uploaded to JustFans. Content that enables or facilitates the exploitation of people – including modern slavery and human trafficking – is removed and, if necessary, reported.

We continuously improve our content moderation systems to ensure that all content complies with our Terms of Service and Acceptable Use Policy.

All of our moderators are trained to quickly identify and immediately report potential signs of modern slavery or human trafficking.

Before content becomes visible in the newsfeed, we use advanced technology to check whether it is allowed on JustFans. Each upload is automatically compared with databases and tools also used by law enforcement agencies to combat human trafficking.

Content that passes this automatic check is also manually reviewed by trained moderators within 24 hours.

Our moderators are specialized in immediately identifying and escalating suspicious content if there is a possible connection to modern slavery or human trafficking.

We reserve the right to review and remove any content – including images, videos, or messages – at any time, including in private direct messages.

JustFans nutzt keine Ende-zu-Ende-Verschlüsselung. Das bedeutet: Alle Inhalte auf der Plattform sind für unser Moderationsteam sichtbar. Es gibt keine versteckten Beiträge, geheimen Bereiche oder selbstlöschenden Nachrichten auf JustFans.

We generally require agencies and temporary staff by contract to comply with all applicable laws as well as our internal policies for combating modern slavery and human trafficking. In addition, we have introduced a company-wide mandatory training on modern slavery and human trafficking. This training is required annually for all employees and is conducted through a certified online provider.

When we enter into commercial agreements with manufacturers, we ensure that they align with our principles. In doing so, we specifically take into account the relevant provisions from our Code of Conduct & Ethics Guidelines, the Terms of Service, the Acceptable Use Policy, and this Anti-Slavery and Anti-Human Trafficking Statement. This ensures that all agreements reflect and support our stance against modern slavery and human trafficking.

We have further expanded our support functions to better respond to questions, concerns, or complaints from users and the community. Every post and every profile on JustFans includes a report button. All incoming reports are internally reviewed by our moderation team and – if necessary – followed up on. If you see content on JustFans that suggests someone may be in immediate physical danger – for example, in connection with human trafficking – we ask you to report it immediately: compliance@justfans.io

When JustFans detects content that contains indications of modern slavery or human trafficking, the affected account is immediately suspended. The relevant information is then forwarded to law enforcement agencies and relevant non-governmental organizations (NGOs) to assist in identifying those responsible.

We continuously invest in our technical and operational capabilities to detect exploitative content more quickly – especially in connection with human trafficking and modern slavery. Our investments aim to identify illegal actors, networks, organizations, and businesses engaged in such activities and to take appropriate countermeasures. These measures are implemented both on our platform and through external partnerships to prevent the misuse of our services for criminal purposes – at all stages of the exploitation cycle. We collaborate with a wide range of NGOs, aid organizations, and hotlines to support our strict protection policies for creators, fans, and employees. This also includes cooperation with and participation in reporting systems of the National Center for Missing & Exploited Children (NCMEC) as well as other recognized organizations committed to fighting exploitation.

JustFans aims to be one of the safest social media platforms in the world. We take responsibility for our actions and regularly publish data that documents our measures. You can find this information in our transparency reports, which are available here. In addition, we have commissioned an independent external audit body to review and continuously improve our security measures and compliance program.

We promote a culture of openness, honesty, and accountability. All employees are encouraged to report concerns or misconduct – including violations of human rights, modern slavery, or human trafficking. If you have a suspicion or concrete evidence of a violation of applicable law by the company itself, employees, contractors, agency staff, or external partners, please report it via email to: compliance@justfans.io

If the report concerns a supplier or service provider, we work with the relevant authorities to investigate and appropriately address the incident. If a violation is confirmed, we take concrete action – up to and including the termination of the business relationship.

Modern slavery and human trafficking are complex challenges that all companies must address. JustFans’ measures to combat these practices are ongoing, dynamic, and continuously evolving. Our approach to preventing modern slavery and human trafficking is regularly communicated throughout the company as well as to our suppliers – both at the start of a partnership and on an ongoing basis.

We are committed to continuously improving and maintaining our measures. In doing so, we continuously consider actions that are appropriate and proportionate to our risk profile as ZVN Digital Limited and operator of JustFans:

• Identification and assessment of new risk areas within our company or our supply chains
• Risk mitigation to prevent the occurrence of modern slavery and human trafficking to the best extent possible.
• Protection of whistleblowers and taking appropriate corrective actions when necessary.
• Updating our processes in response to changes in relevant laws, such as the UK Modern Slavery Act, the Australian Modern Slavery Act, or similar regulations.
• Monitoring potential risk factors and developing solutions to ensure that employees, users, and external partners are best protected from exploitation.

The management of ZVN Digital Limited bears overall responsibility for ensuring that all individuals and areas under our control comply with this statement and its associated policies. Leaders at all levels are responsible for ensuring that their teams understand the content of this statement and implement our policies against modern slavery and human trafficking. Our legal team holds primary responsibility for overseeing the principles outlined in this statement

It is also responsible for:

• the handling of inquiries regarding this statement,
• the assessment and development of internal control systems and processes,
• and ensuring that our measures are effective in combating modern slavery and human trafficking.

This statement has been approved by the board of ZVN Digital Limited.