This statement outlines the commitment of VeryMine, operated by 1618 TECHNOLOGIES SAS ("VeryMine", "We", "Us"), registered in Paris, France, to preventing modern slavery and human trafficking in all aspects of our business and supply chains. We strive to operate ethically and transparently, in line with our company values and relevant legal and ethical standards.
1. Our Commitment to Preventing Modern Slavery
Modern slavery is a crime and a fundamental violation of human rights. It encompasses various forms, including slavery, servitude, forced or compulsory labour, and human trafficking, all involving the exploitation of individuals for personal or commercial gain by depriving them of their liberty.
VeryMine maintains a zero-tolerance policy towards modern slavery and human trafficking. We are committed to acting with integrity and preventing such practices within our platform operations, business dealings, partnerships, and supply chains.
2. Scope and Policies
This policy applies to all persons working for or on behalf of VeryMine, including employees at all levels, directors, officers, agency workers, contractors, creators, suppliers, and other business partners.
Our internal Code of Conduct & Business Ethics requires all employees and representatives to act with integrity and comply with applicable laws, including those prohibiting modern slavery and human trafficking. We expect similar standards from our key suppliers and contractors.
Our Terms and Conditions and Acceptable Use Policy explicitly prohibit content on VeryMine that:
- Shows, includes, or refers to any individual without their explicit, verifiable, written consent for their name and/or image to be used in the content.
- Shows, promotes, advertises, or refers to escort services, prostitution, sex trafficking, or any form of non-consensual sexual content or exploitation.
We expect our suppliers and partners to adhere to anti-slavery principles, and we reserve the right to include specific contractual clauses prohibiting the use of forced, compulsory, or trafficked labour.
3. Risk Assessment
VeryMine acknowledges the risks of modern slavery associated with operating an online platform with user-generated content and engaging with global suppliers and partners. We identify potential risk areas including:
- Platform Content: The risk that users might attempt to upload content related to exploitation, despite our prohibitions and moderation efforts.
- Creators: Ensuring creators are acting freely, are properly identified and age-verified, receive their earnings directly, and have obtained verifiable consent from any other individuals depicted.
- Third-Party Suppliers/Contractors: Risks associated with partners providing services like content moderation, verification, or IT infrastructure, particularly those operating internationally.
- Direct Operations: While likely lower risk with a skilled workforce, we remain vigilant within our own operations.
4. Risk Mitigation Efforts & Due Diligence
VeryMine implements the following measures to combat modern slavery and human trafficking:
- Creator Verification: We employ processes such as government ID verification, selfie checks, age verification technology, and cross-referencing payment details to confirm creator identity, legal age, and ensure they are operating their own account and receiving payments directly. Additional checks may be implemented for accounts flagged as higher risk.
- Consent Verification: Creators are contractually obligated to obtain and provide proof upon request of the age and explicit consent of any individual depicted in their content. We utilize manual review processes and random spot checks to monitor compliance.
- Content Moderation: All uploaded media undergoes review using AI detection tools and trained human moderators to identify and remove content violating our Terms, paying specific attention to indicators of exploitation, trafficking, or non-consensual activity.
- Supplier Due Diligence: We assess potential suppliers through questionnaires, requiring adherence to our Code of Conduct, and including relevant clauses in contracts.
- Training: Relevant employees and key contractors receive training on identifying and reporting modern slavery risks.
5. Reporting Mechanisms
We encourage the reporting of any concerns related to modern slavery or human trafficking.
- Users and creators can report suspicious content or accounts directly through the reporting tools available on the VeryMine platform.
- Anyone can report concerns via email to: [email protected]
VeryMine is committed to investigating reported concerns promptly and appropriately. We strive to ensure that no individual suffers detrimental treatment for reporting genuine concerns in good faith (whistleblower protection).
6. Governance and Responsibility
Overall responsibility for this policy and its implementation rests with Executive Leadership of 1618 TECHNOLOGIES SAS.
The Legal and Compliance Department holds primary day-to-day responsibility for overseeing, maintaining, and updating this policy and related procedures.
Management at all levels are responsible for ensuring their teams understand and comply with this policy.
7. Continuous Improvement
VeryMine recognizes that combatting modern slavery is an ongoing effort. We are committed to regularly reviewing our policies, procedures, risk assessments, and mitigation strategies to ensure their effectiveness and adapt to evolving risks and legal requirements.
