Website Policies

Anti-Slavery & Anti-Trafficking Statement

Updated: 18th December 2025

Shift Holdings Ltd operates the website Fanvue (www.fanvue.com) (“Fanvue” or the “Company”), a subscription-based social platform connecting creators with their fans. Our platform is inclusive of content creators from all genres and empowers Creative Users to monetise their content in a safe and respectful environment.

Fanvue is committed to combating modern slavery and human trafficking. We do not tolerate modern slavery or human trafficking in any form - whether on our platform, in our partnerships, or in our supply chain.

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and the California Transparency in Supply Chains Act 2010. It sets out the steps taken by Fanvue to ensure that modern slavery and human trafficking is not taking place in our business operations, partnerships, and supply chains during the financial year 2024 (“FY2024”).

Our Commitment

Fanvue stands against all forms of modern slavery and human trafficking. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including:

  • Slavery – the status or condition of a person over whom any or all of the powers attaching to the right of ownership are exercised
  • Servitude – the obligation to provide services imposed by coercion
  • Forced and compulsory labour – work or service extracted from any person under threat of penalty and for which the person has not offered themselves voluntarily
  • Human trafficking – arranging or facilitating the travel of another person with a view to their exploitation

All of these have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We are committed to:

  1. Acting with integrity and mitigating the risk of modern slavery and human trafficking in our business dealings and relationships with our Creative Users and Fans
  2. Treating all employees, partners, and vendors with respect and dignity
  3. Ensuring safe working conditions across our operations
  4. Conducting environmentally responsible and ethical operations

Steps Taken This Financial Period

During FY2024, we have:

  1. Continued to roll out company-wide mandatory modern slavery and human trafficking training
  2. Issued and updated company-wide policies and procedures regarding acceptable business practices and ethical conduct
  3. Reviewed our supply chain to identify and mitigate risks of modern slavery and human trafficking
  4. Invested in enhancing our approach to content moderation, including hiring additional specialist resources
  5. Maintained and enhanced our identity verification and age verification processes
  6. Increased our engagement with third parties that seek to combat modern slavery and human trafficking
  7. Continued our partnerships with organisations including the National Center for Missing & Exploited Children (NCMEC)

Our Policies

Fanvue is committed to taking all reasonable and appropriate steps to ensure that there are no modern slavery or human trafficking activities taking place on our platform, in our business, or in our supply chain.

Code of Conduct & Business Ethics

We maintain a Code of Conduct & Business Ethics that sets out our expectation that all employees act with integrity and exercise good judgment in their efforts to comply with all applicable laws, rules, and regulations, including those relating to modern slavery and human trafficking. This Code is also shared with key suppliers and contractors.

Terms of Service and Acceptable Use Policy

Our General Terms & Conditions and Acceptable Use Policy specifically prohibit the uploading, posting, displaying, or publishing of content on Fanvue that:

  1. Shows, includes, or refers to any other individual unless written consent is obtained from each individual to use their name or images (or both) in the content
  2. Shows, promotes, advertises, or refers to escort services, sex trafficking, human trafficking, or prostitution - whether explicitly or by use of slang, symbols, acronyms, or abbreviations

Supplier Standards

We strive to hold our employees and suppliers to high standards. Any violation of our standards by an employee can result in disciplinary action, including termination of employment. Any violation by a supplier can result in contract termination.

Our Risk Assessment

We continually assess modern slavery and human trafficking risks in our business environment by identifying and analysing higher-risk areas. Our assessment is based on external reports and standards, country and sector risk profiles, and we adjust our processes and controls as appropriate based on changing risks.

Direct Business Operations

We consider the risks of modern slavery and human trafficking to be relatively low in our direct business operations, as our direct workforce is largely comprised of professionally qualified or skilled personnel based primarily in the United Kingdom. We recognise that in areas where we engage contractors outside of the United Kingdom, there may be a higher risk of modern slavery and human trafficking. We ensure that our entire workforce is aware of these risks and our position on these issues, and that they can report any instances of suspected modern slavery or human trafficking.

Platform and Supply Chain

Creator Content. As with all social media platforms, there are risks related to creator content, including the risk of material being uploaded that is exploitative and in breach of various laws and our policies. We address this through our comprehensive verification and content moderation processes described below.

Contractors and Third Parties. We use contractors and engage third-party suppliers to assist with various services including identity verification, age verification, content moderation, payment processing, and cloud hosting. These contractors and third parties are required to comply with relevant laws and our policies.

Payment Processors. We work with payment processors and financial services providers who are themselves subject to extensive regulatory oversight and anti-money laundering requirements.

Our Risk Mitigation Efforts

We have continued to work to mitigate the risks identified above and are committed to continuous improvement.

Creator Verification

We carefully verify all identity and payment details for each Creative User account application to ensure that individuals can only create an account on their own behalf:

  1. All Creative Users must complete identity verification through our Know Your Customer (KYC) process before they can upload content or receive payments
  2. We verify that identity documents match the legal name provided on payment methods
  3. We employ technological safeguards to ensure creators receive payments directly from Fanvue
  4. In certain high-risk jurisdictions or where an account has been flagged for additional security, we require enhanced verification procedures

For full details of our verification requirements, see our Age Verification Policy.

Content Moderation

In order to prevent and detect harm, we monitor content uploaded to the platform and remove (and report where necessary) any content that facilitates or coordinates the exploitation of people, including modern slavery and human trafficking:

  1. Automated Detection: We use AI-assisted technology to screen content before it appears on the platform
  2. Human Review: Trained human moderators review content to ensure compliance with our Terms of Service and Acceptable Use Policy
  3. Moderator Training: All content moderators are trained to identify and swiftly report any suspected modern slavery, including trafficking indicators
  4. No Hidden Content: Fanvue does not use end-to-end encryption for content, meaning all content on the platform is visible to our team of trained reviewers. There are no hidden posts, secret areas, or disappearing messages on Fanvue

For full details of our content moderation processes, see our Content Moderation & Protection Policy.

Contractor and Supplier Due Diligence

  1. We include contractual obligations for agencies, contractors, and suppliers to comply with relevant laws and our policies to combat modern slavery and human trafficking
  2. We conduct due diligence on our suppliers to assess their compliance with applicable laws and regulations
  3. We review commercial agreements to ensure alignment with our anti-slavery and anti-trafficking principles

Community Reporting

We provide multiple channels for reporting concerns:

  1. In-Platform Reporting: Each post and account on Fanvue has a report function. Reports are reviewed by our moderation team
  2. Email Reporting: Anyone can report concerns directly to compliance@fanvue.com
  3. Emergency Situations: We encourage anyone encountering content on Fanvue that indicates someone is in immediate physical danger relating to human trafficking to report immediately via the channels above and to local law enforcement

Law Enforcement Cooperation

If Fanvue identifies content which contains indicators of modern slavery or human trafficking:

  1. We immediately suspend the associated account
  2. We preserve relevant evidence
  3. We pass information to law enforcement and relevant non-governmental organisations
  4. We cooperate fully with any resulting investigations

We work with a range of NGOs, helplines, and charities to support our safeguarding efforts, including working with and participating in the reporting systems of the National Center for Missing & Exploited Children (NCMEC).

For information about how we share user data with law enforcement, see our Privacy Policy.

Transparency and Accountability

Fanvue is committed to building a safe platform. We take responsibility for our actions and regularly review our safety controls and compliance programmes.

Our Reporting Mechanisms

We foster a culture of transparency, honesty, and accountability, which encourages our employees to report any concerns or wrongdoing, including human rights violations, modern slavery, and human trafficking.

How to Report Concerns

If you have any concerns or suspect a violation of any law by the Company - whether by its employees, contractors, agency staff, or any third party doing business on the Company’s behalf - please report the matter by email to compliance@fanvue.com.

Investigation and Response

If a concern is raised regarding a supplier or contractor, we will coordinate with appropriate stakeholders to investigate and address the issue. If a reported concern is substantiated, corrective action will be taken, up to and including termination of the business relationship.

Whistleblower Protection

We are committed to protecting individuals who raise concerns in good faith. No employee will suffer any detrimental treatment as a result of raising genuine concerns about modern slavery or human trafficking.

Our Ongoing Commitment

Modern slavery and human trafficking are complex challenges for all businesses. Fanvue’s efforts to combat these practices are ongoing, evolving, and continually improving. Our approach to modern slavery and human trafficking will continue to be communicated throughout our business and to our suppliers, both at the outset and periodically throughout the business relationship.

We are committed to maintaining and improving our practices to combat modern slavery and human trafficking. We will continue to:

  1. Identify and assess any further risk areas within our business or supply chain
  2. Mitigate the risk of modern slavery and human trafficking occurring in our business or supply chain
  3. Protect whistleblowers and take appropriate remedial action as needed
  4. Stay up to date with any changes to the UK Modern Slavery Act, California Transparency in Supply Chains Act, and any other relevant legislation
  5. Monitor potential risk areas and implement solutions to ensure employees, users, and third parties are safe from the risk of modern slavery and human trafficking

Responsibility for This Statement

Our Executive Leadership has overall responsibility for ensuring that all those under our control comply with this statement and our related policies.

Management at all levels are responsible for ensuring their teams understand this statement and comply with our anti-slavery and anti-trafficking policies and procedures.

Our Legal and Compliance team has primary and day-to-day responsibility for overseeing the principles in this statement, addressing any queries about the statement, and ensuring internal control systems and procedures are effective in countering modern slavery and human trafficking.

Board Approval

This statement has been approved by the Board of Shift Holdings Ltd.

Signed:

William Monange Director of Shift Holdings Ltd

Date: 18th December 2025

Need Help?

If you have questions about this statement or need assistance:

Fanvue reserves the right to amend this statement from time to time. The latest version will always be accessible at legal.fanvue.com, and significant changes will be communicated where required.