ANTI-HUMAN TRAFFICKING POLICY

Effective June 1, 2025

1. Purpose

This policy declares ClamCams’ zero-tolerance commitment to preventing, detecting, and reporting any form of human trafficking, forced labor, or sexual exploitation within our ecosystem.

2. Scope

The policy applies to every ClamCams stakeholder, including employees, contractors, affiliate studios, models, users, payment/technology providers, and strategic partners—without exception.

3. Legal Framework

• UN Palermo Protocol (2000)
• U.S. Trafficking Victims Protection Reauthorization Act (2022-2023)
• FOSTA-SESTA (2018) – platform liability
• FAR 52.222-50 for U.S. federal contractors
• All local anti-trafficking laws in jurisdictions where we operate

4. Guiding Principles

• Zero tolerance
• Enhanced due diligence
• Transparency & accountability
• Co-operation with authorities
• Victim-centered redress

5. Prevention

• Robust KYC with Amazon Rekognition (Face Liveness + CompareFaces) and OCR of government ID
• Real-time age verification & duplicate detection against global blacklists
• Anti-trafficking clauses in all contracts and audit rights for ClamCams

6. Detection & Monitoring

• 24/7 hybrid moderation (AI + human reviewers)
• Risk-scoring and fraud-detection algorithms
• Quarterly internal audits and annual external reviews

7. Reporting & Response

Suspected trafficking can be reported 24/7 via compliance@clamcams.com or our encrypted online form. Reports are acknowledged within 24 hours. Content and accounts are preventively blocked while an investigation is conducted. Where evidence indicates trafficking, ClamCams notifies the relevant authorities within 48 hours.

8. Training

All personnel must complete mandatory anti-trafficking training at onboarding and annual refresher courses. Specialized modules are provided for Support, Moderation, and Finance teams.

9. Supply Chain

Vendors and partners undergo criminal and reputational due-diligence screenings and must certify compliance annually. Violations trigger immediate contract termination.

10. Sanctions

Proven violations may result in account suspension or permanent banning, contract rescission, payment holds or release to victims, and full co-operation with judicial proceedings.

11. Governance

The Chief Compliance Officer (CCO) reports quarterly to the Board. This policy is reviewed annually or sooner if regulatory changes require.

12. Validity & Approval

Approved by the Board of Directors on May 23 2025. The policy takes effect on June 1 2025.