Anti-Slavery and Anti-Trafficking Statement
Preamble and principle
Copy link to “Preamble and principle”DAAR GLOBAL LIMITED, which operates desioart (desioart.com), tolerates no form of modern slavery, human trafficking or sexual exploitation — not on the platform, not in our business relationships, not in our supply chain.
Modern slavery covers slavery, servitude, forced and compulsory labour, debt bondage and human trafficking: recruiting, transporting, harbouring or receiving a person through force, threat, deception, abuse of a position of vulnerability or payments, for the purpose of exploitation. For a platform carrying adult content the central risk is that people are made to produce content against their will, or under someone else’s control, or to hand their earnings to a third party. This document sets out what we do about that.
We make this statement voluntarily, taking our lead from section 54 of the UK Modern Slavery Act 2015 — whose turnover threshold of GBP 36 million we do not reach — from the California Transparency in Supply Chains Act and from the Australian Modern Slavery Act, because being open about our safeguards is part of our responsibility. It forms part of our terms of service (Terms section 19.1) and supplements Acceptable Use sections 2.10 to 2.13, Age Verification, NCII Takedown, Co-Performers and Creator Earnings section 7.
1 What we commit to
Copy link to “1 What we commit to”We commit ourselves:
- to admit nobody to the platform whose identity and age are unverified once they publish content of a sexual nature or receive money
- to take any indication of coercion, third-party control or exploitation seriously, to follow it up at once and to protect the people affected
- to arrange the flow of money so that earnings reach only the verified person themselves
- to tolerate no arranging of real sexual services, escort offers or prostitution on the platform (Acceptable Use section 2.12)
- to work with law enforcement and specialist organisations, while preserving victims’ rights and safety
- to bind our staff, reviewers and service providers to these standards and to train them
- to review this statement annually and to report on the measures we have taken
2 The legal framework
Copy link to “2 The legal framework”We follow: the United Nations Palermo Protocol; Directive 2011/36/EU on preventing and combating trafficking in human beings, as amended by Directive (EU) 2024/1712; Cypriot Law 60(I)/2014 on preventing and combating trafficking in human beings and protecting victims; the relevant provisions of the countries our users live in (in Germany, sections 232 to 233a StGB); 18 U.S.C. §§ 1591 and 1595 and § 2421A (FOSTA-SESTA) where there is a US connection; and the Digital Services Act (Articles 16, 18 and 23) for notice and action. We implement these requirements in a single programme, which follows whichever requirement is strictest.
3 Risk assessment
Copy link to “3 Risk assessment”| Area | Risk | Our assessment |
|---|---|---|
| Content and accounts | people forced to produce by third parties (“managers”, partners, traffickers), or their accounts and earnings controlled by someone else; victims recruited through messages | the highest risk — the focus of everything in section 4 |
| Payments | payouts to third parties, money mules, “send it back” arrangements, laundering the proceeds of exploitation | high — covered by verification, account-holder checks and anti-money-laundering controls (Creator Earnings section 7) |
| Our own staff | small, skilled, employed in EU countries | low |
| Service providers | verification, payments, hosting, AI, moderation support — regulated or established providers in the EU and the USA | low; bound by contract (section 4.5) |
| Goods and merchandise | no physical products at present | not relevant |
| The company’s AI personas | no real people involved | not relevant; provenance records kept (2257 Statement section 2.4) |
We review this assessment annually, and whenever there is reason to.
4 What we do
Copy link to “4 What we do”4.1 Verification — nobody earning money is anonymous
Copy link to “4.1 Verification — nobody earning money is anonymous”| Measure | Effect |
|---|---|
| Age verification of every user before any subscription, purchase or access to messages | no anonymous fans; contact only ever between verified adults |
| Identity checks (identity document, liveness, comparison, sanctions and PEP screening) for every creator before their first adult content, before paid messages and before their first payout | creators are known to us by their legal names; forged and borrowed documents are caught |
| Identity checks on everyone taking part in adult content, their own consent, withdrawal at any time, and a direct line to us without the creator knowing | no “invisible” people in content; those taking part do not depend on the creator |
| One human being, one identity: several accounts only as openly linked accounts of the same verified person; a hash of the identity document prevents multiple identities | no front accounts |
| Re-verification where we suspect an account takeover, where the country of verification and the country of connection diverge, or where we receive reports | third-party control becomes conspicuous |
4.2 Money reaches only the verified person
Copy link to “4.2 Money reaches only the verified person”- Payouts go only to a bank account or crypto address the creator entered themselves, in their own verified name or their registered business name (Creator Earnings section 5.1). Where the account holder and the name on the identity document differ, we clear that up before paying out; any change to payout details requires fresh authentication and takes effect only after a 7-day waiting period, with notice to every contact route on file
- We never pay third parties, agencies or “managers” — not even at the creator’s request (Creator Terms section 4.7)
- Conspicuous patterns (the same bank details or device identifier across several creators, payouts to high-risk countries, “send it back” arrangements in messages, card testing) trigger a review and, where necessary, a stop on payouts (Creator Earnings sections 3.2 and 7.7)
- Sanctions screening before payouts; where we suspect money laundering we end the business relationship and report the case to the competent Cypriot body, so far as we are obliged or entitled to (Creator Earnings section 7)
4.3 Detecting and responding
Copy link to “4.3 Detecting and responding”- A report category “human trafficking and sexual exploitation” in every reporting dialogue, with the highest priority: hidden immediately once the first plausible report arrives, decided within 24 hours, and open to anonymous reports (Moderation section 3.5)
- A confidential mailbox, trafficking@desioart.com — for the people affected themselves as well
- A prohibition on arranging sexual services, advertising escort work and paid meetings (Acceptable Use section 2.12), with a report category of its own
- Where a suspicion is well founded: the account is suspended at once, payouts are frozen so that exploiters do not profit, evidence is preserved, a four-eyes review follows, and we report under section 6
- Training for our reviewers on the indicators (section 5); cases involving coercion are handled by experienced staff
What we deliberately do not do: we do not read private messages and we do not monitor users without cause (Privacy section 2.6). Unlike some platforms, we rely on verifying everyone involved, on payment controls, on easily reachable reporting routes and on the direct line for those taking part. Where something is reported to us, we can look at the messages reported.
4.4 Protecting people affected
Copy link to “4.4 Protecting people affected”- People affected are not treated as offenders: their account can be protected, their visibility reduced and their access to earnings secured. Frozen earnings owed to someone affected we pay, once the matter is clear, to them personally (Creator Earnings section 10)
- We make contact only by safe routes and after agreeing it with them, and we put them in touch with specialist support (section 6.3)
- We report to the authorities in a way that does not put them in danger, and we disclose a victim’s identity data only to law enforcement
4.5 Staff and service providers
Copy link to “4.5 Staff and service providers”- Staff and freelance reviewers are bound by contract to this statement, to confidentiality and to fair working conditions (the employment law of the place of work, at least the statutory minimum wage); sensitive roles (compliance, moderation, support) are trained before they start and every year afterwards
- Service providers (age and identity verification, payment processing, hosting, object storage, content delivery, email, AI text generation, hash matching) are checked before we contract with them for legal compliance and, where it applies, for anti-slavery statements of their own
- A breach leads to employment measures, or to the end of the business relationship
5 The indicators we watch for
Copy link to “5 The indicators we watch for”For our reviewers, and for users who want to report something:
- Account and behaviour: the account is plainly run by someone other than the verified person (language, style and time zones change abruptly); payout details are changed to another name shortly after verification; several creators share a device, bank details or an address; content appears around the clock without a break; the person seems to be under instruction or under watch in livestreams or messages
- Content: signs of fear, injury or intoxication; instructions from off camera; recurring settings that suggest several people are housed together; tattoos or marks asserting ownership; people who do not match those verified as taking part
- Messages and purchases: fans offering meetings, travel, “introductions” or payments away from the platform; custom requests involving coercion or humiliation of people who are plainly real; creators asking fans for “help” or talking about debts to third parties
- Recruitment: accounts recruiting other users as “models”, promising travel or accommodation, or wanting to hold on to documents
No single indicator proves trafficking — we look at the picture as a whole, and we do not penalise the person affected in haste.
6 Reporting, and working with the authorities
Copy link to “6 Reporting, and working with the authorities”6.1 To us
Copy link to “6.1 To us”| Channel | Notes |
|---|---|
| “Report” → “human trafficking and sexual exploitation” | the fastest route, can be anonymous, attaches the content |
| trafficking@desioart.com | confidential; open to the people affected, their families and specialist bodies |
| desioart.com/report | without an account, anonymously |
Whoever reports stays anonymous towards the person reported and suffers no disadvantage for it; people affected who report themselves face no penalty.
6.2 Straight to the authorities — first, where there is immediate danger
Copy link to “6.2 Straight to the authorities — first, where there is immediate danger”- Emergency number 112 (EU) and 911 (USA)
- Germany: the police, the Bundeskriminalamt (its reporting portal), the helpline for violence against women, 116 016
- Cyprus: Cyprus Police 112 · the Cyprus Police Office for Combating Trafficking in Human Beings · helpline 1440 (SPAVO)
- USA: National Human Trafficking Hotline +1 888 373 7888 (text 233733)
- EU: Europol, through the national police
6.3 Our own reports and co-operation
Copy link to “6.3 Our own reports and co-operation”Where a suspicion is well founded we report without delay under Article 18 DSA to the competent law enforcement authorities (in Cyprus; in Germany the Bundeskriminalamt; where there is a US connection, NCMEC and the competent federal agencies; where minors are involved, always NCMEC), preserve evidence tamper-proof for 5 years, and co-operate with investigations (Moderation section 6). We disclose users’ identity data on a lawful order, and where life or safety is in immediate danger without a formal order as well (Moderation section 6.2). We work with specialist organisations and refer people affected to: KOK e.V. (the German nationwide co-ordination group against trafficking), SOLWODI (Germany), Cyprus Stop Trafficking and the Mediterranean Institute of Gender Studies (Cyprus), the Polaris Project (USA), La Strada International (EU) and ECPAT (child protection).
7 Training and responsibility
Copy link to “7 Training and responsibility”- Every member of staff and every reviewer in contact with users is trained, before starting and every year afterwards, on the indicators, on trauma-informed communication and on reporting routes; those responsible for compliance are trained on money laundering and sanctions law as well.
- The management bears overall responsibility for this statement; the compliance function (the compliance office of DAAR GLOBAL LIMITED) is responsible for implementation, training and reporting.
- Reports of wrongdoing inside the company: legal@desioart.com (Complaints section 9) — confidential, with no disadvantage for anyone reporting in good faith.
8 What we did in the reporting period, and what comes next
Copy link to “8 What we did in the reporting period, and what comes next”Before the platform launched we: set up two-stage verification (age for everyone, identity for creators and for those taking part); built the consent system for those taking part, with a direct route to us; implemented payout protection (own account only, a waiting period, sanctions screening); introduced the “human trafficking” report category at the highest priority and open to anonymous reports; created the confidential trafficking@ mailbox and the reporting route that needs no account; prepared evidence preservation and the channels to the authorities; and published this statement and the AUP prohibitions.
In the coming year we intend to: agree our training material with a specialist organisation; develop the list of indicators further in the light of real cases; introduce a supplier questionnaire; publish figures (reports, measures, reports to authorities) in the transparency report (Moderation section 9.3); and, as we grow, commission an independent review of our safeguarding programme.
9 Updates
Copy link to “9 Updates”We review this statement at least once a year, and whenever something material changes (the law, new features, new countries). We publish changes 30 days beforehand; the current version is at legal.desioart.com/anti-slavery.
10 Contact and approval
Copy link to “10 Contact and approval”| Matter | Channel |
|---|---|
| Suspected coercion, exploitation, trafficking (confidential, 24 h) | trafficking@desioart.com · “Report” · desioart.com/report |
| Help if you are affected | trafficking@desioart.com · the specialist bodies in section 6.3 |
| Authorities | legal@desioart.com |
| Questions about this statement, suppliers | legal@desioart.com |
| Reports of wrongdoing inside the company | legal@desioart.com |
Postal address: 1 Apriliou 52, 7600 Athienou, Larnaca, Cyprus
This statement was approved by the management of DAAR GLOBAL LIMITED on 16 September 2026.
Alexander Repp, Director