ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

Effective Date: 01st day of January 2026

Version: 2.0 (Expanded & Platform-Specific)

Swipey.ai operates exclusively with AI-generated content. The platform does not host real individuals or user-uploaded media.

The Company implements safeguards to prevent:

Generation of content depicting real individuals without consent
Generation of minors or age-ambiguous characters
Simulation of coercion, exploitation, or non-consensual scenarios
Any content that may resemble human trafficking or exploitation

All AI models are subject to prompt filtering, output moderation, and safety alignment controls.

Swipey.ai does not facilitate or enable interaction with real persons in exchange for payment.

All interactions are exclusively with AI systems.

1. Purpose:

This Anti-Slavery and Human Trafficking Policy (the "Policy") formalizes Swipey.ai's zero-tolerance stance against modern slavery, human trafficking, forced labor, debt bondage, and all forms of exploitation — both within our internal operations and across our creator supply chain, and technology platform as an AI-generated content service.

We recognize that digital content platforms can be misused for coercive or non-consensual activities. This Policy ensures that Swipey.ai operates as a safe, transparent, and ethically verified environment.

2. Scope:

2.1. Sections of this Policy referring to creators, performers, earnings retention, content removal by third-party rights holders, and creator-specific financial metrics are included for completeness and reflect standard anti-slavery frameworks.

Such sections shall be read as not applicable until such time as Swipey.ai introduces human-generated content, which it has no current intention of doing.

For the avoidance of doubt:

Swipey.ai does not onboard, pay, or contract with human content creators.
References to "creator retention", "earnings diversion", or "voluntary creator confirmation" do not impose operational obligations under current business model.

These provisions are retained to demonstrate alignment with UK Modern Slavery Act 2015, California Transparency in Supply Chains Act, and EU Anti-Trafficking Directive, without implying current obligations that contradict Swipey.ai's AI-only operation.

2.2. This Policy applies globally to:

All employees, contractors, and leadership of Swipey.ai
End users interacting with AI-generated content
Payment processors, IT vendors, moderation services, and any third-party providers
Any user who interacts with the platform, including via text-based prompts, AI-generated interactions, or AI voice calls

Swipey.ai does not host or distribute user-uploaded media content (including video, audio, or images) and does not operate as a user-generated content (UGC) platform.

3. Definitions (Platform-Ready):

Term	Definition for Swipey.ai
Modern Slavery	Situations where an individual cannot leave or refuse work due to threats, coercion, or abuse of power.
Human Trafficking	Recruitment or transfer of a person via deception, force, or fraud for exploitation — including sexual exploitation.
Forced Labor	Any work or service exacted under menace of penalty and not offered voluntarily.
Debt Bondage	When a person is forced to work to repay a loan — including fake "production costs" or "agency fees".
Consent	Freely given, reversible, informed, and specific agreement. Not possible under coercion, intoxication, or power imbalance. Within Swipey.ai, this applies to user interaction with AI systems only, as no real individuals are present on the platform. Consent is irrelevant to the portrayal of any character within AI‑generated content, as no real person is depicted. However, user prompts must not simulate non‑consent, coercion, or exploitation of any real or fictional individual.

4. Policy Statement:

Swipey.ai operates exclusively using artificial intelligence. The platform does not facilitate interaction with real individuals, performers, or content creators. All interactions occur with AI-generated systems.

Swipey.ai absolutely prohibits:

Any form of non-consensual content, coercion, or exploitation on or off the platform
Any attempt to simulate or represent controlled, coerced, or exploited individuals within AI-generated content
Minors or legally incapable persons (including those under guardianship without independent legal advice)
Content trafficking — i.e., forcing individuals to perform or distribute against their will
Use of the platform to launder money derived from human trafficking

Any credible violation triggers: immediate suspension, platform ban, legal referral, and (where required) notification to law enforcement.

5. Platform-Specific Controls (Risk-Based):

5.1 User Verification & Platform Access Controls:

KYC (where required by payment providers or regulatory obligations)
Age verification (18+ mandatory — third-party biometric or ID scan)
Voluntary confirmation that the user understands all generated content and voice interactions are entirely AI‑based and involve no real individuals

5.2 Consent & Revocability:

Users who generate AI content via prompts must confirm their voluntary use of the platform every 6 months
Right to delete their account, prompt history, and AI interaction data at any time, without penalty
No "lock-in" contracts via Swipey.ai tools

As Swipey.ai:

Does not involve real individuals or performers, consent principles apply to user control over account usage, data, and interaction with AI systems
Involves no human performers, this section refers exclusively to end‑user control over their own account and AI‑generated outputs

5.3 Content & Behavior Monitoring:

Automated detection of trafficking indicators:
- Prompts attempting to simulate real individuals or identifiable persons
- Prompts suggesting coercion, exploitation, or non-consensual scenarios
- Repeated financial routing to a single third party
Manual moderation escalation
User reporting button — anonymous and prioritized

5.4 Financial Red Flags:

Swipey.ai does not process payouts to content creators, performers, or third party content providers. However, we monitor for:

Suspicious payment routing suggesting money laundering linked to exploitation
Repeated microtransactions from multiple users to a single third party wallet without legitimate AI service reason

No creator specific metrics (retention, earnings diversion) apply, as Swipey.ai operates without human generated content.

5.5 AI-Specific Safeguards:

Swipey.ai implements technical safeguards to prevent:

Generation of minors or age-ambiguous characters
Simulation of real persons without consent
Creation of exploitative, coercive, or trafficking-related scenarios
Any output that may resemble non-consensual activity

All AI outputs are subject to filtering, moderation, and safety alignment controls.

6. Supply Chain & Third-Party Risk:

As Swipey.ai does not employ human content moderators for real‑time video/audio review, this section applies primarily to vendors involved in AI training data annotation and infrastructure support.

We require every vendor, hosting provider, AI training data partner, and moderation service to:

Sign a Modern Slavery Compliance Addendum
Certify no forced labor in their supply chain
Permit audit on request (if high-risk category)
High-risk categories: moderation services, data labeling, offshore support, production studios

7. Reporting & Whistleblowing (Low-Retaliation):

Any user, employee, or contractor must report suspected trafficking or forced labor.

Internal reports (confidential):

Email: [email protected]

Platform ticket: Report → Human trafficking concern

8. Breach & Enforcement:

Violation consequence:

First violation (non-consensual content) — Permanent ban + referral
Any attempt to misuse the platform for illegal, exploitative, or trafficking-related purposes
Employee complicity — Immediate dismissal + legal action
We also reserve the right to withhold funds where trafficking is suspected (pending investigation)

9. Governance & Responsibility:

CEO / Head of Trust & Safety — final owner of this Policy
Compliance Officer — annual risk assessment + third-party audits
Board-level review — every 12 months or after any material incident

10. Legal Alignment & Jurisdictions:

This Policy aligns with:

UK Modern Slavery Act 2015 (Section 54)
California Transparency in Supply Chains Act
EU Anti-Trafficking Directive 2011/36/EU
UN Guiding Principles on Business and Human Rights

11. Contact & Questions

For legal, compliance, or partnership inquiries regarding this Policy:

Email: [email protected]

ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

Page: Swipey.ai

Effective Date: 01st day of January 2026

Version: 2.0 (Expanded & Platform-Specific)

Swipey.ai operates exclusively with AI-generated content. The platform does not host real individuals or user-uploaded media.

The Company implements safeguards to prevent:

Generation of content depicting real individuals without consent
Generation of minors or age-ambiguous characters
Simulation of coercion, exploitation, or non-consensual scenarios
Any content that may resemble human trafficking or exploitation

All AI models are subject to prompt filtering, output moderation, and safety alignment controls.

Swipey.ai does not facilitate or enable interaction with real persons in exchange for payment.

All interactions are exclusively with AI systems.

1. Purpose:

2. Scope:

Such sections shall be read as not applicable until such time as Swipey.ai introduces human-generated content, which it has no current intention of doing.

For the avoidance of doubt:

Swipey.ai does not onboard, pay, or contract with human content creators.
References to "creator retention", "earnings diversion", or "voluntary creator confirmation" do not impose operational obligations under current business model.

2.2. This Policy applies globally to:

All employees, contractors, and leadership of Swipey.ai
End users interacting with AI-generated content
Payment processors, IT vendors, moderation services, and any third-party providers
Any user who interacts with the platform, including via text-based prompts, AI-generated interactions, or AI voice calls

Swipey.ai does not host or distribute user-uploaded media content (including video, audio, or images) and does not operate as a user-generated content (UGC) platform.

3. Definitions (Platform-Ready):

Term	Definition for Swipey.ai
Modern Slavery	Situations where an individual cannot leave or refuse work due to threats, coercion, or abuse of power.
Human Trafficking	Recruitment or transfer of a person via deception, force, or fraud for exploitation — including sexual exploitation.
Forced Labor	Any work or service exacted under menace of penalty and not offered voluntarily.
Debt Bondage	When a person is forced to work to repay a loan — including fake "production costs" or "agency fees".
Consent	Freely given, reversible, informed, and specific agreement. Not possible under coercion, intoxication, or power imbalance. Within Swipey.ai, this applies to user interaction with AI systems only, as no real individuals are present on the platform. Consent is irrelevant to the portrayal of any character within AI‑generated content, as no real person is depicted. However, user prompts must not simulate non‑consent, coercion, or exploitation of any real or fictional individual.

4. Policy Statement:

Swipey.ai absolutely prohibits:

Any form of non-consensual content, coercion, or exploitation on or off the platform
Any attempt to simulate or represent controlled, coerced, or exploited individuals within AI-generated content
Minors or legally incapable persons (including those under guardianship without independent legal advice)
Content trafficking — i.e., forcing individuals to perform or distribute against their will
Use of the platform to launder money derived from human trafficking

Any credible violation triggers: immediate suspension, platform ban, legal referral, and (where required) notification to law enforcement.

5. Platform-Specific Controls (Risk-Based):

5.1 User Verification & Platform Access Controls:

KYC (where required by payment providers or regulatory obligations)
Age verification (18+ mandatory — third-party biometric or ID scan)
Voluntary confirmation that the user understands all generated content and voice interactions are entirely AI‑based and involve no real individuals

5.2 Consent & Revocability:

Users who generate AI content via prompts must confirm their voluntary use of the platform every 6 months
Right to delete their account, prompt history, and AI interaction data at any time, without penalty
No "lock-in" contracts via Swipey.ai tools

As Swipey.ai:

Does not involve real individuals or performers, consent principles apply to user control over account usage, data, and interaction with AI systems
Involves no human performers, this section refers exclusively to end‑user control over their own account and AI‑generated outputs

5.3 Content & Behavior Monitoring:

Automated detection of trafficking indicators:
- Prompts attempting to simulate real individuals or identifiable persons
- Prompts suggesting coercion, exploitation, or non-consensual scenarios
- Repeated financial routing to a single third party
Manual moderation escalation
User reporting button — anonymous and prioritized

5.4 Financial Red Flags:

Swipey.ai does not process payouts to content creators, performers, or third party content providers. However, we monitor for:

Suspicious payment routing suggesting money laundering linked to exploitation
Repeated microtransactions from multiple users to a single third party wallet without legitimate AI service reason

No creator specific metrics (retention, earnings diversion) apply, as Swipey.ai operates without human generated content.

5.5 AI-Specific Safeguards:

Swipey.ai implements technical safeguards to prevent:

Generation of minors or age-ambiguous characters
Simulation of real persons without consent
Creation of exploitative, coercive, or trafficking-related scenarios
Any output that may resemble non-consensual activity

All AI outputs are subject to filtering, moderation, and safety alignment controls.

6. Supply Chain & Third-Party Risk:

As Swipey.ai does not employ human content moderators for real‑time video/audio review, this section applies primarily to vendors involved in AI training data annotation and infrastructure support.

We require every vendor, hosting provider, AI training data partner, and moderation service to:

Sign a Modern Slavery Compliance Addendum
Certify no forced labor in their supply chain
Permit audit on request (if high-risk category)
High-risk categories: moderation services, data labeling, offshore support, production studios

7. Reporting & Whistleblowing (Low-Retaliation):

Any user, employee, or contractor must report suspected trafficking or forced labor.

Internal reports (confidential):

Email: [email protected]

Platform ticket: Report → Human trafficking concern

8. Breach & Enforcement:

Violation consequence:

First violation (non-consensual content) — Permanent ban + referral
Any attempt to misuse the platform for illegal, exploitative, or trafficking-related purposes
Employee complicity — Immediate dismissal + legal action
We also reserve the right to withhold funds where trafficking is suspected (pending investigation)

9. Governance & Responsibility:

CEO / Head of Trust & Safety — final owner of this Policy
Compliance Officer — annual risk assessment + third-party audits
Board-level review — every 12 months or after any material incident

10. Legal Alignment & Jurisdictions:

This Policy aligns with:

UK Modern Slavery Act 2015 (Section 54)
California Transparency in Supply Chains Act
EU Anti-Trafficking Directive 2011/36/EU
UN Guiding Principles on Business and Human Rights

11. Contact & Questions

For legal, compliance, or partnership inquiries regarding this Policy:

Email: [email protected]