Anti-Slavery & Anti-Trafficking Statement 2024

PlayHouse International Pty Ltd, the operator of the website PlayHouse (www.playhouse.fans) ("PlayHouse" or the "Company"), is committed to the fight against modern slavery. We are dedicated to building a safe social media platform and have zero tolerance for modern slavery or human trafficking in any form, including on our platform, in our partnerships, or in our supply chain.

This statement is made in accordance with our Company's values and goals, and in compliance with the Australian Modern Slavery Act, UK Modern Slavery Act, and the California Transparency in Supply Chains Act. It outlines the steps taken by PlayHouse to ensure that modern slavery and human trafficking are not taking place in our business operations, partnerships, and supply chains.

Our Commitment

PlayHouse is firmly opposed to all forms of modern slavery and human trafficking. These practices are crimes and violations of fundamental human rights. They encompass various forms such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person's liberty for personal or commercial exploitation.

We are committed to acting with integrity and mitigating the risk of modern slavery and human trafficking in our business relationships with creators, fans, employees, partners, and vendors. We prioritise the safety, well-being, and dignity of all individuals, ensuring safe working conditions, ethical operations, and environmental responsibility.

Steps Taken to Prevent, Detect, and Report Modern Slavery and Human Trafficking Risks

We have taken the following actions:

  • Implemented company-wide mandatory training on modern slavery and trafficking.
  • Established company-wide policies and procedures outlining acceptable business practices and ethical conduct.
  • Conducted a comprehensive review of our supply chain to identify and mitigate risks related to modern slavery and human trafficking.
  • Made significant investments to enhance our content moderation processes, including the recruitment of specialised resources.
  • Appointed an independent monitor to review and enhance our safety controls and compliance program.
  • Strengthened partnerships with third-party organisations dedicated to combating modern slavery and human trafficking.
Our Policies

PlayHouse is committed to taking all reasonable and appropriate steps to ensure that modern slavery or human trafficking activities do not occur on our platform, in our business operations, or in our supply chain.

  • We have a Code of Conduct & Business Ethics that sets clear expectations for all employees, requiring them to act with integrity and exercise good judgement while complying with all applicable laws, rules, and regulations, including those related to modern slavery and human trafficking. This Code is also shared with key suppliers and contractors.
  • Our Anti-Slavery and Anti-Trafficking Statement reflects our overarching commitment to combating modern slavery and human trafficking. It outlines concrete actions we take to mitigate risks and provides channels for reporting suspected instances of modern slavery or human trafficking.
  • Our Terms of Service and Acceptable Use Policy explicitly prohibit the uploading, posting, displaying, or publishing of content on PlayHouse that:
    • Shows, includes, or refers to any other individual without obtaining written consent from each individual to use their name or images; or
    • Shows, promotes, advertises, or refers to unlawful escort services, sex trafficking, or unlawful prostitution.

We strive to hold our employees and suppliers to high standards, and any violation of our policies by an employee or supplier can result in disciplinary action or contract termination, respectively.

Our Risk Assessment

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

  1. Our Direct Business Operations
    We consider the risks of modern slavery and human trafficking to be relatively low in our direct business operations. Our workforce is primarily composed of professionally qualified or skilled personnel. However, we acknowledge that employing contractors outside of Australia, United States of America and the United Kingdom may present slightly higher risks. We ensure that our entire workforce is aware of these risks and our stance on these issues. We maintain open channels for reporting any suspected instances of modern slavery or human trafficking.
  2. Our Platform and Supply Chain
    Creator Content:
    Similar to other social media platforms, there are risks associated with the content created by our users. We are vigilant in monitoring media uploaded to our platform to prevent and detect any content that facilitates or coordinates the exploitation of individuals, including modern slavery and human trafficking.
    Contractors and Third Parties: We engage contractors, temporary staff, and third-party suppliers to support our platform services, including user verification and content moderation. While we have stringent requirements and policies in place, there is a potential risk of non-compliance with relevant laws or our policies by these parties.
    Merchandise: We procure promotional merchandise for marketing purposes, which may be manufactured by workforces at higher risk of exploitation. We acknowledge that the garment manufacturing industry has the potential for modern slavery and human trafficking. We prioritise partnerships with suppliers who align with our policies against modern slavery and human trafficking and ensure their adherence to our Code of Conduct & Business Ethics, Terms of Service, and Acceptable Use Policy.
Our Risk Mitigation Efforts

To mitigate identified risks, we have implemented the following measures:

Creator Verification: We conduct thorough checks on identity and payment details for each creator account application to ensure accounts are created by the rightful individuals. We employ technological safeguards to prevent unauthorised changes to creator payment details, ensuring direct payments from PlayHouse to the creators.

Content Moderation: Our content moderation processes are designed to prevent and swiftly remove any content that may facilitate or indicate modern slavery or human trafficking. We continuously enhance our content moderation capabilities, employing state-of-the-art digital technologies and trained human moderators to review and remove content that violates our policies.

Contractor or Agency Staff: We include contractual obligations for agencies and temporary staff to comply with relevant laws and our policies against modern slavery and human trafficking. We provide annual training to all employees on these issues through an online training provider.

Merchandise: When entering into agreements with manufacturers, we assess their compliance with our policies against modern slavery and human trafficking. We consider provisions from our Code of Conduct & Business Ethics, Terms of Service, Acceptable Use Policy, and this Anti-Slavery and Anti-Trafficking Statement.

Community Reporting: We encourage users to report any concerns or complaints related to modern slavery or human trafficking through our reporting mechanisms. Reports are internally reviewed by our moderators, and we take immediate action upon substantiation of the reported concerns.

Law Enforcement Collaboration: If we identify content indicating modern slavery or human trafficking, we suspend associated accounts and share relevant information with law enforcement and non-governmental organisations to aid in identifying perpetrators.

Investments and Partnerships: We invest in technology and operations to detect and combat content related to human exploitation. We collaborate with NGOs, helplines, and charities to support our policies and work closely with organisations such as the National Center for Missing & Exploited Children (NCMEC) to report and combat modern slavery and human trafficking.

Transparency & Reporting: PlayHouse is committed to transparency and regularly publishes data to verify the steps we are taking. Our Transparency Reports provide detailed information on our efforts and can be accessed on our platform. We also engage an independent third-party monitor to audit our safety controls and compliance program.

Our Reporting Mechanisms

We foster a culture of transparency, accountability, and reporting within our organisation. We encourage employees, users, and stakeholders to report any concerns, including potential violations of laws or our policies related to modern slavery and human trafficking. Concerns can be reported via email to [email protected].

Upon receiving a report, we promptly investigate and take appropriate action. Whistleblowers are protected, and confidentiality is maintained throughout the process.

Our Ongoing Commitment to Continuous Improvement

The fight against modern slavery and human trafficking is an ongoing and evolving challenge. PlayHouse is dedicated to continuous improvement and will consider and take the following actions:

(a) Identify and assess additional risk areas within our business and supply chain.

(b) Mitigate the risk of modern slavery and human trafficking through robust measures.

(c) Protect whistleblowers and take remedial action as necessary.

(d) Stay informed of changes to relevant laws and regulations, including the Australian Modern Slavery Act and UK Modern Slavery Act, and adjust our practices accordingly.

(e) Monitor potential risk areas and implement suitable solutions to safeguard employees, users, and third parties.

(f) Continually review and improve our processes and controls based on the changing risk landscape.

Responsibility for this Statement

The Executive Leadership of PlayHouse International Pty Ltd holds overall responsibility for ensuring compliance with this statement and related policies. Management at all levels is responsible for ensuring understanding and compliance with our anti-slavery and anti-trafficking policies and procedures. Our Legal team is primarily responsible for overseeing the principles outlined in this statement, addressing inquiries, and assessing the effectiveness of internal control systems and procedures to counter modern slavery and human trafficking.

This statement has been approved by the Board of PlayHouse International Pty Ltd.

Signed by

William O’Halloran

Founder and CEO

PlayHouse International Pty Ltd (operator of PlayHouse.fans)