1. Policy Statement
1.1 Human trafficking, otherwise known as modern slavery, is a serious criminal offence and a direct violation of Article 4 of the Universal Declaration of Human Rights. This policy lays out the expectations we have and the rules that must be followed when working with or for P14 Media with the purpose of keeping human trafficking out of our business.
1.2 Victims are often forced to work, with no regard for their physical or mental wellbeing. They are given no say in their choice of work, or manipulated into choosing work under extreme pressure. They are deprived of their liberty and freedom of movement, and are often held in a location against their will by physical or psychological means. Sometimes, they are transported illegally across international borders.
1.3 Victims are always exploited for the personal or financial gain of another person.
1.4 The adult industry is rightly secretive in nature, to protect the privacy and safety of its legitimate workers and customers. However this, combined with potentially high financial rewards makes sex work an attractive target for human traffickers. Adult media production is a high risk industry.
1.5 P14 Media has a zero tolerance policy to human trafficking within its own business, within any business with which we have a working relationship or via any other freelance or third party source including those who provide content for our services and platforms. We expect high anti human trafficking standards from all persons and businesses we work with, or which supply us regardless of their own industry.
1.6 This policy applies to: All divisions of the company. Full and part time employed staff working in any position. Agency workers. Freelance Workers. Volunteers. Contractors. External Consultants. Interns. Or any other person working for or representing the interests of P14 Media.
1.7 P14 Media is committed to acting ethically, carefully and with integrity in all our business dealings with any person, with the aim of preventing human trafficking from impacting our business.
1.8 P14 Media is committed to eradicating human trafficking from the adult industry as a whole, and will raise concerns and point out flaws in any other external area, or business, which may put the industry at risk.
2. Identifying and Mitigating
2.1 P14 Media will ensure all its procedures, policies and protocols are designed with anti human trafficking in mind.
2.2 Anti human trafficking clauses will be included in all relevant contracts produced by P14 Media.
2.3 P14 Media will ensure all staff are aware of this policy, the responsibilities they have in upholding it, and the role they play in identifying potential human trafficking within the business or from external sources.
2.4 There is no typical victim of human trafficking and while some areas of our business are at higher risk than others, attention should not be taken away from lower risk areas.
2.5 The following could be signs a person is a victim of human trafficking:
- Not being in possession of their own ID, passport, visas or travel documents.
- Acting unnatural in general conversation, as if instructed or coached to avoid certain topics or repeat certain phrases.
- Allowing others to speak for them when spoken to directly.
- Dropped off and collected from work.
- Reluctant to leave company property on their own after the workday or at break times.
- Appears withdraw or frightened.
- Shows no sign of, or does not talk about friends and family outside of work.
- Has limited social contact with people outside their own workspace.
- Little to no interest in the social lives of colleagues outside of work.
- Can not easily, or at all, remember basic details of their home life. Such as their postcode, house number or well known local landmarks.
2.6 The list above contains examples and other indicators that may be present. It is also important to remember that a person may display some of these signs and not be a victim of human trafficking.
2.7 Suspicions should be handled discretely and the potential victim should not be approached or accused directly. This could lead to further danger for the victim.
2.8 Victims of human trafficking may be vulnerable in a number of ways, and not necessarily immigrants or those with limited English skills. People from all backgrounds may also be victims of human trafficking and some may not realise themselves that they are victims.
3.1 P14 Media will not employ staff who do not possess the right to work within the UK, and can not provide proof of permanent address, contact details, national insurance number or work visa.
3.2 Final interviews for potential staff will be conducted face to face and no employment will be offered solely on the basis of a telephone call, email or chat service discussion, video chat, or agreement with a third party.
3.3 Face to face interviews will be conducted with the potential employee only, in a private location, and not involve chaperones, or any other person who does not already work for P14 Media.
3.4 All group interviews will also involve an individual private interview conducted as above.
3.5 No persons not already employed by P14 Media or seeking employment by P14 Media shall be present during group interviews.
3.6 No new employee shall commence work without personally supplying original documents supporting their ID and right to work. Photographs, photocopies or written notes are not acceptable.
3.7 Documents shall be checked for forgery by utilising the anti forgacy features on the document. For example, checking holograms are present on driving licences and passports.
3.8 Documents shall also be checked using official online methods where possible. For example checking postcodes with the post office, driving licence numbers with the DVLA and NI numbers with HMRC.
3.9 P14 Media managers are encouraged to confirm a person is living a life free from human trafficking by other online methods where possible, such as checking social media or using Google Maps to check an address is a legitimate residential property.
3.10 Even if a person is not hired. Suspicions a person is being trafficked will be reported as detailed in the reporting section below.
4. Freelance Staff and Contractors
4.1 On site freelancers and contractors will be subject to the same ID checks as employees.
4.2 Agencies and businesses supplying freelance staff or contractors will be scrutinised to ensure they have robust anti human trafficking policies in place.
5.1 The responsibility for ensuring this policy meets our ethical standards and complies with all legal obligations lies with the company’s senior management.
5.2 Any person working for, on behalf of or in partnership with P14 Media in any way, must comply with this policy.
6.1 Staff should report any concerns, worries or suspicions they have regarding potential human trafficking to senior management staff without delay. Concerns should also be raised regarding any errors in implementing this policy, ideas to better protect our business, or weak areas identified.
6.2 In the event a victim of human trafficking is suspected, or a staff member relays their concerns to a manager, the manager is expected to strictly follow the protocols laid out in their managers handbook.
6.3 Agencies, suppliers or other business partners are expected to report any suspicions of human trafficking to their P14 Media contact immediately.
6.4 Suspicions raised by employees or third parties of human trafficking will be investigated, not to confirm an offence under law, but to confirm the suspicion itself is legitimate and valid.
6.5 Suspicions of human trafficking will be reported to law enforcement officials and/or The Modern Slavery Hotline.
6.6 Any documents or evidence required to support suspicions of human trafficking will be provided to officials in line with our data protection obligations.
6.7 Any reports made under this policy will be referenced (without the inclusion of personal details) in our annual transparency statement.
7.1 This policy shall remain published and publically available on our company website.
7.2 This policy forms part of, and is referenced in all employment, freelance, and contractor contracts.
7.3 Breaches of this policy may result in disciplinary action, termination of employment, or termination of contract.
7.4 P14 Media reserves the right to terminate any contract, agreement or relationship with any supplier or other business without notice or penalty, if such business has violated this policy or found to have broken any law or legal obligation relating to human trafficking.
7.5 P14 Media may at times seek external legal advice with regards to this policy and protecting itself further from human trafficking activities.
7.6 This policy may be amended at any time.
7.7 P14 Media will take full and immediate legal action against any employee, independent worker, contractor, agency, supplier or other partner business found to have facilitated human trafficking in any area of its business.
8. Additional Commitments for Online Platform Moderation
8.1 P14 Media owns, maintains and operates online services and platforms, some of which allow user generated content or user generated links to external websites. This section applies to such services and covers our commitment to keeping them free from human trafficking or otherwise illegal content.
8.2 All services and platforms operated by P14 Media will be designated as 18+, and not for use by children, regardless of the service containing adult content or not.
8.3 All viewers of these services will either be age verified using age verification technology, or clearly warned the service may contain or link to adult content if age verification is not required or appropriate to the service.
8.4 Services which allow links to be created will be monitored by human and AI moderators and any links to illegal content, or content which could contain human trafficking, will be reported and removed.
8.5 Where possible services will not allow unverified users to upload content. Such users will be restricted to viewing content only.
8.6 To be verified, users wishing to upload content to a service which does not allow full adult material will need to confirm their email address and may be required to pass technology based age verification.
8.7 Users wishing to upload content to a service allowing full adult material will be required to pass further age verification checks, such as supplying P14 Media with government issued photo ID along with a clear facial image of the person holding the ID.
8.8 We may, at our discretion, restrict access to our services in areas of the world considered at high risk of human trafficking, if existing checks are considered insufficient and further checks unfeasible.
8.9 We will constantly monitor content for signs its creation is not consensual and investigate any user featured in such content.
8.10 If content is deemed to feature human trafficking it will be removed immediately. With all details relating to the content reported to the authorities as needed.
8.11 P14 Media will continue to look for new ways to combat human trafficking on its services and platforms through the use of awareness campaigns, moderation techniques, and embracing and developing new technologies.
Last Reviewed and Updated 15th March 2021