1. Our Commitment
At ModelBoard, we take a zero-tolerance approach to modern slavery, forced labor, debt bondage, and human trafficking. We are committed to acting ethically, with integrity and transparency, in all business dealings and relationships, and to complying with all applicable laws and regulations in the jurisdictions where we operate and where our users reside, including the Canadian Criminal Code and the Immigration and Refugee Protection Act (IRPA), and applicable provincial/territorial legislation in Québec.
As a digital platform connecting creators and users, we recognize our responsibility to ensure our space remains safe, consensual, and free from exploitation. ModelBoard strictly prohibits the use of our platform to recruit, advertise, facilitate, or profit from any form of forced labor or human trafficking.
2. Definitions
- "Modern slavery" includes forced labor, debt bondage, servitude, and human trafficking.
- "Creator" means any individual or entity that publishes or monetizes content on ModelBoard.
- "Minor" means any person under 18 years of age, or the age of majority where higher under applicable provincial/territorial law in Canada (the age of majority in Québec is 18).
- "Supplier" includes any third party providing goods or services to ModelBoard (e.g., web hosts, payment processors, agencies).
3. Scope of Policy
This policy applies to:
- All ModelBoard employees, directors, and contractors.
- All creators, models, and partner agencies utilizing our platform.
- All third-party suppliers, payment providers, and technology partners.
- All users of the platform, who must not engage in conduct that facilitates exploitation or trafficking.
- ModelBoard subsidiaries and affiliates.
4. Due Diligence and Safety Measures
Given the nature of our industry, we have implemented specific protocols to minimize risks of exploitation:
- Identity Verification (KYC): We mandate rigorous identity checks for every creator wishing to monetize or publish content on ModelBoard, including verification of government-issued identification, age confirmation (18+), and liveness/face-matching checks where permitted by law. We may require re-verification periodically or upon risk triggers.
- Consent and Autonomy: We actively monitor the platform for any signs indicating a creator may be acting under duress. Any content suggesting a lack of consent or coercion is immediately removed and investigated.
- Payment Transparency: Payments are remitted directly to verified creators or their legally authorized representatives. We prohibit payments to unverified third parties and may suspend or freeze payouts pending investigation where exploitation risk is identified, in accordance with applicable law and our Terms of Service.
- Onboarding and Ongoing Risk Assessment: We apply risk-based screening during onboarding and continuously monitor for indicators of trafficking (e.g., unusual account control patterns, third-party coercion, grooming signals).
- Content Moderation: We use proactive and reactive moderation, combining human review and automated detection, to identify potential exploitation, non-consensual content, or trafficking indicators.
- Data Privacy and Retention: Personal data used for verification and safety reviews is handled and retained in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws, including Québec's Act respecting the protection of personal information in the private sector (as amended by "Law 25"). We conduct privacy impact assessments where required, implement appropriate safeguards, and comply with breach notification obligations to the Commission d'accès à l'information (CAI) and affected individuals under Québec law.
5. Supply Chain Responsibility
We expect our partners (e.g., web hosts, payment services, marketing agencies) to share our commitment. We require suppliers to adhere to our Supplier Code of Conduct and to warrant compliance with applicable human rights laws. We conduct risk-based due diligence during supplier onboarding, reserve audit and information rights, and may suspend or terminate relationships where non-compliance is identified. Where applicable, we comply with Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211), including any required annual reporting, and we ensure any disclosures are available in French for Québec stakeholders as required.
6. Reporting and Whistleblower Protection
The safety of our community is everyone's business.
- How to Report: If you suspect that a creator on ModelBoard is a victim of trafficking, exploitation, or coercion, or if you have concerns regarding the ethics of one of our partners, you must report it immediately via our designated reporting channels. Concerns involving suspected child exploitation can also be reported to Cybertip.ca (https://www.cybertip.ca). Reports in Québec may also be directed to local police services or the Sûreté du Québec, as appropriate.
- Confidentiality: All reports are treated with the strictest confidentiality.
- Non-Retaliation: ModelBoard prohibits retaliation against anyone who, in good faith, raises a concern or participates in an investigation.
- Cooperation with Law Enforcement: ModelBoard is committed to cooperating fully with local and international law enforcement agencies, including local police services in Canada, the Royal Canadian Mounted Police (RCMP), and the RCMP's National Child Exploitation Crime Centre (NCECC), as well as the Sûreté du Québec where applicable in cases of suspected criminal activity related to human trafficking.
- Prioritization and Response: Reports indicating immediate safety risks or involving minors are prioritized for urgent review and escalation. Where child protection concerns arise in Québec, we cooperate with the Directeur de la protection de la jeunesse (DPJ) in accordance with applicable law.
7. Consequences of Non-Compliance
Any violation of this policy will result in immediate action, which may include:
- Immediate and permanent ban from the platform.
- Withholding of pending funds (in accordance with applicable law).
- Reporting to relevant legal authorities.
- Preservation of evidence and account records, and cooperation with lawful requests from authorities.
8. Policy Review
We review and update this policy at least annually, and more frequently as needed to adapt to new digital risks and evolving legal requirements. The Policy Owner (Compliance or Trust & Safety) is responsible for implementation, training, and periodic effectiveness assessments. In Québec, we ensure policy availability and related communications in French in accordance with the Charter of the French Language.
9. Protection of Minors
We maintain an absolute prohibition against any material that depicts, exploits, or endangers minors (anyone under the age of 18, or the age of majority where higher under applicable law).
- No Minor Participation: Minors are not permitted to create, appear in, or be depicted within content on ModelBoard. Creators must ensure all individuals featured are 18+ and may be required to provide documentation confirming the age of all participants.
- Zero Tolerance for CSAM: Any suspected child sexual abuse material (CSAM) or content involving minors is removed immediately, reported to relevant authorities in Canada (including local police/RCMP and the RCMP NCECC), and may be reported via Cybertip.ca, and the associated account permanently banned. In Québec, we escalate as required to the appropriate authorities, which may include the Sûreté du Québec and the DPJ.
- Proactive Detection and Monitoring: We employ proactive measures to detect grooming, coercion, or indicators that a person depicted may be underage or acting under duress. Suspicious activity triggers immediate review and escalation.
- Mandatory Reporting and Evidence Preservation: Reports alleging minor involvement are treated as urgent. We preserve relevant records and cooperate fully with law enforcement and child protection agencies in accordance with the Canadian Criminal Code and applicable provincial/territorial child protection laws, including collaboration with the DPJ in Québec where required.
- Creator Responsibilities: Creators must not solicit or engage with minors for content creation, and must refrain from publishing communications or materials that could facilitate exploitation or grooming.
- Staff Training: Moderation and support teams receive ongoing training in child safety, exploitation indicators, escalation protocols, and appropriate cooperation with authorities.
- Accessible Reporting Channels: Clear reporting tools are available to users and partners for concerns about minor safety. Reports related to minors are prioritized and actioned without delay.
- Record-Keeping: Where required by applicable law, we maintain age-verification and participant records and comply with relevant record-keeping and notice/reporting obligations, ensuring such records are handled in compliance with PIPEDA and applicable provincial privacy laws, including Québec's Law 25 and guidance from the CAI.
10. Training and Awareness
We provide periodic training to employees and contractors on modern slavery risks, reporting protocols, and escalation procedures, with enhanced training for Trust & Safety, moderation, and compliance personnel. Training materials and key policies are available in French for Québec personnel and stakeholders.
11. Governance and Accountability
The Board or designated executive committee oversees this policy, receives periodic risk reports, and reviews remediation actions. Management is accountable for implementing controls, conducting risk assessments, and maintaining appropriate documentation, including privacy governance required under Québec's Law 25 (e.g., appointing a person in charge of the protection of personal information and documenting policies and practices).
12. No Contractual Rights
This policy does not create contractual rights for third parties and may be updated at ModelBoard's discretion, subject to applicable law.