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    Anti - Slavery Policy

    Last Updated

    BOSA GROUP S.R.L., a Romanian legal entity, registered at the Trade Register Office attached to the Bucharest Tribunal under no. J2024012889404, having a unique registration code 50305303, headquartered in Bucharest, 3rd District, Sector 3, 317. Calea Călărași street, 1st floor, ap. 2, room nr. 8, e-mail: info@bosagroups.com, sole licensee of the website www.escogram.com , (hereinafter referred to as EscoGram), is acting ethically and with integrity and doing what can reasonably be done in order to ensure that modern slavery and human trafficking are not occurring in our business, in our partnerships or our supply chains. Bosa Group S.R.L. conducts its business by complying to the provisions of Modern Slavery Act 2015, European Convention on Human Rights and of EU Directive 20111/36/EU on preventing and combating trafficking in human beings and protecting its victims.

    1.INTRODUCTION

    1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour institutions and practices similar to slavery, and human trafficking.

    1.2 Forced labour represents all work or service exacted under menace of penalty for which the person has not offered themselves voluntarily, except compulsory military service, normal civic obligations, work exacted as a result of a court conviction, work in times of emergency, and minor communal services. Forced labour usually also involves unacceptably low pay, poor working conditions or excessive wage deductions. In case the perpetrator is taking advantage of a child or vulnerable person, it is considered forced labour even without the element of coercion.

    1.3 Modern slavery can also present in the form of servitude, which means the obligation to perform services for others imposed by use of coercion, an aggravated form of forced labour falling short of slavery. This typically involves victims working in a private family home where they are ill treated, humiliated, subjected to unbearable conditions or working hours or made to work for little or no pay. Again, it is very difficult for them to leave, for example because of threats, the perpetrator holding their passport, or using a position of power over the victim.

    1.4 Another form of slavery is the human trafficking, which is the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation includes the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs.

    1.5 Companies can be implicated in modern slavery both directly and indirectly in a variety of ways: in their own operations, through their global supply chains and through their involvement with business partners.

    2.DEFINITIONS

    In this document, the following terms shall mean:

    2.1 User means that person who accesses EscoGram and who is interested in the services provided by Bosa Group S.R.L. and/or who registers in order to use the services provided by Bosa Group S.R.L, has read and accepts the provisions of this policy;

    2.2 Client means a User who follows a Model and is able to view the Model’s content;

    2.3 Model means a User who has set up his/her EscoGram account to post content on EscoGram to be viewed by Clients; Model’s content may be freely available or pay-per-view on the basis of free and autonomous choice of the Model.

    3. ANTI-SLAVERY PROCEDURES

    3.1 Bosa Group S.R.L. encourages openness and guarantees that no person shall suffer detrimental treatment for reporting a genuine concern about modern slavery, human trafficking, other breaches of law or unethical practices that they suspect are occurring.
    3.2 Anti-slavery statement
    3.2.1 Bosa Group S.R.L. hereby makes a clear statement that the company takes the responsibilities to help root out modern slavery and human trafficking both within the business and in the supply chains seriously.
    3.2.2 All employees, consultants, contractors, partners and directors of Bosa Group S.R.L are aware of this Policy and to whom it applies.
    3.2.3 By accepting this Anti-slavery Policy, all Users of EscoGram declare that they understand and agree with this Policy and undertake to comply with its provisions.
    3.3 Supply chains
    3.3.1 Bosa Group S.R.L. regularly checks its supply chain to reduce the potential for slavery and human trafficking.
    3.3.2 Bosa Group S.R.L. informs its business partners that the company is not prepared to accept any form of exploitation. All significant supplier agreements and all agreements concluded with the Models, should contain an anti-slavery clause.
    3.3.3 Suppliers who do not share Bosa Group S.R.L.’s commitment to stamping out slavery and human trafficking will not be selected as business partners.
    3.3.4 Bosa Group S.R.L.’s business partners and Users shall comply with all applicable laws relating to anti-slavery and human trafficking and warrant that they:
    a. have not committed an offence under any applicable laws;
    b. have not been notified that they are subject to an investigation relating to an alleged offence or prosecution under any applicable laws;
    c. are aware of any circumstances within their supply chain that could give rise to an investigation relating to an alleged offence or prosecution under applicable laws.
    3.3.5 Otherwise, the business partner and Users shall notify Bosa Group S.R.L. immediately in writing if it becomes aware or has reason to believe that it and/or any of its personnel (when applicable) has breached or potentially breached this Anti-slavery Policy and the anti-slavery clause provided by the agreement, when applicable. Any notice shall set out full details of the circumstances concerning the breach or potential breach of this Anti-slavery Policy and of the agreement, when applicable.
    3.4 Identifying slavery
    3.4.1 There is no typical victim, and some victims do not understand they have been exploited and are entitled to help and support.
    3.4.2 However, there are key signs that could indicate that someone may be a slavery or trafficking victim, including, but not limited to:
    a. The person is not in possession of their own passport, identification or travel documents;
    b. The person is acting as though they are being instructed or coached by someone else;
    c. They allow others to speak for them when spoken to directly;
    d. They are dropped off and collected from work;
    e. The person is withdrawn or they appear frightened;
    f. The person does not seem to be able to contact friends or family freely;
    g. The person has limited social interaction or contact with people outside their immediate environment.
    3.5 Prohibitions
    3.5.1 Bosa Group S.R.L. specifically prohibits the uploading, posting, displaying, or publishing of content on EscoGram that:
    a. shows, includes or refers to any other individual unless written consent is obtained from each individual to use their name or images (or both) in the content; or
    b. shows, promotes, advertises or refers to escort services, sex trafficking and/ or prostitution.
    3.5.2 It is strictly forbidden to form a contract, through EscoGram, between any Client and a Model regarding escort or prostitution services. EscoGram is not, and cannot be considered, a mediator, intermediary, or party to any agreements between the Client, Model and any other individual regarding the escort or prostitution services.
    3.5.3 The solicitation, promotion, and facilitation of prostitution and sex trafficking are strictly prohibited. If a User engages in such activity, whether on EscoGram or by posting links to external websites that promote or facilitate prostitution or sex trafficking, Bosa Group S.R.L. may delete your account without refunding and/or paying out any funds in the account at the time of the offense or deletion.
    3.5.4 Bosa Group S.R.L. prohibits pornographic content involving minors known as child sexual abuse material. Bosa Group S.R.L. only allows visual media of consenting adults for consenting adults on EscoGram. If a User sees any visual media, real or simulated, depicting minors engaged in sexual activity within EscoGram, please promptly report this to Bosa Group S.R.L. Including all appropriate evidence, the date and time of identification is necessary. Bosa Group S.R.L. will promptly investigate all reports and take appropriate action. Bosa Group S.R.L. fully cooperates with any law-enforcement agency investigating CSAM.

    4. REPORTING SLAVERY

    4.1 The prevention, detection and reporting of modern slavery in any part of the business or supply chains is the responsibility of all those working with Bosa Group S.R.L. or under the company’s control.
    4.2 Bosa Group S.R.L. encourages raising concerns about any issue or suspicion of modern slavery in any parts of the business or supply chains of any supplier tier at the earliest possible stage.
    4.3 In case there is a suspicion that someone is in immediate danger, the recommendation is to call the police. Otherwise, these concerns should be notified to Bosa Group S.R.L. before taking any further action using the following e-mail address: info@escogram.com.
    4.4 Bosa Group S.R.L. aims to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. Bosa Group S.R.L. will not charge, discipline, demote, suspend, threaten or in any manner discriminate against any person who reports in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of the supply chains.
    4.5 Any person who believes suffering such treatment in any activity related to EscoGram should inform the Bosa Group S.R.L.
    4.6 Anyone reporting under this Policy must be acting in good faith and have an honest belief that the report is well founded. Any reports based on allegations without basis or that are proven to be intentionally misleading, malicious or for personal will be regarded as a serious offense and might be subject to termination of the agreement and/or cancellation of membership, if applicable.

    5. AMENDMENT OF ANTI – SLAVERY PROCEDURE

    5.1 Bosa Group S.R.L. will review this Anti-slavery Policy regularly and has the right to amend or supplement the this Policy accordingly at any time.
    5.2 Such revision will be notified by changing the Last Updated date. After the date on which the updated policy is published, accessing the site will represent the User’s acceptance of the respective updated conditions.