ANTI-SLAVERY AND ANTI-TRAFFICKING

Hyper Lab LLC / Seacrets Platform

Hyper Lab LLC (“Hyper Lab”), a Delaware-registered company, owns and operates Seacrets, a digital platform that enables creators to monetize exclusive and adult content through subscriptions, pay-per-view, live streaming, and tips. Seacrets is designed to empower creators while ensuring the highest standards of safety, compliance, and user protection.

Hyper Lab is firmly committed to preventing modern slavery, human trafficking, and any form of exploitation within our platform, operations, partnerships, and supply chain. We maintain a zero-tolerance policy toward all forms of forced labor, servitude, exploitation, or human trafficking, and we continuously improve our processes to ensure a safe and compliant environment for creators, users, employees, and partners.

This statement is issued in alignment with our corporate values, responsible technology principles, and applicable legal frameworks, including the UK Modern Slavery Act, Australian Modern Slavery Act, and the California Transparency in Supply Chains Act.

Our Commitment

Hyper Lab stands unequivocally against modern slavery and human trafficking. These crimes constitute severe violations of human rights and manifest through slavery, servitude, forced labor, coercion, and trafficking. Seacrets’ mission requires that every person engaging with our platform does so freely, autonomously, and safely.

We are committed to:

• Conducting business with integrity.
• Ensuring no forced or exploitative labor is present within our direct operations or supply chain.
• Implementing strong onboarding, KYC, AML, and content safety protections.
• Treating all employees, contractors, creators, and partners with dignity.
• Operating transparently, ethically, and in full alignment with international human rights standards.

Actions Taken to Prevent, Detect, and Address Human Trafficking and Modern Slavery

During this reporting period, Hyper Lab has taken the following steps:

• Implemented mandatory training for all employees and contractors on modern slavery, trafficking risks, and safety protocols.
• Strengthened KYC, identity verification, age validation, and AML/OFAC screening.
• Enhanced content moderation capabilities, combining AI detection with trained human reviewers.
• Updated internal policies and platform guidelines to reinforce expectations of ethical conduct.
• Expanded monitoring and partner engagement with organizations committed to combating exploitation and trafficking.
• Reviewed suppliers and service providers for risk exposure and compliance alignment.

Our Policies

Hyper Lab maintains a framework of internal and platform-level policies designed to protect individuals from exploitation. These include:

• Code of Conduct and Business Ethics governing employee and contractor behavior.
• Anti-Slavery and Anti-Trafficking Policy, outlining expectations, obligations, and enforcement mechanisms.
• Terms of Service and Acceptable Use Policy, which strictly prohibit:
  • Content depicting or referencing minors, coercion, trafficking, or exploitation.
  • Content that includes other individuals without documented consent.
  • Any material promoting sex trafficking, forced labor, illegal escorting, or exploitation.
• KYC & AML Policy, requiring:
  • Verified ID
  • Biometric liveness
  • Age verification (18+)
  • AML/OFAC screening
  • Ongoing monitoring and periodic re-verification

Violations by employees, creators, or suppliers may result in termination of contracts, removal from the platform, or reporting to authorities.

Risk Assessment

Direct Operations

Our direct operational risk is considered low due to the nature of our workforce—composed primarily of skilled professionals in Costa Rica. Remote contractors may present increased risk based on geographic region, and we require all staff to complete compliance training and adhere to our Code of Conduct.

Platform and Supply Chain

1. Creator Content:
User-generated content carries inherent risks. Hyper Lab mitigates this through:

• Automated AI moderation detecting minors, coercion, violence, or exploitative elements.
• Manual review for flagged content before publication.
• Strict enforcement of consent and identity requirements.

2. Contractors and Third-Party Providers:
We rely on external vendors for KYC, AML, payout processing, fraud detection, and moderation. All are subject to contractually binding compliance requirements and periodic review.

3. Merchandise and Promotional Materials:
Where physical products are sourced, we conduct due diligence to ensure suppliers maintain ethical labor standards.

Risk Mitigation Measures

Hyper Lab continuously strengthens safeguards to prevent exploitation across the platform.

1. Creator Verification

We enforce a multi-layer identity and safety verification process, including:

• Government ID validation
• Document vs. selfie biometric comparison
• Liveness detection
• Age verification (18+)
• AML/OFAC screening
• Payment details matching to prevent third-party exploitation

High-risk jurisdictions or accounts triggering security alerts require additional selfie re-verification.

2. Content Moderation

All media uploaded to Seacrets undergoes:

• AI scanning to detect possible trafficking indicators, minors, coercion, weapons, or non-consensual acts
• Human moderator review
• Manual escalation protocols for suspected trafficking
• 24/7 monitoring capabilities

Seacrets does not use end-to-end encryption, enabling moderation of all content, including direct messages when necessary to enforce safety and compliance.

3. Contractors and Agencies

All agencies and contractors must comply with our anti-slavery policies and local labor laws. Annual training is required for all personnel working with or on behalf of Hyper Lab.

4. Community Reporting

Users may report suspicious content or activity directly through the platform. All reports are triaged by our Trust & Safety team.

5. Law Enforcement Cooperation

Any confirmed or suspected trafficking indicators are:

• Immediately escalated internally
• Reported to authorities, including NCMEC when minors may be involved
• Handled in partnership with verified organizations and NGOs

6. Technology & Operational Investments

We continuously invest in improving fraud detection, identity verification, and behavioral analysis tools to identify illicit networks and prevent their use of our platform.

Reporting Mechanisms

Hyper Lab encourages employees, creators, users, and partners to report concerns confidentially. Reports may be submitted to:

[email protected]

All credible reports are investigated promptly. Substantiated concerns may result in account suspension, removal, or vendor termination. Whistleblowers are protected from retaliation.

Our Commitment to Continuous Improvement

We recognize that modern slavery and trafficking risks evolve over time. Hyper Lab is committed to:

• Periodic risk assessments
• Updating policies based on legal and industry best practices
• Strengthening whistleblower protections
• Adjusting controls based on new threat intelligence
• Maintaining strong relationships with regulators, NGOs, and law enforcement
• Ensuring transparency in our progress and challenges

Responsibility and Oversight

The Executive Leadership of Hyper Lab LLC holds ultimate accountability for this Statement and the associated compliance program.

Management teams ensure implementation and adherence across their departments.
The Legal & Compliance Department oversees daily enforcement, training, reporting procedures, documentation, and policy updates.

This Statement is approved by the Board of Directors of Hyper Lab LLC.