1. Introduction
EOTT Ltd, a company incorporated in England & Wales, owns and operates the website BangGuys (www.bangguys.com) (“BangGuys”, the “Company”, “we”, “our”, or “us”), a platform that enables verified adult creators to share and monetise lawful content and that connects them with fans.
BangGuys is committed to operating one of the safest adult content platforms in the industry. We do not tolerate modern slavery or human trafficking in any form — on our platform, in our partnerships, or in our supply chain.
This statement is made in line with the UK Modern Slavery Act 2015 and comparable legislation, including the Australian Modern Slavery Act 2018 and the California Transparency in Supply Chains Act, to the extent applicable to the Company. It sets out the steps we take to seek to ensure that modern slavery and human trafficking are not taking place in our operations, partnerships, or supply chains.
2. Our Commitment
BangGuys stands against all forms of modern slavery and human trafficking. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms — including slavery, servitude, forced or compulsory labour, and human trafficking — all of which involve depriving a person of their liberty in order to exploit them for personal or commercial gain.
We are committed to acting with integrity and to mitigating the risk of modern slavery and human trafficking in our dealings and relationships with creators, fans, employees, partners, and vendors. We are committed to treating everyone we work with respectfully and with dignity, ensuring safe working conditions, and conducting ethical operations.
3. Steps We Take to Prevent, Detect and Report Risks
Our programme to combat modern slavery and human trafficking includes the following measures:
• providing training to relevant personnel on identifying and responding to modern slavery and trafficking;
• issuing policies and procedures setting out acceptable business practices and ethical conduct;
• reviewing our supply chain to identify and mitigate risks;
• investing in content moderation, including specialist resources and detection technology;
• reviewing our safety controls and compliance programme on an ongoing basis; and
• engaging with third parties and organisations that work to combat modern slavery and human trafficking.
Note: Specific factual claims — such as the appointment of an independent monitor, the frequency of mandatory training, or membership of particular reporting schemes — should only be stated as completed facts where they are accurate for EOTT Ltd. Adjust this section to reflect the measures actually in place.
4. Our Policies
We take reasonable and appropriate steps to ensure that no modern slavery or human trafficking takes place on our platform, in our business, or in our supply chain. Our framework includes:
• Code of Conduct & Business Ethics: setting our expectation that everyone acting for the Company complies with applicable laws, including those addressing modern slavery and trafficking. This is shared with key suppliers and contractors.
• This Statement: setting out our overarching commitment, the concrete actions we take, and the channels for reporting suspected modern slavery or trafficking.
• Terms & Conditions and Community Guidelines: which prohibit content that depicts any individual without their written consent, or that shows, promotes, advertises, or refers to sex trafficking, exploitation, coerced sex work, or prostitution.
Violations of our standards by an employee may result in disciplinary action up to termination of employment; violations by a supplier may result in termination of the contract.
5. Our Risk Assessment
We assess modern slavery and human trafficking risks across our business by identifying and analysing higher-risk areas, drawing on external reports, standards, and country and sector risk profiles, and we adjust our processes and controls as risks change.
5.1 Direct Business Operations
We consider the risks in our direct operations to be relatively low, as our workforce is largely made up of skilled and professionally qualified personnel. Where we engage contractors outside the United Kingdom, the risk may be slightly higher; we make our workforce aware of these risks and of how to report any suspected modern slavery or trafficking.
5.2 Platform and Supply Chain
• Creator content: as with any user-generated-content platform, there is a risk of exploitative material being uploaded in breach of law and our policies.
• Contractors and third parties: we may use contractors and third-party suppliers for services such as verification and content moderation, who could breach laws or our policies.
• Merchandise: where promotional or sale merchandise is procured, garment and goods manufacturing can carry elevated risks relating to working conditions, wages, hours, and freedom of association.
6. Our Risk Mitigation Efforts
6.1 Creator Verification
We check identity and payment details for each creator account application so that individuals can only create an account on their own behalf. We look for discrepancies between identity documents and the legal name on payment methods, and we apply safeguards to protect payout details, so that creators receive payments directly from us. In higher-risk situations or where an account is flagged, we may require additional “selfie” verification, including at login.
6.2 Content Moderation
To prevent and detect harm, we review media uploaded to the platform and remove — and report where necessary — content that facilitates or coordinates the exploitation of people, including modern slavery and human trafficking. Moderators are trained to identify and promptly escalate suspected indicators. We may use detection technologies and comparison against recognised industry and law-enforcement databases as part of this process, followed by human review. We can review and remove any image or video shared on the platform, including in direct messages.
6.3 Contractors and Agency Staff
We include contractual obligations requiring agencies and temporary staff to comply with applicable laws and our policies on modern slavery and trafficking, and we provide training to relevant personnel.
6.4 Merchandise
When entering commercial agreements with manufacturers, we take account of our Code of Conduct & Business Ethics, Terms & Conditions, Community Guidelines, and this Statement to ensure alignment with our policies against modern slavery and trafficking.
6.5 Community Reporting
Each post and account can be reported. Reports are reviewed internally by our moderators. Anyone who encounters content indicating that a person may be in immediate physical danger relating to trafficking should report it to us immediately at bg_sup@bangguys.com, and should contact local emergency services where there is an immediate threat to life.
6.6 Assisting Law Enforcement
Where we identify content containing indicators of modern slavery or human trafficking, we suspend the associated account and pass relevant information to law enforcement and appropriate organisations to help identify those responsible.
6.7 Investments and Partnerships
We continue to invest in our ability to detect content related to human exploitation and to identify and disrupt the actors and networks that perpetrate it. We seek to work with NGOs, helplines, and charities, including participating in recognised reporting systems such as those operated by the National Center for Missing & Exploited Children (NCMEC), where applicable.
6.8 Transparency and Reporting
We take responsibility for our actions and intend to publish data on the steps we take in our Transparency Reports, available on the Website.
7. Our Reporting Mechanisms
We foster a culture of transparency, honesty, and accountability that encourages reporting of any concerns or wrongdoing, including human-rights violations, modern slavery, and human trafficking.
If you have any concerns or suspect a violation of any law by the Company — whether by employees, contractors, agency staff, or any third party acting on our behalf — please report it by email to bg_sup@bangguys.com.
Where a concern is raised about a supplier or contractor, we will coordinate with appropriate stakeholders to investigate and address it. If a reported concern is substantiated, corrective action will be taken, up to and including termination.
8. Our Ongoing Commitment to Continuous Improvement
Modern slavery and human trafficking are complex challenges. Our efforts to combat them are ongoing and continually improving, and our approach is communicated throughout our business and to suppliers, both at the outset and periodically. We are committed to taking the following actions, proportionate to our risk profile:
• identifying and assessing further risk areas within our business and supply chain;
• mitigating the risk of modern slavery and trafficking occurring;
• protecting whistleblowers and taking appropriate remedial action;
• keeping up to date with the UK Modern Slavery Act and other relevant legislation; and
• monitoring potential risk areas and solutions to keep employees, users, and third parties safe.
9. Responsibility for This Statement
Our executive leadership has overall responsibility for ensuring that those under our control comply with this statement and our related policies. Management at all levels is responsible for ensuring their teams understand and comply with our anti-slavery and anti-trafficking policies and procedures. Our legal function has day-to-day responsibility for overseeing the principles in this statement, addressing queries, and reviewing internal controls to ensure they are effective.
This statement has been approved by the leadership of EOTT Ltd.
Signed:
Martin B.
Director, EOTT Ltd (operator of BangGuys.com)
Date: 29 June 2026
Note on required details: The company registration number and registered-office address of EOTT Ltd should be inserted here, and the financial period covered by this statement should be specified, as required under the UK Modern Slavery Act.