ANTI-SLAVERY AND ANTI-TRAFFICKING STATEMENT 2019/2020
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (“MSA”). This statement sets out the steps to be taken by Koneksi Group(“KG”) and constitutes our slavery and human trafficking statement for the current financial year.
- About Us Konekita is the social media platform revolutionising the connection between creators and fans. The site is inclusive of artists and content creators from all genres and allows them to develop authentic relationships with their fan base. Konekita gives creators the opportunity to monetise the content they want to share and how they share it in a secure environment ensuring full compliance with relevant laws, rules and regulations.
- Policy Statement Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and, taking into account our creator/fan platform structure to implementing and enforcing effective systems to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.
- Our Policies We are committed to ensuring that there are no modern slavery or human trafficking activities taking place on our platform or via our third-party suppliers. Our Anti-Slavery and Anti-Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place within the Konekita community. Konekita entered into a cooperation agreement with the NCMEC in 2020 in relation to their hash database and participate in their CyberTipline reporting system. Konekita utilises an ever expanding range of systems, including SightEngine, to monitor and review all uploaded content. We work with a range of NGOs, helplines and charities in order to support our strict policies on safeguarding. We are also engaged with the Safer Internet Centre which is a combination of SWGfL (which includes the revenge porn hotline) and ChildNet (part of the Internet Watch Foundation). Konekita is also linked into a total of 31 helplines (including the Internet Watch Foundation, the Mix, StopHateUK, the INSAFE network of helplines and the three UKSIC helplines). On discovering child sexual abuse material (CSAM) we immediately report to the relevant authorities and provide them with as much information as possible to support their investigations and their efforts to safeguard any minors. The prevention, detection and reporting of modern slavery in any part of our business or throughout our supply chain is the responsibility of all those working for us, with us or under our control. Our employees are required to avoid any activity that might lead to, or suggest, a breach of this statement. All employees are required to read, understand and comply in full with our Anti-Slavery and Anti-Trafficking Policy. Internally we brief and encourage our employees to report any concerns or wrongdoings which extends to any human rights violations like modern slavery. All reports will be fully investigated and appropriate remedial action taken. We enforce our Terms of Service and comply with our obligations as a host to remove content once reported. For our users we have a community reporting process which allows fans and creators and any concerned people to report any breaches of policy and regulations and law. This can be done by contacting [email protected] or [email protected] We have a whistleblowing policy which encourages our employees to report any concerns or wrongdoings which extends to human rights violations like modern slavery. All reports are investigated, and appropriate action taken. If any employee or user or third party raises a genuine concern, they will not suffer any detriment as a result of doing so even if they turn out to be wrong.
- Areas of Risk to KG We understand that our biggest exposure to modern slavery is within our own business. We are committed to report on key points of action that we intend to take going forward.
- The areas that we operate in could contain high risk regions and we are conscious of this.
- There are risks relating to uploading the content by our creators and the risk of material being used that is exploitative and in breach of the MSA. In order to disrupt and prevent harm we monitor all media uploaded to the platform and remove, and report where necessary, any content that facilitates or coordinates the exploitation of humans, including human trafficking. We define human trafficking as the business of depriving someone of liberty for profit. It is exploitation of humans in order to force them to engage in commercial sex, labour or other activities against their will. It relies on deceptive force or coercion.
- Our recruitment of staff.
- Our contracts with suppliers regularly specify the Act as a contractual obligation for them to comply with and we will promote a requirement that any suppliers confirm their compliance with the Act. That said we have a limited number of suppliers because of the nature of our industry. We are implementing company wide training on modern slavery to new customer facing employees and existing employees and an annual refresher for all employees and contractors the training is mandatory and is provided via an online training provider.
- Responding to Areas of Risk
- Security. We have a robust onboarding and Know-Your-Customer (KYC) process when new users join the platform to become a creator. This is a critical part of our zero tolerance policy against modern slavery. In 2020, we have added user verification methods that require user presence.
- Content Moderation. We have continued to develop the depth and sophistication of our content moderation to ensure compliance with our TofS. This has included the addition of hiring many customer service agents to review content in addition to our automated services.
- We monitor to make sure that only a creator is allowed to make an account on their own behalf. We further enforce this rule throughout their usage of the platform. We review any discrepancies between ID’s added and the Payout legal name provided.
- Community Reporting. In 2020, we have significantly expanded our Support functions to deal with any concerns or complaints from our users and from the wider community. Any reports escalated from our platform are reviewed internally by our Moderators.
- We will continue to consider and take the following actions which are appropriate and proportionate to the risk proKGe for Fenix and Konekita.
- Identify and assess any further risk areas within our business or supply chain.
- Mitigate the risk of slavery and human trafficking occurring in our business or supply chain.
- Protect whistleblowers within our business and take appropriate remedial action as needed.
- Stay up to date with any recognised changes to the MSA or related legislation. We are committed to transparency in our business and in our approach to tackling modern slavery throughout that business and any supply chains consistent with our obligations under the MSA. We expect very high standards within our business and from our users, contractors and other suppliers and we include specific prohibition against the use of force, compulsory or trafficking labour or any held in slavery or servitude whether adults or children.
- Monitoring potential risk areas and possible solutions to ensure employees, users and any third party are safe from the risk of slavery and human trafficking.
- We encourage anyone encountering content on Konekita that indicates someone is in immediate physical danger relating to human trafficking to immediately report the content to us at [email protected]
- Responsibility for the statement Our Executive Management have overall responsibility for ensuring that all those under our control comply with this statement and our related policies. Management at all levels are responsible for ensuring their teams understand this statement and comply with our Anti-Slavery and Anti-Trafficking Policy. The KG Legal Team have primary and day to day responsibility for dealing with this statement and any queries about it and considering internal control systems and procedures to ensure they are effective in countering modern slavery.
- Training Training on the risks KG faces from modern slavery in our business and if appropriate our supply chain are mandatory for all key individuals who work for KG and is provided annually. Our approach to modern slavery will continue to be communicated throughout our business and to any suppliers at the outset of any business relationship with them and shall be reinforced as appropriate thereafter. We are committed to maintaining and improving our practices to combat slavery and human trafficking. This statement has been approved by the Board of KG.