Modern Slavery and Anti-Trafficking Statement

1. Introduction

Corestack Digital Ltd, trading as TDolls, is committed to preventing modern slavery, human trafficking, and sexual exploitation in every aspect of our operations and in the use of our platform. We recognise that as an adult services directory operating across multiple European jurisdictions, we carry a particular responsibility to ensure that our platform is not used to facilitate harm to any person.

This statement sets out our commitment, the safeguards we have in place, how we respond to concerns, and how we work with others to address these issues. It is reviewed and updated annually.

This statement is published in fulfilment of our obligations under the UK Modern Slavery Act 2015 (applicable to our UK operations and .uk domain), equivalent obligations under Gibraltar law, and consistent with the standards expected of adult platforms under the EU Digital Services Act and related EU frameworks.

2. Our Zero Tolerance Position

Corestack Digital Ltd has zero tolerance for:

• Human trafficking in any form, including sex trafficking, labour trafficking, and debt bondage
• Forced, coerced, or non-consensual sexual services of any kind
• Sexual exploitation of any person, including through the use of technology
• Any conduct that facilitates, promotes, or profits from the above

This position is non-negotiable and applies without exception to all users of the Platform, all content hosted on the Platform, and all business relationships we maintain.

We recognise that the adult services sector can be misused by those seeking to exploit vulnerable people. We take this risk seriously and have designed our platform, policies, and operational processes with this in mind.

3. Our Business and the Risk We Address

3.1 What We Do

TDolls is an online directory and intermediary platform operating primarily in the European market. We enable self-employed adults to advertise their services and to be contacted by prospective clients. We are not an employer of service providers, a party to arrangements between providers and clients, or a provider of sexual services ourselves.

3.2 The Risk

We acknowledge that online platforms in the adult services sector carry an inherent risk of being misused to advertise or facilitate trafficking and sexual exploitation. This risk exists even where the platform operator acts in good faith. Our approach to this risk is not to deny it but to address it systematically through the safeguards described in this statement.

3.3 Who Is at Risk

The persons most at risk of harm in connection with our platform are:

• Service providers who may be operating under coercion, control, or exploitation by a third party
• Persons whose identities are being used without their knowledge or consent to create profiles
• Persons who may have been trafficked and whose services are being advertised without their free and informed consent

Our safeguards are designed specifically to identify and disrupt these scenarios.

4. Platform Safeguards

4.1 Identity and Age Verification

All Service Providers are required to complete identity and age verification before their profile is published on the Platform. This process, described in full in our Age Verification Policy, includes:

• Self-declaration of date of birth at registration
• Government-issued identity document verification via a contracted third-party verification provider
• A liveness check to confirm the person registering matches the identity document submitted

This process is designed to ensure that every profile on the Platform represents a real, identifiable adult who has voluntarily registered. Profiles that cannot be verified are not published.

4.2 Content Moderation

All content uploaded to the Platform is subject to our Content Policy and Moderation Policy. Our moderation processes are specifically designed to identify indicators of trafficking or coercion in profile content, including:

• Language or imagery suggesting control by a third party
• Multiple profiles sharing identical or near-identical content, imagery, or contact details
• Profiles that appear to be managed by someone other than the advertised person
• Content that suggests a person is not acting freely or voluntarily

Where such indicators are identified, the content is reviewed urgently and the account may be suspended pending investigation.

4.3 Behavioural Monitoring

We monitor Platform activity for patterns consistent with trafficking or exploitation, including:

• Accounts created in bulk from the same device or IP address
• Rapid creation of multiple profiles with similar characteristics
• Unusual payment patterns associated with subscription purchases
• Accounts where communication appears to be managed by a third party rather than the registered account holder

4.4 Reporting Mechanisms

We provide accessible reporting mechanisms for anyone — users, visitors, or third parties — who encounters content or behaviour that may indicate trafficking or exploitation:

• In-Platform reporting: A report button is available on every profile and content page
• Dedicated email: safeguarding@tdolls.net — monitored and responded to as a priority
• Anonymous reporting: We accept anonymous reports and will investigate them to the extent possible without identifying information

Reports of suspected trafficking or exploitation are treated as urgent and reviewed within one hour of receipt.

4.5 Staff Awareness and Training

All staff with responsibilities for moderation, customer support, or platform operations receive training on recognising indicators of human trafficking and sexual exploitation in the context of adult online platforms. This training is reviewed and updated annually.

4.6 Third-Party Due Diligence

We apply due diligence to significant third-party relationships, including our payment processor, identity verification provider, and hosting providers, to ensure they operate ethical and lawful practices. We will not maintain business relationships with organisations that we know or reasonably suspect to be involved in trafficking or exploitation.

5. How We Respond to Concerns

5.1 Internal Response

When we identify or receive a report of suspected trafficking or exploitation in connection with the Platform, we will:

1. Immediately suspend the relevant account(s) pending investigation
2. Remove or restrict access to the relevant content
3. Preserve all relevant records and evidence
4. Conduct an urgent internal review within one hour
5. Report the matter to relevant authorities (see Section 5.2)
6. Cooperate fully with any subsequent law enforcement investigation

We do not notify the account holder before taking action where we suspect trafficking or exploitation. To do so could endanger a victim or prejudice an investigation.

5.2 Reporting to Authorities

We will report suspected trafficking and exploitation to the relevant authorities without delay. Depending on the nature of the concern and the jurisdictions involved, this may include:

• Gibraltar Royal Police: For matters within Gibraltar's jurisdiction
• National Crime Agency (UK): For matters involving UK-based persons or activity
• Europol: For cross-border matters within Europe
• NCMEC (National Center for Missing and Exploited Children): For any content involving minors
• Internet Watch Foundation (IWF): For illegal online content including CSAM
• Any other relevant national law enforcement or competent authority

We maintain records of all reports made to authorities in accordance with our legal obligations.

5.3 Supporting Victims

We recognise that a person who may be a victim of trafficking or exploitation may contact us directly, may be identifiable from a report, or may come to our attention through our moderation processes. In such cases we will:

• Treat the person with care and without judgement
• Not share their information with the suspected trafficker or exploiter
• Provide information about support services where appropriate
• Cooperate with victim support organisations and law enforcement as requested

We do not provide direct victim support services. If you are in immediate danger, please contact the emergency services in your location.

6. Reporting Concerns — External Resources

If you have reason to believe that a person is being trafficked or exploited in connection with the TDolls platform or otherwise, please report your concerns to us at safeguarding@tdolls.net and to the relevant authorities.

7. Annual Review

This statement is reviewed annually by the directors of Corestack Digital Ltd. Each annual review will assess:

• Whether our safeguards remain effective and appropriate
• Any changes in the risk environment, including changes in trafficking patterns and methods
• Any incidents or reports that have occurred during the year and what they indicate about our safeguards
• Changes in applicable law or regulatory guidance
• Any improvements to our processes, training, or technology that should be implemented

The outcome of each annual review will be reflected in an updated version of this statement, which will be published at tdolls.net/modern-slavery.

8. Director Approval

This statement has been approved by the directors of Corestack Digital Ltd and reflects our commitment at the highest level of the organisation.

9. Contact

To report suspected trafficking or exploitation:

For general enquiries about this statement:

This document is version TDOLLS-MSS-v1.0. The current version is always available at tdolls.net/modern-slavery, tdolls.eu/modern-slavery, and tdolls.uk/modern-slavery.