This document is published by PAC INVEST, a limited company registered in Paris under number 952824787, whose registered office is located at 10 rue de penthievre, 75008, PARIS - France, (hereinafter "the Operator", "We" or "Dropfeet") as part of our commitments to its payment services partners providing Creators, through it, with payment services. It is addressed to all users of the Dropfeet Platform, including subscribers, Internet users, Creators, Ambassadors and partner agencies (hereinafter "Users", or "You").
Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, such as slavery, servitude, forced and compulsory labor and all forms of human trafficking, all of which have in common the deprivation of one person's freedom by another in order to exploit them for personal or commercial gain. Dropfeet has a zero-tolerance approach to modern slavery and all forms of exploitation of people in situations of weakness, and is committed to acting ethically and with integrity in all its transactions and business relationships, and to implementing and enforcing effective systems and controls to minimize the risk of modern slavery, whether within our company, with our partners and other subcontractors, or among our creators. We are also committed to ensuring the transparency of our own business and the processes put in place to combat modern slavery. We expect the same level of intransigence from all our designers, suppliers and other business partners.
Thus, as part of our contractual processes, we include specific prohibitions against the use of forced, compulsory or trafficked labor, or any person held in slavery or servitude, whether adults or children, and we expect our suppliers to impose the same standards on their own suppliers. This policy applies to all persons working for us, with us or on our behalf, in any capacity whatsoever, including employees at all levels, directors, managers, temporary workers, seconded workers, volunteers, trainees, agents, contractors, external consultants, third-party representatives and business partners.
RESPONSABILITY
Dropfeet has overall responsibility for ensuring that this policy complies with our legal and ethical obligations, and that all those with whom it is associated comply with it. We are responsible for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure that they are effective in combating modern slavery. Management at all levels must ensure that their employees and other representatives understand and comply with this policy, and receive adequate and regular training on it and on the issue of modern slavery in supply chains. You are invited to comment on this policy and suggest ways of improving it. Comments, suggestions and questions are encouraged and should be addressed to legal@Dropfeet.com.
Details of this policy towards Creators
Dropfeet intends to combat any form of human trafficking that may be linked, directly or indirectly, to the content provided by the creators referenced on its platform. In this respect, Dropfeet systematically verifies the age and consent of people who may appear on content.
In practice, Dropfeet :
All Creator candidates must provide proof of identity, as well as a real-time selfie to show that they have reached the age of majority and have given their consent. This data is processed and authenticated by an artificial intelligence solution.
Dropfeet seeks to ensure that any person who appears in content published on its platform and who is not the Creator himself is of legal age and consents to the content representing him being broadcast on its platform. Each Creator is thus contractually bound to guarantee and to be able to prove that any person who may appear in one of his/her contents is of legal age and that he/she formally agrees that the content in which he/she appears may be broadcast and marketed on Dropfeet. In addition, Dropfeet uses an artificial intelligence solution to analyze all content uploaded by creators, in order to automatically detect potentially illicit elements. If a creator uploads content featuring several third parties, he or she is required to provide proof of these people's consent (assignment of image rights and authorization to distribute). In addition, during random checks, creators may be required to provide proof of consent and majority of a third party appearing in content. Finally, Dropfeet requires any agency that presents itself as the agent of a creator registered on the platform to :
The same applies to Ambassadors registered on Dropfeet, who must, at the end of the General Terms and Conditions of Sponsorship, sign and accept without reservation the present Anti-exploitation Policy.
Policy compliance
You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of modern slavery is the responsibility of everyone who works with us or under our control. You are expected to avoid any activity that may lead to or suggest a breach of this policy. You must inform your line manager OR your Dropfeet contact as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. We encourage you to raise concerns about any issues or suspicions of modern slavery with any of our designers, ambassadors, or business partners as soon as possible. If you are unsure whether a particular act, the treatment of workers in general, or their working conditions at any level of our supply chains constitute one of the various forms of modern slavery, raise the issue with your line manager or by writing to legal@Dropfeet.com.
We wish to encourage open-mindedness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be wrong. We are committed to ensuring that no one suffers detrimental treatment for reporting in good faith their suspicion that modern slavery, in any form, is or may be practiced in any part of our business or in any of our supply chains. Adverse treatment includes dismissal, disciplinary action, threats, termination of established business relationships or any other adverse treatment related to raising a query or concern. This policy and declaration on modern slavery and all forms of human trafficking is addressed to designers, ambassadors, agencies and companies in all countries.
Communicating and raising awareness of this policy
Any employee, ambassador or designer working with us may be offered training on this policy and on the risk our company faces as a result of modern slavery. Our zero-tolerance approach to modern slavery must be communicated to everyone working for or with us.
If you believe or suspect that a breach of this policy has occurred or may occur, we invite you to :
inform your line manager or the head of your company, who will contact our own departments; report it to legal@Dropfeet.com.
Violation of this policy
Any employee who breaches this policy may be subject to disciplinary action, which may result in dismissal for misconduct or gross misconduct. Similarly, any offence involving modern slavery or any form of human trafficking may give rise to measures restricting contractual relations with the ambassador or designer concerned.