This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending [Date]. Although CASTD Europe is not legally required to produce this statement as we are below the £36 million turnover threshold, we are publishing it voluntarily to demonstrate our firm commitment to preventing modern slavery and human trafficking in our business operations and the ecosystem we facilitate. We believe that transparency and proactive measures are essential to upholding ethical standards and protecting vulnerable individuals within the creative industries.
Introduction
CASTD Europe ([Company legal name], Company Number: [Company number]) is a premium European creative talent marketplace headquartered in the United Kingdom. Our platform connects brands directly with a diverse range of creative professionals, including models, content creators, influencers, actors, and photographers. We are dedicated to operating ethically and with integrity in all our business dealings. We have a zero-tolerance approach to modern slavery and human trafficking and are committed to implementing and enforcing effective systems and controls to ensure that it is not taking place anywhere in our own business or in the interactions facilitated by our platform.
1. Our Organisation and Business Structure
CASTD Europe operates a digital platform accessible via our website. Our primary business is providing a subscription-based service for two user groups: 'Brands' (clients seeking talent) and 'Talent' (creative professionals). Our registered office is at [Registered address].
Our business model is built on direct connection. We do not act as an agent, manager, or employer. Instead, we provide the digital infrastructure for Brands and Talent to find each other, communicate securely, and form their own contractual agreements. Key platform features include:
- Talent profiles and digital portfolios.
- Advanced search and discovery tools.
- Secure in-platform messaging with attachment capabilities.
- Tools for managing enquiries, campaigns, and applications.
- An AI Contract Advisor to help users understand and create contracts (providing legal information, not advice).
- Subscription management handled by Stripe.
Our core team is based in the UK, and our platform is available in multiple European languages. All platform transactions are processed in GBP (£).
2. Our Supply Chains
As a technology company, our supply chain is relatively simple and primarily consists of providers of digital and professional services. We do not have complex manufacturing or physical logistics chains where modern slavery risks are often highest. Our key suppliers include:
- Cloud Hosting and Infrastructure Providers: For hosting our platform, data, and services.
- Software as a Service (SaaS) Providers: Including payment gateways (Stripe), customer support software, and analytics tools.
- Professional Services: Including legal, accounting, and consultancy firms based primarily in the UK.
- Marketing and Advertising Partners: Digital agencies and platforms used for promoting CASTD Europe.
We consider the talent on our platform to be users of our service, not part of our supply chain. However, we recognise our responsibility to safeguard the ecosystem they operate in.
3. Policies in Relation to Modern Slavery and Human Trafficking
We have established a framework of policies that underpin our approach to identifying and preventing modern slavery and human trafficking.
- Terms of Service: Our user agreement, which all Brands and Talent must accept, explicitly prohibits any illegal activity, including but not limited to coercion, exploitation, deception, and any form of human trafficking. A breach of this term can lead to immediate account suspension and termination.
- Community Guidelines: These guidelines set clear expectations for professional and ethical conduct on the platform. They forbid harassment, misleading job posts, and any behaviour that could be construed as exploitative.
- Safeguarding Policy (Minors): We recognise the particular vulnerability of minors in the creative industry. Our policy requires users under the age of 18 to have their account managed and contracts approved by a parent or legal guardian. We are exploring verification methods to strengthen this process.
- Internal Whistleblowing Policy: Our employees are encouraged and empowered to report any concerns related to the company's operations or user activities, with clear, confidential channels for doing so without fear of reprisal.
- Supplier Code of Conduct: We expect our suppliers to share our commitment to ethical practices. We prioritise working with reputable, established providers who have their own robust policies against modern slavery.
4. Due Diligence and Risk Assessment
We undertake due diligence to minimise the risk of modern slavery within our business and on our platform.
In Our Business and Supply Chains: We assess our direct suppliers by prioritising large, reputable companies (such as major cloud providers and Stripe) that are themselves subject to the Modern Slavery Act or similar international legislation and publish their own transparency statements. For smaller, critical suppliers, we communicate our ethical expectations and would not hesitate to terminate a relationship if we suspected involvement in modern slavery.
On Our Platform (Risk Assessment): The primary risk associated with our business is not in our direct operations but in the potential for our platform to be misused for exploitative purposes. We have identified the following key risk areas:
Talent Exploitation: The risk of a user posing as a legitimate 'Brand' to exploit 'Talent' through deceptive job offers, unfair contract terms, or coercion.
- Mitigation: Our secure messaging system keeps a record of communications, which can be reviewed by our administrators if a dispute or complaint is filed. Our AI Contract Advisor is designed to help talent scrutinise contracts, flagging potentially unfair clauses related to payment, usage rights, and exclusivity.
Risks to Minors: The creative industries can attract individuals seeking to exploit young and inexperienced talent.
- Mitigation: We require parental/guardian involvement for all users under 18. We do not allow private profiles for minors to be publicly searchable without explicit consent. Any reported instance of inappropriate contact with a minor is treated with the highest priority, leading to immediate investigation and potential reporting to law enforcement.
Unpaid or Unfairly Compensated Work: The risk that Talent may be pressured into unpaid work or that a Brand may default on payment.
- Mitigation: CASTD Europe does not take a commission, ensuring no financial incentive exists to drive down talent fees. Our platform promotes clear agreements through our contract tools. While we are not a party to the contract, our dispute resolution process allows Talent to report non-payment. A Brand that repeatedly fails to honour contracts will be removed from the platform.
5. Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, we will provide training to our staff. All employees, particularly those in roles such as customer support, community management, and platform moderation, will receive training on:
- The basic principles of the Modern Slavery Act 2015.
- How to identify potential red flags of human trafficking and exploitation on the platform.
- The appropriate procedures for escalating and investigating concerns.
- Our policies on safeguarding, reporting, and user conduct.
6. Measuring Effectiveness (Key Performance Indicators)
We are committed to continuously improving our approach. We will measure the effectiveness of our actions by monitoring the following KPIs:
- Number of staff who have completed modern slavery training.
- Number of user reports related to exploitation, coercion, or other serious ethical breaches.
- The time taken to investigate and resolve such reports.
- Regular reviews and updates to our Terms of Service and Community Guidelines to address emerging risks.
- Feedback from our user base on the safety and trustworthiness of the platform.
7. Reporting Concerns
We have clear channels for raising concerns. All users on our platform can use the built-in reporting tools to flag suspicious profiles, messages, or campaign postings to our admin team. Concerns can also be raised directly by contacting our Trust and Safety team at [Contact email]. All reports are treated seriously and investigated promptly and confidentially.
This statement has been approved by the board of directors and reflects our commitment to acting ethically and with integrity in all our business relationships.
Signed by:
[Director name] Director [Company legal name]
Date: [Effective date]