This website is owned, regulated, and operated by Bright Mobile B.V, hereinafter referred to as “we”.
1. Policy Statement
We are committed to conducting its business in a manner that is ethical, transparent, and compliant with all applicable anti-slavery and anti-trafficking laws. We are dedicated to preventing modern slavery, human trafficking, forced labour, and all forms of exploitation in every aspect of our business and supply chain.
2. Scope
This policy applies to all employees, contractors, freelancers, suppliers, and partners, including those involved in operations, customer support, moderation, and technology development. It also applies to all users of the dating platform.
3. Legal Framework
This policy is aligned with the following:
- UK Modern Slavery Act 2015 (Section 54)
- ILO Fundamental Principles and Rights at Work
- UN Guiding Principles on Business and Human Rights
- Applicable local laws in countries where we operate
4. Zero Tolerance Commitment
We have a zero-tolerance approach to modern slavery and human trafficking. This includes any activity involving coercion, deception, abuse of power, or exploitation for personal or commercial gain.
5. Risk Areas and Mitigation Measures
We acknowledge that certain functions, such as outsourced customer support and freelance moderation in jurisdictions including Ukraine and other global markets, may present elevated risks. To mitigate these risks, we will:
This includes risks arising from outsourced call center operations, especially in jurisdictions with weaker labor protections. We ensure these providers are subject to our due diligence and anti-slavery obligations.
- Identify and monitor high-risk jurisdictions using external sources (e.g., US TIP Report)
- Include anti-slavery clauses in contracts with third-party vendors and freelancers
- Prohibit recruitment fees or deposits for any worker, in line with ILO guidelines
- Implement due diligence processes for onboarding new suppliers or contractors
6. Employment Practices
We prohibit all forms of forced or bonded labour. We do not charge recruitment fees or require deposits from workers. We are in the process of updating employment and contractor agreements to include modern slavery prohibitions.
7. Platform Protection Measures
We are committed to ensuring that the platform is not used to facilitate trafficking or exploitation. To that end, we:
Interactions managed through non-human communication systems (e.g., chatbots or call center scripts) are monitored to ensure they do not facilitate coercion, exploitation, or trafficking.
- Require manual and AI-assisted moderation of all user profiles and messages
- Monitor user interactions using real-time alert systems
- Provide in-app tools for users to report suspected abuse or trafficking
- Ban underage users and profiles containing deceptive or coercive content
8. Roles and Responsibilities
The CEO is currently responsible for reviewing and escalating all reports of suspected exploitation. This role may be delegated to the Legal Counsel in due course.
9. Reporting and Escalation
Any suspicion of human trafficking or modern slavery on the platform or in the supply chain should be reported via:
All reports will be reviewed confidentially and may be escalated to law enforcement where appropriate.
10. Law Enforcement Cooperation
We have not been contacted to date by any law enforcement or NGO regarding suspected trafficking. However, we maintain a readiness to respond and escalate cases in line with legal obligations and best practice.
11. Modern Slavery Statement (UK)
If we meet the threshold under the UK Modern Slavery Act, we will publish an annual Modern Slavery Statement outlining the steps taken to prevent slavery and trafficking in our operations and supply chain.
12. Training and Awareness
We will begin rolling out internal awareness initiatives and training for key staff involved in content moderation, contractor engagement, and supplier relationships.
13. Review and Updates
This policy will be reviewed annually or more frequently if required. Updates will reflect changes in legal requirements, operational practices, or risk assessments.