Human Trafficking Policy
The Erotic Review (www.theeroticreview.com), and the company that owns it, No Excuses Agents LTD (collectively, “TER,” “us,” or “we”) strictly prohibits employees, subcontractors, subcontractor employees, and agents from engaging in human trafficking- related activities. These activities include engaging in sex trafficking, procuring commercial sex acts (even if this practice is legal in the jurisdiction where it transpires), using force, fraud, or coercion to subject a person to involuntary servitude, or obtaining labor from a person by threats of serious harm to that person or another person, among others.
No Excuses Agents LTD also prohibits employees, subcontractors, subcontractor employees, and agents from engaging in practices relating to trafficking in persons, including:
No Excuses Agents LTD will take appropriate disciplinary action for violations of these rules, up to and including discharge of employees, subcontractors, and agents.
No Excuses Agents LTD must cooperate fully with the Cyprus Government or other appropriate governmental authorities in audits or investigations relating to such violations. Employees of No Excuses Agents LTD are required to cooperate in any internal or external investigation of suspected wrongdoing under this policy.
Mandatory Reporting Requirements.
Employees having knowledge of credible information concerning actual or potential violations of this policy must report them immediately in accordance with the No Excuses Agents Escalation Procedure. Timeliness of reporting any suspected violation is critical as the European Union under Directive 2011/36/ EU has imposed an especially stringent reporting obligation when there is credible information of violations. Failure to report actual or potential illegal behaviour or actual or potential violations of this policy may also subject employees to disciplinary action, up to and including termination of employment.
No Excuses Agents LTD has many channels available to receive reports of possible violations of policy. However, given the immediacy of our notification requirements to the Cyprus government, possible violations of this policy should be reported directly to the Office of combating trafficking in human beings (+35722808063 / +35722808573 / +35722808552). Employees may also report possible violations to line management, human resources, compliance professionals throughout the organization, the General Counsel and members of No Excuses Agents LTD . Any person who receives reports of possible violations under this policy must notify Corporate Internal Audit immediately. When making a report, employees are encouraged to share as much information as possible so that appropriate action can be taken.
In addition to the reporting requirements described above, it is possible for No Excuses Agents LTD employees to report activity inconsistent with this policy to a third-party managed hotline. Such reporting does not satisfy an employee’s obligation to report to No Excuses Agents LTD credible information concerning actual or potential violations of this policy immediately, in accordance with the No Excuses Agents LTD Escalation Procedure.
No Excuses Agents LTD do not tolerate retaliation or threats of retaliation against anyone who raises a concern under this policy or who assists with an internal or governmental audit or investigation. Any employee who engages in retaliation or threats of retaliation will face disciplinary action, which could include termination of employment.
Destroying or otherwise denying access to an employee’s identity or immigration documents;
Using misleading or fraudulent practices to recruit employees, such as failing to disclose key terms and conditions of employment;
Using recruiters that do not comply with local labor laws;
Charging employees recruitment fees;
Failing to provide an employment contract or work document where required by law.