Anti-Slavery & Human Trafficking Policy

1. Our Commitment

Swingable, owned and operated by Entity Promotions LTD (company number NI721452, registered in Northern Ireland), has a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude, child exploitation, and any form of human exploitation. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our own business, our platform, or our supply chains.

Entity Promotions LTD is below the annual turnover threshold at which a statement is required under section 54 of the Modern Slavery Act 2015. We publish this statement voluntarily, applying the same standards, and will publish a section 54 statement if and when the threshold applies to us.

2. Scope

This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, third-party representatives, and business partners. It also applies to all members and users of the Swingable platform.

3. Our Business and Platform

Swingable operates an invite-only social platform for the adult lifestyle community in the United Kingdom and Ireland. Our only physical supply chain is print-on-demand merchandise produced by a third-party fulfilment partner; we expect that partner to uphold equivalent standards and we will cease working with any supplier found to be involved in forced labour. Our platform is restricted to adults aged 18 and over.

We use rigorous identity and photo verification, device fingerprinting, and human moderation to ensure that only genuine adult members can participate. Any account suspected of being operated under coercion or used to exploit another person will be immediately suspended and reported to the relevant authorities.

4. Prohibited Activity

The following activities are strictly prohibited on Swingable and will result in immediate and permanent removal from the platform, as well as referral to law enforcement and relevant safeguarding agencies:

• Any form of human trafficking, smuggling, or facilitation thereof
• Forced labour, servitude, or debt bondage
• Sexual exploitation, coercion, or solicitation of any kind
• The sale or commercial exchange of sexual services
• Child sexual abuse material (CSAM) or content depicting any person under 18
• Recruitment, grooming, or transportation of persons for the purpose of exploitation
• Operating an account on behalf of, or under coercion of, another person
• Advertising or arranging meetings that involve any element of exploitation or trafficking

5. Our Supply Chain

We work with a small number of carefully selected third-party suppliers, primarily for cloud infrastructure, payment processing, identity verification, and communications. We expect all of our suppliers to adhere to standards consistent with our own and to comply with the Modern Slavery Act 2015. We reserve the right to terminate any supplier relationship where modern slavery practices are identified.

6. Due Diligence and Risk Assessment

We take the following steps to identify and mitigate the risk of modern slavery:

• Mandatory photo and identity verification before members can access core platform features
• Device fingerprinting and account-creation limits to prevent coercive multi-account use
• Trained human moderators reviewing reports, profiles, and content daily
• Clear reporting tools allowing members to flag suspected exploitation
• Cooperation with the National Crime Agency, the Modern Slavery Helpline, and police forces
• Periodic review of suppliers to ensure ongoing compliance

7. Training and Awareness

All moderators and staff are trained to recognise the signs of modern slavery and human trafficking, including indicators of coercion, grooming, and exploitation. Refresher training is provided regularly and our internal procedures are updated to reflect emerging risks.

8. Reporting Concerns

If you suspect that any member, supplier, or contact of Swingable is involved in or a victim of modern slavery, you must report it immediately:

• Use the in-app report tool on any profile, post, or message
• Email us directly at admin@swingable.co.uk
• Call the UK Modern Slavery Helpline on 08000 121 700 (24 hours)
• In an emergency, always call 999

All reports are treated confidentially. We do not tolerate retaliation against anyone who raises a genuine concern in good faith.

9. Responsibility and Governance

The directors of Entity Promotions LTD have overall responsibility for ensuring this policy complies with our legal and ethical obligations. The Head of Trust and Safety is responsible for its implementation, monitoring its use and effectiveness, and reviewing internal control systems to ensure they are effective in countering modern slavery.

10. Review & Board Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Entity Promotions LTD's slavery and human trafficking statement for the financial year ending 31 March 2026. It was approved by the board of directors of Entity Promotions LTD and signed on their behalf by the Director on 19 July 2026. This policy is reviewed annually and updated as required to reflect changes in our business, applicable legislation, and best practice. Any material changes will be published on this page.

11. Contact

Questions about this policy should be directed to:

Entity Promotions LTD
Email: admin@swingable.co.uk

12. Website & Marketing Provider

Website development and all marketing activity for Swingable are handled by Fubar Marketing (www.fubar.marketing) as a service provider to Entity Promotions LTD. Fubar Marketing is contractually required to uphold the same anti-slavery and human trafficking standards set out in this policy.