Anti‑Trafficking and Safeguarding Policy

Zero‑Tolerance Policy on Trafficking, Exploitation and Violence; Protocols for Prevention, Detection, Reporting and Protection

Anti‑Trafficking and Safeguarding Policy — Katrina Elite

Effective date: [16/10/2025]

1. Objective and scope

The purpose of this Policy is to set out Katrina Elite’s commitment and procedures to prevent, detect, report and respond to any indication or situation of human trafficking, sexual exploitation, violence or violation of human rights related to the Platform’s activity. It applies to all Agency personnel, models, collaborators, suppliers, contractors and third parties involved in the operation. This policy complements other Platform policies (Terms and Conditions, Privacy Policy, Verification and Security Policy, Conduct and Services Policy).

2. Zero‑Tolerance Principle

Katrina Elite declares zero tolerance towards human trafficking, sexual exploitation, debt bondage, coercion, trafficking and any conduct that undermines liberty, dignity or human rights. Any indication will be investigated and, where appropriate, reported to the competent authorities.

3. Legal framework and institutional cooperation (Colombia)

Katrina Elite is committed to complying with applicable Colombian law and to cooperating with competent authorities in Colombia: the Fiscalía General de la Nación, Policía Nacional and other bodies responsible for the protection of human rights. The Agency will also seek to establish cooperation channels and referral protocols with organisations specialised in victim support and trafficking prevention.

4. Guiding principles of the policy

• • Prevention and due diligence: apply reasonable controls to reduce risks of trafficking and exploitation.
  • Early detection: training and procedures to identify risk indicators.
  • Victim protection: prioritise the safety, health and rights of the affected person.
  • Confidentiality and privacy: handle information discreetly and in accordance with the Privacy Policy.
  • No re‑victimisation: avoid actions that may harm or re‑victimise the person.
  • Cooperation: coordinate with authorities and specialised entities.
  • Transparency and accountability: record and document incidents and actions taken.

5. Basic definitions (practical effect)

• • Human trafficking: recruitment, transport, transfer, harbouring or receipt of persons by means of threat, use of force or other forms of coercion for the purpose of exploitation.
  • Sexual exploitation: the sexual use of another person in exchange for money or other consideration.
  • Victim: a person who suffers trafficking, exploitation or any form of coercion or abuse.
  • Risk indicator / alert: any objective sign that permits suspicion of a situation of vulnerability or exploitation.

6. Warning signs (non‑exhaustive indicators)

During onboarding, interaction with profiles or booking coordination, pay attention to signs such as:

• • Inconsistencies between documents and photographs or difficulty in producing identification.
  • Photos or profiles duplicated across different websites or on suspicious marketplaces.
  • Messages controlled by third parties (an intermediary answering for the purported model and preventing direct communication).
  • Restrictions on movement or evidence of coercion (the person avoids speaking alone, cannot set their own terms, appears watched).
  • Requests for payments to third‑party accounts or unidentified intermediaries.
  • Physical signs of violence, injuries or indications of mistreatment.
  • Contradictions in personal history or statements made during interviews.
  • Presence of minors in images or in the profile information.
  • Offers of “packages” or organisations managing multiple profiles under suspicious conditions.

Detection of one or more signals does not prove trafficking, but requires activation of the verification and security protocol.

7. Preventive measures (controls and due diligence)

• • Rigorous onboarding: identity verification, photographic checks and video‑call interview; document registration.
  • Due diligence of suppliers: contractual clauses and vetting of partners and photographers to avoid exploitation chains.
  • Limitation of intermediaries: where possible, maintain direct communication between the model and the Agency; when intermediaries exist, document their identity and relationship.
  • Continuous training: mandatory training for staff on detection of trafficking signs and reporting protocols.
  • Periodic re‑verification: regular photo updates and checks to detect suspicious changes.
  • Transparent payment policy: avoid recommending payments to anonymous intermediaries; promote transfer traceability where appropriate.
  • Contract clauses: include anti‑exploitation clauses in contracts with photographers, agencies and providers.

8. Operational procedure upon indication or complaint (basic process)

Phase 1 — Activation and immediate containment

• • If an employee, model or user detects a risk signal: notify immediately the Security/Privacy Officer (seguridad@katrinaelite.com / privacidad@katrinaelite.com).
  • Initial internal assessment (24 hours): determine severity and immediate risk to the person.
  • Containment measures: suspend publication of the profile or set it to hidden mode, restrict access and communications, and preserve evidence (logs, messages, files) with chain of custody.

Phase 2 — Protection and assistance to the potential victim

• • Secure contact with the affected person (always prioritising their safety and consent): offer assistance, inform about rights and options.
  • Referral to support services: if the person accepts, facilitate contact with NGOs, helplines and medical/psychological/legal services.
  • If there is evident risk or consent to report: prepare a report and submit it to the competent authorities, providing support in the communication.

Phase 3 — Investigation and formal reporting

• • Documentation: record facts, evidence and actions taken in a reserved internal file.
  • Report to authorities: if appropriate and based on the assessment, report to the Fiscalía / Police and cooperate with the investigation.
  • Communication and follow‑up: inform involved parties of the investigation status as permitted and maintain support for the victim.

Phase 4 — Resolution, corrective measures and lessons learned

• • Adopt administrative and contractual measures against implicated third parties (blocking, contract termination).
  • Review controls and update policies.
  • Final report and closure of the file with a record of actions and results.

9. Confidentiality protection and data handling during the process

• • All information collected in a suspicion file is treated as confidential, accessible only to authorised personnel.
  • When reporting to authorities, only the necessary information will be shared and in accordance with the law or after obtaining the victim’s consent, except where there is a legal obligation to report without consent.
  • The Privacy Policy will be strictly applied with respect to retention, access and deletion of data.

10. Reporting channels and contact mechanisms

• • Secure email: seguridad@katrinaelite.com / privacidad@katrinaelite.com (mark subject "URGENT: possible trafficking case").
  • Confidential hotline (recommended): a 24/7 telephone number for anonymous or urgent reports (contract external service if appropriate).
  • Anonymous reporting: enable an anonymous reporting option for employees and users.
  • Victim contacts: provide contacts for NGOs and referral centres to facilitate appropriate assistance.

11. Cooperation with authorities and referral to specialised services

• • The Agency will cooperate with the Fiscalía General de la Nación, Policía Nacional and other authorities when required.
  • Katrina Elite will proactively seek agreements with organisations and victim support centres (NGOs, helplines, medical and legal services) to enable rapid and appropriate referrals.
  • Documenting agreements (MOUs) with entities providing victim support is recommended.

12. Protection and non‑retaliation

• • The Agency guarantees non‑persecution and non‑retaliation against persons who report in good faith indications of trafficking or exploitation. Any retaliation will be sanctioned and may give rise to disciplinary or legal measures.
  • If a person fears for their safety, the Agency will offer appropriate protection measures and secure communication alternatives.

13. Recording, traceability and retention of reports

• • All incidents will be recorded in a secure system with: date, reporting person, summary of facts, evidence, actions taken and outcome.
  • Retention periods: files will be kept in accordance with the Privacy Policy and applicable law, taking into account the need to preserve evidence for authorities.

14. Sanctions and disciplinary measures

• • Upon verification of conduct involving exploitation, trafficking or abuse, the Agency will apply internal sanctions that may include expulsion from the platform, contract termination and criminal reporting.
  • Contracts or relationships with third parties that facilitate illicit practices will be terminated and legal actions initiated.

15. Training, awareness and capacity building

• • Mandatory training for staff on detection of trafficking, warning signs and reporting protocols. Frequency: at least annually and upon induction.
  • Training materials for models: guides on personal safety, risk detection, reporting channels and their rights.
  • Drills and updates: annual practical exercises to test procedures.

16. Additional preventive measures and supplier due diligence

• • Include anti‑trafficking clauses in contracts with photographers, agencies, suppliers and third parties.
  • Periodic evaluation of higher‑risk suppliers and random audits.
  • Avoid commercial relationships with intermediaries that refuse reasonable verifications.

17. Review and continuous improvement

• • This Policy will be reviewed annually and whenever processes change or new threats are identified.
  • Feedback from internal and external stakeholders (NGOs / authorities) will be encouraged to improve procedures.

18. Organisational responsibilities

• • Security/Prevention Officer: coordinates receipt of reports, initial investigation and communication with authorities.
  • Privacy Officer: ensures confidential handling and compliance with data protection rules.
  • Executive Management: decides on disciplinary measures, institutional cooperation and allocation of resources.
  • Staff: obligation to report risk indicators and to cooperate with protocols without delay.

19. Resources and victim support (operational recommendations)

• • Prepare a referral pack: contacts for local NGOs, medical services, legal and psychological assistance.
  • Accompaniment: offer Agency support in communications with authorities if the victim requests it.
  • Immediate protection: when there is imminent risk, prioritise measures to guarantee the person’s physical safety (do not expose the victim through the Agency’s actions).

20. Contact for reports and enquiries

• • Confidential channel: seguridad@katrinaelite.com
  • Privacy and support: privacidad@katrinaelite.com
  • Phone/WhatsApp for assistance: +57 (316) 040-7830
  • In case of imminent risk, contact local authorities: Policía Nacional / Fiscalía General de la Nación.