Modern Slavery & Human Trafficking Policy – EroticNovel.app

Effective Date: December 2025

1. Introduction

This Modern Slavery & Human Trafficking Policy explains the measures taken by
Tiro Alp Advertising SRL (“the Company”, “we”) to prevent all forms of
modern slavery, forced labour and human trafficking in our operations and supply chain.
We maintain a strict zero-tolerance approach toward exploitation, forced labour or abuse.

2. Our Business

Tiro Alp Advertising SRL operates EroticNovel.app, a digital-only service
that provides AI-generated storytelling experiences for adults.
We do not manufacture physical goods, do not operate warehouses and do not engage in
industrial production.

Our supply chain consists primarily of hosting providers, cloud infrastructure services,
technology vendors and professional service contractors. The overall risk of modern slavery
within this type of digital service environment is considered low, but we remain fully
committed to monitoring and mitigating any potential risks.

3. Our Commitment

We are committed to:

  • Preventing any form of slavery, bonded labour, forced labour or human trafficking.
  • Conducting business with integrity and respect for human rights.
  • Reviewing our suppliers to ensure compliance with legal and ethical standards.
  • Responding promptly to any credible concerns or reports of exploitation.

4. Legal Framework

This Policy aligns with applicable international human rights standards and relevant
Romanian and EU legislation addressing modern slavery, exploitation and trafficking.
Where we work with partners in other jurisdictions, we expect them to comply with local
law and, at a minimum, with the principles set out in this Policy.

5. Risk Assessment

Given the nature of our digital services, the risk of modern slavery within our direct
operations is assessed as low. However, we recognise that risk can exist within any
supply chain, particularly in:

  • Data centre and hosting infrastructure providers;
  • Third-party technology and SaaS vendors;
  • External contractors and outsourced services.

We review our key suppliers and partners periodically, taking into account their geographic
location, industry sector and publicly available information regarding ethical practices.

6. Suppliers and Third Parties

We expect all suppliers, contractors and partners who work with EroticNovel.app to:

  • Comply with all applicable laws on labour, employment and human rights;
  • Prohibit the use of forced, bonded or involuntary labour of any kind;
  • Prohibit child labour and ensure that minimum working age laws are respected;
  • Provide safe and fair working conditions, including fair wages and reasonable hours;
  • Allow workers freedom of movement and freedom to leave employment with reasonable notice.

Where appropriate, we may ask suppliers to confirm their own modern slavery policies or
provide contract clauses requiring compliance with these standards.

7. Employees and Internal Practices

All staff engaged by Tiro Alp Advertising SRL are employed under written agreements that
comply with Romanian and EU labour laws. We do not charge recruitment fees and do not
confiscate identity documents or apply any practices that could create conditions of
forced or bonded labour.

We aim to foster an internal culture where exploitation and abuse are never tolerated.
Employees are encouraged to raise concerns in good faith without fear of retaliation.

8. Training and Awareness

Given the size of our organisation, formal training programmes are proportionate and
focused on key people involved in supplier management, compliance and legal matters.
Those individuals are made aware of:

  • The indicators of modern slavery and human trafficking;
  • How to escalate concerns or suspected cases;
  • Our obligations towards users, employees and third parties.

9. Reporting Concerns

Anyone who has concerns about possible modern slavery or human trafficking related to
EroticNovel.app, our suppliers or our partners is strongly encouraged to report this.
Reports can be made confidentially to:

We will review all credible reports, take appropriate action where necessary and cooperate
with competent authorities in line with legal requirements.

10. Review of this Policy

This Modern Slavery & Human Trafficking Policy is reviewed periodically and may be
updated to reflect changes in law, our business operations or best practices. The latest
version will always be available on EroticNovel.app.

By using EroticNovel.app, you acknowledge that this Policy forms part of the broader
governance and compliance framework of Tiro Alp Advertising SRL and complements our
Terms & Conditions and Privacy Policy.