Financial Year: [2024]
Publication Date: [30.03.2025.]
Applicable To: DIFUSIE and its subsidiaries.

1. Introduction

This Modern Slavery and Human Trafficking Statement outlines the steps DIFUSIE has taken to ensure that modern slavery and human trafficking are not taking place in our own operations or our supply chains. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

DIFUSIE has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2. Our Business and Structure

DIFUSIE is a digital media company that publishes a premium e-magazine focusing on film, music, sports, TV series, travel, food, drink, and luxury goods. Our primary business involves the creation of digital content and the sale of e-magazines directly through our website and via our partner platform, Patreon. Our operations are primarily digital and based in [Your Country, e.g., the United States].

3. Our Supply Chains

Our supply chains are limited and primarily consist of:

  • Digital Infrastructure Providers: Including cloud hosting services, software platform providers, and data center operators.
  • Professional Service Providers: Including legal, financial, and marketing services.
  • Payment Processors: Specifically, PayPal.
  • Publishing Partners: Specifically, Patreon Inc.

Given the nature of our business and our digital-first model, we do not have complex, multi-tiered supply chains associated with physical manufacturing or agricultural production, which are typically considered high-risk for modern slavery.

4. Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our adherence to this commitment is embodied in our internal policies, which include:

  • Ethical Code of Conduct: This code sets out our expectations for ethical behavior and requires employees to avoid any activity that might lead to, or suggest, a breach of this policy.
  • Whistleblowing Policy: We encourage all our workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, our organization. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

5. Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk, we:

  • Assess Supply Chain Risk: We continuously evaluate our limited supply chain to identify and assess potential risk areas.
  • Engage with Partners: We communicate our expectations to our key partners and service providers, requiring them to confirm their compliance with all applicable anti-slavery and human trafficking laws.
  • Leverage Reputable Providers: We prioritize partnering with large, established, and reputable technology and service providers (e.g., PayPal, Patreon) who are themselves subject to stringent regulatory environments and are expected to have their own robust anti-slavery policies.

6. Further Steps and Commitment

In the coming financial year, we commit to taking the following further steps to combat slavery and human trafficking:

  • Provide specific training on modern slavery risks and this policy to all employees with supply chain management responsibilities.
  • Incorporate specific anti-slavery clauses into our contracts with new suppliers.
  • Regularly review this statement and our related policies to ensure their continued effectiveness.

This statement is made pursuant to relevant legislation and constitutes DIFUSIE’s slavery and human trafficking statement for the current financial year.

Approval

This statement was approved by the leadership of DIFUSIE.

Name: [Dusan Nikola Ripley]
Title: [Director, Founder]
Date: [07.05.2009.]