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Modern Slavery and Human Trafficking Statement

Effective: 25 May 2026 Version: 1.0 Basis: Modern Slavery Act 2015. Although Eternal Elegance Models Limited is below the £36 million turnover threshold at which a statement is legally mandated, we publish this statement proactively as a commitment to ethical practice and industry standards.

1. Our commitment

Modern slavery is a crime and a violation of fundamental human rights. Eternal Elegance Models Limited ("the Agency") has a zero-tolerance approach to modern slavery and human trafficking in any form — including forced labour, servitude, debt bondage, human trafficking, child labour, and 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 in our business or in our supply chains.

2. Our business and structure

The Agency is a UK-registered modelling agency (Company No. 17115788, England and Wales) operating the Eternal Elegance platform. We represent self-employed models for fashion, commercial, editorial, and runway work in the UK and internationally.

Our workforce consists of:

  • A small team of agency staff (Bookers, Finance Admins, Platform Admins) engaged on employment contracts or consultancy terms under UK law
  • Self-employed models, photographers, and designers who use the Eternal Elegance platform

Our clients are primarily UK and international brands, fashion houses, and production companies.

3. Our supply chains

Our supply chains include:

  • Technology providers — cloud hosting (Google Cloud Platform), authentication (Google Identity Platform), payments (Stripe), identity verification (Veriff), e-signature (self-hosted DocuSeal), transactional email (Resend), AI services (Anthropic)
  • Professional services — legal, accounting, insurance, audit
  • Creative supply chain — photographers, designers, and other creatives who engage with models booked through the platform

4. Key risks we monitor

We recognise that the modelling and fashion industries have historical risks around:

  • Exploitation of young or inexperienced models — we mitigate this by enforcing a strict 18+ age policy, two-stage identity verification, and human-in-the-loop approval of all new accounts
  • Coercion through financial pressure — the Employment Agencies Act 1973 prohibits charging models fees for work-finding; we comply strictly, and no model-side fees are possible on our platform
  • Unsafe working conditions — we mandate safety check-in/check-out, welfare provisions in booking contracts, and chaperone accommodation where required under the Equality Act 2010
  • Trafficking and forced work — identity verification via Veriff (including face-match) ensures the person engaging with us is the person whose identity is being used, reducing the risk of identity misuse
  • Supply-chain exploitation — we select suppliers with demonstrable human rights commitments and review our exposure annually

5. Policies

In addition to this statement, the following policies support our modern slavery commitment:

  • Code of Conduct — explicit prohibitions on coercion, harassment, and exploitation; safeguarding language for all users
  • Acceptable Use Policy — prohibits illegal content, trafficking-related material, and exploitation
  • Privacy Policy — explicit consent-based processing; strong identity verification
  • Complaints Procedure — clear route for any individual to raise safeguarding concerns

6. Due diligence and risk assessment

Our due diligence processes include:

6.1 User onboarding

  • Two-stage approval for all talent and provider accounts — human pre-approval before paid verification, then independent Veriff identity check, then final human-in-the-loop approval by a different Booker (separation of duties)
  • Veriff identity verification for all models and providers — document authenticity check, biometric face-match
  • Age verification (18+) — under-18 applicants are automatically rejected
  • Code of Conduct acceptance is mandatory before account activation

6.2 Ongoing monitoring

  • Portfolio content review by the Portfolio Review Agent with human-in-the-loop for flagged content
  • Safety check-in / check-out on every booking
  • Misconduct reporting with triage and investigation
  • Complaints procedure with SLA-bound response times

6.3 Supplier selection

  • We prefer suppliers who publish their own modern slavery statements or demonstrable commitments
  • Cloud and technology providers used are subject to established commercial governance frameworks
  • Insurance and banking suppliers are regulated entities in the UK or EEA

7. Training

Agency staff receive training on:

  • Identifying signs of modern slavery and human trafficking
  • Safeguarding principles and escalation pathways
  • The Code of Conduct, Complaints Procedure, and their operational role in both
  • Equality Act 2010 awareness and reasonable adjustments
  • GDPR and data subject rights

Training is refreshed at least annually.

8. Reporting concerns

Anyone — a model, provider, Brand user, staff member, third party, or member of the public — can raise a modern slavery concern via:

  • The platform Complaints Procedure — use the complaints form at eternalelegancemodels.com/complaint
  • In an emergency, contact the police directly (999 in the UK)
  • The Modern Slavery Helpline: 08000 121 700

All reports are treated confidentially and investigated promptly. Retaliation against a person who raises a concern in good faith is itself a material breach of the Code of Conduct.

9. Effectiveness and review

We measure the effectiveness of our modern slavery policies by:

  • Number and nature of safeguarding concerns raised
  • Outcomes of identity verification checks (rejection rates, suspicious patterns)
  • Compliance audit findings
  • Regulatory engagement (ICO, Employment Agency Standards Inspectorate)

This statement is reviewed annually by the Agency's directors. We will update it to reflect changes in our business, supply chains, risk profile, and legal obligations.

10. Approval

This statement has been approved by the Board of Directors of Eternal Elegance Models Limited and is signed on behalf of the Board.

Signed: Ainsley Bilton Name: Ainsley Bilton Title: Director Date: 25 May 2026

Eternal Elegance — Modern Slavery Statement | Version 1.0 | Eternal Elegance Models Limited | Company No. 17115788