Anti-Trafficking Policy
Noir maintains a zero-tolerance policy on human trafficking, sexual exploitation, and any form of coercion. This is our commitment to human dignity.
If you are in immediate danger or believe you are a victim of human trafficking, contact your local emergency services (911, 999, 112, or your local equivalent) immediately. International resources include the National Human Trafficking Hotline (US: 1-888-373-7888) and the EU Anti-Trafficking Helpline.
1. Our Commitment
Noir is unequivocally committed to the prevention and detection of human trafficking, sexual exploitation, and forced labor in all forms. We recognize that online platforms can be misused by bad actors, and we take active, ongoing measures to prevent our Platform from being used in connection with any form of exploitation.
We cooperate fully and proactively with law enforcement authorities worldwide. We will immediately report any confirmed or credibly suspected instance of trafficking, exploitation, or coercion to relevant authorities, including providing all available platform data in support of investigations.
2. Zero Tolerance Policy
The following are absolutely prohibited on the Noir Platform and will result in immediate, permanent account termination and reporting to law enforcement:
- Posting or operating profiles on behalf of another person without their full, informed, and freely given consent.
- Recruiting, advertising, or facilitating the trafficking of persons.
- Using force, fraud, or coercion to compel any person to create a profile or fulfill bookings.
- Using the Platform to profit from the exploitation of another person.
- Booking services for a third party without that individual's full knowledge and consent.
- Any conduct that controls, supervises, or restricts a Companion's freedom, earnings, or movements.
- Arranging bookings for persons who are minors or who lack legal capacity to consent.
- Facilitating the transport of persons for the purpose of exploitation.
3. Platform Safeguards
Identity Verification
All Companions are required to complete identity verification, including submission of government-issued identification confirming their age and identity. This procedure is designed to detect the use of false identities and to confirm that Companions are acting voluntarily on their own behalf.
Profile Monitoring
Our trust and safety team monitors profile content, booking patterns, and communications for indicators of trafficking or exploitation, including:
- Multiple profiles operating from the same device or IP address.
- Accounts receiving large volumes of bookings attributed to a single manager or agent.
- Communications suggesting coercion, script-controlled responses, or control by a third party.
- Profile content inconsistent with the identity documents on file.
- Reports from other users or third parties suggesting exploitation.
Staff Training
All Noir staff with access to platform data receive anti-trafficking awareness training and are required to report any indicators of trafficking through internal escalation procedures.
4. Red Flags We Monitor
Indicators that may suggest a Companion is being trafficked or exploited include:
- Scripts or templated responses suggesting communication is controlled by a third party.
- References to a manager, agent, or booker handling all arrangements.
- Expressions of fear, duress, or inability to speak freely.
- A pattern of bookings that suggest the individual cannot decline or control their schedule.
- Requests that the Companion's earnings be paid to a third-party account.
- Evidence of physical control, surveillance, or restriction of movement.
- Profiles operated from locations associated with known trafficking routes.
Where these indicators are present, we will pause the account, conduct an internal review, and contact appropriate authorities.
5. How to Report Suspected Trafficking
If you suspect that someone on the Platform is being trafficked, exploited, or coerced, please report it immediately through any of the following channels:
- Email our Trust & Safety team: dmca@noireliteagency.co.uk (Mark subject: TRAFFICKING REPORT — URGENT)
- Use the in-platform reporting tool on the relevant profile page.
- Contact the National Human Trafficking Hotline: 1-888-373-7888 (US) or your country's equivalent.
- Contact local law enforcement or emergency services.
- Text 'HELP' or 'INFO' to 233733 (US BeFree Hotline).
All trafficking reports are escalated immediately to senior staff and, where credible, to law enforcement. We will not suspend a report pending internal review if there is any risk to a person's safety.
6. Law Enforcement Cooperation
Noir will cooperate fully and promptly with law enforcement agencies investigating trafficking, exploitation, or related offenses. This cooperation includes:
- Providing account information, IP addresses, and communication records in response to valid legal process.
- Proactively reporting confirmed trafficking indicators to appropriate authorities without waiting for formal requests.
- Preserving evidence upon receipt of a legal hold request.
- Designating a senior point of contact for law enforcement inquiries.
7. Resources for Survivors
If you or someone you know is a survivor of trafficking or exploitation, the following resources are available:
- National Human Trafficking Hotline (US): 1-888-373-7888 — available 24/7 in 200+ languages.
- Polaris Project: polarisproject.org
- IOM — International Organization for Migration: iom.int
- ECPAT International: ecpat.org
- Local domestic violence and exploitation shelters (your national emergency number can provide referrals).
8. Policy Review
This Anti-Trafficking Policy is reviewed annually and updated as needed to reflect evolving best practices, legal requirements, and platform learnings. Questions or suggestions about this policy may be directed to dmca@noireliteagency.co.uk.