Introduction

VerticalScope Inc. and its subsidiaries (collectively “VerticalScope”, “we”, “us”, and “our”) are committed to ensuring a safe and secure online environment for our users and keeping our websites, mobile or other applications and platforms (collectively, “Platforms”) free of child sexual abuse and exploitation (“CSAE”). We have a zero-tolerance policy across our Platforms for any sexual or suggestive content involving minors (i.e., persons less than 18 years old), including child sexual abuse material (“CSAM”) and actively work to prevent, detect, report, and remove any such content from our Platforms.

This policy (the “Policy”) outlines our approach to preventing, identifying, reporting, and removing CSAM, and ensuring compliance with legal obligations and industry best practices to combat child exploitation.

Prohibited Content

We strictly prohibit the use of our Platforms for any form of child endangerment, abuse, or exploitation. This includes, but is not limited to, the following:

• Predatory Behavior Towards Children - We do not allow any content, activity, or interaction that involves or facilitates predatory behavior toward children. This includes, but is not limited to:
• Child grooming (e.g., befriending a child online to facilitate, either online or offline, sexual contact and/or exchanging sexual imagery with that child).
• Sexualization of a minor (e.g., media or text that depicts, encourages or facilitates the sexual exploitation of children, including altered or artificial imagery).
• Sextortion (e.g., threatening or blackmailing a child by using intimate images, real or alleged).
• Child trafficking (e.g., advertising or solicitation of a child for commercial sexual exploitation).
• CSAM and Exploitation Content - The following is strictly prohibited:
• Posting, sharing, or distributing any media (images, videos, text, links) that depicts, facilitates, or encourages the sexual exploitation of minors.
• Any attempt to solicit, distribute, or trade CSAM.
• Any content that violates child protection laws and regulations, regardless of jurisdiction.

We enforce permanent bans for any individual found to be engaging in or attempting any of the above activities, and we promptly report all such violations to law enforcement.

Compliance with Industry Standards

As described in the following sections of this Policy, we strictly adhere to industry best practices and platform policies regarding child safety. This includes:

• Prohibiting any content that sexualizes minors or exploits children in any manner.
• Ensuring that all user-generated content is pro-actively moderated to prevent CSAM.
• Providing clear reporting mechanisms for users to flag inappropriate content.
• Implementing strict enforcement measures against violators, including permanent account bans and reports to law enforcement.

Detection and Reporting Mechanisms

To combat the presence of CSAM on our Platforms, we employ a combination of:

• Automated Detection: We use state-of-the-art technology to scan for known CSAM using robust hashing techniques and AI-driven detection tools.
• User Reporting: Users can report content directly through:
• In-Platform Reporting Tools: Available on our Platforms for quick and easy reporting.
• Dedicated Abuse Reporting Channels: Our Trust & Safety team is directly accessible via csam-reporting@verticalscope.com.
• Moderator Review: Our trained Trust & Safety team immediately investigates all reported CSAM content and takes immediate action in accordance with this Policy.

Our Trust & Safety Team

To ensure swift and effective handling of CSAM incidents, we have a designated Trust & Safety team responsible for monitoring and enforcing compliance with this Policy, collaborating with law enforcement on child exploitation matters, and responding to CSAM reports.

Users can report suspected CSAM directly through our reporting tools or contact csam-reporting@verticalscope.com.

Response to CSAM Incidents

Upon detection of CSAM, we execute a strict protocol that involves the following steps:

• Immediate Removal: Any CSAM is immediately removed from the applicable Platform.
• Reporting to Authorities: We promptly report confirmed CSAM cases to the appropriate legal and child protection agencies in accordance with applicable laws and regulations. This includes the National Center for Missing & Exploited Children (NCMEC) in the United States and the Royal Canadian Mounted Police (RCMP) in Canada.
• Account Actions: Users responsible for posting CSAM will be permanently banned, and their account details may be shared with relevant agencies to aid investigations and law enforcement for potential prosecution.
• Legal Compliance: We fully cooperate with law enforcement agencies and comply with all applicable legal requirements regarding CSAM investigations.

Continuous Improvement

We continuously evaluate and improve our CSAM detection and reporting processes by:

• Keeping up to date with cutting-edge CSAM detection technologies to enhance detection capabilities and enforcement.
• Refining our policies and practices in response to emerging threats and evolving compliance requirements. We commit to regularly reviewing and updating this Policy to address new threats, evolving legal requirements, and advancements in technology.

Conclusion

VerticalScope recognizes the importance of maintaining a safe digital space free from CSAM or any content that facilitates child exploitation. VerticalScope’s Platforms are not intended for minors; however, we remain steadfast in our commitment to proactively prevent and address CSAM through the use of cutting-edge technology, the application of our strict policies, collaborating with law enforcement and child protection organizations and ensuring strict compliance with legal obligations. We encourage our users to report any suspected CSAM

For inquiries regarding this Policy, please contact our Trust & Safety team at csam-reporting@verticalscope.com.

Adopted: March 12, 2025