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Code of Conduct

Effective date: [Effective Date] · Last updated: October 11, 2026

Draft boilerplate pending legal review. Bracketed items are placeholders.

This page brings together the following policies.

  1. Ethics and Code of Conduct
  2. Non-Discrimination Policy
  3. Whistleblower Policy
  4. Modern Slavery Statement

1. Ethics and Code of Conduct

At [Legal Entity Name], operating as Neon Orchid at neonorchid.app, we hold ourselves to rigorous ethical standards in supporting independent adult content creators. This Ethics and Code of Conduct establishes our core operational principles, outlining our unwavering commitment to creator autonomy, ethical technology deployment, financial transparency, and strict data privacy compliance.

1.1 Purpose and Scope

This Code of Conduct applies universally to all directors, officers, employees, independent contractors, and representatives of [Legal Entity Name]. Neon Orchid operates as a talent management agency, payments advisory provider, and technology service partner for independent creators active on platforms such as OnlyFans and Fansly.

Compliance with the standards set forth in this document is mandatory for all personnel and partners associated with our operations. Failure to adhere to these ethical principles may result in immediate disciplinary action, up to and including termination of employment or business contracts. We conduct our business in strict accordance with the laws of [Jurisdiction].

1.2 Creator Autonomy and Empowerment

We believe that independent adult content creators (18+) retain the absolute right to control their creative output, intellectual property, brand identity, and career direction. Neon Orchid acts solely as an agency and operational partner, and we never claim ownership over a creator's personal accounts, content libraries, or core assets.

Our talent management services are entirely voluntary. Creators maintain the freedom to manage their professional trajectories and terminate representation agreements in accordance with the agreed terms established in their individual contracts with [Legal Entity Name].

1.3 Ethical Artificial Intelligence and Likeness Standards

Neon Orchid provides specialized technology services, including consented AI likeness models and creator infrastructure tools designed to scale independent businesses. We strictly prohibit the creation, deployment, or monetization of any artificial intelligence likeness without explicit, verifiable, and fully documented consent from the respective creator.

We maintain a zero tolerance policy for non-consensual synthetic media, unauthorized digital replicas, or deceptive deepfakes. All technology services deployed through our platform require rigorous authentication procedures, clear usage boundaries, and ongoing creator oversight to protect individual likeness rights.

1.4 Financial Integrity and Transparency

Our payments advisory and payment operations support services are built on a foundation of absolute clarity and fairness. We ensure that all fee structures, administrative charges, and revenue-sharing agreements are fully disclosed to creators prior to the execution of any formal business relationship.

We operate in compliance with applicable financial regulations, implementing robust anti-fraud and anti-money laundering protocols to protect all transactions. [Legal Entity Name] maintains secure financial recordkeeping standards consistent with the requirements of [Jurisdiction].

1.5 Data Privacy and Global Compliance

Our website at neonorchid.app functions as a marketing hub and application portal collecting names, email addresses, platform handles, stated interests, and free-text business goals. We treat all prospective and active creator data with the utmost confidentiality and administrative security.

Depending on your geographic location, we adhere to recognized international privacy frameworks, including the General Data Protection Regulation (GDPR), the UK Data Protection Act, and the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). Users may exercise their privacy rights by contacting our designated privacy team at [Email].

1.6 Professional Conduct and Workplace Safety

Neon Orchid is committed to fostering a safe, professional, and inclusive environment for all staff members, corporate partners, and represented creators. We strictly prohibit any form of discrimination, harassment, or hostile behavior based on race, gender, sexual orientation, background, or personal beliefs.

All professional interactions involving our agency must be conducted with mutual respect and ethical integrity. We prohibit unauthorized conflicts of interest that could compromise our duty of care to creators or undermine our administrative standards.

1.7 Reporting Violations and Enforcement

If you suspect, observe, or experience a violation of this Ethics and Code of Conduct, you are strongly encouraged to report the incident immediately. [Legal Entity Name] maintains a confidential reporting process designed to protect individuals who speak up in good faith.

Reports may be submitted directly to our compliance department or to our designated custodian of records, [Custodian of Records Name], via email at [Email] or by postal mail at our registered address: [Registered Address]. We investigate all reported concerns promptly and implement appropriate corrective measures.

2. Non-Discrimination Policy

At Neon Orchid, operated by [Legal Entity Name], a [State] [entity type] located at [Registered Address], we are firmly committed to maintaining an environment free from discrimination, harassment, and bias. This Non-Discrimination Policy outlines our standards across talent management, technology services, and business operations conducted via neonorchid.app.

2.1 Commitment to Equal Opportunity

Neon Orchid prohibits unlawful discrimination against any independent creator, applicant, employee, or business partner. We embrace diversity across all aspects of our organization and ensure fair treatment for everyone interacting with our digital platform and services.

2.2 Scope of Policy

This policy applies to all business activities conducted by Neon Orchid. This includes our talent management agency services for independent adult content creators on platforms such as OnlyFans and Fansly, payments advisory, payment-operations support, and technology services including consented AI likeness models, audience data tools, and creator infrastructure.

3. Whistleblower Policy

This Whistleblower Policy establishes the formal procedures for reporting suspected violations of law, ethics, or company policy at Neon Orchid, operated by [Legal Entity Name].

3.1 Purpose and Scope

[Legal Entity Name] and its subsidiaries operating as Neon Orchid are committed to maintaining the highest standards of integrity, transparency, and legal compliance. This policy applies to all employees, contractors, independent adult content creators, and business partners associated with our talent management, payments advisory, and technology services.

The scope of this policy includes reporting any serious concerns regarding unlawful conduct, financial malfeasance, breaches of privacy regulations, or gross operational failures related to the neonorchid.app platform and associated services.

3.2 Reporting Channels and Procedures

Individuals who observe or suspect a violation are encouraged to report the matter immediately. Reports can be submitted through designated confidential communication channels managed by [Legal Entity Name].

Submissions may be sent electronically via email to [Email] or delivered in physical form to our registered office located at [Registered Address], addressed to the attention of [Custodian of Records Name].

3.3 Confidentiality and Privacy Safeguards

[Legal Entity Name] handles all reports with strict confidentiality. Information concerning the identity of the reporting individual and the specifics of the investigation will be restricted to individuals who have a legitimate need to know.

Where applicable under international and domestic frameworks, such as GDPR in the European Union or state regulations in [Jurisdiction], privacy rights of both reporters and respondents will be fully respected throughout the review process.

3.4 Prohibition of Retaliation

Neon Orchid strictly prohibits retaliation of any kind against any individual who reports a suspected violation in good faith. Good faith does not require that the reporting party be certain of the facts, but it does require that the report is made honestly and without malicious intent.

Any employee, contractor, or partner who engages in retaliatory behavior against a whistleblower will face immediate disciplinary action, which may include termination of employment or cancellation of commercial agreements.

3.5 Investigation and Review Process

Upon receiving a formal report, [Legal Entity Name] will initiate a prompt, objective, and thorough review. Investigations will be managed by qualified personnel or independent legal counsel designated by management to ensure complete impartiality.

The investigative process includes gathering relevant evidence, interviewing pertinent individuals, and documenting findings in a formal compliance record.

3.6 Corrective Actions and Enforcement

If an investigation determines that a violation has occurred, [Legal Entity Name] will take swift and appropriate remedial action. Such actions are designed to correct the underlying issue and prevent recurrence.

Depending on the severity of the violation, measures may include revising internal procedures, retraining personnel, terminating business contracts, or reporting unlawful acts to law enforcement authorities within [Jurisdiction].

4. Modern Slavery Statement

This Modern Slavery Statement sets forth Neon Orchid's policies, practices, and ongoing commitments regarding the prevention of modern slavery, human trafficking, and unethical labor practices across our operations and supply chains.

4.1 Introduction and Our Ethical Commitment

[Legal Entity Name] and its affiliates operating as Neon Orchid ("Neon Orchid," "we," "us," or "our") are firmly committed to conducting business with integrity, transparency, and a strict respect for human rights. We maintain a zero tolerance approach to modern slavery, human trafficking, forced labor, and any form of exploitation.

We recognize our responsibility to ensure that our business operations and commercial relationships remain entirely free from abusive labor practices. This statement outlines the measures we take to identify, assess, and mitigate potential risks within our digital ecosystem and supply chain.

4.2 Organizational Structure and Business Operations

Neon Orchid is a [State] [entity type] with its principal place of business located at [Registered Address]. We operate primarily through our digital platform accessible at neonorchid.app, serving as a specialized talent management agency for independent adult content creators aged 18 and older on subscription platforms such as OnlyFans and Fansly.

In addition to creator representation, our business encompasses payments advisory and operational support, alongside advanced technology services. We do not host or sell explicit adult content directly on our marketing website, which functions solely as an informational portal and application collection point.

4.3 Supply Chains and Vendor Relationships

Because our core operations center on digital talent management, payment operations advisory, and software infrastructure, our supply chain is structured differently from traditional manufacturing, agriculture, or physical retail sectors. We do not maintain raw material supply chains or physical factories.

However, we do engage third-party software vendors, technology providers, professional service firms, and independent contractors to support our digital infrastructure. We expect all vendors, contractors, and business partners to uphold high ethical standards and comply fully with all applicable employment and labor laws.

4.4 Risk Assessment and Due Diligence

We acknowledge that digital services, entertainment platforms, and payment advisory operations require careful oversight to prevent indirect exposure to exploitative practices. We conduct reasonable vetting of our critical business partners and technology vendors during the onboarding process.

Our review procedures are designed to evaluate the compliance history, reputation, and operational integrity of third parties who provide essential services to our organization. We continuously evaluate our internal workflows to minimize potential vulnerabilities.

4.5 Creator Safety, Verification, and Consent

Neon Orchid exclusively represents independent adult content creators who operate on trusted third-party subscription platforms and have reached the legal age of majority. We enforce strict identity verification checks to confirm that every creator entering our management program does so voluntarily, independently, and without coercion.

Furthermore, any technology services we offer, such as consented artificial intelligence likeness models and audience data tools, require explicit written authorization from the creator. These services are governed by transparent, binding contractual agreements that protect creator rights and autonomy.

4.6 Policies and Reporting Procedures

We believe that maintaining a culture of accountability is essential to preventing modern slavery and ethical breaches. Employees, contractors, creators, and external stakeholders are encouraged to report any suspected violations or operational concerns without fear of reprisal.

Reports, inquiries, or concerns regarding our labor practices or supply chain ethics can be directed confidentially to our compliance team at [Email] or by mail to [Registered Address], attention to [Custodian of Records Name].

4.7 Continuous Improvement and Compliance Review

Combating modern slavery and human trafficking requires sustained diligence and continuous adaptation. Neon Orchid is dedicated to regularly reviewing our internal policies, risk assessment procedures, and partnership guidelines to ensure ongoing alignment with best practices.

As our technology offerings, payment operations support, and talent management services expand, we remain committed to refining our compliance framework to meet or exceed statutory expectations in the United States, California, the United Kingdom, the European Union, and other applicable regions.