Modern Slavery Statement

Modern Slavery, Forced Labor & Ethical Conduct Standard

Helios is committed to supporting lawful, ethical, and responsible activity across end-to-end manufacturing and related industries. Helios does not permit the Platform to be used to support, conceal, facilitate, normalize, or profit from modern slavery, forced labor, child labor, human trafficking, coercive labor practices, or other exploitative conduct.

This Modern Slavery, Forced Labor & Ethical Conduct Standard explains the expectations Helios places on users regarding labor practices, ethical sourcing, worker treatment, truthful claims, and responsible conduct in connection with Platform use.

This Standard applies to all users of Helios, including experts, companies, students, vendors, suppliers, associations, partners, customers, service providers, and any other person or entity using the Platform.

This Standard should be read together with the Helios Terms of Service, Trust & Safety Policy, Code of Conduct, Restricted Activities & Prohibited Transactions Policy, Marketplace Integrity & Anti-Fraud Policy, Privacy Policy, and any supplier, onboarding, or category-specific requirements published by Helios.

1. Purpose

The purpose of this Standard is to:

• prohibit labor exploitation and abusive labor practices in connection with Helios use
• support ethical conduct across manufacturing, sourcing, and service relationships
• prevent deceptive claims regarding labor, sourcing, and workplace conditions
• establish expectations for lawful and responsible business behavior
• give Helios a basis to review, restrict, or remove activity connected to labor exploitation or unethical conduct.

2. General Rule

Users may not use Helios to request, offer, promote, facilitate, transact in, or profit from activity involving:

• child labor
• forced labor
• bonded labor
• debt servitude
• human trafficking
• coercive labor recruitment
• involuntary prison labor where unlawful or exploitative
• confiscation or retention of worker identity documents
• unlawful recruitment fees imposed on workers
• threats, coercion, intimidation, or deception used to control workers
• exploitative subcontracting practices that violate applicable law or ethical obligations.

Note: Users operating in Canada or facilitating supply chain activity involving Canada should also be aware of obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c.9), which may require annual public reporting to the Minister of Public Safety regarding measures taken to prevent and reduce the risk of forced labour and child labour in supply chains.

Helios may restrict, remove, or prohibit activity that appears to involve exploitative labor conditions even where the full facts are still under review.

3. Child Labor

Users may not use Helios in connection with unlawful child labor or activity that exploits minors in violation of applicable law.

This includes, without limitation:

• employing or sourcing labor from children below the minimum legal working age
• exposing minors to hazardous industrial, manufacturing, or technical work contrary to law
• misrepresenting worker ages, apprenticeships, or lawful employment status
• using subcontractors or suppliers in a way that conceals unlawful child labor

Where young workers are lawfully employed under applicable law, users remain responsible for ensuring legal protections, safety requirements, supervision requirements, and restrictions on hazardous work are fully observed.

4. Forced Labor, Coercion, and Human Trafficking

Users may not use Helios in connection with forced labor, coercive labor practices, or human trafficking.

Prohibited conduct includes, without limitation:

• compelling a person to work through force, threats, coercion, intimidation, deception, or abuse of vulnerability
• retaining passports, work permits, identity cards, or other personal documents improperly
• restricting a worker’s freedom of movement unlawfully
• using debt bondage or unlawful financial dependency to compel labor
• trafficking persons for labor or services
• using misleading promises about wages, conditions, location, immigration status, or job type to induce labor

5. Recruitment and Employment Practices

Users are expected to use fair and lawful recruitment and labor practices.

Users may not:

• charge workers unlawful recruitment fees
• mislead candidates or workers about wages, hours, duties, location, housing, immigration support, or job conditions
• use deceptive contracts or hidden deductions
• retaliate against workers for raising safety, wage, labor, or legal concerns
• knowingly use labor intermediaries or recruiters engaged in unlawful or exploitative conduct

Users are responsible for the labor practices of third parties they engage where those practices are connected to Helios activity.

6. Wages, Working Conditions, and Workplace Treatment

Users may not use Helios in connection with unlawful or exploitative working conditions.

This includes, without limitation:

• unlawful withholding of wages
• unlawful deductions or wage manipulation
• unsafe or hazardous work conditions where legal protections are ignored
• denial of legally required rest, safety protections, or lawful working conditions
• abusive treatment, intimidation, or coercive discipline
• knowingly misrepresenting workplace safety, labor protections, or compliance standards.

Helios may consider workplace safety and treatment concerns relevant where work arranged, promoted, or supported through Helios creates risk of labor exploitation or serious harm.

7. Ethical Sourcing and Supply Chain Integrity

Users may not make false, misleading, incomplete, or unsubstantiated claims about:

• ethical sourcing
• fair labor conditions
• anti-trafficking compliance
• supply chain due diligence
• worker protections
• social compliance certifications
• audit results
• origin or sourcing conditions

Users must not use Helios to conceal abusive sourcing relationships, exploitative subcontracting structures, or supply chain practices that violate law or this Standard.

8. Subcontractors, Suppliers, and Third-Party Responsibility

If you use subcontractors, staffing agencies, suppliers, or service partners in connection with Helios activity, you are responsible for ensuring that their conduct does not violate this Standard.

Users may not:

• knowingly use subcontractors engaged in child labor, forced labor, or trafficking
• structure sourcing or contracting relationships to avoid accountability
• shift work to opaque or high-risk intermediaries to hide unlawful labor conditions
• ignore credible warning signs of exploitation in the labor or sourcing chain connected to your Helios activity

Helios may request information about sourcing, subcontracting, or labor practices where risk is reasonably suspected.

9. False Certifications and Misleading Ethical Claims

Users may not forge, falsify, manipulate, or misuse:

• labor compliance certifications
• audit reports
• supplier declarations
• workplace safety records
• social responsibility statements
• anti-trafficking representations
• ethical sourcing claims

Misleading statements about labor, sourcing, or workforce conditions may be treated as both an ethical conduct issue and a fraud or marketplace integrity issue.

10. Reporting Concerns

Users are encouraged to report conduct or listings that appear connected to:

• child labor
• forced labor
• trafficking
• coercive recruitment
• unsafe or exploitative working conditions
• deceptive ethical sourcing claims
• abusive subcontracting or supply chain concealment

Reports should include as much detail as reasonably available, such as:

• the account, company, or listing involved
• relevant communications or representations
• supporting documents, screenshots, or links
• dates, locations, or supplier relationships where known
• explanation of why the conduct appears exploitative or deceptive

Helios encourages good-faith reporting and may review such matters under its broader Trust & Safety and enforcement processes.

11. Helios Review and Response

Where Helios becomes aware of possible labor exploitation, trafficking risk, forced labor concerns, or deceptive ethical conduct, Helios may:

• request clarification or supporting documentation
• review related listings, profiles, files, or transactions
• require compliance-related representations or evidence
• restrict visibility, category access, or transaction activity
• delay or deny payouts where permitted by policy or law
• suspend or terminate accounts
• report concerns to appropriate authorities, payment providers, partners, or affected parties

12. Related Policy Violations

Conduct that violates this Standard may also violate other Helios policies, including:

• Terms of Service
• Trust & Safety Policy
• Code of Conduct
• Restricted Activities & Prohibited Transactions Policy
• Marketplace Integrity & Anti-Fraud Policy
• Enforcement, Appeals & Account Actions Policy

13. User Responsibility for Compliance

Users are solely responsible for complying with all laws and obligations applicable to labor, employment, anti-trafficking, supply chain, workplace safety, and ethical sourcing conduct connected to their use of Helios.

Helios does not provide labor, employment, or regulatory advice. Users are responsible for ensuring that their own operations, contracting, sourcing, and worker relationships comply with applicable law.

14. Policy Updates

Helios may update this Standard from time to time to reflect changes in law, industry expectations, platform activity, operational needs, or evolving trust and safety risks.

When Helios updates this Standard, it will post the revised version on the Platform and update the “Last Updated” date above. Continued use of the Platform after the effective date of an updated version constitutes acceptance of the revised Standard, except where additional notice or consent is required by law

15. Contact and Reporting

For questions or reports relating to child labor, forced labor, trafficking, exploitative sourcing, deceptive ethical claims, or other concerns under this Standard, contact: