At Media.com, we are committed to ensuring the accuracy and trustworthiness of the information shared on our platform. While we verify user profiles to enhance accountability, we recognize that not all content may be free from misinformation. We respect diverse opinions but will take action if any user-generated content threatens to harm our users or the wider public.

Fact Checking

At Media.com, we are dedicated to keeping our community safe from harmful, violent, or unlawful users and groups. We do not allow any content that threatens, promotes, or glorifies violence, hate, or criminal activity. Our goal is to maintain a secure online space for everyone.

Dangerous Organizations

At Media.com, we are deeply committed to protecting our users from sexual abuse and the sharing of non-consensual intimate images. We understand the serious violation this represents and will take immediate action to ensure user safety and privacy.

Adult Sexual Abuse

At Media.com, our mission is restore public trust in online information. We aim to achieve this by providing a platform for viewing, publishing, and sharing content from trusted and verified sources. To help maintain the integrity of our network, we offer profile verification for individuals and organizations wishing to post content on Media.com.

Verified Accounts

At Media.com, we are committed to sharing accurate and reliable information, especially during critical times like global crises. Our goal is to prevent the spread of false or misleading information that could cause harm, especially to people affected by these situations.

Misinformation

At Media.com, we’re committed to creating a space that’s positive, respectful, and informative for everyone. These guidelines will help you understand how to contribute to our community while ensuring the integrity of discussions and respect for others.

Content Creation Standards

At Media.com, we want to create a space where everyone can share their thoughts freely, while feeling safe and respected. To do this, we have a zero-tolerance policy against hate speech, which can lead to intimidation, exclusion, or even harm.

Hate Speech

At Media.com, we want everyone to feel safe and respected. Bullying or harassment is not allowed on our platform. These guidelines explain what bullying and harassment look like and how we handle these situations to keep our community secure.

Bullying And Harassment

At Media.com, we work closely with law enforcement and government agencies to ensure safety while respecting our users' privacy. These guidelines explain how we handle requests from law enforcement and official bodies and what steps we take to protect both our users and the integrity of our platform.

Law Enforcement Liaison

At Media.com, we are dedicated to maintaining a safe and respectful community for all users. This guide explains our policies on high-risk users, who may pose a threat to our platform or others.

High Risk Users

At Media.com, we take the safety and protection of minors very seriously. This guide outlines how we keep young users safe and what behaviors are not allowed on our platform.

Youth Safety

Media.com is committed to ensuring that content shared on our platform respects copyright laws. This policy applies to all content posted on Media.com.

Intellectual Property

Media.com frequently communicates with law enforcement, intelligence agencies, regulators, and other government bodies. Our goal is to work effectively with these agencies while ensuring that any exchange of information follows the law and protects our users' rights.

Overview

- Head of Trust and Safety: Approves high-priority (Category 1) requests for information. - Director of Public Sector Relations: Oversees all interactions with government agencies and ensures Media.com’s policies align with legal requirements. - Law Enforcement Response Team (LERT): Handles law enforcement requests for user data, content removal, and emergency disclosures. They ensure that any requests are legitimate and follow legal standards. - Law Enforcement Liaison Office (LELO): Builds long-term relationships with government agencies and ensures Media.com complies with regulations.

Who’s Responsible?

When dealing with law enforcement, we follow these guiding principles: - Preventing harm: Our top priority is to stop any criminal activity that could harm our users or the platform. - Ethical decision-making: We ensure that all decisions and actions are made ethically and are well-documented. - Clear communication: We encourage transparent communication within the company when handling law enforcement matters.

Our Key Principles

We handle requests for information (RFI) from law enforcement agencies through our dedicated email (<a href="mailto:lert@media.com">lert@media.com</a>). RFIs may come in the form of: - Formal information requests - Emergency requests - Preservation requests - Legal requests (subpoenas, court orders, warrants) - International legal processes (e.g., Mutual Legal Assistance Treaties) The Law Enforcement Response Team (LERT) assesses each request to ensure it's valid, checks the relevant jurisdiction, and categorizes the request: - Category 1 RFI: Serious or sensitive requests that may affect the public, users, or the company’s reputation. - Category 2 RFI: Routine requests that can be handled without needing significant coordination.

Requests for Information (RFI)

Determining the jurisdiction for each request is essential. We look at factors like the requesting authority’s location, IP addresses, and where the parties involved are based.

Stakeholder Jurisdictions and Agencies

If Media.com detects criminal activity on our platform—such as hate speech, terrorism, fraud, or harassment—we report it to the Law Enforcement Liaison Office (LELO). They assess whether the activity needs to be reported to law enforcement and determine the appropriate jurisdiction.

Criminal Activity Detection

User data is only shared with law enforcement when the agency complies with legal requirements. We take careful steps to verify the legitimacy of each request and ensure the data transfer is secure. - Category 1 RFI: Data is released by the Head of Trust and Safety. - Category 2 RFI: Data is released by the Director of Public Sector Relations.

Protecting User Data

At Media.com, we are committed to cooperating with law enforcement while safeguarding our users’ privacy. These guidelines help ensure that we meet our legal obligations while keeping the platform safe for everyone.

Conclusion

Media.com regularly interacts with public sector agencies, including law enforcement, intelligence agencies, regulators, and other government entities. The Law Enforcement Liaison Policy outlines the principles governing these interactions. This procedure specifically delineates the methods and practices Media.com employs to implement this policy effectively within the organisation.

Trust and Safety roles and responsibilities relevant to this procedure are contained in the following table.<figure class="table" style="width:100%;"><table class="ck-table-resized"><colgroup><col style="width:50%;"><col style="width:50%;"></colgroup><thead><tr><th>Role</th><th>Responsibility</th></tr></thead><tbody><tr><td>Head of Trust and Safety</td><td>Releasing authority for Category 1 requests for information.</td></tr><tr><td>Director - Public Sector Relations</td><td>Strategic Oversight: Overseeing the development and implementation of strategies for interaction with public sector agencies, ensuring alignment with media.com's overall objectives.</td></tr><tr><td>Law Enforcement Response Team (LERT)</td><td>Response to Requests for Information (RFI) including law enforcement requests for user data or content removal in compliance with legal standards. Emergency Disclosure: Quickly assessing and responding to urgent law enforcement requests involving imminent threats to ensure public safety. Compliance and Verification: Verifying the authenticity of requests and ensuring compliance with legal requirements and company policies to protect user privacy and company integrity.</td></tr><tr><td>Law Enforcement Liaison Office (LELO)</td><td>Strategic Relationship Building: Establishing and nurturing long-term relationships with government agencies for collaborative efforts and understanding regulatory environments. Regulatory Compliance and Consultation: Actively engaging with agencies to comprehend and influence policy developments, ensuring media.com's services comply with legal standards. Communication and Coordination: Serving as a liaison for communication and coordination between media.com and government entities, facilitating official requests and proactive collaborations.</td></tr></tbody></table></figure>

Roles and Responsibilities

When liaising with public Sector Agencies media.com staff are to apply the following principles:<ol><li>Priority is to prevent and stop criminal activity, particularly that causing any form of harm to individual users, stakeholders, and the organisation.</li><li>Ethical and accountable decision-making and record keeping</li><li>A culture of clear and effective internal communication, both vertically and horizontally, when matters are actioned</li></ol>

Principles of Liaison with Public Sector Agencies

In the normal course of business, requests for information (RFI) are to be received electronically via the LERT shared mailbox (<a href="mailto:lert@media.com">lert@media.com</a>). RFI received elsewhere in the organisation are to be forwarded to the LERT mailbox. RFI may take the form of<ol style="list-style-type:lower-latin;"><li>Formal requests for information or assistance</li><li>Emergency requests</li><li>Preservation requests</li><li>Legal requests from official government agencies by way of subpoena, court order or warrant</li><li>Requests from official government agencies under Mutual Legal Assistance Treaties (MLAT) or similar international legal processes</li></ol>Actioning RFI's is the responsibility of the LERT.Reasonable steps should be taken to ensure the identity and veracity of the RFI to identify RFI that are suspicious, unverifiable, or from sanctioned jurisdictions. Such RFI should be referred to Director Public Sector Relations.Upon receipt of an RFI, LERT is to triage the RFI to determine:<ol><li>Validity of the RFI</li><li>Relevant Jurisdiction</li><li>Category of the RFI (Category 1 or 2)</li></ol>Category 1 RFI’s are those that that may be sufficiently serious, sensitive or likely to become public in an impactful way, particularly those causing any form of harm to individual users, stakeholders and/or the organisation, are likely to require a coordinated response, or may be expected to have a significant media attention.Category 2 RFI’s are those that can be described as routine or “business as usual requests” that can be assessed and actioned within the public sector relations team without significant assistance.Where an RFI is determined to be a category 1 RFI, LERT is to notify:<ol><li>Director, Public Sector Relations</li><li>Head of Trust and Safety</li><li>Head of Trust and Safety</li><li>Any other departments relevant to the specific matter.</li></ol>

Public Sector Requests for Information

The question of jurisdiction is both complex and fundamental to any incoming RFI to media.com.Potential indicators of jurisdiction may include:<ul><li>The jurisdiction of the requesting authority</li><li>In the case of a legal document, the jurisdiction of the authorising court or tribunal</li><li>IP addresses related to the relevant material or account</li><li>The place of residence or business of any involved party</li></ul>Upon receiving an RFI, LERT is to determine the jurisdiction relating to the RFI.RFI related to third party civil proceedings are to be referred to media.com legal.

Staff may detect criminal activity occurring on or through the media.com platform such as:<ul><li>Hate Speech or Terrorism</li><li>Cyberbullying and Harassment</li><li>Fraud and Scams</li><li>Attempted or actual fraud during account creation</li></ul>All actual or suspected criminal activity should be reported to the LELO. The LELO is to determine:<ul><li>Whether a criminal activity is suspected or known to have occurred</li><li>The relevant jurisdiction in which the (alleged) activity occurred</li><li>An assessment of any obligation to report the activity to law enforcement or other agency.</li></ul>In ambiguous cases or where the criminal threshold is not clear, advice should be sought from legal counsel as to the requirement to undertake this procedure.The LELO is responsible for discharging any reporting obligation that arises. The authorising authority for reporting is the Director - Public Sector Relations.

Detection of Criminal Activity

Account holder (customer) data should not be disclosed to any party, unless the requesting agency has complied with the relevant laws and regulations in both its own and Media dot com Inc’s jurisdiction.LERT is responsible for gathering data to comply with RFI. Authority for release of customer data in response to RFI is:<ul><li>Category 1 RFI - Head of Trust and Safety</li><li>Category 2 RFI - Director - Public Sector Relations</li></ul>The relevant information should be transferred to the requesting official government agency by 'safe hand' physical transfer or through an approved secure network upon approval. In all cases, this transfer should be recorded in a verifiable manner and recorded as such.<figure class="table" style="width:100%;"><table class="ck-table-resized"><colgroup><col style="width:31.58%;"><col style="width:68.42%;"></colgroup><thead><tr><th colspan="2">Accountabilities</th></tr></thead><tbody><tr><td>Contact Officer</td><td>Director - Public Sector Relations</td></tr><tr><td style="background-color:#F8F8FB;" colspan="2">Supporting Information</td></tr><tr><td>Legislative Compliance</td><td>This procedure supports Media Dot Com's compliance with the following legislation: <a href="https://bills.parliament.uk/bills/3137">Online Safety Act (UK) 2023</a> <a href="https://www.meity.gov.in/writereaddata/files/Information%20Technology%20%28Intermediary%20Guidelines%20and%20Digital%20Media%20Ethics%20Code%29%20Rules%2C%202021%20%28updated%2006.04.2023%29-.pdf">The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 20211 (India)</a></td></tr><tr><td>Parent Document (Policy)</td><td>Media.com Law Enforcement Liaison Policy</td></tr><tr><td>Supporting Documents</td><td>Law Enforcement Liaison Guidelines (TBI)</td></tr><tr><td>Related Documents</td><td>Media.com Sanctions Compliance Program (TBI)</td></tr></tbody></table></figure>