Child Safeguarding Policy

1. Purpose and scope

1.1 Purpose

This policy and its relevant procedures specify the promise of protection of children and youths made by “Net-Chinese Co., Ltd.” (hereinafter referred to as “Net-Chinese.”) As a prerequisite of compliance with Taiwan’s domestic law and the applicable international policies, this policy aims to reduce the possibility that users indirectly distribute Child Sexual Abuse Material (CSAM) through services provided by Net-Chinese. We expect this policy and its relevant procedures to establish guidelines with relevant measures for concerned parties as a way to avoid continuous harm to children and youths. These relevant measures are applicable to levels of Domain Name System (DNS) and Host in accordance with the services Net-Chinese provides to its users.

1.2 Scope

This policy is applicable to all the individuals listed below:

• Net-Chinese corporate governance team, inclusive of the board, the shareholders and the operational teams.
• All the individuals employed by Net-Chinese, inclusive of contractors, interns, consultants and related volunteers, regardless of positions, ranks, locations and pay.
• Users who obtain DNS and hosting services provided by Net-Chinese.

2 Definition

2.1 Child and Youth

Anyone under the age of 18.

2.2 Child Sexual Exploitation

The term “child and youth sexual exploitation” herein shall refer to any of the following behaviors:

• Causing a child or youth to engage in sexual intercourse or obscene acts in exchange for monetary or other considerations;
• Using a child or youth to engage in sexual intercourse or obscene acts for others to watch;
• Filming a child or youth engaging in sexual intercourse or obscene acts, or producing pictures, photographs, films, videotapes, compact disks, electronic signals or other objects that show a child or youth engaging in sexual intercourse or obscene acts.

2.3 Domain Name Registrar

An entity that provides domain name registration services.

2.4 Domain Name Registry

The authoritative entity that manages a specific top-level domain, delegates second-level domain names and maintains the relative documents and data.

2.5 DNS Level

The DNS defines domain namespaces, and designates top-level domains (such as .com,) second-level domains (such as net-chinese.com,) and subdomains (such as system.net-chinese.com.) Each of these levels is managed by a different entity. The term “DNS Level” herein shall refer to the domain namespace managed by Net-Chinese as a registrar, with the exception of “.政府” and “.taipei” nonetheless.

2.6 DNS Level Action

The DNS level actions a registrar can take, including to hold, to lock, to redirect, to transfer, and to delete, vary according to the extent of authorization granted by respective top-level domain registries.

2.7 Hosting Level

Hosting service providers maintain the infrastructures necessary to a website for users to upload and save web content, images or videos, and by visiting the website the server of which is managed by a hosting service provider, Internet users can access to the web content hosted for the users. The term “Hosting Level” herein shall refer to the server space provided by Net-Chinese as a hosting service provider.

2.8 Hosting Level Action

Hosting level actions are measures a hosting service provider can take, including removal of web content, images, videos, and so on. Net-Chinese will, under the precondition of proportionality, take different measures based on individual cases and the relevant procedures.

3. Document Details

3.1 Brief

Net-Chinese devotes itself to providing Internet users with the safest, the most convenient and a wide variety of domain name registration service. Net-Chinese, as a domain name registrar, believes that everyone has the responsibility to promote the welfare of children and youths, and to ensure their safety with conducts that protect them. Net-Chinese acknowledges that all children and youths have the right to protection from “all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse” outlined in the Convention on the Rights of the Child, and we promise the following methods to protect children and youths from sexual exploitation on the Internet.

3.2 Principles

3.2.1 Principle 1: Zero-tolerance of Sexual Exploitation of Children and Youths

Net-Chinese takes zero-tolerance attitude towards Sexual Exploitation of Children and Youths. Net-Chinese, with actual knowledge, will not provide services that directly or indirectly help others distribute CSAM.

3.2.2 Principle 2: Acknowledgement of Children’s and Youths’ Best Interest

Net-Chinese devotes itself to the protection of children and youth, having children’s and youths’ best interest at heart.。

3.2.3 Principle 3: Commitment to Prioritizing the Protection of Children’s and Youths’ Rights

Net-Chinese recognizes the irreversibility of harm and assault, as well as the fragility of children and youths. Therefore, Net-Chinese promises to prioritize the protection of children’s and youths’ rights, and incorporate such awareness into our operational guiding principles.

3.2.4 Principle 4: An Internet Space and Environment Created for Children’s and Youths’ Safety

Despite the unlikelihood that all the risks of sexual exploitation of children and youths could be eliminated, Net-Chinese is willing to take every reasonable action to create an Internet space and environment in protection of children and youths, including relevant terms and conditions mandatory for all Net-Chinese service receivers.

3.2.5 Principle 5: Shared Responsibilities for Protection of Children and Youths

In order to effectively control the risks to children and youths, Net-Chinese urges every party should share the responsibility for protecting children and youths from sexual exploitation. In this regard, Net-Chinese will collaborate with key players including governmental agencies, social welfare institutes, and child and youth protection facilities.

3.2.6 Principle 6: Procedural Justice

Every accusation of sexual exploitation of children and youths should be given timely assessment, in order that reasonable attention is warranted and element assessment can be carried out subsequently. If one accusation comes with sufficient evidence and therefore meets the processing standards of Net-Chinese, Net-Chinese will implement the corresponding measures. Procedural Justice will be applied by Net-Chinese in the process to ensure that the respondent(s) can have ample opportunity for defense.

3.3 Our Actions

3.3.1 Capacity Building

Net-Chinese will ensure that every staff member is fully aware of the risks of online sexual exploitation. Considerable resources have been provided for Net-Chinese staff to familiarize themselves with related laws and regulations and their responsibility for protection of children and youths. In addition, Net-Chinese is required to educate its staff about this policy, in ways including but not limited to onboarding and online/physical training courses. These resources are published in a database freely accessible to the entire staff.

3.3.2 Policy Tracking

Net-Chinese will continue to track and coordinate with policies relevant to sexual exploitation of children and youths at home and abroad, and meanwhile to actively participate in all kinds of consultation meetings and introduce applicable mechanisms of industry self-regulation.

3.3.3 Receipt of Abuse Reports

Net-Chinese will publish its Abuse Contact on its official website at
https://www.net-chinese.com.tw/nc/index.php/MenuLink/Index/AbuseReport and assign communications coordinators to receive abuse reports of sexual exploitation of children and youths 24/7.

3.3.4 Processing, Response and Notification

Net-Chinese will assess the abuse case within 24 hours after receipt of the report. Net-Chinese will take necessary and appropriate measures in conformity of the law, and will respond to the abuse reporter with the measures taken as well as notify the concerned domain name registrant of involvement in sexual exploitation of children and youths.

3.3.5 Weeding Out Policy

If members of Net-Chinese involve themselves in sexual exploitation of children and youths by way of services provided by Net-Chinese, Net-Chinese will stop providing its complete or partial services to such members.

3.3.6 Crossover Collaboration

Net-Chinese will introduce “Trusted Notifier Framework” in this effort with the intention to sign written collaborative agreements with Trusted Notifiers to collectively mitigate sexual exploitation of children and youths. For those cases reported from Trusted Notifiers, Net-Chinese will establish specific point of contact(s) and specialized task force(s) for proactive implementation and provision of any other practical assistance. The term “Trusted Notifier” herein shall refer to entities with the following qualifications:

• Profound and professional knowledge about the issue of sexual exploitation of children and youths;
• Insistence on high-quality factual and procedural due diligence process;
• Points of argument in support of the submitted reports, and a written statement ensuring the low rate of false reports and the absolute accuracy of notifications;
• Explicit procedures for domain name registrants to express concerns.

4. Assistive Document

4.1 Laws and Regulations

• The Protection of Children and Youths Welfare and Rights Act (https://law.moj.gov.tw/ENG/LawClass/LawAll.aspx?pcode=D0050001)
• Child and Youth Sexual Exploitation Prevention Act (https://law.moj.gov.tw/ENG/LawClass/LawAll.aspx?pcode=D0050023)
• Telecommunications Management Act (https://law.moj.gov.tw/ENG/LawClass/LawAll.aspx?pcode=K0060111)

4.2 Contractual Terms

• RAA

4.3 International Mechanisms of Industry Self-regulation

• I&JP Tool
• Trusted Notifier Framework
• Guide to Registrar Abuse Reporting Practices

4.4 Net-Chinese Internal Policies

• Processing Policy on Infringement Reports
• Anti-abuse Policy

5. Appendix

5.1 Judging Criteria for Judgement about Child and Youth Sexual Exploitation

5.1.1 Children and youths are people who are under the age of 18. People who have reached the age of 18 shall be calculated by fully completed year.
5.1.2 Web content consists of images and videos document of sexually explicit conduct or nudity involving children and/or youths.
5.1.3 Persons who are involved in the reported CSAM should be clearly identified. Cases will be set and proceeded individually when identity or age of persons who are involved are indistinguishable or faceless.
5.1.4 Proof documents in relation to the reported incidents of child or youth sexual exploitation need to be provided. The forms can be orders issued by administration authorities or police agencies in Taiwan, or any official documents including adjudications, injunctions or judgements from the courts in Taiwan.
5.1.5 Entities that sign written collaborative agreements with Net-Chinese need to provide roof documents issued by their national authorities. The forms can be orders issued by administration authorities or police agencies, or any official documents including adjudications, injunctions or judgements from the courts.