Shorter CONTENT MONITORING POLICY

1. Purpose and Scope

1.1This Content Monitoring Policy (the "Policy") sets out the principles, standards and procedures adopted by WT Publishing LTD (the "Company", "we", "us") to ensure that all audiovisual content produced, published and distributed on the Platform complies with applicable law, the operating rules of the card schemes (including Visa Global Brand Protection Program and Mastercard Business Risk Assessment and Mitigation (BRAM) requirements), and the acceptable-use requirements of the Company's payment service providers and acquiring banks.

1.2This Policy applies to all content made available on the Platform, to all Company employees, contractors and in-house production personnel involved in the creation, review or publication of content, and to all AI tools and systems used in the production pipeline.

1.3The Platform does not host, accept or publish user-generated content of any kind. All content is originated, produced and controlled exclusively by the Company's in-house studio. Accordingly, this Policy is structured as a pre-publication content control framework rather than a post-publication moderation framework: no content is released to end users until it has passed every stage of review described in Section 4.

2. Nature of Content and Production

2.1Content description. The Platform distributes short-form, episodic fictional entertainment ("micro-series") produced with the assistance of generative AI technologies. The content is intended for adult audiences only and may contain mature themes, partial or full nudity, and depictions of sexual activity of a non-explicit, softcore nature. The content does not contain explicit or close-up depiction of genital contact, penetration, or sexual acts of a pornographic nature.

2.2Production model. All content is created by the Company's in-house studio under the Company's direction and control. All characters are fictional and entirely computer-generated. No performers, models or real persons are recorded, filmed, photographed or depicted in the content, and no real person's face, body, likeness or voice is used as a generative or likeness reference.

2.3Intellectual property. The Company is the sole owner of, or holds all necessary licences to, all rights in the content published on the Platform, including scripts, characters, imagery, audio and derivative materials. The Company does not use third-party copyrighted works, trademarks or protected likenesses without authorisation.

2.4Absence of user-generated content. The Platform provides no functionality for end users to upload, submit, embed, stream or otherwise publish content. Any user-facing comment, review or messaging features, if introduced in the future, will be subject to a separate moderation procedure to be adopted prior to launch.

2.518 U.S.C. § 2257 exemption. Because all content is generated entirely by artificial intelligence and no actual human performers are recorded or depicted, the Platform does not produce or distribute visual depictions of actual or simulated sexually explicit conduct by real persons. Accordingly, the record-keeping, labelling and inspection requirements of 18 U.S.C. § 2257 and § 2257A and 28 C.F.R. Part 75 do not apply to the content. The Company publishes a corresponding 18 U.S.C. § 2257 Exemption Statement on the Platform. Should the Company ever produce content involving real performers, it will implement full § 2257 compliance, including age and identity verification and the appointment of a Custodian of Records, before any such content is published.

3. Prohibited Content

3.1The following categories of content are strictly prohibited on the Platform and shall not be scripted, generated, produced, approved or published under any circumstances:

(a)Minors and apparent minors. Any depiction of a person under the age of eighteen (18), or any character who is, is represented as, or could reasonably be perceived as being under the age of eighteen, in any sexual, suggestive or nude context. As an internal safeguard exceeding the legal threshold, the Company requires that all characters appearing in the content be scripted, designed and rendered as adults aged twenty-one (21) years or older, and that no textual, visual or narrative element (including references to school, age, "teen", "barely legal", uniforms or similar signifiers) suggests otherwise.

(b)Non-consensual sexual activity. Any depiction of rape, sexual assault, coercion, drugging, or sexual activity portrayed as occurring without the clear consent of all characters involved; any content that presents non-consent as erotic or desirable.

(c)Violence. Any depiction of sexual violence, torture, mutilation, bodily harm, blood, or degradation combined with sexual content, or any content that glorifies or eroticises violence.

(d)Incest. Any depiction or narrative implication of sexual activity between characters presented as family members, whether by blood, adoption, marriage or step-relationship, including so-called "fauxcest" framing.

(e)Bestiality. Any depiction of sexual activity involving animals or animal-like creatures.

(f)Hateful or degrading content. Any content that demeans, degrades or discriminates against persons on the basis of race, ethnicity, national origin, religion, disability, or other protected characteristics, or that uses such characteristics as an element of sexual degradation.

(g)Real persons and deepfakes. Any depiction of an identifiable real person, living or deceased, including public figures; any use of a real person's face, body, likeness, voice or name as a generative or likeness reference.

(h)Infringing content. Any content that infringes third-party copyright, trademark, publicity, privacy or other rights.

(i)Unlawful content. Any content that is illegal in the jurisdiction of production or in any jurisdiction in which the Platform is made available, or that would breach the rules of any card scheme, payment service provider or acquiring bank.

3.2The list in Section 3.1 is not exhaustive. The Content Compliance Officer may reject any content which, in his or her reasonable judgement, presents legal, regulatory, reputational or payment-network risk, notwithstanding that it does not fall within a listed category.

4. Content Review and Approval Procedure

4.1No episode or other content item may be published on the Platform unless it has successfully completed each of the three review stages set out below. The stages are sequential; failure at any stage returns the content item to production for revision or results in its rejection.

4.2Stage 1 — Automated script-level screening. Prior to production, every script, synopsis, character profile and prompt set is submitted to an AI-based compliance classifier configured to detect the prohibited categories listed in Section 3. The classifier assesses, inter alia: character age references and age-suggestive language; consent framing of all sexual scenes; family or relationship descriptors indicative of incest; references to violence, animals, real persons, or protected characteristics in a degrading context. Any script flagged by the classifier is blocked from proceeding to production until the flag is resolved by revision and re-screening, or overridden in writing by the Content Compliance Officer with documented justification.

4.3Stage 2 — Automated production-level screening. All generated visual and audio assets, and each assembled episode, are subjected to automated analysis prior to human review, including: (i) nudity and sexual-content classification to confirm that output remains within the non-explicit parameters defined in Section 2.1; (ii) facial and body age-estimation to confirm that all rendered characters present as adults; (iii) facial similarity screening against reference sets of public figures to detect unintended resemblance to real persons; and (iv) such other legal and technical checks as the Company may implement from time to time. Assets failing any check are quarantined and regenerated or discarded.

4.4Stage 3 — Manual review and approval by the Content Compliance Officer. Every episode, in its final form, is viewed in full by the Content Compliance Officer, who reviews it against this Policy and a written compliance checklist. The Content Compliance Officer records a written approval or rejection decision for each episode. Content may be published only upon the recorded approval of the Content Compliance Officer. No other person is authorised to approve content for publication, and automated screening results do not constitute approval.

4.5Independence. The Content Compliance Officer reports to senior management and is not subject to the direction of production or commercial personnel in the exercise of his or her review function.

4.6Post-publication re-review. Published content is subject to re-review upon (i) receipt of a complaint under Section 5; (ii) any change in law, card-scheme rules or provider requirements; or (iii) periodic sampling at the discretion of the Content Compliance Officer. Content found to be non-compliant is removed from the Platform without delay.

5. Complaints and Content Removal

5.1Any person may report content which they believe to be unlawful, in breach of this Policy, or in violation of their rights by contacting the Company at support@shorter.tv. A link to this reporting channel is displayed on the Platform.

5.2Complaints and content removal requests are acknowledged within two (2) business days of receipt and are escalated to the Content Compliance Officer for investigation.

5.3Where a complaint alleges depiction of a minor, non-consensual activity, or use of a real person's likeness, the content concerned is suspended from the Platform immediately pending investigation. All other complaints and content removal requests are resolved within five (5) business days of receipt.

5.4Where a complaint is upheld, the content is permanently removed and the underlying cause is reviewed and remediated in the production process. The complainant is informed of the outcome.

5.5The Company will cooperate fully with law enforcement authorities, card schemes, payment service providers and acquiring banks in relation to any complaint or investigation concerning content on the Platform.