Ethical instructions for Partners, including Prohibited and Restricted segments.

Purpose and Objective

Wurthy has adopted these instructions to give partners and other external parties guidance on Wurthy's ethical standards and other restrictions. Wurthy's aim is to quickly and consistently be able to assess what is in accordance with its values and expectations.

Aim

Wurthy strives to only cooperate with partners whose activities are in line with Wurthy's desire of making payments and commerce safer. For Wurthy, this means that Wurthy's products and services may only be used for lawful purposes, and that ethical aspects of the partner's business are taken into account. As a major player Wurthy aims to realize this vision and to have a positive influence on the market. Wurthy's products and services may only be used for lawful purposes. In addition, Wurthy wants to prevent our products and services from being used in an unethical way. If a partner, which uses Wurthy's services, acts in an unethical way or sells goods and services which are unethical, it may harm the public's confidence in both the merchant and Wurthy and introduce customer harm. To reduce this risk Wurthy has adopted the following Ethical Instructions for Partners.

Principles

Judging upon ethical issues is subjective. Wurthy will judge upon such issues in its sole discretion. Below are some general principles, which are exemplified in Prohibited and Restricted Segments. The examples listed as "Prohibited" are not allowed while examples listed as "Restricted" may be allowed under certain conditions and upon pre-approval from Wurthy.

Unethical Business Methods and Practices

Wurthy shall not cooperate with partners, which sell products or carry out services with means and methods that are misleading, deceptive, abusive or unfair to customers, or otherwise unethical or illegal.

A partner's means of marketing, advertising, distribution channels and reputation shall be considered when assessing if the business practice is unethical or contrary to consumer protection legislation. Wurthy may also take into account links to/from such a partner's website and other associations. Wurthy shall make a global, proportionate, case-by-case assessment of each partner, and decide in its sole discretion what is acceptable.

Unethical Products and Services

Wurthy will not cooperate with partners providing products or services which Wurthy considers, in its sole discretion, as unethical under these instructions. Some products can be categorized as products of dual use, meaning that they may have a legitimate use, but also an illegitimate use. When assessing partners providing products of dual use, Wurthy will try to determine if its typical end customers intend to use the product in an illegitimate way and if the partner supports such use. Wurthy shall make an overall assessment of the partner, its business practices, its conduct in general and its product portfolio.

Consequences

If a partner fails to comply with these instructions, depending on severity or other relevant circumstances, Wurthy may temporarily suspend the provision of the services and/or give the partner an opportunity to adjust to meet the requirements set out by these instructions. Alternatively, Wurthy may terminate the cooperation agreement with such a partner.

Prohibited and Restricted Partners

The following restrictions and prohibitions have been defined as a part of Wurthy's instructions on what ethical stance to make for products, services and practices in partnerships. The lists with items in the tables below are not exhaustive, hence Wurthy may in sole discretion decide on businesses, concepts, products and services that are not allowed to process via Wurthy's services. The assessment of prohibited and restricted businesses is based on:

None of the prohibited items or services listed below can be processed using Wurthy's services. For items being defined as restricted, a restriction might indicate limitations in markets, products, items, volume or marketing that can be allowed and shall not be processed without Wurthy's approval.

Prohibited

Adult

Deceptive or Unfair Marketing

Drugs and Legally Derived Substances and Products

Financial and Legal Services

Gambling

High Risk Industries, Goods and Services

Illegal Products or Services

Restricted

Segments listed below will only be allowed with the pre-approval from Wurthy and subject to any conditions that Wurthy may impose at its sole discretion.

Adult

Drugs and Legally Derived Substances and Products

Financial and Legal Services

High Risk Industries, Products and Services