Prohibited & Restricted Businesses

Last updated: [TBD] · This is a working draft pending legal review.

1. About this policy

Coded B.V. ("Coded", "we", "us", or "our") operates an international commerce platform on which a merchant can create and run one or more branded online projects, supported by a curated product catalog, built-in payments, and built-in fulfilment. This Prohibited & Restricted Businesses policy (the "Policy") sets out the categories of businesses, products, and services that merchants and their Organizations may not offer, sell, or facilitate through the Coded platform, and the categories that we permit only under defined conditions.

This Policy applies worldwide to every merchant, Organization, project, and end customer that uses or transacts through the platform, regardless of where the merchant or its customers are located. It forms part of, and must be read together with, our Terms of Service, Acceptable Use Policy, Privacy Policy, and any product- or country-specific terms that apply to you.

Coded is a private limited company registered in the Netherlands (a subsidiary of Coded Holding B.V.) and serves merchants globally. The Netherlands is our registration and initial-launch market; the platform itself is built for international use. Where the mandatory law of a merchant's or customer's own jurisdiction imposes stricter or additional requirements than those described here, those requirements also apply, and the stricter standard governs.

1.1 Why this Policy exists

We maintain this Policy for three independent reasons, each of which is sufficient on its own to restrict or prohibit a category:

• Law. Some goods, services, and activities are illegal, regulated, or sanctioned in one or more of the jurisdictions we operate in or serve.
• Payments and financial-crime rules. Payments on the platform are processed through our payment partners, Stripe and Mollie. Card networks, banks, and payment regulators impose anti-money-laundering ("AML"), counter-terrorist- financing ("CTF"), know-your-customer ("KYC"), sanctions, and acceptable-use rules that bind both Coded and every merchant. A category that our payment partners prohibit cannot be supported on the platform regardless of its legality.
• Risk and integrity. Some categories carry an unacceptable risk of fraud, chargebacks, consumer harm, or reputational damage to the platform and the merchants on it.

Note on payment costs. Coded charges a 0% platform fee on a merchant's payment transactions. Merchants pay only the pass-through processing cost of Stripe or Mollie. This Policy is about what may be sold, not about pricing; nothing in it introduces a Coded transaction fee. Subscription fees for publishing a project, where they apply, are addressed separately in our commercial terms.

1.2 Prohibited vs. restricted

This Policy uses two defined categories:

• Prohibited — Not permitted on the platform under any circumstances. These categories may not be offered, sold, listed, fulfilled, or promoted through any project, and no exception or approval is available.
• Restricted — Permitted only if specific conditions are met. These categories may be offered on the platform where the merchant satisfies the stated conditions, holds any required licences or authorisations, and, where indicated, receives prior written approval from Coded. Permission for a restricted category may be limited, conditional, or revoked.

The legality of a product or service in a given country does not by itself make it permitted on the platform. Many categories below are lawful in some jurisdictions yet remain prohibited or restricted here because of payment- network rules or risk considerations.

2. Prohibited businesses, products, and services

The following are prohibited and may not be offered, sold, listed, fulfilled, financed, or promoted through any project on the platform. The list is illustrative, not exhaustive: we may treat a business as prohibited even where it is not expressly named, where it falls within the spirit of a category below, or where our payment partners or applicable law require it.

2.1 Illegal goods, services, and activities

• Any product, service, or activity that is illegal in any jurisdiction where the merchant operates, where the project is offered, or where the customer is located.
• Goods or services that infringe, misappropriate, or violate any law, regulation, or third-party right.
• Goods or services that promote, facilitate, or instruct on illegal activity, including evasion of law enforcement, sanctions, or taxation.

2.2 Controlled substances and related goods

• Narcotics, controlled substances, and any equipment designed for making or using controlled substances (drug paraphernalia).
• Substances marketed as a legal alternative to a controlled substance, and novel psychoactive substances.
• Cannabis and cannabis-derived products, including CBD products, are not permitted as a general matter. Limited categories may be considered under Section 3 (Restricted) only where lawful and where our payment partners support them.

2.3 Weapons, explosives, and dangerous materials

• Firearms, firearm parts, ammunition, and weapons; explosives, fireworks, and pyrotechnic devices; and other dangerous, hazardous, or restricted materials.
• Items prohibited or non-mailable under applicable postal, transport, or customs rules.

2.4 Adult content and services

• Pornographic or sexually explicit imagery, video, audio, or text, and services of a sexual nature, in any digital or physical form.
• Any product or service that exploits, sexualises, or endangers minors. We report suspected child sexual abuse material to the relevant authorities and terminate the account immediately, without notice.

2.5 Counterfeit and infringing goods

• Counterfeit goods, replicas passed off as genuine, and unauthorised or "grey-market" goods.
• Goods or services that infringe the intellectual-property rights of a third party, including unauthorised copies of copyrighted works, trademark misuse, and devices or services primarily intended to circumvent technical protection measures, access controls, or licences.

2.6 Restricted financial and high-risk monetary services

• Money transmission, money-service businesses, currency exchange, remittance, and peer-to-peer transfer services.
• Cryptocurrency, virtual-asset, token, mining-hardware, and decentralised- wallet businesses; initial coin or token offerings.
• Investment products, securities, derivatives, binary options, forex trading, and similar speculative instruments.
• Credit, lending, debt collection, debt settlement, credit repair, and "buy-now-pay-later" origination.
• Crowdfunding, collective-investment, and unregistered fundraising schemes.
• Multi-level-marketing, pyramid, matrix, "get-rich-quick", and no-value-added reselling schemes.
• Shell companies and businesses established primarily to obscure beneficial ownership.

2.7 Gambling and games of chance

• Casinos, betting, sports wagering, lotteries, sweepstakes, fantasy sports for money, and other games of chance played for money or monetary value, except where expressly permitted as a restricted category under Section 3 with the required licences.

2.8 Fraud, deception, and unfair practices

• Any scheme that involves fraud, deception, or material misrepresentation.
• Deceptive, predatory, or undisclosed subscription, "negative-option", or recurring-billing practices.
• Sale of personal or financial data, account credentials, or "traffic", clicks, followers, reviews, or engagement.
• Goods or services obtained through, or intended to facilitate, account takeover, carding, phishing, or other fraud.

2.9 Regulated and sensitive goods that we do not support

• Prescription medicines, controlled pharmaceuticals, and pharmacies.
• Tobacco, e-cigarettes, vaping products, and nicotine products.
• Human body parts, organs, fluids, and remains.
• Endangered or protected species and products derived from them.
• Government identification documents, and services to obtain them unlawfully.

2.10 Hate, violence, and exploitation

• Goods, services, or content that promote, incite, or glorify hatred, violence, terrorism, extremism, or discrimination against any person or group.
• Goods or services that promote self-harm, or that exploit, harass, threaten, or endanger any person.

2.11 Sanctions and embargoes

• Any transaction involving a person, entity, region, or country that is the target of trade or economic sanctions administered by, among others, the European Union, the United Nations, the United States (including OFAC), the United Kingdom, or the Netherlands.
• Any attempt to evade, or to help a third party evade, applicable sanctions or export-control law.

3. Restricted businesses, products, and services

The following categories are restricted. They may be offered on the platform only where the merchant (a) complies with all applicable law in every relevant jurisdiction; (b) holds and maintains every licence, registration, permit, and authorisation required; (c) meets any age-verification, labelling, disclosure, and consumer-protection requirements; and (d), where indicated, obtains Coded's prior written approval and our payment partners' support before going live.

Approval for a restricted category, where granted, may be conditional, limited in scope, time-bound, and revocable. The merchant remains solely responsible for confirming that its activity is lawful and supported in each market it serves.

3.1 Age-restricted goods

• Alcohol — subject to licensing, age verification at sale and delivery, and marketing restrictions.
• Other goods lawful only for adults — subject to robust age verification.

3.2 Regulated consumer categories

• Nutritional supplements, cosmetics, and wellness products making no medical claims — subject to applicable product-safety, labelling, and advertising law.
• Medical devices and health-adjacent products — subject to certification and marketing-claim limits.
• Children's products, toys, and goods subject to safety standards — subject to applicable conformity and safety requirements.

3.3 Professional and licensed services

• Legal, accounting, financial-advisory, healthcare, and similar regulated professional services — subject to the merchant holding the required professional licence and complying with conduct rules.

3.4 Conditionally supported financial-adjacent activity

• Fundraising and charitable collection by a registered organisation — subject to registration, disclosure, and our payment partners' support.
• Donation-based or pre-order/crowdfunding models — subject to clear disclosure, fulfilment commitments, and prior approval.

3.5 Travel, events, and future-dated delivery

• Travel services, ticketing, events, and other businesses that take payment well in advance of delivery — subject to refund, escrow, or guarantee arrangements appropriate to the chargeback risk.

3.6 Digital goods and content services

• Digital goods, downloads, software, and subscriptions — subject to clear delivery terms, refund policy, and prohibition of the infringing or deceptive uses described in Section 2.

3.7 Other categories supported by our payment partners on a case-by-case basis

• Categories that Stripe or Mollie classify as high-risk and support only with additional underwriting, reserves, or conditions may be permitted on the platform on the same case-by-case basis, where Coded also approves them.

4. Merchant responsibilities

By creating an Organization or project, or by transacting on the platform, the merchant represents and undertakes on a continuing basis that it:

• offers only goods and services that are lawful in every jurisdiction where its projects are available and where its customers are located;
• does not offer any prohibited category, and offers a restricted category only in full compliance with Section 3;
• holds and maintains every licence, registration, and authorisation required for its business and keeps proof available for inspection on request;
• describes its goods, services, pricing, and refund and cancellation terms accurately and without deception;
• complies with all applicable AML, CTF, KYC, sanctions, consumer-protection, product-safety, tax, and advertising laws; and
• promptly informs Coded of any material change to its business that may affect its standing under this Policy.

The merchant is solely responsible for its products, services, content, and customer relationships. Coded does not pre-screen merchant catalogs and is not a party to the contract of sale between a merchant and its customers.

5. Verification, monitoring, and information requests

We, and our payment partners Stripe and Mollie, may carry out onboarding checks and ongoing monitoring as required by applicable law and payment-network rules, including identity verification, beneficial-ownership checks, sanctions screening, and transaction monitoring. We may ask a merchant at any time for information or documentation about its business, products, licences, supply chain, or transactions, and the merchant must respond within the time we specify. Failure to respond adequately may result in suspension or termination.

6. Enforcement

Where we reasonably believe that a merchant, Organization, or project breaches this Policy, or where our payment partners or applicable law require it, we may, with or without prior notice and at our discretion:

• remove or disable specific listings, products, content, or projects;
• suspend payments, place funds on hold or in reserve, or reverse transactions, to the extent permitted by our payment partners and applicable law;
• suspend or terminate the merchant's account, Organization, or access to the platform;
• report the matter to regulators, payment partners, or law-enforcement authorities where we are required or permitted to do so; and
• take any other step reasonably necessary to comply with law, protect customers and other merchants, or limit risk to the platform.

We will act proportionately and, where practicable and lawful, give notice and an opportunity to remedy a non-serious breach. For serious breaches — including illegal goods, child sexual abuse material, sanctions violations, or fraud — we may act immediately and without notice. Suspension or termination does not relieve a merchant of obligations to its customers or under applicable law.

7. Changes to this Policy

We may update this Policy from time to time to reflect changes in law, payment- network rules, our payment partners' requirements, or our risk assessment. Our payment partners may change their own prohibited and restricted lists at any time, including without prior notice, and such changes may take effect on the platform immediately. We will post the current version with its effective date, and material changes will take effect as described in our Terms of Service.

8. Relationship to other terms

This Policy supplements and does not replace our Terms of Service, Acceptable Use Policy, Privacy Policy, and any product- or country-specific terms, as well as the merchant terms of our payment partners Stripe and Mollie. If there is a conflict, the stricter requirement applies. Capitalised terms not defined here have the meaning given in our Terms of Service.

9. Governing law and jurisdiction

This Policy is governed by the laws of the Netherlands. The courts of Amsterdam, the Netherlands, have jurisdiction over any dispute arising out of or relating to this Policy. Nothing in this section deprives a merchant or customer of the protection of mandatory provisions of consumer-protection, data-protection, or other law of the jurisdiction in which it is established or resident, where such law applies and cannot be excluded by agreement.

Contact

Questions about this Policy, or requests to confirm whether a business is permitted, can be sent to:

• Policy and legal queries: legal@coded.eu
• Compliance and risk: security@coded.co

Coded B.V. De Taling 15, 2761 SL Zevenhuizen, The Netherlands Netherlands Chamber of Commerce (KvK): 42027097 VAT: NL869368795B01 Effective date: 11 June 2026