1. Introduction Klarna strives to only cooperate with Merchants whose activities are in line with Klarna's vision of making payments and e-commerce safer. For Klarna, this means that ethical aspects of the Merchant's business are taken into account. As a major player we aim to "pull our weight" in realizing this vision and to have a positive influence on the market. Klarna's products and services may only be used for lawful purposes. In addition, we want to prevent our products and services from being used in an unethical way. If a Merchant, which uses Klarna's services, acts in an unethical way or sells goods and services which are in some way unethical or immoral, it could harm the public's confidence in both the Merchant and Klarna. To reduce this risk Klarna has adopted the following Instructions for Merchants. 2. Background and purpose Klarna has adopted these Instructions to give employees, Merchants and other external parties guidance on Klarna's ethical standards. Klarna's aim is to quickly and consistently be able to assess what is in accordance with its values and expectations and communicate this to the Merchants. 3. Principles Judging upon moral or ethical issues is subjective. Klarna will judge upon such issues in its sole discretion. Below are some general principles, which are exemplified in the Appendixes. The examples listed as “Prohibited” are completely disallowed while “Restricted” are allowed under certain conditions and upon pre-approval from Klarna. 4. Prohibited Merchants Klarna is a non-political group of companies and has therefore taken the decision to not cooperate with any political organisation or party. 5. Unethical Business Methods and Practices Klarna shall not cooperate with Merchants, which sell products or carry out services with means and methods that can be regarded as intrusive, misleading, abusive, and disadvantageous to endcustomers or in any other way unethical. The Merchant's means of marketing, advertising, distribution channels and reputation shall be considered when assessing if the business practice is unethical. Klarna may also take into account links to/from the Merchant site and other associations f.ex. in web forums. There is a reputational risk for both the Merchant and Klarna if the Merchant is associated with anything unethical. Klarna shall make a global, proportionate, case-by-case assessment of each Merchant and decides in its sole discretion what is acceptable. For examples of unethical business practices and methods - see Appendix 1. 6. Unethical Products and Services Klarna will not cooperate with Merchants providing products or services, which Klarna considers as unethical. Certain products can be categorized as products of dual use, meaning that they may have a legitimate use, but also an apparent illegitimate use. When assessing Merchants providing products of dual use, Klarna should try to determine if its typical end-customers intend to use the product in an illegitimate way and if the Merchant supports such use. For example, a large proportion of products of dual use would suggest that a Merchant supports the illegitimate use. Klarna shall make an overall assessment of the Merchant in question and pay attention to the Merchant's business practice and conduct in general and its product portfolio. Klarna's assessment shall be proportionate which means that in some cases a Merchant, which sells unethical, but legal, products, can be accepted if such products represent a minor part of the business. For examples of unethical products and services - see Appendix 2. 7. Klarna Checkout In Klarna Checkout (KCO), Klarna cooperates with various partners. Several of these partners apply their own restrictions. This means that additional restrictions apply for Merchants, who wishes to use KCO. For examples of such partner driven restrictions – see Appendix 3. 8. Sanctions If a Merchant fails to comply with these Instructions, Klarna may terminate the cooperation contract. Alternatively, and depending on the severity, Klarna may give the Merchant an opportunity to improve. 9. Division of responsibility Each Country Sales Manager shall ensure that all prospective Merchants, which are brought to the due diligence process are compliant with these Instructions to the best of his/her knowledge. Any uncertainties regarding a prospective or existing Merchant shall be highlighted by the responsible Sales person to the Merchant Decisions Department. The Merchant Decisions Department is responsible for investigating any suspected noncompliance with these Instructions for both prospective and existing Merchants, as well as terminating existing cooperations when needed. Furthermore, the Merchant Decisions Department is responsible for ensuring that each Merchant is reviewed from an ethical perspective in the due diligence process, taking these Instructions and previous cases into consideration and when needed escalate cases to the Ethical Committee described in Klarna's Ethics and Environmental Policy. Customer Service and other departments shall inform the Merchant Decision Department about any suspicious cases. Exceptions from these Instructions may only be granted by Klarna's Ethical Committee or in accordance with the escalation process in the Ethics and Environmental Policy. 10. Adoption and revisions These Instructions shall be adopted by the COO. The Compliance Director is responsible for keeping them updated. The Instructions shall be revised annually or when required. 11. Relevant documents Klarna's Ethics and Environmental Policy Examples of prohibited and restricted business practices and methods: Prohibited Marketing, distribution or other handling of products or services in Appendix 2 Practices and methods abusing cross-border trading for VAT fraud, tax evasion, avoiding consumer protection rules etc Pyramid type schemes for marketing, distribution and sales Door-to-door sales Any type of practices misleading or confusing consumers or discarding consumer protection laws Possession of, or association with, sites, products or services which without doubt can be considered as unethical, immoral or unlawful Use of workforce, for which tax is not declared or without any work permit Delivery methods that may cause suffering to animals Restricted Aggressive or misleading marketing Business practices, which in any other way are controversial and/or may cause the Merchant and Klarna reputational harm Examples of prohibited and restricted products and services: Prohibited Illegal products or services Products that encourage crime or may provide support to illegal activities Illegal substances, such as drugs, and products typically used for manufacturing or using such Unlicensed copies and other products infringing intellectual property rights Replicas, such as fake merchandise Gambling, gaming or lotteries provided without appropriate licenses Products or services, which can inflict danger, injury or suffering to humans or animals Content encouraging or in other ways inappropriately related to hate, violence, racism or discrimination Sexual or pornographic services, such as: o Prostitution o Escort services o Live web cam The sale of a product or service, including an image, which is patently offensive and lacks serious artistic value (such as, by way of example and not limitation, images of nonconsensual sexual behavior, sexual exploitation of a minor, nonconsensual mutilation of a person or body part, and bestiality). Financial products or services, such as: o Savings or investment services o Financial advice or subscriptions Timeshares Donations to political parties or initiatives Transactions that provide the end-customer with cash, such as currency exchange Restricted Tobacco products or substitutes thereof, such as electronic cigarettes Alcohol products Armaments, including replicas, soft air guns, knives etc. These partner driven restrictions can be based on both ethical and/or financial considerations. Prohibited Armaments & Weapons o Investment opportunities o o Free trials or other marketing activity which requires a negative response from the cardholders and binds them to long term subscriptions Penny auctions o o o Guarantees Memberships/clubs Negative response marketing o Ponzi type schemes with reliance upon a continual stream of new participants Get rich quick schemes Lifetime products o o Weapons such as guns, rifles, heavy knives etc. Hunting stores are acceptable with the exception of those selling the products mentioned previously. Paintball, and hunting knives distinctly meant for hunting purposes are accepted. Purchase of bid credits Open ended auctions Repeat / automated bids Tobacco o o Cigarettes / Cigars Pipe / Snuff tobacco Restricted Adult o o o o Physical goods Dating agencies Erotic images / downloads Chat lines Airlines o o Scheduled Non-scheduled / charter flights Auctions Coin Merchants o Computer o o o o Casino / poker / lotteries Contracts for difference / Binary Raffles and prize draws Pay to play games Home furnishing o o o Guaranteed results Seminar download Gambling / gaming o o o o CV-services Guaranteed placement Educational Seminars o o Daily vouchers websites Deal of the day Employment agencies o o Film and music download/streaming Discount vouchers (3rd party) o o File sharing File hosting File storage Digital downloads o Computer maintenance / repair services Computer network / information services / data retrieval services Computer software stores Website hosting Cyberlockers o o o Dealers / Investments Furniture Carpets Bathroom / kitchens Marketing o o o Multi-level marketing Online marketing services / web design / SEO services Outbound telemarketing / inbound telemarketing Motor vehicle supplies / parts o Nutraceutical o o Hotels Cruises Tours Virus protection products and services o o Ticket brokers / agents / resellers Travel agencies / tour operators o o o Prepaid phone cards and services VOIP Ticket agencies o E-wallets Gift / pre-paid cards Telecom o o Prescription drugs Pharmacists and chemists Stored Value Load o o Provision of transaction or processing to sub merchants / third parties Pharmaceuticals o o Vitamin and / or herbal selling in Europe Weight loss centres / muscle gain Payment facilitators o Trading ecom only, no physical outlets or trading from domestic address High pressure sales Unsolicited marketing approach Warranties not provided by the manufacturer o Third party provider e.g. satellite services / maintenance Klarna AB Org nr: 556737-0431 Sveavägen 46 SE-111 34 Stockholm Tel: +46 (0)8 - 120 120 00 Web: www.klarna.com E-mail: [email protected]
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