ReShopMe Limited — Antitrust Standards and Guidance Notes

Version 2.0 · Effective 10 August 2026

1. Policy and introduction

ReShopMe's antitrust policy is established by The Way We Operate:

"ReShopMe is committed to the principles of free and fair competition. It is our policy to compete vigorously and effectively while always complying with the applicable competition laws and regulations in all countries in which we operate."

ReShopMe makes decisions about its commercial strategy independently.

Improper contact with competitors exposes the company and individuals to severe penalties — including, for cartel conduct, criminal liability in both New Zealand and Australia — and to damage to the reputation on which a marketplace depends. Conduct in one country that affects trade in another must comply with the laws of both.

Standards and guidance. The standards in section 3 are mandatory; the guidance notes in section 4 assist in applying them. If you are in any doubt, ask a director before acting; where the question is not simple, the board takes external competition-law advice. In some circumstances written communications may not be privileged — raise sensitive questions by phone first.

Application. These standards apply to all directors, officers and employees of ReShopMe Limited, and we expect consultants, agents, contractors and suppliers acting on our behalf to comply with them. Failure to comply may result in disciplinary action up to dismissal. Where these standards and local law differ, comply with the more stringent. The board is the custodian of these standards and reviews them at least every two years.

2. Definitions

Competition laws — laws prohibiting anticompetitive practices, including the Commerce Act 1986 (NZ) and the Competition and Consumer Act 2010 (AU).

Commercially sensitive information — any information not publicly known relating to: prices, fees and commission rates; contract negotiations; costs; supply terms; credit terms; wage rates; commercial strategies or plans; intentions to bid or not bid; and current or prospective market share, customers or sellers.

Competitor — a business which offers, or could reasonably be expected to offer, services the same as or similar to ReShopMe's: other marketplaces, resale platforms and consignment services. A supplier or partner may also be a competitor in particular circumstances; if in doubt, ask.

Marketplace participants — the buyers and sellers who trade on ReShopMe. They are our customers, and the sellers among them are also competitors of each other — which is why section 3.6 exists.

3. Antitrust standards

3.1 Information sharing. You must not — directly or indirectly — disclose to, seek from or exchange with a competitor any commercially sensitive information, unless the exchange has been specifically approved by the board on advice. Price fixing, group boycotts and market allocation are serious offences; under no circumstances discuss or agree fees, commission rates, trade terms, customers or markets with a competitor. Indirect disclosure counts: do not use a journalist, a trade publication or a public announcement as a means of signalling future pricing without advice first.

3.2 Contact with competitors. Keep intentional business contact with competitors to a minimum, and only with a director's prior approval. There are legitimate reasons for contact — an industry-wide regulatory change, a genuine acquisition discussion — but the information-sharing standard applies throughout, and the contact and its subject matter must be documented.

3.3 Industry meetings and events. Attend meetings of industry groups, associations and conferences only with a director's approval. If commercially sensitive matters come up among competitors at such an event, decline to participate, leave, and report it.

3.4 Benchmarking and joint activity. Any benchmarking or joint activity involving a competitor requires a written plan — what information, for what purpose, through what process — approved by the board on advice, and limited to what the purpose genuinely requires.

3.5 Vertical arrangements and market position. Arrangements with carriers, payment providers and other suppliers or partners often enhance efficiency, but any arrangement that could be viewed as substantially lessening competition, excluding others from a market, or — as ReShopMe grows — taking advantage of market power, must be approved by the board on advice. This includes exclusivity terms and any clause restricting a counterparty's dealings with our competitors.

3.6 The marketplace itself. Standards specific to operating a platform on which thousands of sellers compete:

• Sellers set their own prices. ReShopMe does not fix, floor or cap the price a seller lists at, and no employee may direct a seller's pricing. Commission is our price; the listing price is theirs.
• No price-parity or platform-MFN clauses — terms requiring a seller to price on ReShopMe no higher than elsewhere — without prior board approval on advice.
• No facilitation of coordination between sellers. We must not aggregate and share one seller's commercially sensitive information with another, and features that would let sellers coordinate prices are not built.
• Fair access. Our tools, placement and search are operated on criteria we can state; we do not degrade a seller's access for reasons we would not publish.

3.7 Reporting violations. Report any suspicion or allegation of an antitrust violation, or breach of these standards, to a director immediately — verbally first. The board will decide, on advice, whether to investigate, and the speak-up protections in The Way We Operate apply.

4. Guidance notes

4.1 If a competitor volunteers sensitive information — say that ReShopMe's policy is never to discuss such matters, end the conversation, and tell a director immediately. What you heard, and that you objected, should be noted in writing.

4.2 Market intelligence — you may use reputable public sources and genuinely independent third parties. Document the source; take extra care when a customer or partner is also a competitor.

4.3 Meetings that include competitors — agree a written agenda in advance, limit attendance to necessary people, stay on the agenda, and keep minutes.

4.4 Recruiting — do not agree with a competitor to fix wages or not to hire each other's people; both are cartel conduct.

4.5 When in doubt — the test is simple: if the arrangement only works because rivals stop competing, it is the thing the law prohibits. Ask before acting, not after.

Dr Neil Loftus Chairman

ReShopMe Limited · NZBN 9429041194492 · support@reshopme.com