Content Policy

1. Scope

This policy applies to documents that users publish with Clarifo's publishing feature and that are shown to readers on clarifo.com (published documents). For this content Clarifo acts as a hosting service under the EU Digital Services Act (Regulation (EU) 2022/2065, "DSA").

Authors are responsible for what they publish. Clarifo does not review published documents in advance and does not endorse their content, analysis or opinions.

2. Prohibited content

You must not publish content that falls into any of the following categories. The numbers are the references we use in our decisions.

• 2.1 Misleading financial information: false or deceptive figures, fabricated quotes or events, or forecasts and opinions presented as established facts.
• 2.2 Market manipulation: content that gives, or is likely to give, false or misleading signals about the supply, demand or price of a financial instrument, such as pump-and-dump schemes or false rumours, and the unlawful disclosure of inside information (Regulation (EU) No 596/2014, the Market Abuse Regulation).
• 2.3 Undisclosed conflicts of interest: recommending or promoting a financial instrument without disclosing a position you hold in it, payment you receive for the content, or another material interest (see section 3).
• 2.4 Spam and platform abuse: unsolicited promotion, scams, link farms, repetitive or automatically generated content published to manipulate search engines or readers.
• 2.5 Copyright and intellectual property: content that infringes copyright or other intellectual property rights, such as copying paid research or reports without permission.
• 2.6 Harassment and hate: threats, abuse, doxxing, or content that attacks people on the basis of protected characteristics.
• 2.7 Other illegal content: any other content that is illegal under EU law or the law of an EU Member State, such as fraud or the unlawful disclosure of personal data.

3. Investment recommendations

If a document recommends or suggests an investment decision or strategy, for example a buy, sell or hold view or a price target, we expect the author to:

• disclose any position they or closely associated persons hold in the instrument, and any payment or other relationship with the issuer;
• clearly separate facts from opinions, estimates and projections;
• name the sources of material facts and date the document and the prices used.

A "not financial advice" disclaimer does not replace these disclosures. These expectations follow Article 20 of the Market Abuse Regulation and Commission Delegated Regulation (EU) 2016/958. Authors remain personally responsible for complying with the rules that apply to them.

4. How to report content

Anyone can report a published document with the "Report content" link at the bottom of the page. Choose the category that fits best and explain what is wrong, pointing to the exact part of the document.

If you report illegal content (market manipulation, copyright infringement or other illegal content), your notice must include your name and email address, an explanation of why you consider the content illegal, and a statement that the notice is accurate and complete and made in good faith, as required by Article 16 of the DSA. Reports of child sexual abuse material do not need to identify you; you can send them to [email protected] or report them directly to the police.

You receive a reference number when you submit a report. If you give an email address, we confirm receipt by email and tell you the outcome. We may stop processing reports from people who frequently submit manifestly unfounded reports.

5. How we decide

A person on our moderation team reviews every report. We may use automated content review to flag newly published documents for faster review; such flags only set priorities, and we do not hide or remove content on the basis of an automated decision alone.

We assess each case diligently, objectively and in context, taking into account the document as a whole and the freedom of expression and information. Possible outcomes are no action, hiding the document from readers, or removing it from publication. We may suspend accounts that repeatedly publish manifestly illegal content.

6. Statement of reasons and appeals

When we restrict a published document, we tell the author in the app and by email what was restricted, the ground for the decision (the law or the section of this policy), the facts and circumstances we relied on, whether automated means were used, and how to seek redress.

The author can appeal within six months with the "Appeal this decision" button in the document editor. A person reviews every appeal, and we reverse the decision if it was not justified. People who reported the document are told the outcome of their report.

Authors and notifiers may also have the right to refer a dispute to an out-of-court dispute settlement body certified under Article 21 of the DSA, or to a court.

7. Single point of contact

Authorities of the EU Member States, the European Commission, the European Board for Digital Services and users can contact us about this policy and the DSA at [email protected]. We communicate in English and Finnish.

8. Who we are

The Clarifo service is provided by:

Katse Holding Oy Business ID: 3274118-8 Registered office: Helsinki, Finland Email: [email protected]