POLICY – PREVENTION OF SHILL BIDDING AND AUCTION INTEGRITY

CONSIGNATION SAVAGE INC.

Last Updated: 2026-05-26

1. Purpose of the Policy

This Shill Bidding Policy (the “Policy”) establishes the rules, control mechanisms, internal procedures, and administrative measures applicable to any activity involving the manipulation of auctions relating to Cards consigned to Consignation Savage Inc. (“Consignation Savage” or the “Company”).

The Company considers shill bidding to be a critical risk that may compromise its eBay seller account, its business reputation, and its ability to provide its services.

This Policy is intended, in particular, to:

1. Protect the integrity of sales conducted by the Company;
2. Ensure compliance with eBay policies;
3. Protect the Company’s reputation and business operations;
4. Reduce the risk of suspension or restriction of the Company’s eBay seller account;
5. Establish consistent procedures for the Company’s interventions; and
6. Ensure adequate documentation of incidents and interventions.

2. Applicable Documents

This Policy supplements and shall be interpreted consistently with:

1. The Website and Portal Terms of Use;
2. The Consignment Services Agreement; and
3. Any other applicable internal policy or directive.

In the event of a conflict between this Policy and the Consignment Services Agreement, the latter shall prevail.

Unless otherwise indicated, capitalized terms used in this Policy shall have the meanings assigned to them in the Website and Portal Terms of Use and the Consignment Services Agreement.

3. Scope of Application

This Policy applies to:

1. Any Consignor using the Company’s services;
2. Any consigned Card;
3. Any activity conducted on eBay in connection with sales made by the Company;
4. Any user of the Portal; and
5. Any person acting directly or indirectly for the benefit of a Consignor.

4. Definition of Shill Bidding

For the purposes of this Policy, “Shill Bidding” means any practice intended to, or having the effect or result of, artificially increasing the selling price of a consigned Card through deceptive, fraudulent, or artificial means.

Shill Bidding includes, without limitation:

1. Bidding on one’s own Cards;
2. Having a third party place bids;
3. Using multiple eBay accounts;
4. Using the accounts of friends, family members, employees, or business partners;
5. Coordinating artificial bids;
6. Placing bids without a genuine intention to purchase;
7. Manipulating the normal course of an auction; and
8. Any other activity contrary to eBay policies.

Shill Bidding may be carried out directly or indirectly.

5. Zero-Tolerance Policy

Consignation Savage maintains a strict zero-tolerance policy regarding Shill Bidding. Any actual or reasonably suspected activity involving attempted auction manipulation may result in immediate intervention by the Company.

6. Prohibited Conduct

Every Consignor is strictly prohibited from:

1. Engaging in Shill Bidding;
2. Attempting to engage in Shill Bidding;
3. Assisting, encouraging, or enabling Shill Bidding;
4. Circumventing the Company’s or eBay’s detection mechanisms; and
5. Providing false or misleading information regarding bidding activity.

The Consignor remains responsible for acts committed by any person using the Consignor’s account, acting for the Consignor’s benefit, or otherwise associated with the Consignor.

7. Compliance with eBay Policies

Consignors must comply at all times with:

1. eBay policies;
2. Auction rules;
3. Applicable commercial practices; and
4. The obligations set out in the Consignment Agreement.

The Consignor acknowledges that eBay may impose restrictions, that certain users may lose their ability to bid, and that accounts may be suspended or closed. The Company does not control decisions made by eBay.

8. Monitoring and Detection

Consignation Savage may monitor, analyze, and review any bidding activity related to consigned Cards.

9. Risk Indicators

The following circumstances may constitute indicators of Shill Bidding:

1. Repeated bids from the same accounts;
2. Unusual or artificial bidding behavior;
3. Frequent bid retractions;
4. Rapid and unnatural price increases;
5. Activity concentrated around a specific Consignor;
6. Recently created accounts;
7. Apparent connections between multiple accounts;
8. Suspicious transaction history;
9. Lack of a genuine intention to purchase;
10. Repeated cancellations;
11. Information received from eBay; and
12. User complaints or reports.

The presence of one or more indicators does not automatically constitute proof of misconduct but may justify an investigation.

10. Investigative Authority

The Company may conduct any reasonable review or investigation when suspicious activity is detected.

In particular, the Company may:

1. Analyze bidding histories;
2. Review the accounts involved;
3. Review relevant communications;
4. Retain screenshots;
5. Document events;
6. Temporarily suspend certain operations;
7. Contact eBay; and
8. Request explanations from the Consignor.

The Consignor must fully cooperate with any investigation. A refusal to cooperate may constitute an independent ground for suspension or termination of services.

The Company is not required to disclose its internal detection methods or analytical criteria. The detection mechanisms, criteria, thresholds, and analytical procedures used by the Company are confidential.

11. Temporary Preventive Measures

While an investigation is ongoing, the Company may, in particular:

1. Suspend certain sales;
2. Temporarily suspend an account;
3. Remove items from sale;
4. Temporarily withhold funds;
5. Restrict access to the Portal; and
6. Delay certain payments.

These measures may be implemented as a precautionary measure and without any admission of wrongdoing.

12. Mandatory Documentation

Every instance of Shill Bidding or reasonable suspicion thereof must be documented in writing. Any warning issued to a Consignor must be retained in the relevant file.

Where available, the internal file must include the date, the Consignor’s name, the affected consigned Cards, lot numbers, accounts involved, screenshots, relevant communications, observations made, measures taken, the name of the employee responsible, communications sent to the Consignor, any response received, and any other relevant information.

13. Record Retention

Records relating to an investigation or intervention may be retained for any period reasonably considered necessary to ensure the Company’s compliance, respond to a request from eBay, protect the Company’s rights, manage a potential dispute, or satisfy any legal obligation.

14. Administrative Measures and Sanctions

When Shill Bidding is detected or reasonably suspected, Consignation Savage may, at its sole discretion:

1. Issue a warning;
2. Cancel bids;
3. Remove Cards from sale;
4. Temporarily suspend an account;
5. Permanently suspend an account;
6. Terminate the business relationship;
7. Prohibit future use of the Company’s services;
8. Report the matter to eBay;
9. Withhold funds;
10. Charge administrative fees;
11. Exercise any other available remedy; or
12. Refuse any future consignments from the Consignor.

The Company is not required to issue a warning before imposing any administrative measure.

Any Shill Bidding constitutes a material breach of the Consignment Services Agreement. The Company may terminate the Agreement immediately, without prior notice or an opportunity to remedy the breach.

15. Withholding of Funds

The Company may withhold any Consignor Balance:

1. During an investigation;
2. Until the matter has been fully resolved; or
3. Until the Company considers the matter satisfactorily resolved.

Such withholding constitutes a reasonable administrative measure intended to protect the Company’s interests.

16. Administrative Fees

Without limiting any other rights or remedies available to the Company, any instance of Shill Bidding, attempted Shill Bidding, or investigation reasonably conducted in connection with Shill Bidding may result in the following administrative fees:

1. Investigation and administrative processing fees of $50 for a first case;
2. Investigation and administrative processing fees of $100 for a second case;
3. Investigation and administrative processing fees of $500 for any subsequent case or any situation that has resulted in an intervention, warning, restriction, or other measure taken by eBay in connection with the case;
4. Full reimbursement of any penalty, fee, charge, chargeback, withholding, loss, or claim imposed on or incurred by the Company in connection with the situation; and
5. Reimbursement of any professional, legal, technological, administrative, or operational costs reasonably incurred by the Company in investigating, managing, or resolving the case.

The amounts set out in this section shall become immediately due and payable once determined by the Company and may be offset against, withheld from, or deducted from any Consignor Balance or any other amount payable to the Consignor.

17. Reporting to eBay or Authorities

The Company reserves the right to report any suspicious activity to eBay, a business partner, a service provider, or any competent authority.

18. No Requirement to Establish Criminal Offense

The Company is not required to conclusively establish that fraud has occurred in order to take action.

Reasonable suspicion supported by objective evidence may be sufficient to justify administrative measures.

19. Limitation of Liability

Consignation Savage shall not be held liable for decisions made by eBay, restrictions imposed on users, account suspensions, losses resulting from the application of this Policy, or consequences arising from the Consignor’s actions.

20. Policy Review

The Company may amend this Policy at any time to reflect evolving practices, maintain compliance, improve its control mechanisms, or meet the requirements of the platforms it uses.

21. Effective Date

This Policy shall take effect on October 29, 2026.