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Exhibit E — SHAFT Policy

Exhibit E (EU)

SHAFT Policy

Restrictions on Sex, Hate, Alcohol, Firearms, and Tobacco messaging

Last update: 05/18/2026

This Exhibit E (EU) forms part of, and is incorporated by reference into, the Software as a Service Agreement (the "SSA") between Maestra B.V. ("Provider") and the Customer identified in the Engagement Letter. Capitalized terms not defined in this Exhibit have the meanings given in the SSA. This Exhibit applies to all messages sent through the Services, with particular relevance to SMS, MMS, and other carrier-delivered messaging channels.

1. Background

1.1. Mobile network operators, messaging aggregators, and industry associations across multiple jurisdictions apply restrictions on the use of carrier-delivered messaging channels for content relating to: Sex, Hate, Alcohol, Firearms, and Tobacco (referred to as "SHAFT" content). These restrictions are designed to protect minors and to address the heightened risk profile of such content.

1.2. Although SHAFT terminology originated in the North American messaging-industry guidelines, the underlying restrictions are mirrored, in substance, in the rules of European mobile network operators, in the codes of practice of European messaging aggregators, and in national legislation regulating the advertising of alcohol, tobacco, gambling, and adult content.

1.3. This Exhibit sets forth the rules that the Customer must follow when using the Services to send messages relating to SHAFT content, and supplements the obligations of the Customer under Exhibit D (EU) (Sender Compliance and Subscriber List Certification).

2. SHAFT Categories

For the purposes of this Exhibit, the following categories of content are subject to additional restrictions:

Sex (S)

Content of an explicit sexual nature, adult entertainment content (including but not limited to adult video, escort services, and adult dating where the primary value proposition is sexual), and content promoting commercial sexual services.

Hate (H)

Content that incites hatred or discrimination on the basis of race, ethnicity, national origin, religion, gender, sexual orientation, disability, age, or any other protected characteristic; content promoting or condoning violence on such grounds; content otherwise contrary to applicable hate-speech legislation.

Alcohol (A)

Marketing or promotional content for alcoholic beverages, including advertisements, promotions, contests or sweepstakes involving alcoholic beverages, and content directly linking the consumption of alcohol to the recipient.

Firearms (F)

Marketing or promotional content for firearms, firearm components, ammunition, explosives, knives marketed as weapons, and related accessories; content advertising firearm sales, transfers, or dealer services.

Tobacco (T)

Marketing or promotional content for tobacco products (including cigarettes, cigars, pipe tobacco, smokeless tobacco), nicotine products (including e-cigarettes, vapes, and nicotine pouches), cannabis and cannabis-derived products (including CBD products where regulated), and related accessories.

3. Customer Obligations

The Customer represents, warrants, and covenants that:

(a) the Customer shall not use the Services to send SHAFT content, except in compliance with this Exhibit, with applicable Law, and with the additional rules of the relevant mobile network operator, aggregator, or industry association;

(b) where the Customer sends SHAFT content, the Customer shall ensure age-gating of recipients, by collecting and verifying age of majority (or such higher age as may be required by applicable Law) as part of the opt-in flow, and shall exclude recipients who have not been age-verified;

(c) the Customer shall comply with all applicable advertising restrictions, including but not limited to restrictions on the advertising of alcohol, tobacco, gambling, and adult content under European Union, Member State, and United Kingdom Law;

(d) the Customer shall maintain documented procedures for age verification, exclusion of minors, and exclusion of recipients in jurisdictions where the relevant SHAFT category is prohibited or restricted;

(e) the Customer shall not use the Services to send any content that is unlawful, fraudulent, deceptive, defamatory, or that infringes the rights of any third party.

4. Pre-approval and Carrier Registration

4.1. Some destination operators and aggregators require pre-approval of campaigns or sender IDs for SHAFT content. The Customer is responsible for obtaining all such pre-approvals and registrations prior to sending SHAFT content, including the registration of sender IDs, alphanumeric sender names, short codes, or long codes with the relevant operators and regulators.

4.2. Provider may, in its sole discretion, require additional documentation from the Customer before enabling SHAFT messaging on the Customer’s account, including evidence of age-gating procedures, business licences, and pre-approvals from the relevant operators or regulators.

4.3. Provider may refuse, in its sole discretion, to enable SHAFT messaging on the Customer’s account, or may impose additional restrictions on the routes, destinations, or formats permitted for SHAFT content.

5. Absolutely Prohibited Content

5.1. Notwithstanding any pre-approval or carrier registration, the following content is absolutely prohibited and shall not be sent through the Services under any circumstances:

  • Content depicting or facilitating the sexual exploitation of minors, including any form of child sexual abuse material;

  • Content inciting, glorifying, or facilitating terrorism, violent extremism, genocide, or the murder of identifiable individuals or groups;

  • Content facilitating the sale of unlawful drugs, controlled substances, or prescription medications without appropriate authorisation;

  • Content facilitating human trafficking, modern slavery, or exploitation of vulnerable persons;

  • Content facilitating fraud, phishing, pretexting, identity theft, or other criminal activity;

  • Content distributing malware, spyware, ransomware, or other malicious software;

  • Content otherwise prohibited by applicable Law.

5.2. Any breach of Section 5.1 is grounds for immediate termination of the SSA in accordance with Section 15.3(c) of the SSA, in addition to any other remedies available to Provider at law, in equity, or under the SSA.

6. Enforcement

6.1. Provider may, in its sole discretion, monitor, filter, or refuse to deliver messages that violate this Exhibit, that violate Exhibit D (EU), or that violate Applicable Messaging Laws or the rules of the relevant operator or aggregator.

6.2. Provider may suspend the Customer’s access to messaging services, in whole or in part, for breach of this Exhibit, in accordance with Section 7 of Exhibit D (EU) and Section 2.7 of the SSA.

6.3. The Customer shall indemnify Provider for any Losses arising from the Customer’s breach of this Exhibit in accordance with Section 6 of Exhibit D (EU) and Section 12.2 of the SSA, including any carrier or aggregator penalties, regulatory fines, or third-party claims attributable to the Customer’s SHAFT-related messaging.

7. Updates

7.1. Provider may update this Exhibit from time to time to reflect changes in operator rules, aggregator codes of practice, industry guidelines, or applicable Law. Provider shall publish updated versions of this Exhibit on its website, and the version then in force shall apply to the Customer’s use of the Services.

7.2. Material updates to this Exhibit shall be notified to the Customer through the Means of Communication, and the Customer’s continued use of the Services after the effective date of the update constitutes acceptance of the update, in accordance with Section 2.5 of the SSA.

Exhibit E SSA | Maestra