EU Digital Services Act Statement

1. Purpose

This statement describes how SriLankaExport.com (the “Platform,” operated by Harker International (Pvt) Ltd, Reg. No. PV 00338032, Kandy, Sri Lanka) complies with Regulation (EU) 2022/2065 (the “Digital Services Act” or “DSA”), which entered into force for all online platforms on 17 February 2024.

The Platform is an online intermediary service and an online marketplace under DSA. We provide a platform where Sri Lankan exporters (“Vendors”) list goods that international Buyers can evaluate, request quotes for, and procure. We do not ourselves sell the goods listed by Vendors. EU-resident Buyers and Vendors are covered by this statement.

2. Designation under DSA

We are not a Very Large Online Platform (VLOP) or Very Large Online Search Engine (VLOSE). Our average monthly EU-resident active recipients are well below the 45 million threshold defined in DSA Article 33. The obligations applicable to us are those of an online intermediary that hosts third-party content and an online marketplace under DSA Section 5 (Articles 30 to 32).

3. Single Point of Contact: Articles 11 & 12

For communications from Member State authorities, the European Commission, and the European Board for Digital Services (Article 11), and for direct communications from recipients of the service (Article 12), our designated single point of contact is:

4. Terms of Service & content-moderation rules: Article 14

Our content-moderation rules, restrictions, and grounds for action against Vendor content or Buyer behavior are set out in our Terms of Service, Vendor Agreement, Vendor Code of Conduct, Buyer Code of Conduct, Acceptable Use Policy, and IP Infringement Policy. These documents collectively reflect the “Terms of Service” for DSA purposes. They are written in plain language and are publicly available without account login.

5. Notice-and-action mechanism: Article 16

Any person may notify us of allegedly illegal content on the Platform. Notices must include: (a) a sufficient explanation of why the content is alleged to be illegal; (b) a clear indication of the exact electronic location (URL); (c) the name and email of the notifier (notifier identity is not required for notices of child sexual abuse material); (d) a statement of good faith that the information in the notice is accurate.

Routes for submitting notices:

• For copyright, trademark, or other IP infringement: IP Infringement Policy (preferred, structured form)
• For all other categories of allegedly illegal content (counterfeits, sanctions evasion, hate speech, fraud, etc.): info@harker.international with subject “DSA Article 16 notice”

We acknowledge valid notices within 48 hours and act on them in a timely, diligent, non-arbitrary, and objective manner. We do not require notifiers to use automated tools.

6. Statement of reasons: Article 17

When we take action restricting the visibility, availability, monetization, or access to specific content or a Vendor or Buyer account, we provide a clear statement of reasons to the affected party at the time of the action. The statement includes: the type of restriction; the territorial scope and duration; the facts and circumstances relied on; where applicable, the use of automated means in the decision; a reference to the legal or contractual ground; information on redress mechanisms.

We submit such statements to the European Commission’s DSA Transparency Database, where required.

7. Internal complaint-handling: Article 20

Vendors and Buyers affected by a decision we make under sections 5 or 6 may appeal it without charge. Appeals are reviewed by human operators not involved in the original decision. The appeal route, timelines, and decision criteria are set out in our Dispute Resolution Policy. We respond to appeals within 14 days. Appeal outcomes can reverse, modify, or confirm the original decision.

8. Out-of-court dispute settlement: Article 21

Where an internal complaint does not resolve the matter to the appellant’s satisfaction, the appellant may engage a certified out-of-court dispute-settlement body in their Member State. We will cooperate in good faith with any such body. Decisions of out-of-court bodies are not binding on us unless required by the law of the relevant Member State.

9. Trusted flaggers: Article 22

We give priority handling to notices submitted by trusted flaggers awarded that status under DSA Article 22 by the Digital Services Coordinator of any Member State. To assert trusted-flagger status when submitting a notice, please include the awarding-body name and award reference in the notice header.

10. Measures and protection against misuse: Article 23

We may suspend, for a reasonable time and after prior warning, the provision of services to Vendors who frequently submit content manifestly illegal under the DSA, or the processing of notices submitted by individuals or entities that frequently submit manifestly unfounded notices. Determinations under this section consider the absolute number, the proportion of total submissions, the gravity of misuse, and the intent.

11. Online-marketplace obligations: Articles 30 to 32

Vendor traceability (Article 30): Before a Vendor begins listing goods on the Platform, we collect and verify the Vendor’s legal name, business registration number, Sri Lanka Export Development Board (EDB) registration number, address, contact details, payment account, and certifications relevant to the goods being listed. We retain these details for the duration of the contractual relationship and make them available to Buyers and authorities where required by law.

Compliance by design (Article 31): The Vendor registration flow requires the above information before a Vendor can publish any listing.

Right to information on illegal products (Article 32): Where we identify that a product offered through the Platform is illegal, we will inform Buyers who purchased that product through the Platform within the past six months, providing the identity of the Vendor and any relevant means of redress.

12. Recommender-system transparency: Article 27

The Platform’s product-discovery surfaces (homepage product cards, category landing pages, search results) are ordered primarily by Vendor verification status, certification depth, and listing freshness. We do not use behavioural profiling or personalization that would constitute recommender systems within the scope of DSA Article 27. Search ordering is described in plain language in our Hoe wij werken guide.

13. Transparency reporting: Article 15

We publish a transparency report annually summarizing notices received under Article 16, our own-initiative content moderation, complaints handled under Article 20, and disputes referred to out-of-court bodies under Article 21. The first report will cover the period 2026-01-01 to 2026-12-31 and will be available at /dsa-transparency-report/ by 2027-02-17.

14. No designation as a gatekeeper

We are not designated as a gatekeeper under Regulation (EU) 2022/1925 (the Digital Markets Act). The DMA does not apply to us.