Rules for consumer unions on the platform

A consumer union represents its members and must not be secretly directed, funded or controlled by the company it claims to scrutinise. Companies must not create their own consumer unions to give the impression that customers have an independent organisation.

Financial support, partnerships and other ties that may influence the organisation's positions must be disclosed openly. People with clear conflicts of interest must not make decisions without members knowing about them.

Members must be able to influence which issues the union pursues. There must be rules for membership, votes, election of representatives and changes to the organisation's direction.

Representatives must have a clear mandate. They must not present their own opinions as members' decisions. Major demands, negotiations and collective actions must be decided in the way the statutes prescribe.

Members must be able to see which decisions were made, what they were based on and who is responsible for carrying them out.

Criticism of companies must be described as correctly as possible. The union must distinguish between:

• verified facts
• individual customers' experiences
• interpretations and assessments
• suspicions that have not yet been confirmed

A single account may be published as an individual experience, but must not automatically be presented as proof that all customers are treated the same way. Serious accusations require stronger evidence than minor claims.

Sources must be given where possible. Incorrect or misleading claims must be corrected. Where significant uncertainty remains, that uncertainty must be stated in the text.

Accuracy does not mean the union must be neutral. It may have clear values and pursue firm demands. But the description of what the company did must be kept apart from the organisation's judgement of it.

Before a union publishes a serious accusation or launches a major campaign, the company should normally be given the chance to respond. The company's reply must be reported fairly and made available to members.

The union does not have to accept the company's explanation. The requirement is that members can weigh both sides before deciding.

Exceptions can be made if there is an acute risk to consumers, if the company tries to prevent publication through threats, or if advance notice would put people in danger. The reason for the exception must then be documented.

The union must weigh the problem it wants to solve against the harm a collective action can cause. A minor fault should normally not be met with the most intrusive measure straight away.

Where possible the union should first:

• check the facts
• contact the company
• present the problem and a clear demand
• give the company reasonable time to respond or fix the problem
• inform members of the reply
• decide on the next step

This does not mean the union must always begin with the weakest possible measure. For serious or repeated problems a faster and stronger reaction can be justified. But the organisation must be able to explain why the chosen method is reasonable.

Small companies do not have the financial, legal and communication resources of large groups. A wide digital campaign can damage or destroy a small company before it has even understood the accusation and responded to it.

The purpose of a consumer union is to reduce unreasonable power imbalances. If a large group of consumers directs its combined power at a small company, the union itself can become the stronger party. Small companies should therefore not automatically be met with the same methods as large ones.

When organising against a smaller company, special consideration must be given to:

• the company's revenue and financial margins
• how many people work at the company
• whether the company belongs to a larger group
• how large a customer group the union gathers
• how serious and systematic the problem is
• whether the company has had a chance to fix it
• whether the demand concerns something the company can actually influence
• what harm a public campaign or boycott could cause

As a main rule a small company must be contacted before a public campaign starts. The problem and the demand must be described concretely, and the company must get reasonable time to reply and act. The union should first try to solve smaller problems through contact and negotiation.

This does not give small companies the right to treat consumers badly or escape scrutiny. A small company can commit serious violations and cause significant harm. Company size should affect the choice of method, not remove responsibility.

A boycott or collective exit must not be presented as the union's decision if a single administrator decided it. It must be clear:

• which demand the action concerns
• what evidence the decision rests on
• which members were allowed to vote
• how the vote was carried out
• which threshold must be reached
• when the action starts
• which conditions end it
• when the decision will be reviewed

Members' commitments must be voluntary. A union may argue for its line but must not threaten, harass or expose people who choose not to take part.

If the company meets the agreed demand, the union must consider whether the boycott or exit should end. The goal must not be moved simply to make it impossible for the company to comply.

Consumer unions on the platform must not:

• publish knowingly false or misleading claims
• threaten or harass the company's employees, customers or owners
• publish private personal data
• call for violence, vandalism or other illegal acts
• organise fake reviews or ratings from people who have not used the service
• send mass messages to block the company's communication channels
• make false orders, bookings, complaints or reports
• manipulate member numbers, votes or thresholds
• use discriminatory demands or language
• impersonate the company, a public authority or another consumer union
• target campaigns at individual employees not responsible for the criticised decision
• use the platform for personal conflicts without a clear consumer interest

A union may criticise named decision-makers when their role is relevant. The criticism must then concern their decisions and responsibility, not their private life or traits irrelevant to the issue.

A union must clearly distinguish between registered users, members, verified customers, people supporting a specific demand and people who have committed to take part in an action.

The organisation must not describe everyone who visited or followed the page as members. Nor may it claim that a certain number of customers intend to leave the company when they have only expressed general support.

Platform statistics must be used according to the definitions given on the site. Attempts to create fake accounts or manipulate figures can lead to suspension.

The union may only collect the data needed for membership and its activities. Data used to verify a customer relationship must not automatically become public.

Member lists, contact details, receipts, contracts and other documents must not be handed to the company or others without a legal basis or the member's explicit consent.

Personal stories may only be published openly with the person's permission. Anyone who withdraws permission must be able to have identifying details removed, as far as possible.

Members must be able to see how the union is funded and how its money is used. Larger donations, payments and partnerships must be disclosed when they can affect credibility or priorities.

A union must not accept secret payment from a competing company to attack another. Nor may it let a funder buy control over member decisions or use the organisation as hidden marketing.

An approved union may not claim the exclusive right to represent all of a company's customers. Other customers may start a competing union with different priorities or methods.

The organisation's name and presentation must make it distinguishable from other unions. It must not imitate another union's name or visual identity to confuse members.

Unions may criticise each other factually. The same rules on accuracy, corrections, privacy and harassment apply as when criticising companies.

The union is responsible for updating information about representatives, statutes, funding, current demands and decisions made. Concluded votes and campaigns must not be shown as ongoing.

If the organisation has become inactive, this must be visible. Members must be able to request a new election or restart the organisation according to its statutes.