Marketing Regels

The following guidelines and examples are designed to help make sense of the regulatory requirements for Financial Promotions for promoting the Admirals brand, which are used internally and externally.

1. Basic requirements for all Financial Promotions

Investment firms shall ensure that the information they address to, or disseminate in such a way that it is likely to be received by, retail or professional clients or potential retail or professional clients, including marketing communications, satisfies the following conditions:

1.1 The information includes the name of the investment firm;

1.2 The information is accurate and always gives a fair and prominent indication of any relevant risks when referencing any potential benefits of an investment service or financial instrument;

1.3 The information uses a font size in the indication of relevant risks that is at least equal to the predominant font size used throughout the information provided, as well as a layout ensuring such indication is prominent;

1.4 The information is sufficient for, and presented in a way that is likely to be understood by, the average member of the group to whom it is directed, or by whom it is likely to be received;

1.5 The information does not disguise, diminish or obscure important items, statements or warnings;

1.6 The information is consistently presented in the same language throughout all forms of information and marketing materials that are provided to each client, unless the client has accepted to receive information in more than one language;

1.7 The information is up-to-date and relevant to the means of communication used;

1.8 The information must include not only the example of a positive outcome but also an example of a negative outcome.

1.9 The information must have a risk warning.

2. SEO articles and analysis posts

Principles

2.1 The comparison must be meaningful and presented in a fair and balanced way;

2.2 The sources of the information used for the comparison must be specified;

2.3 The key facts and assumptions used to make the comparison must be included;

2.4 The article or post must include the correct disclaimer.

When indicating to PAST PERFORMANCE:

2.5 The reference period and the source of information must be clearly stated;

2.6 The information must contain a prominent warning that the figures refer to the past and that past performance is not a reliable indicator of future results.

When indicating to FUTURE PERFORMANCE:

2.7 The information must not be based on or refer to simulated past performance;

2.8 It must be based on reasonable assumptions supported by objective data;

2.9 Where the information is based on gross performance, the effect of commissions, fees or other charges must be disclosed;

2.10 It must contain a prominent warning that such forecasts are not a reliable indicator of future performance.

3. Social media

3.1 Twitter

• No 20% text rule, but better to use Main Title and Subtitle if it suits
• Use risk warning
• Possible to use button

Examples of how it should look:

3.2 Facebook

• Images or posts must have risk warning, at least on the text
• Do not use a lot of text in the image. If you are using text, use only main title, text can be no more than 20% of the image size size (including branding and text on graphics)
• It is possible to title and subtitle fields when sharing content (e.g. articles and webpages)
• Possibility to use a button in paid Facebook ads and boosted posts
• In the page’s cover image, do not cover bottom left half of the space, because avatar image located there
• Do not use branding on every image

Examples of how it should look:

3.3 Linkedin

• No 20% text rule, but better to use Main Title and Subtitle if it suits
• Use risk warning
• Possible to use button

Examples of how it should look:

3.4 Google ads

• Must include brand
• Must include risk warning
• Button available for display advertising

Examples of how it should look:

3.5 Instagram

• Risk warning is necessary when promoting
• Possible to use brand
• No 20% text rule

Examples of how it should look:

4. Banners

Basic key points for designing effective communications:

4.1 Easy to understand language with short, understandable messages. The language used should be appropriate for the target audience, jargon-free and contain simple and short messages.

4.2. Designed for a target group of consumers. Communications should be designed to meet the needs of the target audience of consumers.

4.3 Key information displayed prominently and framed effectively.

4.4 Correct use of images and graphics.

Main requirements:

4.5 The information must be fair, clear and not misleading;

4.6 The information must have clear reference to product;

4.7 Avoid unprofessional marketing (context, language, pictures etc.);

4.8 The banner must have balanced information (use a font size for the indication of relevant risks that is at least equal to the predominant font size used throughout the information provided, as well as a layout ensuring such information is prominent);

4.9 The banner must have risk warnings (use a font size in the indication of relevant risks that is at least equal to the predominant font size used throughout the information provided, as well as a layout ensuring such information is prominent);

4.10 Avoid ambiguous wording;

4.11 It’s prohibited to use hashtags on the banner.

The common Financial Promotion failings on the banners are following:

4.12 Het niet onderscheiden van AM-instrumenten van de onderliggende activa; bijvoorbeeld: digitale valuta (het juiste om te zeggen is dat we digitale valuta CFD`s hebben)

4.13 Inadequate product description

4.14 Emphasising only the benefits of the product

4.15 Failure to include a balanced picture of risk and charges

4.16 Unrealistic headline claims

4.17 Missing or inadequate description of the risks

4.18 Risk warning is missing and/or invitation to read terms and conditions

5. Rules of the campaign (Terms and Conditions):

5.1 Contact information of the organiser of campaign (business name, contact details: address, email, telephone).

5.2 Time period of organising the consumer game (start and end dates, the hour, if necessary. Consider if market hours should be included for example).

5.3 List of prizes (description, value). If the winner can choose the prize, then it must be specified out of which products. If there is only one prize per participant, the respective information must be added.

5.4 Requirements for participants (e.g. residency of participant if necessary: participant must be adult; each person can participate only once; however, client can participate as a natural person and with legal entity where he/she is a sole owner for example).

5.5 Conditions for participation (what must a client do in order to participate in the game), including participation in interim lottery draws and a chance to reach the final.

5.6 Time and description of when and how the winner or winners will be chosen, including the winners of interim campaign draws and the winner of main prize. This should also include a description of the ranking of the participants with identical results (e.g. total points or time) or you should consider excluding this option.

5.7 Announcement of winners (through which channel and whether the winners will be contacted personally).

5.8 Information about using the data of the winner (disclosure of the name of the winner).

5.9 Delivery of prizes (location or reference to postal delivery; time period during which the prizes will be delivered).

5.10 Possibilities to obtain additional information (web address; email address; telephone; address of a local branch and main office address).

5.11 Procedure and deadline for handling the complaints (contact details for submission of complaints).

5.12 In case the campaign is targeted to certain region clients, an option to communicate in this language must be ensured. This means also Campaign Rules/Terms and Conditions must be in the local language.

6. Video

6.1 Risk warning must be prominent and not disappear under the media player menu.

6.2 Compliant versions are also applicable for TV commercials where the ESMA sticky risk warning is visible throughout the video.

6.3 Final frame of the video must have longer risk warning and AM company registration information.

7. Risk warning

The relevant risk warning must be:

7.1 Prominent;

7.2 Contained within its own border and with bold and unbold text as indicated;

7.3 If provided on a website or via a mobile application, statically fixed and visible at the top of the screen even when the retail client scrolls up or down the webpage; and

7.4 If provided on a website, included on each linked webpage on the website.

The relevant risk warning, including the font size, should be:

7.5 Proportionate, taking into account the content, size and orientation of the marketing material as a whole; and

7.6 Published against a neutral background.

8. References and risk warning examples

In order to keep the content AM provides reliable, and to protect AM from possible copyright infringement, we expect the pictures, charts, texts (news, studies, books etc.) and graphs added with reference to their original source.

8.1 Charts:

Source: Admirals MT5 with MT5-SE Add-on XXX Daily chart (between XXX, 201X, to XXX 201X). Accessed: XXX, 2019, at XX:00pm GMT - Please note: Past performance is not a reliable indicator of future results, or future performance.

Disclaimer: Charts for financial instruments in this article are for illustrative purposes and does not constitute trading or investment advice or a solicitation to buy or sell any financial instrument provided by Admirals (CFDs, ETFs, Shares). Past performance is not necessarily an indication of future performance

8.2 SEO articles:

This material does not contain and should not be construed as containing investment advice, investment recommendations, an offer of or solicitation for any transactions in financial instruments. Trading financial instruments offered by Admirals (CFDs, ETFs, stocks) carries a high level of risk which is not suitable for all investors due to their complex nature. Before making any investment decisions, you should seek advice from independent financial advisors to ensure you understand the risks involved. Read more at www.admiralmarkets.com.

CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. XX% of retail investor accounts lose money when trading CFDs with this provider. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.

8.3 Analysis post:

INFORMATION ABOUT ANALYTICAL MATERIALS:

The given data provides additional information regarding all analysis, estimates, prognosis, forecasts, market reviews, weekly outlooks or other similar assessments or information (hereinafter “Analysis”) published on the website of Admirals. Before making any investment decisions please pay close attention to the following:

1. This is a marketing communication. The content is published for informative purposes only and is in no way to be construed as investment advice or recommendation. It has not been prepared in accordance with legal requirements designed to promote the independence of investment research, and that it is not subject to any prohibition on dealing ahead of the dissemination of investment research.

2. Any investment decision is made by each client alone whereas Admirals shall not be responsible for any loss or damage arising from any such decision, whether or not based on the content.

3. With view to protecting the interests of our clients and the objectivity of the Analysis, Admirals has established relevant internal procedures for prevention and management of conflicts of interest.

4. The Analysis is prepared by an independent analyst (hereinafter “Author”) based on the NAME + (Position) personal estimations.

5. Whilst every reasonable effort is taken to ensure that all sources of the content are reliable and that all information is presented, as much as possible, in an understandable, timely, precise and complete manner, Admirals does not guarantee the accuracy or completeness of any information contained within the Analysis.

6. Any kind of past or modeled performance of financial instruments indicated within the content should not be construed as an express or implied promise, guarantee or implication by Admirals for any future performance. The value of the financial instrument may both increase and decrease and the preservation of the asset value is not guaranteed.

7. Leveraged products (including contracts for difference) are speculative in nature and may result in losses or profit. Before you start trading, please ensure that you fully understand the risks involved.

8.4 Social media

Twitter

[insert percentage per provider]% of retail CFD accounts lose money.

Facebook, banners, videos

[insert percentage per provider]% of retail investor accounts lose money when trading CFDs with this provider. You should consider whether you can afford to take the high risk of losing your money.

8.5 Webinar, seminar, presentation materials

Trading with financial instruments (CFDs, Stocks, ETFs) offered by Admirals carries a high level of risk which is not suitable for all investors due to their complex nature. Before entering into client agreement or making a transaction, please make sure to read the terms and conditions of our service. Consult a specialist if necessary, to ensure you understand the risks involved in trading.

This content is for information and educational purposes only. The content materials are developed by Admirals and distributed by Admirals Group AS investment firms for a global audience. Therefore, please take into consideration that the information in this session may not be suitable for everyone.

To get the corresponding information on charting, conditions and any other details, please visit admiralmarkets.com, select your country of residence and contact an appropriate entity.

This content is for general information only and is not intended to provide trading or investment advice or personal recommendations. Any information relating to past performance of an investment does not necessarily guarantee future performance. Admirals shall not be responsible for any loss that you incur, either directly or indirectly, arising from any investment based on any information in this content.

The information is not directed at residents of the United States, Belgium or any particular country and is not intended for distribution to, or use by, any person in any country or jurisdiction where such distribution or use would be contrary to local law or regulation.

Related document is annex for Marketing and Financial promotion guidelines of Admirals.