Financial Promotion Policy and Procedures | Assessing Clarity and Fairness | Ability to Mislead | Electronic Money and Authorized Payment Institution | Template for FCA Applications and Authorised Firms

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1 INTRODUCTION

Hirett Ltd is e-wallet services are developed mostly for the business customers who are looking for alternative to the classic banking. Company is oriented for customer services and developed IT solutions for money remittance business, payment card issuing and e-commerce.

Offering this services with the high-class technologies and competitive financial rates give unique business opportunities and added value to the company product.

2 OVERVIEW

Effectively promoting the products and services we offer is a key component of the on-going success of Hirett.

However, it is important that the promotions we produce are clear, fair and not-misleading in accordance with the governance principles established in the Governance Framework document. We want to ensure that our promotions, while highlighting the benefits of our products, allow prospective clients sufficient and accurate information to allow them to make an informed decision as to whether Hirett can provide a solution to one of their needs.

3 ASSESSING CLEAR, FAIR AND NOT-MISLEADING

The overall requirement is for all communications to be clear, fair and not-misleading. However, this policy document and accompanying procedures will solely feature financial promotion – that is promotional material that seeks to invite or induce potential or existing clients to do business with us.

4 CLARITY

In order to ensure that a financial promotion is clear we must understand the information needs of the target audience.

The target audience will be determined by the placement of the promotion and, in some cases, the medium used. For example, website promotions are likely to be accessible by the general population and so must be written in a way that they meet the information needs of a typical member of the general public. Any technical phrases, jargon or acronyms need to be explained and any complex concepts may need further explanation.

However, if an advert was placed in a suitable specialist publication then it would be fair to assume that the reader would have a better understanding of the topic, technical language and complex concepts. As such, the promotion would still be clear to the target audience (the magazine’s readership) despite being potentially unclear to someone from outside the target audience.

5 FRAINESS

Fairness relates to the balance of information given by Hirett to a prospective or actual client or customer. The outcome to be achieved is that the client or customer has sufficient information to make an informed decision whether or not to act.

While it would be unreasonable to expect all the details of how a product or service works to be placed in a promotion, we need to ensure that a balance is achieved, so the more ‘upsides’ that are promoted, the more ‘downsides’ need to be included. In addition, there should be balance in the placing of the relative ‘upsides’ and ‘downsides’. In practice, when a feature of the product is promoted a balance should exist between the ‘upsides’ and ‘downsides‘ described to allow the client or customer to make an informed decision.

The ‘balance’ extends not just to subject matter, but also to prominence within the promotion. So it would be unfair to place all of the benefits of a product in large, bright print at the top of the advert, but hide any possible downsides at the foot of the page in a feint font.

6 ABILITY TO MISLEAD

The final element is ensuring that the promotion is complete and accurate so that it does not intentionally, or otherwise, mislead the client or customer. If any claims are made in the promotion, either for possible savings, client numbers, awards given etc., these must be able to be substantiated.

The promotion should also be checked to ensure that there are no ambiguities or other inaccuracies which could lead to the client or customer feeling that they have been misled.

7 FINANCIAL PROMOTIONS PROCEDURES – UK OPERATIONS

1) All financial promotions issued by the firm must be approved by the Chief Compliance Officer of Hirett, or a suitable member of staff authorized by the Chief Compliance Officer who has had no involvement in the creation of the promotion.
2) Promotions presented for sign-off need to include a copy of the ‘Financial Promotions Approval Document’ (see Appendix 1) completed.
3) The Chief Compliance Officer or delegate will review the promotion and either approve the promotion or return it for further work within 2 business days of receipt.
4) If the promotion is being returned, a full description of the amendments required will be given.
5) All financial promotions received by the Chief Compliance Officer or delegate will be recorded on the Financial Promotions Log (see appendix 2) to ensure that the status of all promotions is known.
6) Once a financial promotion is no longer accurate it must be withdrawn.
7) All active financial promotions must be reviewed on a regular basis to ensure that they are still considered clear, fair and not misleading.

8 FINANCIAL PROMOTIONS PROCEDURES – NON-UK OPERATIONS

1) All financial promotions issued by the firm must ultimately be approved by the Chief Compliance Officer of Hirett, or a suitable member of staff authorized by the Chief Compliance Officer who has had no involvement in the creation of the promotion.
2) Promotions presented for sign-off need include a copy of the ‘Financial Promotions Approval Document’ (see appendix 1).
3) The Chief Compliance Officer or delegate will review the promotion and either approve the promotion or return it for further work within 2 business days of receipt.
4) If the promotion is being returned a full description of the amendments required will be given.
5) All financial promotions received by the Chief Compliance Officer or delegate will be recorded on the Financial Promotions Log (see appendix 2) to ensure that the status of all promotions is known.
6) Once a financial promotion is no longer accurate it must be withdrawn.
7) All active financial promotions must be reviewed on a regular basis, to ensure that they are still considered clear, fair and not misleading and meet local requirements. As part of this review, the date of withdrawal from circulation must be added to the Financial Promotion Log.

9 CONCLUSION

This document fundamentally highlights the company’s approach to Financial Promotions. The Chief Compliance Officer is responsible for incorporating and maintaining this policy and ensuring it effectively manages Hirett’s regulatory and business requirements as the service evolves.

APPENDIX 1: FINANCIAL PROMOTIONS APPROVAL DOCUMENT

APPENDIX 2: FINANCIAL PROMOTION LOG

Date:                     Date promotion is approved

Reference:            Unique sequential reference number

Title:                      The title of the promotion

Countries:              The countries in which the promotion will be issued

Location:               The location / media used, i.e. internet, billboards, magazines, TV etc.

Audience:              The target audience

Approved by:        The name of the person approving the promotion

Comments:                       Any additional comments, including circumstances and date of withdrawal from circulation.

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