Market Conduct: Fair Disclosures & Client Communications

1. Overview

This circular sets expectations for how operators communicate with clients, promote services, and present risk. The objective is to prevent misleading practices and ensure that client-facing information is accurate, clear, and balanced.

2. Core Principle

3. Marketing & Promotion Standards

• no guaranteed profit language
• no exaggerated or unverifiable performance claims
• bonus terms must be clearly disclosed
• conditions must not be hidden or obscured
• marketing must reflect actual product behaviour

4. Client Communication Expectations

5. Affiliate & Third-Party Conduct

• operators are responsible for affiliate behaviour
• affiliate messaging must be monitored
• misleading promotions must be corrected or removed
• affiliate agreements should include conduct expectations

6. Complaints & Communication Records

• complaints must be logged and tracked
• responses must be consistent with disclosures
• communication records must be retained
• patterns of complaints should trigger review

7. Common Failures

• profit claims without context or disclaimers
• bonus conditions hidden in fine print
• affiliate exaggeration not monitored
• inconsistent messaging across channels
• support teams giving incorrect information

8. Supporting Resources

• Complaints Handling & Communications
• Affiliate & Marketing Controls
• Operator Controls Matrix

9. Contact

For clarification:

10. Effective Date

This circular takes effect immediately upon publication.