Marketing Guidelines

Dear Affiliates, in order to create and maintain a successful, responsible and compliant presence, through our relationship, we would like to point to your attention an indicative list of mandatory requirements, related to the marketing of any products, pursuant to the Affiliate Agreement.

Our products are not suitable for everyone, so we aim to target our audience carefully.

  • Already actively trading – using CFDs or similar products;
  • Considering trading – intending to start trading CFDs or similar products, or to restart after a period of inactivity;
  • Potential traders – financially engaged individuals, probably already investing online, who could benefit from adding our leveraged and/or unleveraged products to their portfolios.

Mandatory requirements

In addition to the Affiliate Agreement and any terms and conditions, set out herein you should always ensure that you are compliant with any applicable law, rules and guidelines, which may be applicable with respect to our business, your activity and the chosen method of marketing.

For the avoidance of an doubt, without prejudice and in addition to the above, you should strictly follow ESMA restrictions such, as the obligation to always provide the following language when marketing CFD products:

“CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. 80% 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”.

No reference to any bonus/bonuses should be made at all.

General requirements

Fair, clear and not misleading communications

The Affiliate shall ensure that all of his communication, promotion and marketing in relation to the services provided by Trading 212 is fair, clear and not misleading.

Any Affiliate must ensure that each communication and each financial promotion:

  1. is clearly identifiable as such;
  2. is accurate;
  3. is balanced and, in particular, does not emphasise any potential benefits of a product or service without also giving a fair and prominent indication of any relevant risks;
  4. is sufficient for, and presented in a way that is likely to be understood by, the average member of the group to which it is directed, or by which it is likely to be received; and
  5. does not disguise, omit, diminish or obscure important information, statements or warnings.

The Affiliate must ensure that, where a communication or financial promotion contains a comparison or contrast, the comparison or contrast is presented in a fair and balanced way and is meaningful.

The Affiliate must ensure that a communication or a financial promotion:

  • uses plain and intelligible language;
  • is easily legible (or, in the case of any information given orally, clearly audible);

Fair Communication

A communication or a financial promotion should not describe a feature of a product or service as “guaranteed”, “protected” or “secure”, or use a similar term unless:

  • that term is capable of being a fair, clear and not misleading description of it; and
  • the Affiliate communicates all of the information necessary, and presents that information with sufficient clarity and prominence, to make the use of that term fair, clear and not misleading.

Affiliates are only permitted to promote Trading 212 via websites or other sources which have been prior reviewed and approved by Trading 212.

All traffic to Trading 212 from unapproved affiliate websites and from all other sources will be blocked.

Marketing (information) is not fair in the following cases, when:

  • using misleading headlines;
  • making unfair comparisons;
  • displaying important information only in the small print; or
  • not displaying the risks of a product or service prominently enough.

Clear Communication

Marketing (information) is clear, when it may be unambiguously understood by any potential client to the extent an average customer of the firm would understand, the nature of the service that the firm provides.

Remember that: people have different levels of understanding about financial products and many usually won't understand financial industry's jargon or technical terms.

Marketing (information) is not clear, when:

  • You don't provide enough or the right type of information;
  • it is insufficient or is provided (whether in text or as an image) or it may be ambiguously interpreted so that any potential client may not be aware of any:
    • charges;
    • penalties (e. g. if someone withdraws money early from an investment);
    • risks (e. g. if someone could get back less money from an investment than the amount they paid in);
    • key conditions associated with an offer (e. g. if someone has to pay a certain monthly amount into their bank account to qualify for a benefit).

The requirements to be fair and not misleading imply balance in how financial products and services are promoted, so that consumers have an appreciation not only of the potential benefits but also of any relevant risks.

Affiliates should consider the appropriateness of character-limited media as a means of promoting complex features of financial products or services. It may be possible to signpost a product or service with a link to more comprehensive information, provided that the promotion remains compliant in itself. Alternatively, it may be more appropriate to use ‘image advertising’ in accordance with these guidelines to promote Trading 212 more generally.

Below you may find an example of a tweet where the promotion lacks balance, as it over-emphasises the benefits and includes an inadequate risk warning. It also fails to comply with the past performance rules as it makes the indication of past performance the most prominent feature, and fails to include performance information covering at least the immediately preceding five years. In addition, it does not clearly identify itself as a promotion.

“100 000 people are investing with Trading 212. John Doe made 800 % profit in just 6 months. Become successful like John.”

You should:

  • ensure that promotions are balanced and not give too much prominence to the benefits associated with a product without also highlighting the relevant risks;
  • not ‘cherry pick’ data about a product or service;
  • not create unrealistic expectations.Examples of how unrealistic expectations can be created are:
    • advertising savings that turn out to be smaller than those you'll actually get;
    • using headlines that imply attractive rewards, when in reality such rewards are only achievable in limited circumstances.

You should be also mindful about the following:

While we may be providing No Commission deals, it refers only to commission, since mandatory and/or third party fees, may be applicable. Therefore do not use the terms 'No fees' or 'No trading fees' or ‘No transaction fees’, but instead use “no commissions”.

You have to be extremely cautious about the use of words such as “free”, “success”, “win”, “profits”, “gaming”, “play” etc.

When your marketing services, provide for the possibility to direct link for creating an account with Trading 212 (such as “Sign up” or “Register” etc. buttons) the relevant risk warning massages should be visible around any such button or link. Risk waring is set out above (80% of retail investor accounts lose money when trading CFDs with this provider).

That Trading 212 does not provided services to US citizens, to any under the age of 18 years or without prior checks.

Systems and controls

You should use (and we may independently use) systems and controls to make sure that:

  • people designing and approving promotions understand the rules;
  • promotions remain clear, fair and not misleading over time;
  • you monitor promotions and keep adequate records;
  • you review complaints and apply lessons learned to future promotions.

Social media

What is social media?

Social media share the characteristic of being digital and can be defined as ‘websites and applications that enable users to create and share content or participate in social networking’ (Oxford Dictionaries 2013). The following is a non-exhaustive list:

  • blogs;
  • microblogs (Twitter);
  • social and professional networks (Facebook, LinkedIn, Google+);
  • forums
  • image and video-sharing platforms (YouTube, Instagram, Pinterest).

Trading 212 affiliate links may be posted in social networks. However, it is important that you follow Trading 212’s guidelines and always pay attention to the conditions of use for the respective network, because they are subject to change.

The distribution of affiliate links is permitted, as long as the social media account where the links appear is operated by the Affiliate who is posting them. Affiliates need to update their account information to Trading 212 to include the exact social network URL of where the affiliate links will appear. On some social medias (such as Twitter), it is necessary that the account is verified.

Furthermore, Affiliates are not allowed to use Facebook apps to distribute affiliate links. Affiliate links are considered advertising and must therefore be disclosed as such. For this purpose, you can include a note in the immediate vicinity of the link. This also ensures transparency for other users of the social network.

On YouTube, affiliate marketing can be used as an additional source of income, alongside widespread sponsorship. This makes especially good sense when it is a product-related video. This may, for example, be an experience-based review or the test of a particular product. Affiliate links can be inserted into the YouTube description field below the videos.

Communications through social media can reach a wide audience very rapidly, so Affiliates should take account of that in their decision to promote through social media, and the nature of their promotions. Affiliates should therefore ensure that their original communication would remain clear, fair and not misleading, even if it ends up in front of a non-intended recipient (through others retweeting on Twitter or sharing on Facebook). One way of managing this risk is the use of software that enables advertisers to target particular groups very precisely.

Each communication (e.g. a tweet, a Facebook insertion or page, or web page) needs to be considered individually and comply with the relevant rules.

Example of non-compliant banner (third one - The risk warning is lost in surrounding text, which is also of much smaller font-size).

For example, a tweet expressing satisfaction with considerate service received from the firm will not be a promotion, as good customer service is not itself a controlled activity.

Some practical advice

A popular way to promote affiliate links through social media is to place the full affiliate link on a website that you control, such as your own blog, or any site that is not hindered by long website links. Once you have done this, you then shorten the website address to the page that you placed the Trading 212’s affiliate link on, and distribute that link.

By doing this, you are creating an extra step in the process, but by doing this, you can be confident that you will be paid for the qualifying referrals that are sent to Trading 212’s website.

Many social networks, especially Facebook, are clamping down on affiliate links, and anything that looks spammy or like it might be sales-related. Your affiliate trackers might also be seen by users as suspicious, as they are likely to include random letters and numbers that won't always look automatically trustworthy.

Your solution may be to use a link-shortening application.

When performing marketing and promotion activities in the following social networks: Facebook, Twitter, YouTube, LinkedIn, If you choose to promote yourself/your sites either by a creating a Group/Page/Channel or personal profile you shall always ensure that:

The name of the page/account and the profile picture you select cannot mention ‘Trading 212’s’ name or logo in any way.

You cannot use Trading 212’ official page/corporate accounts to promote yourself/your site by posting advertising materials or links. If you choose to promote your page with paid advertising options (i. e. Facebook ads), you cannot mention Trading 212’s name within the description of the ad or the logo within the creative of the selected image. Also, each of the ads can only direct users to the page you have created OR to an external URL of your choice (i. e. your site).

Affiliates should include risk warnings or other statements in promotions for certain products/services. These rules are media-neutral and therefore apply to social media as they would to any other medium.

Image advertising is exempt from most of the detailed financial promotions rules and guidance, but it will still need to comply with the high-level ‘fair, clear and not misleading’ rules, listed above.

Please note that these Guidelines may be amended by us at an time, upon our sole discretion and without prior written notice. Therefore, whenever you are undertaking any campaign, please make sure that you have reviewed this Guidelines, available at our site at all times.