EToro AUS Capital Ltd. & Gleneagle Asset Management Ltd. Guideline
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eToro AUS Capital Ltd. & Gleneagle Asset Management Ltd. Guideline PARTNER COMPLIANCE GUIDELINES for eToro AUS Capital Ltd – AFSL 491139 and eToro Service ARSN 637 489 466 offered by Gleneagle Asset Management Limited Ltd AFSL 226199. All you need to know in one place August 2021
Marketing Affiliate Rules Below is a checklist of the main rules that should be followed when promoting eToro AUS on your affiliate marketing channel: Always add the Risk Warning: 2 Remember that CFD assets are offered through eToro AUS . 1 - eToro AUS Capital Ltd ACN 612 791 803 AFSL - Real Stocks are offered through eToro 491139. OTC Derivatives are speculative and Service ARSN 637 489 466 operated by leveraged. Capital is at risk. See PDS under Gleneagle Asset Management ACN 103 162 every CTA (Call to Action) when promoting 278 AFSL 226199 and promoted by eToro AUS CFDs. Capital Limited ACN 612 791 803 AFSL 491139. - eToro Service ARSN 637 489 466 promoted by eToro AUS Capital Limited ACN 612 791 803 Always be fair, clear and avoid misleading AFSL 491139. Capital at risk. Other fees apply. 3 statements. See PDSunder every CTA (Call to Action) when promoting real stocks Always mention in your affiliate marketing - eToro Ser vice AR SN 637 4 89 4 66 4 channel which eToro entity you are promoting: promoted by eToro AUS Capital Limited eToro AUS Capital Limited ACN 612 791 803 ACN 612 791 803 AFSL 491139. Capital at AFSL 491139 risk. See PDS. Zero commission does not OR apply to short or leveraged positions. eToro Service ARSN 637 489 466 promoted Zero commission means that no broker by eToro AUS Capital Limited ACN 612 791 fee has been charged when opening 803 AFSL 491139. Capital at risk. Other fees or closing the position. Limited stock apply. See PDS exchanges only. under every CTA (Call to Action) when promoting Zero Commission 1
Use only correct information in your reviews/ Any new communication channels and any 5 articles and always keep them updated as 8 relevant requests should be immediately per the list below (not exhaustive) - more communicated to the Af f iliate Account information can be found at www.etoro.com Manager and should be pre-approved by the a. Current CFD leverage limits Compliance Function/Department of eToro. b. Popular Investors c. Our Story (history of eToro) Affiliates are not allowed to promote eToro d. Team and Investors 9 via sources other than the ones disclosed e. eToro Copy Systems explanation and approved by the Compliance Function/ f. eToro CopyPortfolios Department of eToro. g. Deposits FAQ h. Withdrawal FAQ Affiliates shall not approach, directly or i. Regulation and License 10 indirectly, any traders and/or potential traders j. Customer Service other than promoting eToro as detailed in k. Invite your friends (“Refer a friend” (RAF) program) these partner guidelines. l. General Risk Disclosure Do NOT use fake celebrity endorsement in Affiliates are only permitted to use eToro’s 11 order to promote eToro 6 official marketing materials which can be found in the affiliate marketing tools. 7 Any educational materials and/or marketing Leading Compliance Principles : materials and/or related materials created by the affiliate to be provided to clients (i.e. banners, videos, newsletters, any significant BE FAIR - do not use misleading headlines changes to the communication channels of the and unfair comparisons. Partners should not affiliate etc.), through all of the communication hide important information by using small channels, should be reviewed and approved print. Always make sure that you display risk by the Compliance Function/Department of warnings in a clear and visible way. Never eToro, prior to dissemination to clients. Any promise profits or gains. related requests to this matter should be forwarded to your affiliate account manager. 2
Do not use any unqualified or absolute RESTRICTED WORDS - Ensure you not use statements unless they can be proved by the following expressions: including a source as to where the information • “stockbroker” or “sharebroker”; is taken from. • “futures broker”; BE CLEAR - about any charges, fees or risks. Ensure you do not use the following expressions / words: AVOID MISLE ADING - ensure that all • “independent”; statements are balanced. Partners can not place too much emphasis on the benefits • “impartial”; associated with a product without also • “unbiased”; or highlighting the relevant risks. Always look • similar expressions. for complete, relevant data and add proper warnings when using data (see section “How to display risk warnings”) Checklist of things to consider: U N R E A L I S T I C E X P E C TAT I O N S - t h e information shall not include the name of any Confirm each sentence in the advert is competent authority in such a way that would factually correct. indicate or suggest endorsement or approval Confirm information presented is relevant. by that authority of the products or services offered by eToro entities. Confirm information presented is clear, concise and effective. KEEP THE TERMINOLOGY AND CONTENT UP TO DATE - all the irrelevant information or Confirm important information is aimed old terms need to be replaced and updated at catching the readers attention (e.g. (i.e., words like: “Guru, copyfund, OpenBook disclaimers). and high leverage) Bonuses are subject to Confirm information is in a format that changes. makes it easy for consumers to compare financial products and services. 3
Make it clear that past performance “Gain up to 85% return every 60 seconds” (results achieved) is not necessarily “Start your career as a trader right now” indicative of future results. Furthermore, “Suggestions are great – it is hard not to win” no representation is made that profits “95% return in a few minutes” will be achieved or losses avoided in the Our Pro signals have been tested to have over future. 65% daily success rates” Confirm that there is NO use of “non “What can you do in 60 seconds? Copy and actual” information e.g. “modelled results”, earn extra money.” “averages”, “simulated” etc. “Learn how to turn market opportunities into profit” Any comparisons used are current, “$10,000 – Get your bonus now..” complete and accurate i.e. compared with “Make/earn money” a benchmark or the average for a class of similar products or service. “Risk-free” “low risk” Confirm that the advertisement was “No 1” truthful and precise (i.e. the advertisement “Secure” can not be misleading and/or deceptive or “Safe” likely to mislead and/or deceive). Confirm that the advertisement is suitable Avoid Jargons in general for the full range of its audience i.e. apply the “lowest common denominator” test. Do not use the statements below: a. Become a successful trader! b. You will make profits! c. Make money with the best trader Examples of Misleading Statements d. With eToro, trading is easy e. Copy the best traders and you will make Do not use the statements below: profits “1 click 60 seconds 85% profit” “Trading has never been so easy” Do not make any false promises Please note that all content and marketing materials that include Copyfund or Bonuses offerings need to be immediately removed. 4
How to display risk warning? CFD: eToro AUS Capital Ltd ACN 612 791 803 AFSL 491139. OTC Derivatives are speculative and Whenever there is a Call to Action (‘CTA’) for leveraged. Not suitable for all investors. Capital CFDs,Real Stocks, Cryptos or any kind of at risk. See PDS instrument (i.e., Join now, Trade now, Invest now, Register, Real Crypto Assets: Open account, Verify etc), a RISK WARNING Cr ypto assets are unregulated & highly IS REQUIRED. speculative. No consumer protection. Capital at risk. The disclaimer should be under/next to View Website the button (CTA). It should always be Real + CFD Crypto or Ambiguous in the language of the website, visible and added to EVERY (CTA). eToro AUS Capital Ltd ACN 612 791 803 AFSL 491139. eToro offers both real crypto assets For the small CTA, the disclaimer should as well as crypto assets as OTC Derivatives. always be bold. Real crypto assets are unregulated & highly speculative. Being unregulated, there is no Real Stock: consumer protection. Your capital is at risk. Zero stock commission: Leveraged positions are OTC Derivatives, eToro Service ARSN 637 489 466 promoted which are regulated financial products. OTC by eToro AUS Capital Limited ACN 612 791 Derivatives are considered risky financial 803 AFSL 491139. Capital at risk. See PDS. products, speculative, and include leverage. Zero commission does not apply to short or Not suitable for all investors. Capital at risk. leveraged positions. Zero commission means See PDS that no broker fee has been charged when opening or closing the position. Limited stock exchanges only. 5
For the larger CTA, the disclaimer is: Shares are non transferable. Your capital is at risk. Refer to the Product Disclosure Statement (PDS) before transacting. For CFDs eToro AUS Capital Limited ACN 612 791 803 For Zero Commission AFSL 491139. OTC Derivatives are leveraged This content promotes stocks and is of financial products and considered speculative. a general nature only. Stocks are offered OTC Derivatives may not be suitable for all through eToro Service ARSN 637 489 466 investors. Trading OTC Derivatives does not operated by Gleneagle Asset Management result in ownership of the underlying assets. ACN 103 162 278 AFSL 226199 and promoted You risk losing all of your investment. This by eToro AUS Capital Limited ACN 612 791 information is general only and has been 803 AFSL 491139. Investing in shares via a prepared without taking your objectives, managed investment scheme does not result financial situation or needs into account. in direct ownership of the underlying assets. Consider our Product Disclosure Statement The shares are held on your behalf. Non- (PDS). transferable. Your capital is at risk. Other fees may apply. For additional information For Real Stocks regarding fees, click here. This content promotes stocks and is of a general nature only. Stocks are offered through Zero commission is only available on limited eToro Service ARSN 637 489 466 operated by stock exchanges. All other shares are offered Gleneagle Asset Management ACN 103 162 as OTC Derivatives, and include commission. 278 AFSL 226199 and promoted by eToro AUS This information is general only and has been Capital Limited ACN 612 791 803 AFSL 491139. prepared without taking your objectives, Investing in shares via a managed investment financial situation or needs into account. scheme does not result in direct ownership You should obtain independent advice and of the underlying assets. The scheme has consider our Product Disclosure Statement legal ownership, the investor has beneficial (PDS) before transacting. See full disclaimer. ownership i.e. the shares are held on your behalf. As the scheme has legal ownership, If a CTA is at the end of the review, website, you have no rights in the securities, including blog or article, ALWAYS use the long version voting rights. noted above. 6
If a CTA is at the end of the review, website, For Real Stocks blog or article, and the content mention “copy- Copy trading is offered by eToro AUS Capital trading” ALWAYS use the appropriate long Limited ACN 612 791 803 AFSL 491139. Social version: trading. eToro does not approve or endorse any of the trading accounts customers may For CFDs choose to copy. All instructions and actions Copytrading is offered by eToro AUS Capital related to copied trades will automatically be Limited ACN 612 791 803 AFSL 491139. Social replicated in your account. When you select trading. eToro does not approve or endorse to copy a particular trading account you will any of the trading accounts customers may copy all of their future trades, and you may choose to copy. All instructions and actions select also to follow their existing trades. related to copied trades will automatically be Past performance of an eToro Community replicated in your account. When you select Member is not a reliable indicator of their to copy a particular trading account you will future performance. copy all of their future trades, and you may select also to follow their existing trades. Stocks are offered through eToro Service Past performance of an eToro Community ARSN 637 489 466 operated by Gleneagle Member is not a reliable indicator of their Asset Management ACN 103 162 278 AFSL future performance. 226199 and promoted by eToro AUS Capital Limited ACN 612 791 803 AFSL 491139. OTC Derivatives are offered by eToro AUS Capital Investing in shares via a managed investment Limited ACN 612 791 803 AFSL 491139. OTC scheme does not result in direct ownership Derivatives are leveraged financial products of the underlying assets. The scheme has and considered speculative.OTC Derivatives legal ownership, the investor has beneficial may not be suitable for all investors. Trading ownership i.e. the shares are held on your OTC Derivatives does not result in ownership behalf. As the scheme has legal ownership, of the underlying assets. You risk losing all of you have no rights in the securities, including your investment. This information is general voting rights. Shares are non transferable. only and has been prepared without taking Your capital is at risk. Refer to the Product your objectives, financial situation or needs Disclosure Statement (PDS) before transacting. into account. Consider our Product Disclosure Statement (PDS). 7
For Zero Commission Zero commission is only available on limited Copy trading is offered by eToro AUS Capital stock exchanges. All other shares are offered Limited ACN 612 791 803 AFSL 491139. Social as OTC Derivatives, and include commission. trading. eToro does not approve or endorse This information is general only and has been any of the trading accounts customers may prepared without taking your objectives, choose to copy. All instructions and actions financial situation or needs into account. related to copied trades will automatically be You should obtain independent advice and replicated in your account. When you select consider our Product Disclosure Statement to copy a particular trading account you will (PDS) before transacting. copy all of their future trades, and you may select also to follow their existing trades. A few examples of CTA: Past performance of an eToro Community Member is not a reliable indicator of their • Trade now future performance. • Sign up • Join now Stocks are offered through eToro Service • Invest now ARSN 637 489 466 operated by Gleneagle • Buy and Sell Asset Management ACN 103 162 278 AFSL • Register Now 226199 and promoted by eToro AUS Capital • View Website Limited ACN 612 791 803 AFSL 491139. Investing in shares via a managed investment WARNING: it should be visible and in scheme does not result in direct ownership the language of the website. of the underlying assets. The scheme has legal ownership, the investor has beneficial ownership i.e. the shares are held on your behalf. As the scheme has legal ownership, NOTE: The disclaimers must appear at all you have no rights in the securities, including times separate from other risk warnings. voting rights. Shares are non transferable. Your capital is at risk. Refer to the Product Remember you can use the short version at Disclosure Statement (PDS) before transacting. the beginning of the article, reviews, blog, website, but you always need to use the long version at the end. 8
Remember that it is your obligations and Section 3.1.6. responsibilities to check and comply with The Affiliate’s fulfilment of its responsibilities our guidelines as well as our T&Cs. under this Agreement shall be in strict compliance with the terms and conditions We would like to draw your attention to the set forth herein; following chapter from our T&Cs, related to compliance. The entire T&Cs can be found Section 4.2 HERE The Affiliate shall not publish any material which refers to the Trading Platform, eToro Section 2.3 “The Affiliate acknowledges Brands or any other name or mark owned by and agrees that: eToro unless such publication is in compliance with eToro’s guidelines. Upon request by eToro, a. it will use the eToro Brands only as permitted Upon request by eToro, the Affiliate shall Hereunder; immediately remove any publication referring b. it will use the eToro Brands in a lawful to the Trading Platform, eToro Brands or any other name or mark owned by eToro. manner and in strict compliance with all format(s), guidelines, standards and other Section 4.3 requirements prescribed by eToro; The Affiliate shall not copy any content from c. the eToro Brands are and shall remain the eToro’s Websites and/or publications and shall sole property of eToro; not post in any website and/or elsewhere, any d. nothing in this Agreement shall confer in material published in eToro’s Websites and/or the Affiliate any right of ownership in the publications. The Affiliate shall not copy any eToro Brands and all use thereof by the content from any other Affiliate’s websites. Affiliate shall inure to the benefit of eToro; And e. the Affiliate shall not, now or in the future, attempt to register any eToro Brand and/or domain name and/or contest the validity of any eToro Brands or use any term or mark confusingly similar to any eToro Brands.” 9
ADDITIONAL RESTRICTIONS Please note that if an affiliate cannot amend any of the promotional content of its website in accordance with the above rule, the content shall be required to be removed. • Only target individuals over the age of 18 • Regulatory demands can change often and with no prior notice. When this occurs, all promotional material needs to be updated immediately. If you want to make any changes to eToro promotional materials on your site, you must let us know via the customer service portal by opening a ticket or contacting your affiliate account manager. Restricted Countries - please contact our Customer Service Note that this document may be amended from time to time to include/reflect new operational and/ or new/ amended regulatory requirements. Partner Up! In case you need further assistance, do not hesitate to contact your direct affiliate manager and we will be pleased to assist you. We would like to thank you for your collaboration and hope to deliver the best possible experience for all of our Partners! 10
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