The UK Financial Conduct Authority (“FCA”) and global regulators have specific requirements that relate to client communication with which CMC Markets staff are required to comply. CMC Markets is obliged to pay due regard to the information needs of its clients and communicate information to them in a way which is clear, fair and not misleading. This policy and approach is how we ensure Responsible Marketing in our business.
The Marketing Communications Policy sets out the standards that apply to the content used in in client communications and financial promotions, covering the nature of the content, prominence of certain information, presentation of data and whether it is necessary to add disclosures or risk warnings. Exactly which disclosures or warnings are necessary will depend on the content of the advertisement, what it is seeking to achieve and its target audience.
A financial promotion is defined as any communication constituting an invitation or inducement to engage in investment activity. This is a very broad definition and generally includes any content promoting CMC Markets and/or its products and services.
Financial promotions must give a balanced picture of, the nature of the investment being promoted, the commitment involved and the risks – CMC products are considered to be “complex” and high risk.
All marketing communications must be fair, clear and not misleading. The information is required to be up-to-date and relevant to the means of communication used. Information contained in a communication must be consistent with any information the firm provides to clients in the course of carrying on investment services.
The Marketing Department in each respective office is responsible for all financial promotions and client communications for their region, with the Marketing Department in London having overarching responsibility across the CMC Group. No communications or financial promotions can be published without the approval of relevant compliance functions.