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πŸ“‹ INTERNAL POLICY β€” PM-CAP-001

Compliance Advertising Policy

Version: 1.0 (DRAFT) Date: 14 March 2026 Owner: Compliance Team FCA FRN: 681423

Promise Money β€” Compliance Advertising Policy

Document Reference: PM-CAP-001 Version: 1.1 (DRAFT) Date: 17 March 2026 Owner: Compliance Team β€” Promise Money Authorised By: [Name / Title] Next Review Date: [Date β€” recommend 6-monthly]


1. Purpose

This policy sets out the mandatory rules and standards that govern all advertising and promotional content produced by Promise Money, whether created through:

  • The Content Dashboard (promoney.promisemoney.co.uk/contentdashboard) β€” AI-generated articles, guides, and FAQ content for the website.
  • The Social Media Agent β€” AI-generated posts for Facebook, Instagram, LinkedIn, TikTok, and YouTube.
  • Any manual or third-party content published under the Promise Money brand.

Promise Money is authorised and regulated by the Financial Conduct Authority (FCA FRN 681423). All advertising content must comply with the FCA Handbook, in particular:

Regulation Scope
MCOB 3A Financial promotions for mortgage products
COBS 4 Communicating with clients, including financial promotions
CONC 3 Financial promotions for consumer credit
Consumer Duty (FCA PS22/9) Delivering good outcomes for retail customers
FG24/1 Financial promotions on social media (replaced FG15/4, March 2024)
s.21 FSMA 2000 Restriction on financial promotion β€” criminal offence for unauthorised promotion

2. Scope

This policy applies to all content that could constitute a financial promotion, including but not limited to:

  • Website articles and blog posts (all products listed in the Content Dashboard)
  • Social media posts across all platforms (Facebook, Instagram, LinkedIn, TikTok, YouTube)
  • AI-generated images and graphics accompanying social posts (Imagen 4)
  • Email marketing and newsletters
  • Paid advertising (PPC, sponsored posts, display ads)
  • YouTube video scripts, descriptions, and thumbnails
  • Any content visible to the public that references Promise Money products or services

2.1 Product Categories Covered

All content relating to the following products falls within scope:

Product FCA Regime
Mortgages MCOB
Remortgages MCOB
Secured Loans / Second Charge MCOB / CONC
Bridging Finance MCOB
Equity Release MCOB
Retirement Interest Only MCOB
Buy to Let MCOB
Right to Buy MCOB
Commercial Finance COBS
Development Finance COBS
Asset Finance COBS / CONC
Invoice Finance COBS
Contractor Mortgages MCOB
Grants (Energy/Warm Homes) Information only β€” see Β§6.5
Business Finance COBS
First Time Buyer MCOB

3. Key Principles

All advertising content produced by Promise Money must be:

3.1 Clear, Fair, and Not Misleading (COBS 4.2)

  • Content must be accurate and not omit material information.
  • Benefits must not be emphasised without equally prominent risk warnings.
  • Content must be understandable by the target audience without specialist knowledge.

3.2 Balanced

  • Every piece of content that highlights a benefit must also disclose relevant risks, limitations, and eligibility criteria.
  • Comparisons with competitors must be factual, verifiable, and not misleading.

3.3 Identifiable as a Financial Promotion

  • Content must make it clear that Promise Money is a broker, not a lender.
  • The firm's FCA authorisation must be stated (FCA FRN 681423).

3.4 Treating Customers Fairly (TCF)

  • Content must support the six TCF outcomes and the Consumer Duty principle of delivering good outcomes.
  • Marketing strategies must align with the Consumer Duty, ensuring they lead to good outcomes for retail customers and support informed decision-making.

3.5 Financial Promotions on Social Media (FCA FG24/1)

The FCA's finalised guidance FG24/1 (March 2024) sets out specific expectations for financial promotions on social media. The following principles apply to all Promise Money social media content:

  • Medium-agnostic rules β€” FCA financial promotion rules are technology-neutral and apply to social media identically to print, TV, or web advertising.
  • Standalone compliance β€” Each individual social media post must comply with FCA rules on its own. A post cannot rely on other posts in a series to provide required information (e.g., risk warnings cannot be placed in a separate "follow-up" post).
  • Character limits are not an excuse β€” Where platform character limits make it impossible to include required disclosures, the platform may not be appropriate for that promotion. The shortened risk warning (Β§4.2) is the approved minimum for short-form platforms.
  • Affiliate and influencer responsibility β€” If Promise Money engages any third party, affiliate, or influencer to promote its products, Promise Money remains fully responsible for the compliance of those promotions. Robust systems and controls must be in place to monitor and manage affiliate content.
  • Criminal offence risk β€” Under s.21 FSMA 2000, unauthorised persons who communicate financial promotions without FCA-authorised approval risk criminal prosecution (imprisonment or unlimited fine). All Promise Money promotions must be approved by an authorised person.
  • Suitability for complex products β€” Social media may not always be appropriate for promoting complex financial products. Consider whether the format allows adequate explanation of risks, features, and eligibility criteria.
  • Content must not create unrealistic expectations about product availability or approval.

4. Mandatory Risk Warning

4.1 Full Risk Warning (Long-Form Content)

The following risk warning must appear at the end of every published article, blog post, and long-form social media post. This text must not be modified, abbreviated, or paraphrased.

⚠️ Important Information:

Subject to Status β€” Your property may be repossessed if you do not keep up repayments on your mortgage or any other debt secured on it.

Promise Money is a broker not a lender. Therefore we offer lenders representing the whole of market for mortgages, secured loans, bridging finance, commercial mortgages and development finance. These loans are secured on property and subject to the borrower's status. More than 50% of borrowers receive offers better than our representative examples. The %APR rate you will be offered is dependent on your personal circumstances.

Representative Examples (correct at time of publication):

Mortgages and Remortgages: Borrow Β£270,000 over 300 months at 7.1% APRC representative at a fixed rate of 4.79% for 60 months at Β£1,539.39 per month and thereafter 240 instalments of Β£2,050.55 at 8.49% or the lender's current variable rate at the time. The total charge for credit is Β£317,807.66 which includes Β£2,500 advice/processing fees and Β£125 application fee. Total repayable Β£587,807.66.

Secured / Second Charge Loans: Borrow Β£62,000 over 180 months at 9.9% APRC representative at a fixed rate of 7.85% for 60 months at Β£622.09 per month and thereafter 120 instalments of Β£667.54 at 9.49% or the lender's current variable rate at the time. The total charge for credit is Β£55,730.20 which includes Β£2,660 advice/processing fees and Β£125 application fee. Total repayable Β£117,730.20.

Promise Money is a trading name of Promise Solutions Ltd. Promise Solutions Ltd is authorised and regulated by the Financial Conduct Authority (FCA FRN 681423).

4.2 Short-Form Risk Warning (Social Media)

For platforms with character limits (TikTok, Instagram Stories/Reels), the following approved shortened version must be used:

⚠️ Subject to Status β€” Your property may be repossessed if you do not keep up repayments on your mortgage or any other debt secured on it. Promise Money is a broker not a lender. Representative examples and full details at promisemoney.co.uk. FCA FRN 681423.

4.3 Representative Example Rules

  • Include the Mortgage representative example when the post relates to mortgages, remortgages, buy-to-let, bridging, or equity release.
  • Include the Secured Loan representative example when the post relates to secured loans or second charge products.
  • Include both when the post covers general finance or multiple product types.
  • Representative examples must be reviewed quarterly (or whenever rates change) to ensure they remain accurate. The updated figures must be reflected in both the Social Media Agent prompt and Content Dashboard templates.

5. Content Dashboard β€” Specific Rules

5.1 Content Generation Pipeline

All content generated via the Content Dashboard follows this lifecycle:

β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”   β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”   β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”   β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”   β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”
β”‚ Question │──▢│    AI      │──▢│   Authorised   │──▢│  Export to    │──▢│ Published β”‚
β”‚ Ingested β”‚   β”‚ Generated  β”‚   β”‚   Reviewer     β”‚   β”‚  Sheets/WP   β”‚   β”‚  (Live)   β”‚
β”‚ (pending)β”‚   β”‚(generated) β”‚   β”‚   Review       β”‚   β”‚ (completed)  β”‚   β”‚           β”‚
β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜   β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜   β””β”€β”€β”€β”¬β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜   β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜   β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜
                                   β”‚
                          β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”Όβ”€β”€β”€β”€β”€β”€β”€β”€β”
                          β–Ό        β–Ό        β–Ό
                    β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β” β”Œβ”€β”€β”€β”€β”€β”€β” β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”
                    β”‚ Sign-Offβ”‚ β”‚Refineβ”‚ β”‚Decline β”‚
                    β”‚   βœ…    β”‚ β”‚  ✏️  β”‚ β”‚  ❌    β”‚
                    β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜ β””β”€β”€β”€β”€β”€β”€β”˜ β””β”€β”€β”€β”¬β”€β”€β”€β”€β”˜
                                             β”‚
                                    β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”΄β”€β”€β”€β”€β”€β”€β”€β”€β”
                                    β–Ό                 β–Ό
                             β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”    β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”
                             β”‚ Keep as    β”‚    β”‚  Rerun     β”‚
                             β”‚ Declined   β”‚    β”‚(regenerate)β”‚
                             β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜    β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜

5.2 Rate Disclaimer Rule

All content mentioning interest rates must include the following disclaimer inline:

"rates start from X% per month correct at the time of publishing"

  • The disclaimer must appear within the same paragraph as the rate reference.
  • Applies to all mortgage, loan, and credit products without exception.

5.3 Language Guidelines

Rule Detail
Prohibited words "guaranteed", "risk-free", "always", "never", "100%", "no risk"
Required qualifiers "may", "could", "typically", "generally", "often", "subject to status"
Tone Professional, approachable, authoritative β€” never high-pressure
Plain English Target Flesch Reading Ease score β‰₯ 70 (accessible to general public)
Sentence length Keep sentences concise; max 3–4 sentences per paragraph

5.4 Prohibited Content

The following must never appear in any published content:

  • Unsubstantiated claims about approval rates or success rates
  • Promises of specific outcomes (e.g., "you will be approved")
  • Misleading comparisons with named competitors
  • Time-pressure tactics without genuine, verifiable deadlines
  • Hidden fees or unclear pricing structures
  • Claims that could constitute personal financial advice

5.5 Content Balance (TCF Compliance)

  • Every article discussing product benefits must also present risks and limitations.
  • Eligibility criteria must be mentioned where applicable.
  • The FCA's Treating Customers Fairly principles must be maintained throughout.

5.6 SEO & Metadata

  • Meta descriptions must be 150–160 characters and accurately represent the content.
  • Title tags must not be misleading or exaggerated.
  • Keyword stuffing is prohibited.

6. Social Media Agent β€” Specific Rules

6.1 Platform-Specific Requirements

Platform Risk Warning Max Length Notes
Facebook Full version No hard limit Include link to promisemoney.co.uk
LinkedIn Full version 3,000 chars Professional tone; bullet points preferred
YouTube Full version Description field Include in video description; verbal mention in video
Instagram Short version in caption; full in bio link 2,200 chars Visual-first; compliance in caption text
TikTok Short version 2,200 chars Hook-Value-CTA structure; compliance in caption

6.2 AI-Generated Content Review

All social media content generated by the Social Media Agent must be:

  1. Reviewed before posting β€” AI-generated drafts are posted as scheduled drafts (24h in future) to Facebook Business Suite, not published immediately.
  2. Checked for compliance β€” The Authorised Reviewer must verify the risk warning is present and the content meets all rules in this policy before allowing the scheduled post to go live.
  3. Archived β€” A Google Calendar event is created for each draft post, providing an audit trail.

6.3 Image Generation Standards

AI-generated images (via Imagen 4) accompanying social media posts must:

  • Not contain misleading visual representations (e.g., unrealistic property images).
  • Not include text that contradicts the compliance disclaimer.
  • Not depict specific financial figures, rates, or percentages within the image itself.
  • Comply with platform-specific advertising standards (Meta, LinkedIn, TikTok).

6.4 WordPress-Derived Social Content

When the Social Media Agent generates posts from a WordPress article:

  • The key message must be extracted β€” not just summarised.
  • Tone and format must be adapted for the target platform.
  • A link to the production URL (promisemoney.co.uk) must be included β€” never the staging URL.
  • Financial claims must carry the appropriate disclaimer even if the source article already includes one.

6.5 Grants Content (Energy/Warm Homes)

Content relating to energy grants, warm homes schemes, and insulation grants:

  • Must not imply Promise Money provides grant funding directly.
  • Must clarify Promise Money's role as an information provider or broker.
  • Must link to official government or scheme resources where applicable.
  • The property repossession warning is not required for grant-only content that does not reference secured lending products, but if the content mentions any secured product alongside grants, the full warning applies.

7. Human-in-the-Loop (HITL) Controls & Sign-Off Process

All AI-generated content must pass through mandatory human review gates before publication. The system enforces these controls programmatically β€” they cannot be bypassed.

7.1 Authorised Reviewer Sign-Off

All content must be reviewed and signed off by an Authorised Reviewer before publication. The Authorised Reviewer is responsible for assessing content against both quality standards and regulatory requirements.

Who can perform this action: Users designated as an Authorised Reviewer by the firm. The Authorised Reviewer must have sufficient knowledge of FCA financial promotion rules to assess content compliance.

The Authorised Reviewer checks:

Category Checks
Quality Accuracy, clarity, tone, readability, SEO, completeness
Compliance Risk warning, representative examples, prohibited/qualifying language, content balance, no financial advice, rate disclaimers, FCA FRN reference, broker-not-lender statement

Actions available:

Action When to use What happens
βœ… Sign-Off Content meets all quality and regulatory standards Sign-off recorded (reviewer identity + timestamp). Content is cleared for publication.
✏️ Refine Content needs minor corrections Opens Refine modal. Reviewer edits and documents changes (see §7.7).
❌ Decline Content is fundamentally inadequate Decline with option to regenerate or archive (see §7.8).

7.2 Approval Modes

The system supports two approval modes. The appropriate mode depends on the volume and production method of the content.

Individual Review (Default)

Each piece of content is reviewed and signed off individually by the Authorised Reviewer. This is the default mode for ad-hoc content creation.

Batch Approval (Bulk Campaigns)

For bulk content campaigns producing 10 or more items (e.g., a product-specific campaign with multiple articles or social media posts across several topics), the Authorised Reviewer may approve the campaign as a batch, subject to the following controls:

  1. Automated compliance checks are applied to 100% of items during content generation. These programmatic checks include: - Prohibited language detection - Risk warning presence and format verification - Representative example inclusion (matched to product type) - Rate disclaimer presence (where rates are referenced) - Readability scoring (Flesch Reading Ease) - Qualifying language detection - FCA FRN and broker-not-lender statement verification

  2. All items must pass automated checks. Any item that fails an automated check is excluded from the batch and requires Individual Review.

  3. The Authorised Reviewer approves the batch based on confidence in the automated compliance pipeline and familiarity with the campaign brief.

  4. A mandatory random spot check is triggered (see Β§7.3) β€” the system automatically selects a sample of items for full manual review.

  5. Publication is conditional on the spot check results meeting the acceptance thresholds defined in Β§7.3.

Batch Approval is not available for: - Content that has been individually flagged by the automated checks as having compliance failures - Content types that the Authorised Reviewer determines require individual attention (e.g., new product categories, content produced during or immediately after regulatory changes)

7.3 Random Spot Check Process

When Batch Approval (Β§7.2) is used, the system automatically triggers a random spot check to verify the quality and compliance of the batch.

Selection Method

  • Sample rate: 20% of items in the batch (minimum 5 items, maximum 50)
  • Selection method: Stratified random sampling β€” items are selected proportionally across content categories (e.g., product pillars for website content, or platforms for social media posts) to ensure representative coverage
  • Reproducibility: The random selection seed is recorded for audit purposes

Review Process

Each selected item is presented to the Authorised Reviewer as an individual review task. The reviewer assesses the item against the full compliance checklist (Appendix B) as if it were an Individual Review.

For each item, the reviewer records: - Pass β€” content meets all standards - Fail β€” with documented reason and policy section reference

Escalation Thresholds

Spot Check Result Action
All items pass Batch confirmed. All items in the campaign are cleared for publication.
1–2 items fail Failed items corrected. An additional 20% sample is selected from the remaining (un-checked) items for further review.
3+ items fail Batch Approval is revoked. All items in the campaign require Individual Review before publication.

Audit Trail

The following is recorded for each spot check:

  • Spot check reference and campaign reference
  • Total items in batch and sample size
  • Items selected for review
  • Per-item pass/fail result with reviewer identity and timestamp
  • Escalation actions taken (if any)
  • Final batch disposition (confirmed / escalated / revoked)

7.4 Accept & Publish β€” Final Gate

The system verifies that sign-off has been recorded before allowing the accept action:

  • For Individual Review content: the Authorised Reviewer's sign-off must be on record.
  • For Batch Approved content: the batch approval and spot check results must be on record, with the spot check meeting the acceptance thresholds in Β§7.3.

If sign-off is not recorded, the system returns an awaiting_signoff response. Content cannot reach publication without sign-off on record.

When accepting: - If a refined amendment exists for the content, the refined version (not the original AI output) is used for publication. - The amendment notes are preserved in the record for audit purposes.

7.5 Social Media Workflow β€” HITL Controls

Social media content generated by the Social Media Agent follows the same approval framework as website content.

Individual Posts

Single posts are reviewed individually by the Authorised Reviewer before the scheduled publish time.

Batch Social Campaigns

When the Social Media Agent generates a coordinated campaign across multiple platforms (e.g., a product campaign spanning Facebook, LinkedIn, Instagram, TikTok, and YouTube), Batch Approval (Β§7.2) may be used, subject to:

  • Automated compliance checks on all generated posts (risk warning, prohibited language, link verification)
  • Random spot check (Β§7.3) with stratification by platform β€” ensuring posts are sampled proportionally across each social media platform
  • Platform-specific requirements (Β§6.1) are verified during both automated checks and manual spot checks

The 24-hour scheduling buffer is maintained for all social media content regardless of approval mode, providing a window for review before publication.

Social Media Workflow

β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”   β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”   β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”   β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”
β”‚  AI Generates │──▢│ Scheduled Draft   │──▢│  Authorised   │──▢│  Goes Live   β”‚
β”‚  Post         β”‚   β”‚ (24h delay)       β”‚   β”‚  Reviewer     β”‚   β”‚  (Platform)  β”‚
β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜   β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜   β””β”€β”€β”€β”¬β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜   β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜
                                               β”‚
                                    β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”΄β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”
                                    β–Ό                     β–Ό
                             β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”       β”Œβ”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”
                             β”‚  Approve   β”‚       β”‚  Delete /  β”‚
                             β”‚  (publish) β”‚       β”‚  Amend     β”‚
                             β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜       β””β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”€β”˜

Steps:

  1. Social Media Agent generates the post β€” including platform-appropriate content, hashtags, and an AI-generated graphic (Imagen 4).
  2. Post is scheduled as a draft β€” On Facebook, the post is created with scheduled_publish_time set 24 hours in the future. It appears in Facebook Business Suite's Scheduled tab.
  3. Google Calendar event created β€” A calendar event is created for the scheduled time, with the post content and platform details, providing an audit trail.
  4. Authorised Reviewer checks the draft within the 24-hour window: - Verify risk warning is present and correct (full or short version per platform rules β€” Β§6.1). - Verify representative example is appropriate for the product type. - Check for prohibited language. - Verify link points to promisemoney.co.uk (not staging). - Review the AI-generated image for compliance (Β§6.3).
  5. Reviewer takes action: - Approve β€” No action needed; the scheduled post will go live automatically at the scheduled time. - Amend β€” Edit the scheduled draft directly in Facebook Business Suite / platform tools before the scheduled time. - Delete β€” Cancel the scheduled post if it cannot be brought into compliance.

7.6 Continuous Improvement

Human corrections made during the review process (via Refine actions) are retained and used to improve future AI content generation. When a reviewer corrects content and the corrected version is subsequently approved, the correction is recorded and may inform the AI's approach to similar content in the future.

The details of these corrections, including the reviewer's notes explaining the change, are available to reviewers when assessing content in the same product category, supporting consistency and reducing repeat issues over time.

7.7 Refine Action β€” Human Amendment Workflow

The Refine action allows the Authorised Reviewer to manually edit AI-generated content before sign-off. This is the primary mechanism for human correction of AI output.

How it works:

  1. Reviewer clicks "Refine" on the question detail page.
  2. Refine modal opens pre-populated with the current content: - Title β€” The article title (editable) - HTML Content β€” The full article body (editable) - Meta Description β€” The SEO meta description (editable) - Notes β€” Free-text field for the reviewer to document what was changed and why
  3. If a previous amendment exists for this content, the modal loads the most recent refined version (not the original AI output), so edits are cumulative.
  4. Reviewer makes corrections β€” e.g., fixing a factual error, adding a missing disclaimer, adjusting tone, correcting a rate figure.
  5. Reviewer submits the amendment β€” the refined content is saved and the reviewer can proceed to sign off the content.

Important: The notes field is not optional for compliance corrections. Reviewers must document the reason for any compliance-related edit (e.g., "Added missing secured loan representative example", "Removed 'guaranteed' from paragraph 3").

7.8 Decline Action β€” Rejection Workflow

The Decline action rejects content that is fundamentally inadequate or seriously non-compliant.

How it works:

  1. Reviewer clicks "Decline" on the question detail page.
  2. Decline modal appears with two options:
Option What happens
Keep Declined Content is archived. It remains visible for audit purposes but is excluded from active queues.
Rerun The content is sent back for regeneration. The AI generates new content from scratch for the same question. The regenerated content enters the review pipeline from the beginning.
  1. The decline action, the reviewer's identity, and the timestamp are recorded in the audit trail.

When to use Decline vs Refine:

  • Refine if the content is salvageable β€” e.g., a missing disclaimer, a tone issue, a factual correction.
  • Decline if the content is fundamentally flawed β€” e.g., completely off-topic, contains fabricated regulatory references, or is so poorly structured that editing would be more effort than regeneration.

7.9 Emergency Takedown

If published content is found to breach this policy:

  1. Immediate removal β€” take down the content from all platforms as soon as practicable after identification.
  2. Root cause analysis β€” determine whether the breach was in the AI generation, the review process, or both.
  3. Incident log β€” record the breach in the compliance incident register including: date, content reference, nature of breach, corrective action, and reviewer responsible.
  4. Notification β€” if the breach is material, consider whether FCA notification is required.

8. Record Keeping & Audit Trail

8.1 Retention Requirements

Record Retention Period
Published content (all channels) 5 years from publication
Sign-off and review records 5 years
Spot check records and results 5 years
Representative example history 5 years
Policy versions Indefinite

8.2 Audit Trail

The system maintains a record of:

  • Who generated the content (system/user)
  • Who performed sign-off (reviewer identity + timestamp)
  • Approval mode used (Individual Review or Batch Approval)
  • Spot check results (for Batch Approved content)
  • Workflow status history
  • Any amendments requested and the refined content versions

9. AI-Specific Considerations

9.1 AI Content Disclosure

  • Promise Money uses AI (Google Gemini) to assist in content creation.
  • All AI-generated content is subject to the same compliance standards as human-written content.
  • The use of AI does not reduce the firm's regulatory responsibility β€” the FCA holds the regulated firm accountable regardless of how content is produced.

9.2 Hallucination Risk

AI models may generate content that is factually incorrect ("hallucination"). Reviewers must:

  • Verify all factual claims β€” especially interest rates, product features, eligibility criteria, and legal statements.
  • Cross-check representative examples against current approved figures.
  • Flag and correct any content where the AI has invented statistics, case studies, or regulatory references.

9.3 Prompt Engineering & Guardrails

  • The Social Media Agent's system prompt includes embedded compliance rules and mandatory risk warnings.
  • Any changes to the agent's prompt must be reviewed and approved by the Authorised Reviewer before deployment.
  • The Content Dashboard's generation pipeline applies compliance rules programmatically β€” these rules must not be bypassed.

10. Roles & Responsibilities

Role Responsibilities
Authorised Reviewer Reviews content for accuracy, readability, SEO, brand voice, FCA adherence, risk warnings, balance, and prohibited language. Performs sign-off (Individual or Batch). Maintains this policy.
Social Media Manager Reviews AI-generated social drafts within the 24h scheduling window. Ensures platform-specific rules are met. May be designated as an Authorised Reviewer.
Development Team Maintains the Content Dashboard, Social Media Agent, and WordPress integration. Implements technical guardrails including the automated compliance checks used in Batch Approval. Ensures prompt and template changes go through Authorised Reviewer approval.
Senior Management Accountable for overall compliance. Approves policy changes. Ensures adequate resources for the review process.

11. Breaches & Escalation

Severity Description Action
Minor Typo in risk warning, formatting issue Correct as soon as practicable; log internally
Moderate Missing risk warning, prohibited language used Immediate takedown; correct and re-publish; incident report
Serious Misleading financial claim, missing rep example, advice given Immediate takedown; root cause analysis; senior management notification; consider FCA reporting
Critical Systematic failure (e.g., AI generating non-compliant content at scale, or Batch Approval spot check revealing widespread failures) Halt all AI content generation; full review; FCA notification if required

12. Policy Review

  • This policy must be reviewed every 6 months or immediately following:
  • A regulatory change affecting financial promotions.
  • A compliance breach.
  • A significant change to the Content Dashboard or Social Media Agent.
  • An update to the representative examples.
  • A material change to the Batch Approval or spot check process.

Appendix A β€” Approved Representative Examples

These figures must be updated quarterly or when rates change. Updates require Authorised Reviewer sign-off and must be reflected in: 1. This policy document 2. The Social Media Agent prompt 3. The Compliance Center page 4. Any email templates or ad copy

Current Approved Figures (as at March 2026):

  • Mortgages: 7.1% APRC, 4.79% fixed for 60 months, Β£270,000 over 300 months
  • Secured Loans: 9.9% APRC, 7.85% fixed for 60 months, Β£62,000 over 180 months

Appendix B β€” Quick Compliance Checklist

Use this checklist before approving any content (Individual Review or Spot Check):

  • [ ] Risk warning present (full or short version as appropriate)?
  • [ ] Representative example included (correct product type)?
  • [ ] "Broker not a lender" statement included?
  • [ ] FCA FRN 681423 referenced?
  • [ ] No prohibited language ("guaranteed", "risk-free", "always", "never")?
  • [ ] Qualifying language used ("may", "could", "subject to status")?
  • [ ] Benefits balanced with risks/limitations?
  • [ ] No unsubstantiated claims?
  • [ ] Rate disclaimer present if rates are mentioned?
  • [ ] Plain English β€” readable by general public?
  • [ ] Link to promisemoney.co.uk (not staging)?
  • [ ] No personal financial advice given?

End of Document

Promise Money is a trading name of Promise Solutions Ltd. Promise Solutions Ltd is authorised and regulated by the Financial Conduct Authority (FCA FRN 681423).