ZYC-FINPROM-001 Financial Promotions Approval & Withdrawal Policy
(Applies to all Zeyro staff, directors, contractors, and consultants — Updated October 2025)
Background
Zeyro Ltd is authorised by the FCA to approve financial promotions under s.21 FSMA 2000. Our approvals relate to:
Cryptoasset financial promotions under PS23/6 (COBS 4.12A, GEN, PRIN 7); and
Overseas Fund Regime (OFR) financial promotions for authorised investment funds.
When approving promotions, Zeyro acts as a quasi-regulator, ensuring that communications are clear, fair, and not misleading. Our obligations extend beyond approval to ongoing monitoring for the lifetime of each promotion.
This policy aligns with the Consumer Duty Principle (PRIN 12), the Treating Customers Fairly outcomes, and the FCA’s guidance in FG23/3 (Cryptoassets) and FG24/1 (Social Media Promotions).
Purpose
To ensure Zeyro:
Approves promotions only when we have competence and understanding of the product.
Continues to monitor approved promotions for compliance throughout their lifecycle.
Withdraws approvals promptly when promotions cease to meet FCA standards.
Scope
Applies to all promotions approved by Zeyro, including:
Cryptoasset promotions by unregulated firms (e.g., exchanges, token issuers).
OFR fund promotions by EU-authorised managers.
Any related materials forming part of the same customer journey.
Key Principles
1. Regulatory Framework
We comply with COBS 4.10 and related Handbook provisions:
COBS 4.10.2R(1) – approve only if promotion complies with the financial promotion rules.
COBS 4.10.2R(1A) – monitor continuing compliance.
COBS 4.10.2R(1B) – obtain quarterly attestations from clients.
COBS 4.10.2R(2) – withdraw approval if no longer compliant.
How this controls our risks: Demonstrates full lifecycle control from approval to withdrawal.
2. Approval Process
All promotions are reviewed via Jira Service Management, ensuring auditable review, versioning, and client correspondence.
Two-stage review: initial reviewer + final approval by senior manager (MLRO/Board).
Reviewers assess promotions using the Fair, Clear and Not Misleading checklist and the relevant review procedures for:
Cryptoassets (ZYC-FINPROM-PROC-CRY)
Overseas Funds (ZYC-FINPROM-PROC-OFR)
Reviewers must confirm that:
Claims are substantiated.
Risk disclosures are prominent and accurate.
Target audience and categorisation are appropriate.
No banned incentives are present.
How this controls our risks: Ensures all approvals are based on demonstrable competence and documented review.
3. Consumer Duty and Vulnerable Customers
All reviews must consider:
The end-retail investor’s understanding of the promotion.
Whether communications might disadvantage vulnerable customers.
The broader customer journey (entry points, decision points, friction points).
Language complexity: we aim for Flesch-Kincaid readability testing, aiming for grade ≤8.
How this controls our risks: Integrates Consumer Duty principles into every approval, preventing foreseeable harm.
4. Ongoing Monitoring
Zeyro’s ongoing monitoring framework ensures all approved promotions remain compliant for as long as they are live. Monitoring activity includes four core components:
Weekly Social Media Monitoring
Compliance reviews all client social media platforms weekly to identify unapproved or altered promotions.
Non-compliant posts are flagged and logged in Jira for escalation to the MLRO.
Scheduled Reviews Based on Risk
Each approved promotion is subject to periodic review according to its composite risk score (client + product + promotion).
Typical frequencies:
Low risk: every 6 months
Medium: every 4 months
High / Very High: every 2 months
Reviews reassess content accuracy, risk disclosures, and any material change in product or regulatory environment.
Ad-Hoc Whole-Client Reviews (Trigger-Based)
Full audits of a client’s entire promotional base occur when triggers are detected, such as:
Publication of a non-compliant or misleading promotion;
Repeated borderline compliance issues;
Behaviour suggesting disregard for the letter or spirit of FCA rules.
These reviews include all live promotions, websites, and associated media.
Website-Change Monitoring (MirrorWeb)
Client websites are continuously monitored using MirrorWeb, which captures and archives all site changes.
Alerts are reviewed by Compliance to detect new, modified, or withdrawn content that could affect an approved promotion.
How this controls our risks: Combines proactive, risk-weighted and automated surveillance to maintain compliance throughout the life of each promotion, ensuring that emerging issues are identified and addressed promptly.
5. Withdrawal of Approval
If a promotion no longer meets requirements or client remediation fails, approval is withdrawn:
Client notified formally via Jira within 48 hours.
Withdrawal recorded in Jira and reported to the FCA Connect portal.
Follow-up checks confirm the promotion’s removal within 48 hours of withdrawal.
All communications and remediation steps are logged for audit.
How this controls our risks: Ensures regulatory compliance, consumer protection, and evidential integrity.
6. Record-Keeping
All promotions, review notes, Loom recordings, and attestations are stored in Jira and Confluence for five years.
The Promotions Register includes:
Client and promotion identifiers.
Reviewer names and approval date.
Ongoing monitoring records and withdrawal history.
How this controls our risks: Creates an unbroken chain of accountability from submission to withdrawal.
7. Training and Awareness
All reviewers complete annual training covering:
FCA financial promotion rules (COBS 4, GEN, PRIN 12).
Cryptoasset-specific and OFR-specific considerations.
Treatment of vulnerable customers and Consumer Duty outcomes.
How this controls our risks: Ensures competence and consistent interpretation of FCA expectations.
8. Reporting to the FCA
All approvals are reported via FCA Connect within 7 days.
Zeyro submits bi-annual promotion reports and maintains metrics on complaints, amendments, and withdrawals.
How this controls our risks: Demonstrates transparency and compliance with PS23/6 reporting obligations.
9. Conflicts of Interest
As our clients appoint and pay us, but we hold regulatory responsibility, potential conflicts are inherent. We manage these by:
Adhering to risk appetite and clear independence in decision-making.
Escalating commercial pressure concerns to the MLRO or Board.
Recording all potential conflicts in the Conflicts Register.
How this controls our risks: Preserves independence and regulatory objectivity in the approvals process.
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