Financial Promotions Policy for Cryptoassets

**1. Policy Objective**
This policy aims to ensure all financial promotions related to cryptoassets by H&W Investments Limited comply with the latest regulatory requirements, ensuring that all communications are fair, clear, and not misleading.

**2. Scope**
This policy covers all forms of communication by H&W Investments Limited intended to promote cryptoasset products and services, including digital and social media, print, and in-person communications.

**3. Definitions**
– **Qualifying Cryptoassets:** As per government guidelines, any cryptographically secured digital representation of value or contractual rights which is fungible and transferable, excluding those that are solely transferable to one or more vendors in payment for goods or services.

**4. Compliance with Financial Promotion Order**
– All promotional materials for cryptoassets must be approved by an FCA authorized firm or an internally authorized individual within H&W Investments Limited before release.
– Financial promotions must not mislead or deceive investors about the benefits or risks associated with the cryptoasset.
– Promotions must prominently disclose risks, including the potential for loss of capital and price volatility.

**5. Marketing and Advertising**
– Ensure that all marketing materials regarding cryptoassets are clear, fair, and provide a balanced view of returns and risks.
– Prohibited from using terms like “guaranteed profit” or “risk-free investment.”

**6. Social Media and Online Marketing**
– Monitor and approve all cryptoasset promotions on social media and online platforms to ensure they comply with regulatory requirements.
– Train staff responsible for online marketing on the complexities of cryptoasset promotions and the legal implications of non-compliance.

**7. Training and Awareness**
– Regular training sessions for marketing and sales teams on the regulatory changes and their impact on financial promotions.
– Updating training materials to include the latest regulatory developments and case studies on compliant and non-compliant promotions.

**8. Monitoring and Enforcement**
– Continuously monitor the effectiveness of the financial promotions controls.
– Periodic reviews and audits of promotional materials to ensure ongoing compliance.
– Establish procedures for immediate withdrawal of any non-compliant promotions and corrective measures.

**9. Reporting and Record Keeping**
– Maintain comprehensive records of all financial promotions for a minimum of five years.
– Establish a reporting mechanism for potential breaches of this policy.

**10. Review and Update**
– Review this policy annually or upon significant changes to regulations or business practices.
– Adjust the policy to reflect changes in legislation and best practice standards.

This policy is formally reviewed and approved by the board of H&W Investments Limited and communicated across the organization. It’s essential to integrate regular updates from regulatory bodies and incorporate feedback from compliance audits to ensure the policy remains effective and relevant.