CODE & GROWTH LTD

ADVERTISING & TRAFFIC COMPLIANCE POLICY

This Policy applies to all Clients engaging Code & Growth Ltd for advertising,
media buying, AI campaign automation, or affiliate marketing services.
Acceptance of our Terms & Conditions constitutes acceptance of this Policy in full.

1.  Purpose and Scope
Code & Growth Ltd ('Company', 'we', 'us') provides software development, AI integration, digital marketing, and paid media services to a diverse client base including arbitrage teams, affiliate marketing programmes, e-commerce businesses, media buying agencies, and SaaS companies.
This Advertising & Traffic Compliance Policy ('Policy') establishes the rules governing all advertising creatives, landing pages, traffic sources, affiliate funnels, and promotional content that the Company creates, manages, or optimises on behalf of Clients, or that Clients supply to the Company for use in campaigns.
The purpose of this Policy is to:

• Protect Clients and the Company from legal liability, platform bans, and regulatory enforcement
• Ensure compliance with UK and EU advertising law, platform policies, and industry codes
• Prevent reputational harm arising from misleading, deceptive, or harmful advertising
• Establish clear pre-approval requirements for high-risk verticals

This Policy is incorporated by reference into the Company's Terms & Conditions and forms part of the binding agreement between the Company and each Client.

2.  Applicable Laws and Regulatory Standards
All advertising and traffic activities managed by or on behalf of the Company must comply with the following, as applicable:


The above list is non-exhaustive. Clients are responsible for ensuring their campaigns comply with all laws applicable in their target jurisdictions.


3.  Absolute Prohibitions
The following practices are strictly prohibited in all circumstances, without exception. The Company will not create, implement, or continue managing any campaign or funnel that involves any of the prohibited practices listed below. Violation will result in immediate termination of services under clause 12 of the Terms & Conditions.


3.1  Misleading and Deceptive Advertising
PROHIBITED — Zero tolerance. Immediate termination of services.


The following forms of misleading or deceptive advertising are absolutely prohibited:

• Making false or unsubstantiated claims about a product or service, including exaggerated performance claims not supported by evidence
• Omitting material information that would affect a consumer's decision to purchase, such as hidden costs, subscription terms, or cancellation restrictions
• Creating a false impression of urgency or scarcity ('Only 3 left!', countdown timers that reset) where no genuine urgency or scarcity exists
• Fake 'sold out' or 'limited stock' notices used purely as a conversion tactic
• Misleading price comparisons, including artificially inflated 'was' prices
• False claims of awards, certifications, endorsements, or regulatory approvals
• Bait-and-switch advertising: advertising one product or price but delivering another
• Disguising advertising as editorial content, news articles, or independent reviews without clear disclosure

3.2  Cloaking and Traffic Manipulation
PROHIBITED — Constitutes fraud against ad platforms and regulators.

Cloaking involves showing different content or URLs to ad platform review systems than to actual users. All of the following are prohibited:

• Serving different landing page content to ad platform bots/crawlers than to real users
• Using redirect chains or JavaScript manipulation to obscure the true destination URL from platform review
• Deploying device, IP, or user-agent detection to serve compliant content to reviewers and non-compliant content to users
• Using tracking parameters or redirect scripts to bypass platform policies
• Misrepresenting the domain or business entity behind an advertisement
• Using cloaking tools, services, or scripts of any kind

3.3  Fake Testimonials, Reviews, and Social Proof

PROHIBITED — Violates ASA CAP Code, CPRs 2008, and FTC Guides.

• Fabricating or commissioning fake customer testimonials, reviews, or success stories
• Using stock photography and presenting stock models as real customers or results
• Misrepresenting the origin, authenticity, or representativeness of testimonials
• Using testimonials that were given in exchange for compensation without clear disclosure
• Creating or purchasing fake social media engagement (followers, likes, comments, reviews)
• Misrepresenting user-generated content as independent reviews

3.4  Unauthorised Use of Celebrities, Public Figures, and Fake Experts

PROHIBITED — Constitutes defamation, passing off, and breach of personality rights.

• Using the name, likeness, image, voice, or endorsement of any celebrity, public figure, politician, or member of the Royal Family without documented, written authorisation from that individual or their authorised representative
• Creating deepfake or AI-generated images or audio of real people to simulate endorsements
• Fabricating expert endorsements: presenting individuals as doctors, scientists, financial advisers, or other professionals when they are not qualified, or when no such endorsement was given
• Using 'As Seen On' logos, media outlet names, or broadcaster trademarks without verified, written permission
• Referencing real news publications or TV programmes in a way that implies editorial coverage or endorsement

3.5  Prohibited Health and Medical Claims

PROHIBITED — Regulated by MHRA, ASA CAP Code, and EU Regulation 1924/2006.

• Making medicinal claims for products that are not licensed medicines (i.e., claiming a product can treat, cure, prevent, or diagnose a disease or medical condition)
• Using before-and-after imagery that creates unrealistic expectations about health or weight-loss outcomes
• Claiming clinical or scientific proof for health outcomes without substantiating evidence that meets the applicable regulatory standard
• Advertising prescription-only medicines (POMs) to consumers
• Using health claims for food supplements that are not on the EU/UK approved health claims register
• Referencing or implying medical professional endorsement without documented evidence

3.6  Prohibited and Misleading Financial Claims

PROHIBITED — Regulated by FCA, FPO 2005, and ASA CAP Code Section 14.

• Advertising any financial product or investment as having guaranteed returns, zero risk, or risk-free outcomes
• Omitting legally required risk warnings in financial promotions (e.g., 'Capital at risk', 'Past performance is not indicative of future results')
• Publishing financial promotions for FCA-regulated products (investments, loans, insurance, crypto-assets if regulated) without approval from an FCA-authorised person
• Making income claims (e.g., 'Earn £5,000 per month') for business opportunity or MLM schemes without substantiation and appropriate caveats
• Promoting get-rich-quick schemes or suggesting that significant returns require minimal effort
• Using testimonials showing exceptional financial results without prominent disclaimers that results are not typical

3.7  Spam, Unsolicited Communications, and Malicious Traffic

PROHIBITED — Violates UK PECR, GDPR, CAN-SPAM, and criminal law.

• Sending unsolicited commercial emails, SMS, or push notifications to recipients who have not given valid prior consent under UK PECR or the applicable law of the target jurisdiction
• Purchasing, renting, or using third-party contact lists without verifying that recipients have given valid consent for marketing communications from the Client's specific category
• Deploying bots, click farms, or automated scripts to generate artificial traffic, clicks, impressions, or conversions
• Distributing malware, spyware, adware, or any malicious code through advertising creatives, pop-ups, push notifications, or redirect scripts
• Operating phishing pages: pages designed to fraudulently collect personal or financial data by impersonating legitimate businesses or services
• Using aggressive or deceptive push notification subscription prompts that obscure the opt-in action

3.8  Trademark and Brand Infringement

PROHIBITED — Constitutes trade mark infringement and passing off under UK law.

• Bidding on competitor brand keywords in a way that constitutes trade mark infringement or creates consumer confusion as to the source of the advertised goods or services
• Using competitor brand names, logos, or slogans in ad copy or creative without authorisation
• Registering or using domain names that incorporate third-party trade marks ('typosquatting' or 'cybersquatting')
• Reproducing or modifying a third party's copyrighted creative assets (images, videos, copy) without a valid licence
• Creating advertising that is likely to be confused with a competitor's campaign or brand identity
• Using meta tags, hidden text, or URL strings containing third-party trade marks to manipulate search results

3.9  Non-Compliant Affiliate and Funnel Practices

PROHIBITED — Violates platform policies, ASA rules, and consumer protection law.

• Operating affiliate funnels that use prohibited tactics from any section of this Policy, including fake news articles, fake celebrity endorsements, or misleading before-and-after content
• Publishing advertorials that are not clearly and prominently labelled as 'Advertisement', 'Sponsored', or 'Paid promotion' in accordance with ASA CAP guidance on labelling
• Using pre-sale pages ('bridge pages') that make claims the final offer or product cannot substantiate
• Deploying forced continuity billing: enrolling consumers in recurring subscription payments without their clear and explicit consent to the subscription terms
• Operating negative option marketing without clear disclosure of the terms (e.g., free trial with auto-renewal)
• Using exit-intent overlays or dark patterns that make it materially difficult for consumers to leave a page or cancel a purchase
• Concealing the identity of the advertiser or the commercial nature of the funnel

4.  Restricted Verticals Requiring Pre-Approval

The following verticals are classified as high-risk due to heightened regulatory requirements, elevated risk of platform policy violations, and potential for consumer harm. The Company will not commence or continue services in these verticals without prior written pre-approval from the Company's compliance team, confirmation of the Client's eligibility, and receipt of all required documentation.

Pre-approval requests must be submitted to info@codegrowth.uk before any campaign planning begins.



Pre-approval does not guarantee that the Company will accept the engagement.
The Company reserves the right to decline any high-risk vertical engagement at its sole discretion,
including after pre-approval, if new information arises during campaign development.



5.  Ad Platform Policy Compliance

All campaigns must comply with the current policies of the relevant ad platform(s). Platform policies are updated frequently and take precedence over any prior approval or practice. The Client is responsible for monitoring platform policy changes affecting their vertical.



Where a campaign is disapproved or an ad account is suspended due to a Client's content or funnel violating platform policies, the Company is not liable for lost ad spend, campaign downtime, or revenue impact. The Client bears sole responsibility for ensuring their offer, landing pages, and traffic sources comply with platform policies.


6.  Affiliate and Partner Network Compliance

Where the Company manages or supports affiliate marketing programmes or works with Client-supplied affiliate traffic, the following rules apply.


6.1  Client Obligations for Affiliate Programmes

• Clients must provide the Company with their current affiliate programme terms and conditions, including any permitted and prohibited traffic sources, before the Company can manage or optimise traffic on their behalf
• Clients are responsible for ensuring their affiliate networks and individual affiliates comply with this Policy and applicable law
• The Company will not manage traffic from affiliate networks known to tolerate prohibited practices (cloaking, fake news, malware) without prior written approval and a credible remediation plan

6.2  Funnel and Pre-Lander Standards

• All pre-landers (bridge pages) used in affiliate funnels must accurately represent the offer on the destination page
• Pre-landers must not make claims that cannot be substantiated and that will not be upheld on the destination landing page
• Fake news-style pre-landers, fake social media post formats, and fake video player thumbnails designed to simulate news coverage are prohibited under clause 3.1
• All advertorials must include a prominent, clearly visible 'Advertisement' label in the header of the page

6.3  Sub-Affiliate and Traffic Source Disclosure

• Clients using programmatic or sub-affiliate traffic must be able to disclose traffic sources upon request by the Company or any relevant regulator
• Clients must not knowingly purchase traffic from sources that use prohibited tactics, including bot traffic, click farms, or malware-based ad injection

7.  Advertising Content Standards

7.1  Mandatory Disclosures
The following disclosures are required in all applicable advertising materials:

• 'Advertisement', 'Sponsored', or 'Ad' label: clearly and prominently displayed on all paid promotions, advertorials, and influencer content
• Affiliate income disclosure: where content is produced in exchange for commission or other compensation, this must be disclosed
• Testimonial atypicality: where testimonials or case studies show exceptional results, a disclosure such as 'Results are not typical. Individual results may vary.' must appear prominently
• Financial risk warnings: mandatory for all financial promotions as required by FCA rules and the FPO 2005
• Gambling safer gambling messages: mandatory on all gambling advertisements in the UK

7.2  Creative Standards

• Advertising imagery must not be digitally altered in a way that creates unrealistic expectations about a product's effects, particularly for beauty, health, or weight-loss products
• Before-and-after imagery must be genuine, consented, and representative; the time period and conditions must be disclosed
• Advertising must not target vulnerable consumers, including by exploiting financial distress, health anxieties, or addiction tendencies
• Content must not be designed to distress, alarm, or offend without justification, particularly on sensitive topics including health, death, or personal relationships
• Children must not be featured in advertising for adult products, and advertising for products unsuitable for children must be appropriately targeted

7.3  Landing Page Standards

• Landing pages must accurately reflect the content and claims in the advertisement that drove the click
• All material terms of an offer (price, recurring fees, cancellation terms) must be clearly disclosed before the consumer completes a purchase
• Contact information and the identity of the selling entity must be clearly stated
• Countdown timers and urgency messaging must only be used where genuine urgency or scarcity exists
• Cookie consent must be obtained in compliance with PECR before non-essential tracking cookies are set on landing pages

8.  Client Warranties and Representations

By engaging the Company and instructing it to create or manage advertising campaigns, the Client warrants and represents to the Company on a continuing basis that:

1. All advertising materials, landing pages, offers, and funnels provided to or requested from the Company comply with this Policy, applicable law, and the policies of the relevant ad platforms.
2. The Client holds all necessary licences, regulatory approvals, and intellectual property rights required to operate its business and to advertise its products or services in the target jurisdictions.
3. Any testimonials, case studies, or endorsements provided by the Client are genuine, consented to by the relevant individuals, and accurately represented.
4. All health, financial, performance, or other material claims to be used in advertising are substantiated by credible, documented evidence that the Client will provide to the Company upon request.
5. The Client will promptly notify the Company of any regulatory investigation, platform ban, or legal claim arising in connection with its advertising activities.
6. The Client accepts that breach of any warranty in this clause gives the Company the right to suspend or terminate services immediately in accordance with clause 12 of the Terms & Conditions.

9.  Company's Right to Refuse, Suspend, or Terminate

The Company reserves the right, at its sole discretion and without liability to the Client, to:

• Decline to create, launch, or continue managing any campaign, creative, or funnel that the Company believes, in good faith, may violate this Policy, applicable law, or platform policies
• Pause live campaigns immediately if a compliance concern is identified, without prior notice, where continued operation creates a risk of platform suspension, regulatory enforcement, or legal liability
• Request evidence of regulatory approvals, claim substantiation, or intellectual property rights before proceeding with any campaign element
• Terminate the engagement immediately where the Client has breached this Policy, including where the Company was unaware of the breach at the time of accepting the engagement

Where the Company suspends or terminates services for compliance reasons, fees paid in respect of work completed up to the point of suspension are non-refundable. The Company's liability to the Client in such circumstances is limited as set out in clause 14 of the Terms & Conditions.

10.  Client Indemnity

The Client agrees to indemnify, defend, and hold harmless Code & Growth Ltd, its directors, employees, contractors, and agents from and against all losses, claims, damages, fines, penalties, costs, and expenses (including reasonable legal fees) arising from or in connection with:

• Any breach by the Client of this Policy, the Terms & Conditions, or applicable law
• Any third-party intellectual property infringement caused by materials, assets, or instructions provided by the Client
• Any regulatory investigation, enforcement action, or civil claim arising from the Client's advertising or marketing activities
• Any claim by a consumer arising from misleading, deceptive, or harmful advertising content supplied or approved by the Client
• The Client's use of prohibited or restricted practices, including cloaking, fake testimonials, or unlicensed financial promotions

This indemnity survives termination of the engagement. The Company will notify the Client promptly of any third-party claim covered by this indemnity and will cooperate reasonably with the Client's defence, at the Client's expense.

11.  Reporting and Escalation

Employees, contractors, and Clients who become aware of an actual or suspected violation of this Policy are encouraged to report it promptly:

Compliance Contact:  info@codegrowth.uk
Subject line:  'Compliance Concern — [brief description]'
Response time:  We will acknowledge reports within 2 business days and respond substantively within 10 business days.


Reports can be made anonymously where the reporter does not wish to be identified. The Company does not tolerate retaliation against individuals who raise compliance concerns in good faith.


12.  Policy Updates and Version Control
This Policy will be reviewed at least annually and updated to reflect changes in applicable law, ad platform policies, and industry standards. The Company may also update this Policy at any time in response to regulatory developments or new risk assessments.
Material changes will be notified to active Clients by email to the address held on file at least fourteen (14) days before the change takes effect. Continued engagement with the Company after the effective date of a change constitutes acceptance of the updated Policy.
The current version of this Policy is always available at codegrowth.uk and upon request from info@codegrowth.uk.


13.  Governing Law
This Policy is governed by and construed in accordance with the law of England and Wales. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts of England and Wales, in accordance with clause 19 of the Terms & Conditions.

Quick Reference: Prohibited vs. Permitted




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