Financial Promotions Procedure
Swiss Vans Ltd – Financial Promotions & Advertising Policy
Last updated: October 2025
Applies to: All employees, agents, contractors, and marketing partners of Swiss Vans Ltd
Contact: [email protected]
1. Purpose
Swiss Vans Ltd (“we”, “our”, “us”) is committed to ensuring that all marketing, advertising, and financial promotions are clear, fair, and not misleading, in line with:
- Financial Conduct Authority (FCA) rules on consumer credit promotions,
- The BVRLA Financial Promotions Factsheet, and
- Relevant UK consumer protection legislation.
This policy sets out our internal procedures for creating, approving, and monitoring all promotional communications relating to vehicle sales, leasing, and finance products.
2. Scope
This policy applies to:
- All advertisements and marketing materials issued by or on behalf of Swiss Vans Ltd;
- All digital content (website, social media, email campaigns, online ads);
- All printed materials (brochures, posters, flyers, point-of-sale displays);
- Verbal, telephone, and in-person sales promotions that reference finance or lease offers;
- All third parties producing or publishing promotional content on our behalf.
It covers both regulated financial promotions (e.g. hire purchase, personal contract hire) and general marketing content relating to our vehicle leasing and sales services.
3. Policy Statement
All financial promotions issued by Swiss Vans Ltd must:
- Be clear, fair and not misleading;
- Contain accurate and balanced information;
- Include all mandatory disclosures and representative examples required by the FCA;
- Avoid omitting material facts or presenting information in a way likely to mislead a customer;
- Be approved before publication by an authorised member of staff (see section 8).
4. What Counts as a Financial Promotion
A “financial promotion” is any communication that invites or induces someone to enter into a finance or credit agreement.
This includes, but is not limited to:
- Vehicle leasing or finance offers displayed online or in print;
- Posts, adverts, or videos on social media promoting finance options;
- Email or SMS campaigns mentioning credit or finance terms;
- Verbal or in-person statements that include finance details or pricing.
5. Key Requirements for Compliance
A. Clear and Accurate Content
- Promotions must be easy to understand, using plain English.
- Financial terms (e.g. “zero deposit”, “low APR”) must be factual and not exaggerated.
- Any limitations, fees, or conditions must be displayed clearly and prominently.
B. Representative Examples
When promoting finance:
- Include a Representative Example with:
- Cash price
- Deposit (if any)
- Amount of credit
- Total amount payable
- Duration of agreement
- Representative APR
- Monthly payment amount
- The name of the lender (if not Swiss Vans Ltd)
- The Representative APR must reflect the typical rate available to at least 51 % of customers expected to respond.
C. Regulatory Disclosures
- Identify Swiss Vans Ltd as a credit broker (not a lender) when applicable.
- Include our FCA authorisation details (number and status).
- Include mandatory risk wording such as:
“Finance subject to status and credit approval. Terms and conditions apply.”
“Swiss Vans Ltd is a credit broker and not a lender.”
D. Digital and Social Media
- The same standards apply to posts, banners, and sponsored ads.
- Short-form platforms (e.g. X/Twitter, Instagram) must still include clear finance disclosures or link directly to full terms.
- Links must take users to a compliant landing page, not to generic marketing material.
E. Prohibited Content
Do not:
- Use misleading terms like “guaranteed finance” or “no credit checks”;
- Hide important costs or eligibility criteria;
- Compare products unfairly without substantiation;
- Use testimonials or influencer promotions without proper disclosure.
6. Approval & Sign-Off Process
- All marketing and financial promotions must be reviewed and approved before release.
- The Compliance Manager (or delegated Marketing Compliance Officer) ensures:
- Accuracy of all finance figures;
- Correct FCA disclosures;
- Inclusion of required representative example;
- Balanced presentation of benefits and risks.
- Approvals must be logged with date, version, and approver name.
- Unapproved promotions must not be issued under any circumstances.
7. Record Keeping
Swiss Vans Ltd maintains a Financial Promotions Register recording:
- Description and channel (e.g. web, print, social media);
- Approval date and name of approver;
- Version of creative asset (e.g. “Van Offer June 2025 v2”);
- Where and when the promotion ran;
- Supporting evidence (screenshots, PDFs, links).
Records are kept for at least six years for audit and regulatory purposes.
8. Monitoring & Oversight
- Random audits of live promotions are conducted quarterly.
- The Compliance Manager monitors FCA and BVRLA updates to ensure the policy stays current.
- Non-compliant materials are withdrawn immediately.
- Repeat or serious breaches trigger corrective training and, where required, senior management review.
9. Training & Awareness
All staff involved in marketing, sales, or communications receive annual training on:
- FCA rules on consumer credit promotions;
- BVRLA guidance;
- This internal Financial Promotions Policy.
New staff must complete this training before issuing or approving any promotional content.
10. Working With Third Parties
- Any agency, broker, or partner promoting Swiss Vans Ltd products must receive a copy of this policy and confirm compliance in writing.
- Swiss Vans Ltd remains legally responsible for ensuring third-party communications meet FCA standards.
- All third-party promotions must be pre-approved by our Compliance Manager.
11. Non-Compliance
Failure to follow this policy may result in:
- Withdrawal of promotions;
- Disciplinary action (for employees);
- Termination of contracts (for partners/agents);
- Reporting to relevant regulators if required.
12. Policy Review
This policy is reviewed annually or sooner if there are:
- FCA or BVRLA rule changes,
- Significant changes in our marketing approach,
- Internal audit findings requiring amendment.
The next scheduled review date: October 2026
Contact
Compliance Department
Swiss Vans Ltd
Bridgend, Wales CF31 3AP