Creator Advertising Compliance Policy

COLLABOR TECHNOLOGIES LTD (“Collabor”, “we”, “us” or “our”) is a company registered in England and Wales under company number 16888312. Our registered office is Egerton Mill, 25–27 Egerton Street, Chester, United Kingdom, CH1 3ND. Collabor connects brands and agencies with creators and provides tools for creator discovery, campaign management, messaging, uploads, contracting, payment protection and related support. Collabor is not the advertiser, creator, publisher or legal adviser for a campaign merely because the platform is used.

This policy applies to every Brand, Agency and Creator using Collabor and to all campaign content created, approved, delivered or published through a Collabor campaign. It covers posts, captions, photographs, Stories, Reels, Shorts, videos, livestreams, podcasts, audio, blogs, newsletters, reviews, testimonials, affiliate content, discount codes, competitions, comments, tags, links and materially similar formats. It applies to drafts and published content, on Collabor and on external platforms. It forms part of the rules accepted under the Brand Platform Agreement and Creator Platform Agreement and should be read with the Platform Terms, Standard Campaign Contract, Acceptable Use and Content Standards, Payments and Payout Protection Policy and any campaign brief. If a campaign brief, Brand instruction or external platform rule is less protective than this policy or applicable law, the stricter lawful requirement applies. No agreement may require a Creator to hide a commercial relationship or publish a misleading claim.

For UK-facing advertising, users must comply with the CAP Code, including its rules on recognition of marketing communications and misleading advertising, relevant ASA influencer advertising guidance, and applicable consumer-protection law, including the unfair-commercial-practices provisions of the Digital Markets, Competition and Consumers Act 2024. The CMA’s guidance for content creators, guidance for brands and compliance principles for social media platforms explain the responsibilities of creators, businesses and platforms in preventing hidden advertising and concealed incentivised endorsements. For advertising affecting consumers in other countries, local laws and regulator rules may impose additional or different requirements. Relevant United States campaigns should also consider the FTC’s endorsement and disclosure guidance. This policy sets a platform-wide minimum. It does not replace legal advice, regulator guidance, sector-specific codes, licensing conditions or the advertising rules of the service on which content is published.

Every piece of content produced or published as part of a Collabor campaign must be treated as advertising and disclosed accordingly. This applies whether the consideration is money, a milestone payment, commission, an affiliate benefit, a free or discounted product or service, a loan, travel, accommodation, event access, shares, equity, preferential terms, another benefit or a promise of future work. Disclosure is also required where the Creator:

• has an employment, ownership, family, personal, ambassador or other material connection with

the Brand;

• promotes the Creator’s own brand, product or business through personal or editorial-looking

content;

• uses an affiliate link, personalised code or other mechanism that may generate commission or

another benefit;

• posts about a gift, sample, loan, trip, event or experience supplied by or on behalf of the Brand; or
• reposts, republishes, edits, clips or otherwise reuses campaign content in a new placement or

format. A disclosure is required even if the Creator was not told what to say, gives an honest opinion, was not asked to post, received the benefit through an Agency or intermediary, or believes the audience already knows about the relationship.

The disclosure must use “Ad” or “\#Ad”. “Advert” or “Advertisement” may also be used where equally clear. The disclosure must identify the content as advertising without requiring the audience to interpret surrounding circumstances. The following are not acceptable on their own: “Sponsored”, “Gifted”, “Affiliate”, “Aff”, “Spon”, “PR”, “Collab”, “Partner”, “Ambassador”, “In association with”, “Thanks to”, a brand tag, a discount code, a link, a previous disclosure or a statement in the Creator’s profile or biography.

The disclosure must be visible or audible before, or at the moment, the audience first engages with the advertising. It must not appear only after “more”, below a fold, at the end of a caption, among numerous hashtags, in comments, at the end of a video, on a separate page or behind a link. A visual label must be sufficiently large, legible and high-contrast, remain visible long enough to be read, and not be obscured by interface controls, captions, stickers, subtitles or other content. The disclosure must be in the same language as the principal advertising message and understandable to the intended audience.

• Text posts and captions: place “Ad” or “\#Ad” at the beginning of the first visible line.
• Images and static posts: place an upfront disclosure in the first visible caption line and, where the

image itself communicates the endorsement without the caption, superimpose a clear disclosure on the image.

• Stories and multi-frame sequences: place a clear disclosure on every frame containing

advertising. A label on one frame does not cover later frames.

• Short-form and long-form video: show a clear on-screen disclosure at the start, before the

endorsement or product claim, and include it in the visible caption. Where the promotion is spoken, use both a spoken and on-screen disclosure.

• Audio and podcasts: state clearly at the start of the advertising segment that it is an

advertisement. A description-page disclosure alone is insufficient.

• Livestreams: disclose before or as the promotion begins, repeat the disclosure periodically

because viewers may join later, and use a continuous visible label where the format permits.

• Affiliate links and codes: use an upfront “Ad” or “\#Ad” disclosure. The existence of a code,

affiliate label or link does not itself disclose the commercial relationship.

• Reposts, clips and cross-platform versions: each standalone item must contain its own compliant

disclosure. Content directed at, or likely to be seen by, children may require enhanced, prominent and interruptive disclosure in language children can understand. A basic “Ad” label may not be sufficient in highly immersive or integrated content aimed at younger children.

Creators must use the relevant social platform’s paid-partnership, branded-content or equivalent disclosure tool wherever it is available and applicable. They must also include the standalone “Ad” or “\#Ad” disclosure required by section 5 unless Collabor gives a written exception based on current law and regulator guidance. A platform tool does not transfer responsibility to the platform and may be too small, delayed, hidden, inconsistently displayed or unclear about which Brand is involved. Creators must preview the published content on the devices and formats reasonably used by the audience and correct any disclosure that is not immediately clear. Brands and Agencies must provide any permissions or account linking needed for the Creator to activate platform disclosure tools. A technical failure does not authorise publication without a clear alternative disclosure.

A Creator must give an honest opinion and must not say or imply that they have used, tested, purchased, experienced or achieved results from a product or service when that is untrue. A script, talking point or Brand approval does not excuse a false personal statement. Creators must disclose material limitations affecting an endorsement, including where a result was achieved under unusual conditions or where an item shown differs materially from the item consumers will receive. Testimonials and reviews must be genuine, used with permission and must not be edited or presented in a way that changes their meaning. Incentivised reviews must be clearly identified as incentivised. Users must not create, commission, buy, sell, submit, suppress or manipulate fake reviews, fake engagement or misleading review information.

Before an objective claim is submitted for approval or published, the Brand or Agency must hold adequate documentary evidence supporting the claim. The evidence must relate to the actual product, formulation, service, audience, conditions, territory and time period represented in the content. Objective claims include measurable or verifiable statements about performance, ingredients, results, price, savings, availability, popularity, rankings, comparisons, environmental impact, health, safety, income, financial returns, customer outcomes or scientific testing. The ASA may treat a claim as misleading if adequate substantiation is not held before publication. The Brand or Agency must supply the approved claim wording, material qualifications and supporting evidence to the Creator and, where requested, to Collabor. A Creator must not invent, strengthen, generalise or remove qualifications from an approved claim.

Important conditions, limitations, eligibility rules, commitments, expiry dates, availability, risks, fees and typical-result information must be presented clearly and prominently. A qualification may clarify a claim but must not contradict the overall impression created by words, visuals, audio, editing or context. Prices, discounts, “free” claims, recommended retail prices, savings, comparisons, competitions and promotional claims must be accurate and include the material terms consumers need to make an informed decision.

Filters, retouching, lighting, camera techniques, editing, artificial intelligence, synthetic media, demonstrations and before-and-after imagery must not materially misrepresent a product, result or experience. Where alteration or simulation is material to the audience’s understanding, it must be disclosed clearly. A demonstration must be conducted under fair and representative conditions. Before-and-after comparisons must use genuine, comparable images and must not imply typical or guaranteed results without adequate evidence.

Campaign content must not:

• contain a hidden, late, ambiguous, obscured or misleading advertising disclosure;
• make a false, misleading, exaggerated, unsubstantiated or unverifiable objective claim;
• omit material information or use small print or qualifications to contradict the main message;
• present an opinion as an established fact or imply universal scientific agreement where material

disagreement exists;

• use fake testimonials, fake reviews, fake metrics, purchased engagement or fabricated personal

experience;

• claim or imply regulator, medical, scientific, professional, government or other approval that has

not been granted;

• make a medicinal, disease-treatment, prevention or diagnosis claim for a product that is not

legally authorised for that claim;

• promise guaranteed income, investment returns, winnings, weight loss, health outcomes or other

results where the promise is unlawful, misleading or unsupported;

• use an environmental claim such as “green”, “sustainable”, “carbon neutral”, “eco-friendly” or

“zero impact” without clear scope, lifecycle context and adequate evidence;

• exploit fear, credulity, inexperience, vulnerability or body-image insecurity, or encourage unsafe or

unlawful conduct;

• target a product at an audience to whom it may not lawfully be advertised; or
• promote weapons, adult content, political campaigns or any other category prohibited by Collabor.

Advertising for alcohol, gambling, financial products, investments, cryptocurrency, credit, medicines, medical devices, health and beauty treatments, supplements, weight-control products, tobacco, nicotine, vaping, age-restricted goods, food high in fat, salt or sugar, competitions and products aimed at children may be subject to additional laws, licences, warnings, targeting limits and media restrictions. A Brand or Agency must identify a regulated or higher-risk campaign at the start, provide the applicable legal and regulatory requirements, and obtain any required approval before activating a Creator. Collabor may require enhanced review, supporting evidence, age or location controls, specialist advice or additional contractual terms, or may decline the campaign. Collabor’s decision to allow a campaign onto the platform is not confirmation that the product, claims, targeting or content are lawful.

The Brand or Agency is responsible for:

• ensuring the product, campaign, offer, targeting, required disclosure and supplied materials

comply with applicable law and advertising rules;

• holding adequate evidence for every objective claim before it is communicated to the Creator;
• providing complete, accurate and unambiguous briefs, mandatory wording, qualifications,

warnings and restrictions;

• ensuring an Agency has authority from the Brand and understands the applicable obligations;
• reviewing draft and published content promptly and requiring correction of non-compliance;
• keeping approval, evidence and monitoring records; and
• not instructing or pressuring a Creator to conceal advertising, mislead consumers or make

unsupported claims. An Agency remains responsible under the Brand Platform Agreement when it registers, creates or manages a campaign for a client.

The Creator is responsible for:

• understanding and following this policy, the brief, the campaign contract, applicable advertising

law and the publishing platform’s rules;

• using the mandatory upfront disclosure and applicable platform tool in every relevant placement;
• making only honest statements based on genuine experience and using only approved,

substantiated claims;

• checking the final caption, image, audio, edit, link, tag, targeting and disclosure before publication;
• obtaining approval where the campaign requires it and not making unapproved material changes

after approval;

• correcting, removing or replacing non-compliant content promptly when instructed lawfully; and
• preserving relevant drafts, approvals and publication evidence.

Collabor provides platform rules, campaign tools, reporting routes and proportionate enforcement. Collabor may review content or supporting evidence but does not undertake to pre-approve every campaign, monitor every external publication or provide legal clearance. Any Collabor review is limited to the purpose stated and does not transfer responsibility from the Brand, Agency or Creator.

Where the brief or contract requires pre-publication approval, the Creator must submit the complete proposed content, including caption, disclosure, visuals, audio, claims, links, tags, codes and intended placement. The Brand or Agency must review the overall impression as well as individual words. Approval applies only to the version, placement, audience and timing reviewed. A material change to a claim, edit, product, price, disclosure, caption, soundtrack, visual, link, target audience or publishing context requires renewed approval. Approval by one party does not waive another party’s legal responsibility. Collabor approval, campaign activation or payment release must not be described as regulatory or legal approval.

Brands and Agencies must take reasonable steps to check that commissioned content is published as approved and remains compliant. Creators must monitor content within their control and notify the Brand or Agency promptly if a disclosure disappears, a platform changes presentation, a claim becomes inaccurate, an offer expires or another compliance issue arises. Where content is non-compliant, the responsible parties must act promptly to add or correct the disclosure, amend the claim, stop promotion, remove or replace the content, or take any other step reasonably required. Editing a post is not sufficient if the earlier version continues to circulate elsewhere. Collabor may request evidence of correction or removal and may preserve relevant records.

Brands, Agencies and Creators must retain records reasonably necessary to demonstrate compliance, including briefs, contracts, scripts, claim substantiation, licences, approvals, final files, screenshots or recordings of the live publication, disclosure-tool settings, correction requests and correspondence. Records must be accurate and supplied to Collabor, a regulator or competent authority where required by law or reasonably requested under the platform agreements. Personal data will be handled in accordance with Collabor’s Privacy Notice.

If Collabor reasonably believes this policy has been breached, we may:

• require correction, replacement, prominent clarification or removal of content;
• pause or restrict a campaign, deliverable, publication or account feature;
• reject content from platform publication or prevent further campaign activations;
• issue a warning, require compliance training or impose enhanced review;
• suspend or terminate an account for serious, deliberate or repeated breaches;
• preserve evidence and cooperate with the ASA, CMA, another regulator, a court or law

enforcement where appropriate; and

• take any other lawful and proportionate action available under our agreements and policies.

Commercial and payment consequences will be determined under the campaign contract, Brand Platform Agreement, Creator Platform Agreement and Payments and Payout Protection Policy. A breach does not automatically entitle any party to retain money or avoid accrued obligations unless the applicable contract or law provides that result. Collabor will consider severity, reach, consumer harm, intent, recurrence, cooperation, prior history and whether the content was corrected promptly. A single serious breach may justify immediate suspension or termination.

Suspected hidden advertising, misleading claims, fake reviews or other breaches may be reported through Collabor’s Help Centre. A report should identify the account, campaign and content; provide the relevant URL or file; explain the concern; and include any lawful supporting screenshot or evidence. Collabor may notify the affected user and allow a response unless doing so would be unlawful, unsafe or prejudicial. A user may appeal an enforcement decision through the route stated in the notice. Collabor may uphold, vary or reverse its decision after reviewing the available information. Users may also complain directly to the ASA, CMA, the relevant publishing platform or another competent regulator. Collabor’s internal process does not restrict statutory rights or external complaint routes.

Campaign content must comply with the law and advertising rules of every territory it targets or is reasonably intended to reach. A disclosure should use the language or languages of the endorsement and any locally required wording. If local law is stricter than this policy, local law applies; if it is less strict, this policy remains the minimum standard for use of Collabor. Brands and Agencies are responsible for identifying target territories and supplying territory-specific requirements. Creators must not use location settings, alternative accounts, reposting or other techniques to avoid a disclosure, targeting rule or restriction.

We may amend this policy to reflect legal, regulatory, operational or product changes. The current revision date appears at the top of this policy. Material changes will be communicated where required.

Advertising compliance reports and appeals: use the relevant reporting or support route in Collabor’s Help Centre. Postal address: COLLABOR TECHNOLOGIES LTD, Egerton Mill, 25–27 Egerton Street, Chester, United Kingdom, CH1 3ND.