ANLP Advertising & Marketing Compliance Policy (CAP Code)

The purpose of this Policy is to ensure that every advertising or marketing communication produced, commissioned or disseminated by ANLP International CIC (“ANLP”) complies...

1. Purpose

The purpose of this Policy is to ensure that every advertising or marketing communication produced, commissioned or disseminated by ANLP International CIC (“ANLP”) complies with:

  • The UK Code of Non‑broadcast Advertising, Sales Promotion and Direct Marketing (the “CAP Code”).
  • All relevant legislation, including the Digital Markets, Competition and Consumers Act 2024 (DMCCA), the Consumer Protection from Unfair Trading Regulations 2008 and the Business Protection from Misleading Marketing Regulations 2008.
  • All Advertising Standards Authority (ASA) rulings and formal guidance.

2. Scope

This Policy applies to:

  • All members, employees, officers, contractors and subsidiaries of ANLP.
  • All external agencies, consultants, distributors, affiliates and influencers engaged to create or publish marketing on ANLP’s behalf.
  • All marketing communications—including, but not limited to, paid‑for digital media, social posts, influencer content, promotional emails, print ads, out‑of‑home media, experiential activations and direct mail—aimed at, or accessible by, audiences in the United Kingdom.

3. Key Principles

  1. Legal, Decent, Honest and Truthful – All communications must observe the spirit and letter of the CAP Code.
  2. Total‑Price Transparency – Mandatory charges must be included in the headline price; optional fees must be clearly and prominently disclosed (CAP 3.20, as amended 6 April 2025).
  3. Prohibition on Fake Reviews – The creation, solicitation or publication of fake or non‑genuine reviews is forbidden.  Incentivised reviews must be clearly disclosed (CAP 3.44; DMCCA 2024).
  4. Recognition of Advertising – Paid, controlled or otherwise commercial content must be obviously identifiable as advertising.  Acceptable labels include “Ad”, “Advert”, “Advertising”, “Ad Feature” or “Advertisement Feature”, positioned at the beginning of the material.
  5. Substantiation – Objective claims must be supported by documented evidence that is held on file before publication.
  6. Harm & Offence – Marketing must not cause serious or widespread offence, condone discrimination or encourage unsafe behaviour.
  7. Children & Vulnerable Groups – Extra care must be taken when communications are directed at, or likely to be seen by, children or vulnerable consumers.
  8. Environmental & Sustainability Claims – “Green” claims must be specific, accurate and substantiated; exaggerated or absolute claims are prohibited.
  9. Restricted Product Categories – Marketing for age‑restricted or sensitive products (e.g., alcohol, gambling, HFSS foods) must follow the relevant CAP rules and statutory regimes.

4. Procedures

4.1 Pre‑Publication Review & Approval

  1. CAP Compliance Checklist – Every piece of marketing must pass the checklist in Appendix A.
  2. Approval Workflow – All materials are logged in the Marketing Approval System and must be approved by a Manager.  High‑risk items (environmental claims, competitor comparisons, promotions) require Legal and Compliance sign‑off.

4.2 Substantiation File

Evidence supporting all objective claims must be stored in the secure Claims Substantiation Repository for three (3) years from publication.

4.3 Training & Awareness

  • Induction Training: New joiners complete CAP Code training within 30 days.
  • Annual Refresher: All staff complete e‑learning by 31 March each year. Completion rates are tracked by COO.

4.4 Monitoring & Audit

  • The COO will sample 10 % of live campaigns each quarter.
  • Adverse ASA rulings will trigger a root‑cause analysis and action plan within 30 days.

4.5 Complaint Handling

  • All complaints received directly or via the ASA must be forwarded to COO within 24 hours.
  • COO will acknowledge the complaint, investigate and respond within five (5) business days.

6. Non‑Compliance

Breaches may result in:

  • Withdrawal or amendment of the communication at the offender’s cost.
  • Disciplinary action up to and including termination of membership, employment or contract.
  • Mandatory re‑training and enhanced monitoring.

7. Governance & Oversight

This Policy is overseen by the CEO.  

8. Review

This Policy will be reviewed annually or sooner if the CAP Code, ASA guidance or applicable law changes.