EToro AUS Capital Ltd. & Gleneagle Asset Management Ltd. Guideline

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eToro AUS Capital Ltd. & Gleneagle
  Asset Management Ltd. Guideline
  PARTNER COMPLIANCE GUIDELINES for eToro AUS Capital Ltd – AFSL 491139 and eToro Service
  ARSN 637 489 466 offered by Gleneagle Asset Management Limited Ltd AFSL 226199.

  All you need to know in one place

August 2021
Marketing Affiliate Rules

Below is a checklist of the main rules that should be followed when
promoting eToro AUS on your affiliate marketing channel:

    Always add the Risk Warning:
                                                      2   Remember that CFD assets are offered
                                                          through eToro AUS .
1   - eToro AUS Capital Ltd ACN 612 791 803 AFSL           - Real Stocks are offered through eToro
    491139. OTC Derivatives are speculative and            Service ARSN 637 489 466 operated by
    leveraged. Capital is at risk. See PDS under           Gleneagle Asset Management ACN 103 162
    every CTA (Call to Action) when promoting              278 AFSL 226199 and promoted by eToro AUS
    CFDs.                                                  Capital Limited ACN 612 791 803 AFSL 491139.
    - eToro Service ARSN 637 489 466 promoted
    by eToro AUS Capital Limited ACN 612 791 803          Always be fair, clear and avoid misleading
    AFSL 491139. Capital at risk. Other fees apply.
                                                      3   statements.
    See PDSunder every CTA (Call to Action) when
    promoting real stocks
                                                          Always mention in your affiliate marketing
    - eToro Ser vice AR SN 637 4 89 4 66              4   channel which eToro entity you are promoting:
    promoted by eToro AUS Capital Limited                 eToro AUS Capital Limited ACN 612 791 803
    ACN 612 791 803 AFSL 491139. Capital at               AFSL 491139
    risk. See PDS. Zero commission does not               OR
    apply to short or leveraged positions.                eToro Service ARSN 637 489 466 promoted
    Zero commission means that no broker                  by eToro AUS Capital Limited ACN 612 791
    fee has been charged when opening                     803 AFSL 491139. Capital at risk. Other fees
    or closing the position. Limited stock                apply. See PDS
    exchanges only. under every CTA (Call to
    Action) when promoting Zero Commission

                                                                                                          1
Use only correct information in your reviews/                  Any new communication channels and any
5   articles and always keep them updated as                  8    relevant requests should be immediately
    per the list below (not exhaustive) - more                     communicated to the Af f iliate Account
    information can be found at www.etoro.com                      Manager and should be pre-approved by the
    a. Current CFD leverage limits                                 Compliance Function/Department of eToro.
    b. Popular Investors
    c. Our Story (history of eToro)                                Affiliates are not allowed to promote eToro
    d. Team and Investors
                                                              9    via sources other than the ones disclosed
    e. eToro Copy Systems explanation                              and approved by the Compliance Function/
    f. eToro CopyPortfolios                                        Department of eToro.
    g. Deposits FAQ
    h. Withdrawal FAQ                                              Affiliates shall not approach, directly or
    i. Regulation and License
                                                              10   indirectly, any traders and/or potential traders
    j. Customer Service                                            other than promoting eToro as detailed in
    k. Invite your friends (“Refer a friend” (RAF) program)        these partner guidelines.
    l. General Risk Disclosure
                                                                   Do NOT use fake celebrity endorsement in
    Affiliates are only permitted to use eToro’s
                                                              11   order to promote eToro
6   official marketing materials which can be found
    in the affiliate marketing tools.

7   Any educational materials and/or marketing                Leading Compliance Principles :
    materials and/or related materials created
    by the affiliate to be provided to clients (i.e.
    banners, videos, newsletters, any significant             BE FAIR - do not use misleading headlines
    changes to the communication channels of the              and unfair comparisons. Partners should not
    affiliate etc.), through all of the communication         hide important information by using small
    channels, should be reviewed and approved                 print. Always make sure that you display risk
    by the Compliance Function/Department of                  warnings in a clear and visible way. Never
    eToro, prior to dissemination to clients. Any             promise profits or gains.
    related requests to this matter should be
    forwarded to your affiliate account manager.

                                                                                                                      2
Do not use any unqualified or absolute                RESTRICTED WORDS - Ensure you not use
statements unless they can be proved by               the following expressions:
including a source as to where the information        • “stockbroker” or “sharebroker”;
is taken from.                                        • “futures broker”;
BE CLEAR - about any charges, fees or risks.          Ensure you do not use the following
                                                      expressions / words:
AVOID MISLE ADING - ensure that all
                                                      • “independent”;
statements are balanced. Partners can not
place too much emphasis on the benefits               • “impartial”;
associated with a product without also                • “unbiased”; or
highlighting the relevant risks. Always look          • similar expressions.
for complete, relevant data and add proper
warnings when using data (see section “How
to display risk warnings”)                            Checklist of things to consider:
U N R E A L I S T I C E X P E C TAT I O N S - t h e
information shall not include the name of any         Confirm each sentence in the advert is
competent authority in such a way that would          factually correct.
indicate or suggest endorsement or approval           Confirm information presented is relevant.
by that authority of the products or services
offered by eToro entities.                            Confirm information presented is clear,
                                                      concise and effective.
KEEP THE TERMINOLOGY AND CONTENT
UP TO DATE - all the irrelevant information or        Confirm important information is aimed
old terms need to be replaced and updated             at catching the readers attention (e.g.
(i.e., words like: “Guru, copyfund, OpenBook          disclaimers).
and high leverage) Bonuses are subject to             Confirm information is in a format that
changes.                                              makes it easy for consumers to compare
                                                      financial products and services.

                                                                                                   3
Make it clear that past performance                                 “Gain up to 85% return every 60 seconds”
(results achieved) is not necessarily                               “Start your career as a trader right now”
indicative of future results. Furthermore,                          “Suggestions are great – it is hard not to win”
no representation is made that profits                              “95% return in a few minutes”
will be achieved or losses avoided in the                           Our Pro signals have been tested to have over
future.                                                             65% daily success rates”
Confirm that there is NO use of “non                                “What can you do in 60 seconds? Copy and
actual” information e.g. “modelled results”,                        earn extra money.”
“averages”, “simulated” etc.                                        “Learn how to turn market opportunities into
                                                                    profit”
Any comparisons used are current,
                                                                    “$10,000 – Get your bonus now..”
complete and accurate i.e. compared with
                                                                    “Make/earn money”
a benchmark or the average for a class of
similar products or service.                                        “Risk-free”
                                                                    “low risk”
Confirm that the advertisement was                                  “No 1”
truthful and precise (i.e. the advertisement                        “Secure”
can not be misleading and/or deceptive or                           “Safe”
likely to mislead and/or deceive).
Confirm that the advertisement is suitable                          Avoid Jargons in general
for the full range of its audience i.e. apply
the “lowest common denominator” test.                               Do not use the statements below:
                                                                    a. Become a successful trader!
                                                                    b. You will make profits!
                                                                    c. Make money with the best trader
Examples of Misleading Statements
                                                                    d. With eToro, trading is easy
                                                                    e. Copy the best traders and you will make
Do not use the statements below:                                       profits
“1 click 60 seconds 85% profit”
“Trading has never been so easy”                                    Do not make any false promises

Please note that all content and marketing materials that include Copyfund or Bonuses offerings need to be immediately removed.
                                                                                                                                  4
How to display risk warning?                     CFD:
                                                 eToro AUS Capital Ltd ACN 612 791 803 AFSL
                                                 491139. OTC Derivatives are speculative and
Whenever there is a Call to Action (‘CTA’) for   leveraged. Not suitable for all investors. Capital
CFDs,Real Stocks, Cryptos or any kind of         at risk. See PDS
instrument (i.e.,
Join now, Trade now, Invest now, Register,       Real Crypto Assets:
Open account, Verify etc), a RISK WARNING        Cr ypto assets are unregulated & highly
IS REQUIRED.                                     speculative. No consumer protection. Capital
                                                 at risk.
The disclaimer should be under/next to View
Website the button (CTA). It should always be    Real + CFD Crypto or Ambiguous
in the language of the website, visible and
added to EVERY (CTA).                            eToro AUS Capital Ltd ACN 612 791 803 AFSL
                                                 491139. eToro offers both real crypto assets
For the small CTA, the disclaimer should         as well as crypto assets as OTC Derivatives.
always be bold.
                                                 Real crypto assets are unregulated & highly
                                                 speculative. Being unregulated, there is no
Real Stock:                                      consumer protection. Your capital is at risk.

Zero stock commission:                           Leveraged positions are OTC Derivatives,
eToro Service ARSN 637 489 466 promoted          which are regulated financial products. OTC
by eToro AUS Capital Limited ACN 612 791         Derivatives are considered risky financial
803 AFSL 491139. Capital at risk. See PDS.       products, speculative, and include leverage.
Zero commission does not apply to short or       Not suitable for all investors. Capital at risk.
leveraged positions. Zero commission means       See PDS
that no broker fee has been charged when
opening or closing the position. Limited stock
exchanges only.

                                                                                                      5
For the larger CTA, the disclaimer is:            Shares are non transferable. Your capital is at
                                                  risk. Refer to the Product Disclosure Statement
                                                  (PDS) before transacting.
For CFDs
eToro AUS Capital Limited ACN 612 791 803
                                                  For Zero Commission
AFSL 491139. OTC Derivatives are leveraged
                                                  This content promotes stocks and is of
financial products and considered speculative.
                                                  a general nature only. Stocks are offered
OTC Derivatives may not be suitable for all
                                                  through eToro Service ARSN 637 489 466
investors. Trading OTC Derivatives does not
                                                  operated by Gleneagle Asset Management
result in ownership of the underlying assets.
                                                  ACN 103 162 278 AFSL 226199 and promoted
You risk losing all of your investment. This
                                                  by eToro AUS Capital Limited ACN 612 791
information is general only and has been
                                                  803 AFSL 491139. Investing in shares via a
prepared without taking your objectives,
                                                  managed investment scheme does not result
financial situation or needs into account.
                                                  in direct ownership of the underlying assets.
Consider our Product Disclosure Statement
                                                  The shares are held on your behalf. Non-
(PDS).
                                                  transferable. Your capital is at risk. Other
                                                  fees may apply. For additional information
For Real Stocks
                                                  regarding fees, click here.
This content promotes stocks and is of a
general nature only. Stocks are offered through
                                                  Zero commission is only available on limited
eToro Service ARSN 637 489 466 operated by
                                                  stock exchanges. All other shares are offered
Gleneagle Asset Management ACN 103 162
                                                  as OTC Derivatives, and include commission.
278 AFSL 226199 and promoted by eToro AUS
                                                  This information is general only and has been
Capital Limited ACN 612 791 803 AFSL 491139.
                                                  prepared without taking your objectives,
Investing in shares via a managed investment
                                                  financial situation or needs into account.
scheme does not result in direct ownership
                                                  You should obtain independent advice and
of the underlying assets. The scheme has
                                                  consider our Product Disclosure Statement
legal ownership, the investor has beneficial
                                                  (PDS) before transacting. See full disclaimer.
ownership i.e. the shares are held on your
behalf. As the scheme has legal ownership,
                                                  If a CTA is at the end of the review, website,
you have no rights in the securities, including
                                                  blog or article, ALWAYS use the long version
voting rights.
                                                  noted above.

                                                                                                    6
If a CTA is at the end of the review, website,     For Real Stocks
blog or article, and the content mention “copy-    Copy trading is offered by eToro AUS Capital
trading” ALWAYS use the appropriate long           Limited ACN 612 791 803 AFSL 491139. Social
version:                                           trading. eToro does not approve or endorse
                                                   any of the trading accounts customers may
For CFDs                                           choose to copy. All instructions and actions
Copytrading is offered by eToro AUS Capital        related to copied trades will automatically be
Limited ACN 612 791 803 AFSL 491139. Social        replicated in your account. When you select
trading. eToro does not approve or endorse         to copy a particular trading account you will
any of the trading accounts customers may          copy all of their future trades, and you may
choose to copy. All instructions and actions       select also to follow their existing trades.
related to copied trades will automatically be     Past performance of an eToro Community
replicated in your account. When you select        Member is not a reliable indicator of their
to copy a particular trading account you will      future performance.
copy all of their future trades, and you may
select also to follow their existing trades.       Stocks are offered through eToro Service
Past performance of an eToro Community             ARSN 637 489 466 operated by Gleneagle
Member is not a reliable indicator of their        Asset Management ACN 103 162 278 AFSL
future performance.                                226199 and promoted by eToro AUS Capital
                                                   Limited ACN 612 791 803 AFSL 491139.
OTC Derivatives are offered by eToro AUS Capital   Investing in shares via a managed investment
Limited ACN 612 791 803 AFSL 491139. OTC           scheme does not result in direct ownership
Derivatives are leveraged financial products       of the underlying assets. The scheme has
and considered speculative.OTC Derivatives         legal ownership, the investor has beneficial
may not be suitable for all investors. Trading     ownership i.e. the shares are held on your
OTC Derivatives does not result in ownership       behalf. As the scheme has legal ownership,
of the underlying assets. You risk losing all of   you have no rights in the securities, including
your investment. This information is general       voting rights. Shares are non transferable.
only and has been prepared without taking          Your capital is at risk. Refer to the Product
your objectives, financial situation or needs      Disclosure Statement (PDS) before transacting.
into account. Consider our Product Disclosure
Statement (PDS).

                                                                                                     7
For Zero Commission                               Zero commission is only available on limited
Copy trading is offered by eToro AUS Capital      stock exchanges. All other shares are offered
Limited ACN 612 791 803 AFSL 491139. Social       as OTC Derivatives, and include commission.
trading. eToro does not approve or endorse        This information is general only and has been
any of the trading accounts customers may         prepared without taking your objectives,
choose to copy. All instructions and actions      financial situation or needs into account.
related to copied trades will automatically be    You should obtain independent advice and
replicated in your account. When you select       consider our Product Disclosure Statement
to copy a particular trading account you will     (PDS) before transacting.
copy all of their future trades, and you may
select also to follow their existing trades.      A few examples of CTA:
Past performance of an eToro Community
Member is not a reliable indicator of their       •    Trade now
future performance.                               •    Sign up
                                                  •    Join now
Stocks are offered through eToro Service          •    Invest now
ARSN 637 489 466 operated by Gleneagle            •    Buy and Sell
Asset Management ACN 103 162 278 AFSL             •    Register Now
226199 and promoted by eToro AUS Capital          •    View Website
Limited ACN 612 791 803 AFSL 491139.
Investing in shares via a managed investment          WARNING: it should be visible and in
scheme does not result in direct ownership            the language of the website.
of the underlying assets. The scheme has
legal ownership, the investor has beneficial
ownership i.e. the shares are held on your
behalf. As the scheme has legal ownership,            NOTE: The disclaimers must appear at all
you have no rights in the securities, including       times separate from other risk warnings.
voting rights. Shares are non transferable.
Your capital is at risk. Refer to the Product     Remember you can use the short version at
Disclosure Statement (PDS) before transacting.    the beginning of the article, reviews, blog,
                                                  website, but you always need to use the long
                                                  version at the end.

                                                                                                  8
Remember that it is your obligations and            Section 3.1.6.
responsibilities to check and comply with           The Affiliate’s fulfilment of its responsibilities
our guidelines as well as our T&Cs.                 under this Agreement shall be in strict
                                                    compliance with the terms and conditions
We would like to draw your attention to the         set forth herein;
following chapter from our T&Cs, related to
compliance. The entire T&Cs can be found            Section 4.2
HERE                                                The Affiliate shall not publish any material
                                                    which refers to the Trading Platform, eToro
Section 2.3 “The Affiliate acknowledges             Brands or any other name or mark owned by
and agrees that:                                    eToro unless such publication is in compliance
                                                    with eToro’s guidelines. Upon request by eToro,
a. it will use the eToro Brands only as permitted   Upon request by eToro, the Affiliate shall
Hereunder;                                          immediately remove any publication referring
b. it will use the eToro Brands in a lawful         to the Trading Platform, eToro Brands or any
                                                    other name or mark owned by eToro.
manner and in strict compliance with all
format(s), guidelines, standards and other          Section 4.3
requirements prescribed by eToro;                   The Affiliate shall not copy any content from
c. the eToro Brands are and shall remain the        eToro’s Websites and/or publications and shall
sole property of eToro;                             not post in any website and/or elsewhere, any
d. nothing in this Agreement shall confer in        material published in eToro’s Websites and/or
the Affiliate any right of ownership in the         publications. The Affiliate shall not copy any
eToro Brands and all use thereof by the             content from any other Affiliate’s websites.
Affiliate shall inure to the benefit of eToro;
And
e. the Affiliate shall not, now or in the future,
attempt to register any eToro Brand and/or
domain name and/or contest the validity of
any eToro Brands or use any term or mark
confusingly similar to any eToro Brands.”

                                                                                                         9
ADDITIONAL RESTRICTIONS

    Please note that if an affiliate cannot amend any of the promotional content of its website in accordance with the
    above rule, the content shall be required to be removed.

    • Only target individuals over the age of 18
    • Regulatory demands can change often and with no prior notice. When this occurs, all promotional material
      needs to be updated immediately.

    If you want to make any changes to eToro promotional materials on your site, you must let us know via the customer
    service portal by opening a ticket or contacting your affiliate account manager.

    Restricted Countries - please contact our Customer Service

    Note that this document may be amended from time to time to include/reflect new operational and/ or new/
    amended regulatory requirements.

Partner Up!

In case you need further assistance, do not hesitate to contact your direct affiliate manager and we will
be pleased to assist you.

We would like to thank you for your collaboration and hope to deliver the best possible experience for all
of our Partners!

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