As you’re promoting an opportunity to invest in your business, it is classed as a financial promotion by the Comisión Nacional del Mercado de Valores (CNMV).
Whilst Crowdcube is on hand to provide guidance, it is important to note that you are fully responsible for ensuring any communications related to your raise are compliant, as you are liable for any non-compliant materials that Crowdcube has not approved. If requested, Crowdcube can review and, if appropriate, approve your communications and apply our approval wording as an CNMV regulated firm. We may require changes to ensure compliance, including the addition of risk warnings.
To help ensure your promotional materials are compliant and that you’re not falling foul of CNMV regulations, which is a criminal offense, please follow the guidance below:
All communications must include a risk warning
Any potential rewards will need to be balanced with the risks. This applies to the message itself, as well as the placement and prominence of any risk warning.
Please include the below risk warning, exactly as they are written here, in any communication about your raise:
- Short form copy (such as social posts): ‘Don’t invest unless you’re prepared to lose all the money you invest. This is a high risk investment.’
No social media posts can go out without the risk warning above. This is based on the assumption that a link to the pitch page is included in the posts which will also display the full risk warning. If the pitch page link will not feature then full risk warning plus link to summary must be included. (this excludes instagram stories)
Any posts from raising companies or from crowdcube employees’ own linkedin/instagram accounts must have the full risk warning and link to risk summary
- Long form copy (such as emails): ‘Don’t invest unless you’re prepared to lose all the money you invest. This is a high-risk investment and you are unlikely to be protected if something goes wrong. Take 2 mins to learn more..’
This is the full risk warning above which has a link to our risk summary. This must be used on all marketing email communications. Ensure that the link is included too.
To ensure you comply with local crowdfunding regulations, which vary by country, you should not promote your raise to people in the United States, Canada or Japan.
Please note that Crowdcube will ask for any non-compliant communications to be amended or removed.
Communications should be fair, clear and not misleading
All communications related to your raise should be fair, clear and not misleading. This means they shouldn’t include hyperbole or superlatives, and that anything you say is clear, accurate and not open to misinterpretation. This doesn’t mean that you can’t be positive, it just means you need to back up what you’re saying with verified facts (more on that below).
All statements and claims should be verified
Every statement or claim you make in any communication about your raise needs to be verified with documented evidence. For example, if you state that your business operates in a market that’s worth €1bn, we will need independent evidence to support and approve that claim.
To ensure all statements in your communications are approved, and therefore compliant, you should only use content from your pitch page once it has been approved by Crowdcube.