An internal reference document for anyone creating marketing content, running sales conversations, or collecting testimonials on behalf of Freedom Property Academy.
This is an internal reference document for anyone creating marketing content, running sales conversations, or collecting testimonials on behalf of Freedom Property Academy ("the Academy"). It covers three related areas: marketing claims, testimonials and reviews, and the fair treatment of clients during enrolment.
This Part applies to all marketing content produced for the Academy, including Reels, social media posts, Monday Live sessions, blog content, adverts, and sales pages, whoever creates it.
All marketing must be honest, capable of being substantiated, and not likely to mislead. This reflects the requirements of the CAP Code (the advertising rules enforced by the ASA) and the Digital Markets, Competition and Consumers Act 2024.
Only reference deadlines, limited spaces, or closing offers where these are genuinely true at the time of posting. Do not create artificial time pressure (e.g. a countdown that resets, or a "last chance" claim repeated indefinitely).
Where marketing content includes specific numbers, income claims, or a new promotional offer, it should be reviewed by Andrei Bosancu before it is published, to check it is accurate and compliant with this Policy.
Testimonials are only requested from genuine current or former Academy clients. When asking a client for a testimonial, do not suggest specific claims, figures, or wording for them to use — the testimonial must be in the client's own words and reflect their own genuine experience.
Before publishing a testimonial, check that: the person is a genuine, identifiable client; and any specific factual claims made within it (e.g. a stated income figure) are ones we can reasonably stand behind, or should be edited out if they cannot be verified.
Where a testimonial was provided as part of a free membership arrangement (i.e. given in exchange for enrolment, as described in the Promotional Membership Agreement), this should be reasonably disclosed when the testimonial is used — for example, by describing the person as "an enrolled Academy member" rather than presenting the testimonial as an unprompted, independent review. This reflects the Digital Markets, Competition and Consumers Act 2024's rules on incentivised reviews.
Testimonials may be lightly edited for length or clarity, but must not be edited in a way that changes their substantive meaning or adds a claim the client did not actually make.
A record is kept of each client's consent to their testimonial, image, or video being used in marketing (see clause 9 of the membership agreements). If a client asks for a testimonial or piece of footage to be taken down, we will action this within a reasonable time, though this does not affect material already published or distributed before the request was received.
Regulators have specifically flagged aggressive sales practices that target financially vulnerable people as an enforcement priority in the coaching and training sector. This Part sets out how the Academy expects enrolment conversations — including 1:1 strategy days and sales calls — to be conducted.
Be alert to signs that a prospective client may be vulnerable to a pressured decision, including where someone:
If a team member is ever unsure whether it is appropriate to proceed with an enrolment, they should pause and consult [insert name/role] before continuing.
This Policy is reviewed at least annually, and whenever there is a material change in advertising or consumer protection law, or in how the Academy markets or sells the Programme.
This Marketing, Sales & Testimonials Compliance Policy ensures the Academy maintains the highest standards of integrity and compliance in all marketing and sales activities.