Please read this social media policy and complete the declaration form before you use Facebook, LinkedIn, Twitter or any other social media platform to communicate with current or prospective Momentum clients.

Social media can help you to find new clients, create opportunities, build your relationship with existing clients and reach a wider audience than just your current network. But if you don’t actively manage it, it can have no benefit at all – or worse, it can harm your reputation and give rise to compliance issues with Regulators and/or Industry Bodies.

This policy sets out the rules and guidelines that will ensure that your reputation stays intact, and in line with the Momentum brand. It will also give you some guidelines to make sure that you continue to act ethically and avoid any risk of not complying with regulations.

For more information or if you have questions about social media or this policy, please contact:

Person: Thanya de Carvalho

Mail: [email protected]

Physical Address: Momentum Financial Planning, 272 West Avenue, Lakefield Office Park Lakefield Office building, Block E, 1st floor Die Hoewes, Centurion, 0157

1. Key points of this policy

Below are the key points (summarised) of the social media policy. Please read through them carefully, and then read the full policy that follows. When you have agreed to the social media policy, we will send you a copy by email. If anything is unclear to you either before or after you’ve agreed, please contact us right away.

1. Represent yourself and Momentum Financial Planning (MFP) transparently and honestly. Always look after your reputation and the reputation of MFP.
2. Be clear, fair and don’t mislead – don’t say anything that might give an individual the wrong impression about you, MFP or Momentum products. Write in a straightforward way – as if you’re having a face-to-face conversation.
3. Protect your personal information and data, as well as that of any client or individual that you interact with. Don’t give out or share information that is confidential to your business or to MFP. If you mismanage personal or confidential information, there will be disciplinary procedures, including possible termination of your relationship with MFP.
4. Never give financial advice on social media, including tips that may be deemed financial advice. Include a disclaimer to make it clear that you are giving information and not advice.
5. Don’t give quotations or forward formal documents through social media channels.
6. Take care before you share – if you like or share content, it’s the same as endorsing it.
7. Always check the copyright of an image before you use it – it’s safer to just use MFP imagery if you’re not sure. Never copy and paste content from another source. You could be accused of plagiarising.
8. Never post, share or like anything that could be seen as hate speech, racist, sexist or offensive to any person or group of people. If you see anything on a social media account related to MFP that could be considered to be hate speech, racist, sexist or offensive to any person or group of people, please inform us right away.
9. You are legally liable for everything you do, say or post on social media. If you don’t comply with this policy, we will follow disciplinary procedures. These may in certain instances lead to termination of our relationship with you.
10. Make sure that everyone who uses your social media account agrees to this social media policy.

2. About this policy

Who it is for

This policy is for all MFP employees, Momentum financial advisers (employed, independent and in franchises). It also applies to anyone who posts / shares pictures and add comments on behalf of a Momentum financial adviser or Franchise or in your personal capacity.

What it applies to

Most of the examples we give are about Facebook because this is the channel most used at the moment. Remember that the policy also applies to all other kinds of social media, including LinkedIn, Twitter and Instagram.

Ownership and changes

The owner of this policy is the Head of Marketing, Momentum Financial Planning. The MFP Marketing team is responsible for coordinating, writing and keeping this policy up to date. Any material changes to the policy must be agreed upon with the MFP Executive Committee.

Implementation

The CEO of each business area is accountable for the implementation and adherence to this policy in their business areas.

If anything is unclear

If you are not sure about our social media policy, please contact your Practice Consultant, the MFP Marketing team or the Head of Reputation Management and Public Relations.

3. Setting up social media accounts

Business vs personal accounts

You have a choice whether to set up a business or personal account on any type of social media platform. With Facebook, it is probably best to set up a separate Facebook page as a financial adviser. This way, you can post about personal things on a personal account and keep your professional Facebook page more focused on your role as a financial adviser.

On LinkedIn, you can choose whether to market from your personal profile or to set up a Group for your practice.

The policy on personal vs business accounts:

Whether you’re using a personal or business account to promote your services as a Momentum financial adviser, this policy applies to you. (In other words, the policy applies to any account you use, not only accounts you set up for your business.)

Names

Every social media account has a name. This is how people will find you when they search, so it’s important to be as specific as possible.

Our policy is that you use your personal name or the name of your practice, along with either Momentum Financial Adviser or Momentum Money Coach.

Examples of names for Facebook pages

• Nina Simone – Momentum Financial Planner
• Alan Pearson – Momentum Money Coach

The policy on names

People will find you through searching for the name of your account, so be as specific as possible. We ask you to include Momentum Financial Planning in the name. Please email the details of the account to us before you start posting. This is simply to allow us to help with any difficult situations that may arise.

Describing yourself in a profile or About section

Some types of social media also allow you to add some information about yourself. Facebook calls this a description in Facebook pages (which shows up as the Story in the About section of your page). With LinkedIn, this is the About section of your Profile on a personal account, or an Overview on a LinkedIn Group.

Visitors will read this description to learn more about you – make it as specific as possible. Include information about who you are, what you do, and why clients should choose you.

The policy on profiles or descriptions (content appearing in an `About` section):

• Include the words, Momentum Financial Adviser
• Describe the services that you offer
• Be specific
• Only use images that are approved by MFP
• Complete all profile information

Complete profile information

Your responsibility for others who use your account

If you have an assistant/s or individuals helping you with your social media account or presence, you have an obligation to have a system in place for you to sign-off all digital media communication. You are responsible for making sure that everyone involved agrees to these social media rules and guidelines.

Setting up expectations – response times and editors

If you don’t set clear expectations, your reputation and that of MFP will be negatively affected.

The policy on response times, editors and approvers

If you set up a page, please be honest and clear about:

• Your response time for getting back to comments or direct messages;
• Whether an individual/s must wait for you to approve a post before it’s published on Facebook, and how long this approval is likely to take; and
• Who has the rights to edit the page (‘team members’ on Facebook pages, ‘Admin’ on Linkedin groups).

Information archiving and keeping records

Always keep records of all your communication through social media. When you delete any posts, messages or content, make sure you have saved them somewhere first.

4. Clear, fair and not misleading

All content on social media must be clear, fair, unambiguous and not misleading. This principle comes from the Conduct of Financial Institutions Bill. Please note these principles which will apply to your posts:

The policy on principles from the Conduct of Financial Institutions Bill

Promotional and marketing material of a financial institution must be appropriate to the needs and reasonably assumed level of knowledge of the financial customers at whom it is targeted.

Promotional and marketing material of a financial institution may not be misleading or likely to mislead, deceptive, fraudulent, contrary to the public interest or contain incorrect statements.

Promotional and marketing material must use clear, plain and unambiguous language, and take into account the needs and reasonably assumed level of knowledge of the retail financial customers to whom it is targeted.

The policy on being clear, fair and not misleading

• Never use misleading headlines.
• Don’t hide the risks of products – make sure that the risks are as clear as the benefits.
• Use suitable language at all times – no small print or legalese.
• Make sure that everything you write is accurate.

5. Content and topics to post about

Statement that you’re not giving advice (Disclaimer)

Social media is for giving information, not advice. You need to make this clear always – even if you are replying to a comment with a specific question, remember that other people can take that information out of context. Make it clear that you’re not giving advice.

The policy on giving information, not advice:

In the `About` information of your profile, and at the bottom of any longer post, you must use this statement:

Note: This content is intended to give general information only and is not financial advice. You must contact me directly and privately if you need financial advice.

Share Momentum content

The policy on sharing Momentum content

You may share any content from Momentum or MFP – feel free to add your own comments above the share. However, if it’s more than a short paragraph, don’t copy and paste the text so that it looks like you wrote it yourself. If it’s less than a paragraph, there’s no problem in doing so.

Hashtags to use

Hashtags can be used to make your own content more accessible with a search. They are also useful in tracking your own content (if you create a unique hashtag). Before you use a hashtag, please Google it to ensure that it doesn’t have any bad or controversial connotations.

The policy on hashtags:

Google a hashtag before you use it. Don’t use it if other people have posted any offensive content using that hashtag.

Don’t talk about the news unless it’s relevant

Newsjacking is a technique where marketers try to get attention by talking about things that are trending in the news. Do not use newsjacking as your strategy. If you want to discuss current events, keep it on your personal profile, not your business profile. The exception of course is if something happens that is directly related to your financial advice – for example, a change in financial regulations, an article about how redundancies are affecting insurance claims in South Africa, etc.

Keep wishes for special days, like religious holidays, respectful of all your clients

It’s fine to post about a religious holiday but always be respectful. If you do not know about the holiday, ask for advice before posting. Be careful about cultural or sexist assumptions – see example on sexism.

Remember that all shares are endorsements

If you share or like content from third-party websites or social channels, you are endorsing it.

The policy on liking and sharing content on other pages and channels

Be very careful that you are 100% sure that any content you like or share complies with this social media policy. If you wouldn’t be happy posting something yourself, don’t like or share it to your timeline.

Posting on groups or other pages

It’s a good idea to use Facebook groups (for example, your neighbourhood group) to build relationships. Remember you can join Facebook groups as a page or as your personal profile.

The policy on posting on other Facebook groups

Make sure whether you are joining or commenting on a group as your personal profile or as your page – and make sure your content is appropriate for the profile you’re using.

Always read the policy of the group to see if you are allowed to promote your services on it.

Before posting, always make sure that another financial adviser has not posted the same or similar content in the past week. Remember the group admin probably won’t allow too many similar posts on any group.

6. Advertising and sponsored posts

If you want to advertise your services, recruit staff, run competitions or promotions you must first obtain approval for the content as well as from MFP to check and approve the advert first. This is to ensure that the use of the Momentum logo complies within Momentum requirements and to avoid our clients from being overwhelmed with adverts from different financial advisers.

7. Words and images

Images

Images are essential for good social media. You can use images on your profile, and images within posts.

The policy on images

If you put text over your image in Facebook, make sure that it takes up less than 20% of the space of the image.

For your profile, only use images that are approved by MFP.

If you want to use other images in posts, please only use images that have a `Creative Commons` license. (Most browsers will let you filter image searches by type of license.) If you can’t trace the creator of an image or the terms of a work’s use, do not use that image.

Words to be wary of

Think about social media as public information – if there is just one person that you’re not comfortable with reading a post, don’t post.

The policy on words to be wary of

• Free – always be careful of saying things are for free. If there is any way at all that this can be misunderstood, don’t use the word.
• Guarantee – be careful of any kind of promise or guarantee – again unless you are 100% sure that it will happen.
• Once-off offer – unless you’re sure it is once-off, don’t use this phrase.

Don’t use racist, sexist or otherwise offensive content

It goes without saying that hate speech, including racist or sexist statements, will cause harm to your brand and that of MFP.

Posts that are not allowed under this policy

It’s fine to write a post to build your community with wording like: Happy Valentine’s Day. Have a wonderful evening relaxing. I’ll be watching my favourite film, Love Actually. What’s your favourite Valentine’s Day movie?

It’s not acceptable to write something like: Valentine’s Day is a wonderful time to spend with your wife and kids.

Please also watch out for imagery that can be considered problematic. For example, don’t use:

• pictures of men or women that are undressed
• offensive political comments
• comments about race that may be interpreted as racist
• pictures of flags or symbols that will cause offence, for example, the old South African flag, USSR communist flag or organisations like ISIS
• imagery that makes light of a violent situation
• comments that could be seen as offensive to religious and traditional groups or the LGBTQI community
• comments that may bring Momentum, MFP or Momentum Metropolitan Holdings (MMH) into disrepute.

The policy on racist, sexist and other offensive language

We do not tolerate any language or image that can be seen as racist, sexist or insulting to any person or group of people. We do not tolerate hate speech.

If you see anything on a social media account related to MFP that could be considered to be racist, sexist, political or insulting to a person or group of people, you must inform us right away. We’ll speak directly to the owner of the account.

If you are instructed to delete something, you must do so right away and confirm that you have complied.

8. Confidentiality and privacy

Anything you put on social media is public information. This means that you must never give out client details or anything that is considered personal information. If you want to use client testimonials, make sure that you receive written permission first from the client/s.

Never post any images of children unless they are provided by MFP.

Tagging clients in your posts

There should not be a need to tag clients in your posts. If you have a photograph with a client and want to put it on your page, you must ask for their written permission first. You must keep a record of the permission obtained.

The policy on confidentiality and privacy

• Never put any personal or financial information about a client online (for example, contact details or the financial products that they have).
• If you have their written permission, you can include their name with a testimonial. But do not link their name to their personal social media accounts or contact details.
• Never tag a person without getting their written permission first.
• If a client posts their personal information on your page, delete it immediately and write to the client telling them that you are not able to publish their personal information.
• Never include any images or names of children.
• Don’t include any confidential information about MFP or Momentum.

9. Complaints and crises – what to do

People might leave complaints on your page:

• If the complaint is inappropriate, you feel that it is affecting your or Momentum’s reputation, then delete it. You can send the details to MFP and we will pass it to the right person.
• If the complaint is something that you can help with and it doesn’t break any other areas of the social media policy, then put a polite note saying that you will get back to the person. Then send them a DM to deal with the complaint privately.

Examples of post to delete

This is an example of a comment that you should delete: The XXX area is the centre for financial crime – I was defrauded out of R10,000 by a broker.

This is an example of a comment that you can respond to if you want to: I am not happy with Momentum as I have been asking to change my policy for years but no-one’s got back to me.

An example of a possible response is: I’m sorry to hear about your frustrating experience. I’ll direct message you and try to get it sorted out for you.

10. What happens if you don’t comply

You must co-operate with any investigation by MFP into a breach of this policy. If you notice any use of social media by other members of staff who may be in breach of this policy; please report it to the MFP Marketing team.

MMH views all breaches of this policy, as well as any non-compliance with its obligations in terms of law, in a serious light. Any deliberate action to breach this policy will result in disciplinary action including possible termination of the relationship. All instances of non-compliance with this policy will be included in the regular risk reporting process.

Breaches to privacy or confidentiality

If a complaint or an infringement investigation has been finalised, MFP may recommend any appropriate action to be taken against any financial adviser who is reasonably suspected of being implicated in any non-compliant activity outlined in this policy. The action may be administrative, legal or disciplinary.

In the case of ignorance or minor negligence, MMH undertakes to give awareness training to the financial adviser.

Any gross negligent or the wilful mismanagement of personal information will be considered a serious form of misconduct for which MMH in its sole discretion may take any action permissible in law. Disciplinary procedures will be initiated where there is sufficient evidence of such negligence. Examples of immediate action that may be taken after an investigation include:

• A recommendation for disciplinary action.
• A referral to appropriate law enforcement agencies for criminal investigation.
• Recovery of funds and assets to limit any prejudice or damages caused.

Important: Applicable to all employed advisers: This policy must at all times be read in conjunction with the MMH Social Media Policy which will also apply.