In order to sign off on your campaign as a financial promotion, we need to make sure that it is fair, clear, and not misleading. In practice, this means that we may need to adjust some of the language within it and ask for evidence to back up any factual statements.
When your Campaign Manager requests evidence for factual statements, this means a third party source of the information is required to verify the statement is correct. If it's not possible to provide a third party source (i.e. number of users) then we’ll need to see a document that confirms the information, or a screenshot of your backend showing total numbers. Below are some examples of types of statements that require evidence, and the ideal evidence to provide:
“To date, we have received £25,000 in seed investment.”
To support this statement, you need to show proof that you have received this amount of cash in exchange for equity.
Evidence examples: Signed Investment Agreement, bank statement + share certificate/cap table.
“We have an exclusive contract with a large retailer.”
To support this statement you need to show that there is an in-date contract, exclusivity of contract, and name of retailer.
Evidence examples: Signed full contract, and point to the clause detailing exclusivity.
NB: if your NDA restricts you from sharing the contract with us, we are unlikely to be able to include the statement.
“The market is worth £1bn.” / ”The market has grown 10% over the last three years.”
To support this statement you need to show a third-party source verifying the figures are accurate.
Evidence examples: recent (normally no more than a 2-3 years old) articles / industry white papers / research.
NB: if you are using a lengthy source, please specify where your figures are. If you are making calculations based on figures, please specify which figures, and explain your calculations.
“Younger consumers tend to appreciate X.”
To support this statement you need to show research or similar that demonstrates this.
Evidence examples: independent third party articles / research, or research you have undertaken yourselves.
Example: “We are an award-winning platform."
To support this statement you need to show evidence of the award.
Evidence examples: press release about the award, photo of the award (if it includes details of the company on it), email chains from the awarding body.
“We’ve had significant interest from two large retailers.”
To support this statement you need to show that you have been in contact with retailers (which could reasonably be called large) and that they have expressed interest in working with your company.
Evidence examples: email chains (screenshots), letters of intent.
“We have 15 paying clients.”
To support this statement you need to show evidence of 15 clients, who have paid for your services.
Evidence examples: invoices, management accounts.
WEBSITE PERFORMANCE DATA
“We have 30,000 customers.” / ”We have 20,000 MAUs.” / ”We have grown by 4,000 users a day.”
To support this statement you need to show evidence of X many users, within what time period, and the interface through which you are measuring this.
Evidence examples: screenshots of data tracking interface, showing the numbers you have given, in the time period specified.
NB: if you have not specified a time period, we will ask you to, and may also need to give context of seasonality of your business model.
“Jeff Bezos has called us the one to watch for 2017.”
To support this statement you need to show Jeff Bezos’s approval for you using this quote.
Evidence examples: email confirmation from the person giving the testimonial, third-party source where they are cited.
“We are currently profitable.”/”Our revenue has grown 200%.”
To support this statement you need to show evidence of this, and in what period (which we will disclose to investors).
Evidence examples: management accounts (specifying which period), invoices.
“We are the only company in this market.” / ”Our cost base is significantly below industry standards.” / ”We have no competitors.” / ”We have a unique platform.”
To support this statement you need to show a third-party source verifying this, and if you are comparing yourselves against competitors, relevant documents (e.g. management accounts) with which to compare.
Evidence examples: third-party sources + relevant company documents.
NB: verifying that you are the only company in the market or that you have an entirely unique platform will be very difficult, so we’ll suggest that you reword this. We’ll also need to verify any claims made about competitors.
“We have been featured in The Daily Mail, The Times, and The Sun.”
To support this statement you need to show the articles themselves, or testimonials from your contact at that publication.
Evidence examples: links to the articles, screenshots of the articles, email testimonials.
“We regularly test our platform.”
To support this statement you need to show the interface through which you test your product, and evidence that you have undertaken such a test.
Evidence examples: screenshots of test results.
“We have grown significantly with absolutely no marketing/advertising spend.”
To support this statement you need to show evidence that you have spent nothing whatsoever on marketing, as well as evidence of growth.
Evidence examples: management accounts.
NB: trying to prove a negative will likely be difficult, so we may suggest that you change the wording here if you cannot provide management accounts to substantiate your claim.
For each member on your team section we need to confirm:
They are a real person
They are connected to your company
They are happy to be listed on the campaign
We therefore request an identity document for each one as we feel this satisfies all three requirements.
Evidence examples: driver's license, passport, ID card.
“I’ve worked in the food industry for 25 years.”
To support this statement you need to show third party evidence that you have been working in the sector for the amount of time stated.
Evidence examples: references, press release, p45, payslips. We cannot accept LinkedIn / CVs as evidence.
NB: this statement will be very difficult to prove, so we may suggest that you reword it.
Please note that we cannot include projections, financial or otherwise, in your campaign text. If you would like to include financial projections of revenue or metrics, you may include them in a document uploaded to the campaign page, which is available upon request by investors.