Writing a disclosure policy for a women founder funding publisher

A disclosure policy should let a founder see who controls the service, how it earns and why an option appears before she supplies data or acts. Put material disclosures beside the affected recommendation; a distant policy page cannot repair a misleading comparison.

What to take away

Name the publisher and roles

State the legal entity, company number, contact address and responsible editor. Explain whether the organisation publishes information, gives guidance, advises, introduces, arranges, lends, invests or delivers a programme. Identify separate regulated or professional entities.

Link the complaints and corrections routes. Where FCA status is relevant, give the legal name and reference number, then direct readers to the FCA Register for a current check. Do not use a regulator's logo or status as a quality badge.

Publish the commercial model

Describe founder fees, provider commissions, lead payments, sponsorship, equity interests, free services and other benefits. State when payment arises and whether it changes inclusion, data collected or follow-up.

For a comparison, publish the provider universe, entry method, exclusions and update date. Mark paid placement before the entry. Keep editorial scores and order independent of revenue, or state plainly when the page is advertising rather than editorial.

Explain the method

Define women-founded, women-led or women-owned as used on the service. Explain mixed teams, geography, route and stage. List the evidence types, weighting, testing performed and limitations. An untested public-information review must not sound like a first-hand application.

State whether demographic information is self-reported, optional, inferred or unavailable. The Investing in Women Code 2026 is one defined provider-reporting source; its findings should not be presented as the service's own data.

Place article-level disclosures

At the top or beside the relevant claim, identify:

Worked example: Disclosure: This article contains a paid link to [provider]. We may receive a commission if you apply. Source checked [date].

The Advertising Standards Authority (ASA) enforces the CAP Code.

The CAP Code's recognition of marketing communications rules require marketing to be obviously identifiable. Use an ordinary label readers understand, not a vague phrase such as "partner content".

Govern testimonials and outcomes

Verify that a testimonial comes from a real user of the named service. Record permission, incentive, relationship, date and product version. Do not edit away a material qualification or condition publication on a positive statement.

For money raised or approval claims, give the period, denominator, route and whether figures represent applications, offers, contracts or receipts. Report missing records.

Run the correction process

Give claims an owner and update risk. Recheck provider terms, deadlines, permissions and programme status on publication day. Log corrections with date, previous wording, new evidence and affected pages. Correction log fields: date, page URL, claim, previous wording, new wording, evidence, reviewer and reader notification sent. Notify readers when an error could have changed a financial decision.

Review the policy with the advertising, financial-promotion, consumer and data rules that apply to the actual service. The responsible editor approves the policy before publication, and the policy is reviewed at least every six months.

Maintain a disclosure register

For each provider and contributor, log payments, referrals, sponsorship, gifts, free access, shareholdings, family connections, employment and review participation. Ask for updates at commissioning, fact-check and publication. Record a nil return so silence is not mistaken for a completed check.

Disclosure register fields: provider, contributor, relationship, payment or benefit, amount band, date received, disclosure label, reviewer and next review date.

Define responses. A minor free trial may require a visible note; a material equity interest may require reassignment or exclusion from a ranking. The editor should document the choice and apply it consistently.

Audit a sample of pages against the register every quarter. Confirm that labels remain visible after design changes, links still point to the disclosed partner and archived commercial relationships do not keep influencing current order.

Before you act

Common questions

Where should material disclosures appear?

Put material disclosures beside the affected recommendation, so the reader should see the disclosure before she supplies data or acts on the option.

What should a comparison page publish about its method?

Look for the provider universe, entry method, exclusions and update date. Paid placement should be marked before the entry. Check that scores and order are independent of revenue, or that the page is labelled as advertising.

How should corrections be handled?

Check that claims have an owner and update risk. On publication day, recheck provider terms, deadlines, permissions and programme status. Look for a correction log with date, previous wording, new evidence and affected pages, plus reader notification when an error could have changed a financial decision.