Last Updated: May 2023
As you may be aware, compliance with advertising rules is a legal and licensing requirement. As an Affiliate of PPB, any advertising you do on our behalf must adhere to advertising requirements at all times.
We have created this document to educate our partners on the current ‘DOs and DON'Ts when promoting PPB. We also wish to remind you of your obligations under the terms of our Affiliate agreement regarding the promotion of both brands.
We want to ensure that none of your advertisements on behalf of PPB are in any way misleading to customers so please familiarise yourself with the requirements outlined below and save this document for future reference.
If you are in doubt regarding your obligations under our Affiliates agreement or under the relevant legal requirements, please don’t hesitate to contact your account manager or reach out to us at: email@example.com
Flutter UK & Ireland is a division of Flutter Entertainment Plc and consists of 3 separate brands: Paddy Power, Betfair or Sky Betting & Gaming products, (each a “Flutter Brand”, together the “Flutter Brands”). Flutter UK & Ireland is committed to socially responsible practice. These guidelines set out the standards expected for all third-party partners of Flutter UK & Ireland and apply to all Flutter UK & Ireland advertising.
Please ensure you familiarise yourselves with the guidance provided below, as a failure to comply is likely to result in the termination of our agreement with you.
All social media accounts featuring Flutter Brand content should endeavour to post information about responsible gambling on a regular basis. (Frequency to be discussed with your Flutter Brand programme manager.)
Flutter Brands must not appear in any sponsored (paid) social advertising without the prior consent of your Flutter Brand programme manager. All creative must be created by Flutter UK & Ireland or pre-approved by your Flutter Brand programme manager and must comply with all other relevant sections of these guidelines.
At all times, all available age-gating options must be used to target ads in a socially responsible manner.
The use of any other social media platforms must be discussed with your Flutter Brand programme manager prior to proceeding.
Full details of how a sponsored social media campaign has been targeted must be retained for a reasonable period and must be supplied to your Flutter Brand programme manager upon request.
Use of advertorials and editorials is strictly prohibited without the prior approval of your Flutter Brand programme manager. Any advertorial or editorial content approved by Flutter UK & Ireland must be fully compliant with the Committee of Advertising Practice Code (CAP) and clearly marked as an advertisement or promotional feature in the manner prescribed by your Flutter Brand programme manager. All material and consumer signposting must be approved by your Flutter Brand programme manager beforehand.
All advertorials must be deleted within one month of publication to ensure live content remains compliant with current advertising code requirements.
Flutter Brands do permit selected partners to run paid search campaigns on our behalf. However, such campaigns should not proceed without the prior consent of your Flutter Brand programme manager. The Flutter Brand negative keyword exclusion list must be used in any campaign. This exclusion list will be comprised of keywords supplied by Flutter UK & Ireland and the industry exclusion list required to comply with the IGRG Code. This exclusion list may change from time to time and any new exclusion lists received from your Flutter Brand programme manager must be incorporated into campaigns with immediate effect.
Any exclusion list shared with you must be treated in the strictest confidence and must not be shared externally.
Any PPC ads produced must include 18+ and safer gambling messaging within the core format of the ad.
Flutter does not permit bidding on Flutter Brand terms and Flutter Brand names must not be used in any PPC campagn. This includes any manipulation of Flutter Brand names. (For example, ‘Paddyp0wer’ or ‘Betf@ir’.)
Flutter Brands do not permit pop-under activity of any kind.
Flutter Brands do not permit pop-under activity of any kind.
No influencer advertising should take place without the prior consent of your Flutter Brand programme manager.
When considering the use of specific influencers, Flutter Brands will consider the audience demographic of each influencer, as well as the content featured on their social media pages and any recent or current endorsements the individual influencer has received. If this information is not supplied then Flutter UK & Ireland will be unable to approve the use of an influencer as it cannot be demonstrated they do not have strong appeal to children. Influencers from reality TV programmes popular with children or young persons will not be approved. The platforms which will be used must be agreed with your Flutter Brand programme manager prior to publication.
Influencer content must be pre-approved by your Flutter Brand programme manager to ensure compliance with these guidelines and must be clearly marked as an advertisement through use of the term ‘#ad’. This term must be displayed prominently at all times.
Approved influencers may only produce organic content and may not produce sponsored/paid ads for any Flutter Brand.
Flutter Brand adverts should not appear on voucher sites without prior consent. Creative assets used must be supplied or approved by Flutter Brands. Advertisements must be clearly identifiable as such, with full T&Cs presented no more than one click away. Flutter Brand names should not appear in the ‘from’ field for any direct communications sent on behalf of the site.
Flutter Brand adverts must not include the words “Now”, “Today” or any such alternative that could be considered to be limited by time, or imply impulsiveness or urgency within calls to action contained within the advertisement. Flutter UK & Ireland recommend that “Here” is used as an alternative e.g. “Bet Here”, “Join Here” etc. If you wish to enquire about alternative wording then please contact your Flutter Brand programme manager.
Flutter Brands do permit selected partners to conduct in-app campaigns using material pre-approved and supplied by Flutter UK & Ireland. However, such campaigns should not proceed without the prior consent of your Flutter Brand programme manager. Flutter UK and Ireland’s standard requirements are:
Flutter UK & Ireland have made the decision not to engage in any media buying unless a set domain list can be provided of exacly where Flutter Brand advertising appears. This list should be updated and resubmitted on a monthly basis and any new additions must be submitted to your Flutter Brand programme manager prior to use. Flutter UK & Ireland may require data regarding audience demographic for each site used.
If consent for this activity is approved by your Flutter Brand programme manager then only creative provided by Flutter should be used. Media buying through an ad-exchange programme is prohibited.
Flutter Brand adverts must only be placed on legitimate websites (not copyright infringing sites). Flutter UK & Ireland carries out regular monitoring of websites that provide access to copyrighted material, (as determined by the City of London Police). In addition, Flutter Brands must not feature on any site connected with under 18s, youth culture, alcohol or sites connected with/which promote violence/acts of terrorism or pornography.
Flutter Brand advertisements should not appear on any tipping site without the prior consent of your Flutter Brand programme manager. Content published on tipping sites or pages should not indicate that past winnings are indicative of future success or imply that success is guaranteed. Partners must not present tips as a solution to personal or financial concerns. Results must only ever be displayed when accurate and must not be manipulated in any way. Results should be proofed with a relevant independent party, i.e. the racing press or a solicitor, where possible.
Gambling as a solution to financial concerns
As Flutter’s 3rd Party guidelines state;
“All advertisements must comply with the Committee of Advertising Practice Advertising Codes”
One such rule is CAP 16.3.4 - Marketing communications must not suggest that gambling can be a solution to financial concerns, an alternative to employment or a way to achieve financial security
This means that our advertising should not appear in any articles or content suggesting that gambling can help make money for customers, we should also not be served in any sites aimed at people vulnerable to gambling such as moneymaking forums for students etc.
While individuals might have different ways and strategies of gambling using the BF exchange for example, any advertising that presents our brands as anything other than gambling by suggesting it might be a way to earn money or by appealing to people who are looking for ways to make money either in content or placement.
Our brand should not be advertised either using terms or appearing in content based around financial problems, for example:
Some examples of such adverts leading to upheld ASA rulings are;
In this case, an affiliate had presented an advert including phrases like “Everyone wants to solve theirs [sic] financial problems” and “start to earn ... and make a lot of money”. In mentioning financial problems and using the word earn they were suggesting gambling could be a way to make money and led to a termination of the relationship.
Football Index presented a video with the title “How to make money from Football Index” and even though throughout the video they included descriptions of risk and that there were no guarantee the ASA believed the discussion of Football Index in the context of a stock market and making money was underrepresenting the risk of gambling.
An online promotion for Sing Bingo was headed "DEBT FREE 2011!" It stated "How do you fancy having your bills paid in 2011? Sing is prepared to do just that for one lucky player in our new 2011 Debt Free Heaven promo ... No more stress, no more worries and no more running away from the morning postman!" The ASA received and upheld a complaint on the basis that the ad encouraged people to gamble to become “debt free” and therefore portrayed gambling as a solution to financial concerns