Advertising & Influencer Ethics Policy

1. Purpose & Core Commitment

At TOTEM Worldwide Ltd ("TOTEM," "the Agency," "we," "us," or "our"), we operate at the intersection of luxury, fashion, entertainment, sport-performance, and lifestyle communications. Our campaigns, partnerships, and activations rely on trust, creative authenticity, and commercial transparency.

This Advertising & Influencer Ethics Policy establishes the mandatory standards governing all promotional campaigns, talent endorsements, PR seedings, showroom sample loans, and social media activations orchestrated by TOTEM on behalf of our brand and talent clients. We require our internal teams, contracted talents, brand ambassadors, talent agents, and brand partners to adhere strictly to the rules set out below.

2. Regulatory Compliance Framework

TOTEM operates with cross-border reach across the United Kingdom, France, the European Union, and international markets. All commercial communications executed by or through the Agency must comply with the prevailing statutory and self-regulatory advertising standards of the jurisdiction in which the audience is targeted:

• United Kingdom: The UK Advertising Standards Authority (ASA), the Committee of Advertising Practice (CAP Code), the Competition and Markets Authority (CMA) guidance on consumer protection, and the Digital Markets, Competition and Consumers Act.
• France: Law No. 2023-451 of 9 June 2023 to regulate commercial influence and combat abuses by influencers on social networks (Loi Influenceurs), the French Consumer Code (Code de la consommation), guidance from the General Directorate for Fair Trading, Consumer Affairs and Fraud Control (DGCCRF), and the recommendations of the ARPP (Autorité de Régulation Professionnelle de la Publicité).
• United States & International Reach: The Federal Trade Commission (FTC) Guides Concerning the Use of Endorsements and Testimonials in Advertising (16 CFR Part 255) and the European Union Unfair Commercial Practices Directive (UCPD).

3. Commercial Transparency & Mandatory Disclosures

Commercial marketing communications must be instantly recognizable as such to the consumer. Content must never mislead an audience into believing it is an organic, non-commercial recommendation.

A. The Requirement to Disclose

A clear commercial disclosure is legally required whenever there is any commercial relationship, reciprocal value, or incentive between the client/TOTEM and the talent/creator, including:

• Monetary compensation (fees, retainers, performance bonuses);
• Free or gifted products, sample drops, or press packages;
• Loaned garments, jewelry, or couture pieces for fittings and appearances;
• Free or subsidized travel, flights, luxury hotel stays, event access, or hospitality;
• Affiliate tracking links, discount codes, or sales commissions;
• Ownership, equity, or formal advisory roles in the featured brand.

B. Standardized Disclosure Labels by Market

1. United Kingdom & International (English-Language Content)

• Accepted Labels: Must prominently display #Ad, [Ad], or Paid Partnership.
• Placement: The label must be visible upfront—before the user clicks "more" or scrolls down. On video formats (TikTok, Reels, YouTube Shorts), the identifier must appear on-screen within the video itself or via built-in platform paid partnership tags.
• Prohibited Ambiguity: Vague abbreviations such as #sp, #spon, #collab, #partner, #ambassador, #pr, or burying disclosures in a cluster of generic hashtags at the end of a caption are strictly prohibited.

2. France & Francophone Target Audiences

Under French statutory law (Loi n° 2023-451), the legal requirements for commercial influence are strictly codified:

• Mandatory Terminology: All commercial influence content targeted at the French market must explicitly include either:
• Publicité (Advertising); or
• Collaboration commerciale (Commercial Collaboration).
• Display Criteria: The statutory disclosure must be clear, legible, and identifiable during the entire duration of the promotion (e.g., permanently visible across all video segments, Stories, or live broadcasts, rather than flashing for a fraction of a second).

4. Retouched Imagery, Virtual Avatars & AI Disclosures

In alignment with luxury standards and statutory European consumer legislation:

• Image Retouching & Silhouette Modification (French Law Requirement): In accordance with Article 5 of French Law No. 2023-451, any photo or video where the face or silhouette of the talent/creator has been modified, edited, or filtered using image-processing software must carry the clear and legible mention:

Images retouchées (Retouched Images).

• Synthetic Content & AI Avatars: Any visual or audio content created or altered using artificial intelligence technologies (including synthetic models or virtual influencers) must carry the clear and legible mention:

Images virtuelles (Virtual Images).

• Cosmetic & Performance Authenticity: Campaigns must never use artificial visual effects, digital skin smoothing, or false eyelashes to exaggerate the performance or results achievable by a client’s cosmetic, beauty, or skincare product.

5. Product Gifting, Seeding & Showroom Sample Loans

TOTEM manages VIP dressing suites, fashion showrooms, and PR product seeding. We maintain a clear distinction between contractual partnerships and editorial seeding:

• Unsolicited Press Gifting: Sending a complimentary product or showroom look creates no contractual obligation for the recipient to post, review, or mention the brand.
• Gift Disclosure Rule: If a creator, stylist, or VIP chooses to feature, wear, or showcase a gifted product or access granted via TOTEM, they must disclose the commercial origin clearly to their audience using tags such as #Gifted / Produit offert or by explicitly stating that the items were provided by the brand.
• Sample Custody & Loans: Garments, jewelry, shoes, and runway pieces loaned for specific red-carpet appearances or editorial shoots remain the property of the client or agency. Where an appearance is supported by a brand loan, credits must accurately reflect the arrangement without misleading the public into assuming an uncompensated endorsement.

6. Honest Opinions, Objective Claims & Anti-Greenwashing

• Authentic Experience: Talent and creators engaged by TOTEM may only endorse products or services they have genuinely used and experienced. Opinions expressed must be honest and represent the true belief of the individual.
• Substantiation of Claims: Creators must not make objective claims regarding product performance, clinical efficacy, medical benefits, or technical capability unless those specific claims have been supplied and scientifically substantiated in writing by the brand client.
• Environmental & Sustainability Claims (Anti-Greenwashing): In compliance with the UK CMA Green Claims Code, French climate legislation (Loi Climat et Résilience), and EU directives:
• Terms such as "eco-friendly," "sustainable," "carbon-neutral," or "clean" must not be used in advertising copy unless supported by robust, verifiable life-cycle evidence.
• Commercial claims must never present statutory legal minimums as unique environmental innovations.

7. Sector-Specific Restrictions & Prohibited Activations

TOTEM enforces strict guardrails around high-risk and legally restricted consumer sectors:

• Cosmetic Surgery & Invasive Procedures: Under French law and UK CAP guidelines, commercial influencers are strictly prohibited from promoting cosmetic surgery, medical procedures, or unregulated aesthetic injections.
• Alcohol & Controlled Substances: Activations involving alcoholic beverages must strictly comply with the UK CAP Code (responsible drinking, age-gating, never linking alcohol to social or sexual success) and the French Loi Évin (strictly factual information regarding origin, composition, and production, accompanied by the mandatory health warning: "L'abus d'alcool est dangereux pour la santé, à consommer avec modération"). Promotions must never target or feature individuals under the legal drinking age.
• Financial Products & Crypto-Assets: TOTEM does not orchestrate creator promotions for unregulated financial products, binary options, forex speculation, or non-compliant cryptocurrency/NFT assets.

8. Minor Protection & Young Talent Safeguarding

When conducting campaigns involving talents under the age of 18:

• French Child Influencer Law (Loi Studer / Loi n° 2020-1266): For activations within French jurisdiction featuring minors, TOTEM ensures all statutory prefectural authorizations (agrément préfectoral) are obtained, working hour limits are enforced, and mandatory revenue deposits with the Caisse des Dépôts et Consignations are respected.
• UK Safeguarding Standards: All engagements with child talent adhere to local authority licensing rules, mandatory chaperone oversight, and strict privacy protections.
• Content Targeting Minors: Commercial communications directed at children must not exploit their credulity, vulnerability, or lack of experience, nor encourage them to pressure parents into purchases.

9. Follower Authenticity & Anti-Fraud Standards

TOTEM operates with data integrity across our PR and talent intelligence tools (including Launchmetrics):

• Ban on Artificial Engagement: Contracted talent and creators must build their audiences organically. The purchase of fake followers, automated bot traffic, comment pods, or engagement manipulation is a material breach of our operational standards.
• Metric Verification: TOTEM conducts regular data integrity audits before recommending talent to clients, verifying audience authenticity, engagement health, and demographic alignment.

10. Governance, Contractual Enforcement & Contact

• Mandatory Inclusion in Talent Agreements: These ethical and disclosure standards are incorporated directly into every talent agreement, booking rider, and campaign brief issued by TOTEM.
• Enforcement: Failure to provide required disclosures, tampering with required notices, or breaching applicable advertising laws constitutes a material breach of contract, empowering TOTEM to demand immediate content remediation, withhold talent fees, or terminate the engagement for cause.
• Questions & Compliance Inquiries: For questions regarding our advertising standards, compliance vetting, or campaign practices, contact:

TOTEM Worldwide Ltd, ATTN: Ethics & Compliance Desk

Email: hello@totemworldwide.co

Website: www.totemworldwide.co