Branded Content & Sponsorship Disclosure

Media.com permits branded content, sponsorships, endorsements, affiliate relationships and other forms of commercial publishing.

This Policy establishes when commercial relationships must be disclosed and how those disclosures must be made.

It is intended to ensure that people can distinguish independent content from content influenced by a commercial relationship.

This Policy should be read together with the Media.com Rules of Engagement and other applicable Trust Center policies.

This Policy applies to content published, uploaded, streamed or otherwise distributed through Media.com by individuals and organizations.

It applies to all supported content formats, including:

• Shorts;
• videos;
• posts;
• articles;
• Newsroom publications;
• statements;
• audio;
• live content;
• comments where used commercially;
• links and recommendations; and
• other publishing formats introduced by Media.com.

It applies whether a commercial arrangement was organised directly, through an agency, through an affiliate network or through another intermediary.

For the purposes of this Policy, Branded Content is content that features, promotes, discusses, recommends or otherwise relates to a person, organization, product, service or commercial interest where the publisher has received, expects to receive or may receive something of value in connection with the content.

Something of value can include money as well as non-cash benefits.

A disclosure is required where there is a relationship that could reasonably affect how an audience understands the content, recommendation or endorsement.

Examples include:

Where the publisher receives money to create, publish, feature or distribute content.

Where a person or organization financially supports content, a series, event, project or publisher in return for exposure, association or other commercial benefit.

Where products or services are provided free of charge or substantially discounted in connection with possible coverage or promotion.

Where flights, accommodation, meals, tickets, entertainment, experiences or hospitality are provided.

Where the publisher may receive a commission or other benefit from clicks, registrations, purchases or other actions.

Where the publisher has an ongoing commercial relationship with a brand, even if there is no separate payment for the particular publication.

Where the publisher works for, controls, owns, manages or has another significant commercial interest in the organization or product being promoted and that relationship would not otherwise be apparent.

Where the publisher has a material financial interest that could benefit from promotion of the subject of the content.

Other Media.com policies may impose additional disclosure requirements for financial content.

Where a close relationship with a business owner, advertiser or other relevant party could materially affect the audience's understanding of an endorsement and the relationship is not otherwise apparent.

Any prize, credit, preferential treatment, future benefit or other consideration offered in connection with publishing or promoting content.

Disclosure is required whenever a material commercial relationship exists and would not already be sufficiently clear to an ordinary person encountering the content.

Users should disclose when uncertain.

The fact that:

• the publisher genuinely likes the product;
• the publisher would have discussed it anyway;
• the sponsor did not review the content;
• no specific wording was required;
• only a small amount of money was paid;
• the product was inexpensive;
• the relationship is disclosed elsewhere on the publisher's profile; or
• followers may already know about the relationship

does not, by itself, remove the requirement to disclose.

Where the publishing interface provides a Branded Content, Sponsorship, Commercial Relationship or equivalent disclosure control, publishers must use it.

Media.com may require the publisher to:

1. confirm whether a commercial relationship exists;
2. identify the sponsoring or benefiting party;
3. identify the type of relationship;
4. provide additional information where required; and
5. confirm that the content complies with this Policy.

Media.com may then display an appropriate disclosure on the publication.

Possible disclosures include:

• Paid Partnership with [Organization]
• Sponsored by [Organization]
• Gifted by [Organization]
• Hosted by [Organization]
• Affiliate Relationship
• Commercial Relationship

Media.com may change the wording or presentation of disclosure labels to improve clarity.

A disclosure must be sufficiently prominent that a reasonable user is likely to see, hear or understand it when encountering the commercial content.

A disclosure must not be:

• hidden after a "more" or expansion control where reasonably avoidable;
• placed only at the end of content;
• obscured by graphics or interface elements;
• displayed too briefly to be understood;
• buried amongst hashtags;
• placed only on a publisher's profile page;
• available only through a separate link; or
• otherwise presented in a way designed to reduce its visibility.

Publishers must activate the Media.com commercial relationship disclosure where available.

Where the commercial relationship is central to the video, the relationship should also be made clear visually, verbally or through another prominent method within the content where necessary.

A disclosure should appear at or near the beginning when sponsorship applies to the publication generally.

Where only part of a video is sponsored, disclosure must occur before or when the sponsored portion begins.

A disclosure should be positioned prominently near the title, byline, introductory section or before the relevant commercial recommendation.

A disclosure solely at the end of an article will generally not be sufficient.

Where audiences may consume content without viewing the screen, relevant sponsorship should be disclosed audibly.

Commercial relationships should be disclosed at the beginning of a live publication and repeated when reasonably necessary so that users joining later can understand the relationship.

Affiliate disclosures should appear sufficiently close to the recommendation, link or commercial call to action.

A general disclosure elsewhere on the publisher's account is not sufficient.

Disclosure language must be clear and understandable.

Examples include:

• "Advertisement"
• "Ad"
• "Sponsored"
• "Sponsored by [Brand]"
• "Paid partnership with [Brand]"
• "I was paid by [Brand] to create this content."
• "This product was provided to me free of charge."
• "Gifted by [Brand]."
• "This trip was hosted by [Brand]."
• "I may earn a commission if you purchase through this link."

Publishers may use different wording where it communicates the relationship equally clearly.

Terms that merely suggest a relationship without explaining its commercial nature may be insufficient.

Examples include:

• "sp";
• "spon";
• "collab";
• "collaboration";
• "partner";
• "brand partner";
• "thanks";
• "thanks to";
• "ambassador";
• "client";
• tagging the sponsor without further explanation; or
• merely displaying a brand logo.

Context will be considered, but publishers should favour clarity over shorthand.

Commercially supported content must remain truthful.

Publishers must not:

• claim personal experience they have not had;
• state that they use a product when they do not;
• make a positive statement they do not genuinely hold where presented as personal opinion;
• fabricate testimonials;
• misrepresent results;
• omit qualifying information where doing so would materially mislead people; or
• make factual claims that cannot reasonably be substantiated.

A sponsor must not require or encourage conduct prohibited by this section.

Businesses, sponsors and agencies using Media.com must take reasonable steps to ensure sponsored publishers understand applicable disclosure requirements.

They must not:

• instruct publishers to hide a commercial relationship;
• prohibit legally or contractually required disclosures;
• request misleading testimonials;
• reward publishers specifically for withholding disclosure;
• encourage the use of ambiguous disclosure terminology; or
• structure an arrangement for the purpose of circumventing this Policy.

Media.com may take action against both the publisher and sponsor where appropriate.

An organization publishing information about its own products or services will not ordinarily need to label every publication as sponsored where the commercial relationship is obvious from the identity of the publisher.

However, additional disclosure may be required where the relationship would otherwise be unclear.

For example, an individual recommending a company they own, work for or have invested in may need to disclose that relationship if it would not be apparent to the audience.

Publishers should not create the false impression that commercially interested commentary is independent.

Publishers may accept sponsorship for:

• journalism;
• interviews;
• documentaries;
• podcasts;
• events;
• series;
• newsletters;
• Newsroom content; and
• other editorial projects.

Sponsorship must not be presented as independent editorial activity where the sponsor has provided consideration.

If a sponsor exercises material editorial control, that relationship should be disclosed where necessary to prevent audiences from being misled about the independence of the content.

Publishers may review products or services supplied by brands.

Receiving a product does not automatically make a review prohibited.

The relationship must nevertheless be disclosed.

Publishers must remain truthful about their experience and must not describe a review as independent, impartial or unbiased where contractual arrangements materially compromise that independence.

Users participating in affiliate, referral or revenue-sharing programs must disclose that they may benefit from the audience's action.

Media.com may require affiliate URLs or commercial links to carry additional platform labels.

Publishers must not disguise affiliate links for the purpose of avoiding disclosure.

Branded content remains subject to all other Media.com policies.

Some industries, products or services may be:

• prohibited;
• restricted;
• age-restricted;
• geographically restricted;
• subject to additional verification; or
• subject to additional disclosure requirements.

A sponsorship relationship does not override those restrictions.

Media.com may impose stricter requirements for categories including financial services, health products, gambling, alcohol, political activity or other regulated products and services.

Commercial content involving or directed toward children may be subject to additional restrictions.

Publishers and sponsors must not exploit a child's limited ability to recognise advertising or commercial persuasion.

Media.com may prohibit or restrict branded content involving minors even where the content might otherwise comply with this Policy.

Sponsored political, electoral, governmental or issue-based communications may be subject to separate Media.com requirements and applicable laws.

Publishers must not use branded content arrangements to conceal who paid for political or issue-based messaging.

Media.com may require additional sponsor information, disclaimers, geographic restrictions or verification.

Users must not deliberately design commercial content to make advertising appear to be independent commentary.

Prohibited practices include:

• fake independent reviews;
• fabricated customer testimonials;
• undisclosed paid advocacy;
• paying third parties to recommend a product while requiring them to conceal payment;
• secretly funding supposedly independent publications; and
• coordinated commercial campaigns designed to conceal the identity of the sponsor.

Branded Content is distinct from advertising purchased through Media Ads.

Where content is published organically through a Media.com profile but involves a commercial relationship, this Policy applies.

Where exposure is purchased through Media Ads, the applicable advertising policies also apply.

Users must not use branded content, organic publishing or sponsorship arrangements to circumvent Media Ads restrictions.

Publishers are responsible for determining whether their content requires disclosure.

Sponsors, advertisers, agencies and other commercial participants may also be responsible for their participation.

Compliance with Media.com's disclosure tools does not replace any additional obligations imposed by applicable law.

Where local law requires a higher standard than this Policy, users must comply with that higher standard.

Where content does not comply with this Policy, Media.com may take one or more actions, including:

• adding or correcting a disclosure;
• requesting that the publisher amend the content;
• reducing or removing monetization functionality;
• limiting distribution;
• removing commercial links;
• restricting branded content functionality;
• removing the publication;
• restricting the sponsor's ability to participate in branded content;
• suspending monetization;
• restricting or suspending an account; or
• taking other action permitted under our Terms and policies.

Media.com may consider factors including:

• severity;
• audience impact;
• whether the omission appears intentional;
• previous violations;
• whether the content concerns a regulated product;
• whether the publisher corrected the issue promptly; and
• the risk of users being materially misled.

We may take stronger action where a publisher or sponsor repeatedly fails to disclose commercial relationships or deliberately attempts to conceal them.

Systematic undisclosed advertising may result in loss of branded content privileges, monetization restrictions or account suspension.

Media.com may independently apply a commercial content label where information available to us indicates that a material commercial relationship exists.

Applying a disclosure does not imply that Media.com endorses the sponsor, publisher, product or claims contained in the publication.

Users may report content they believe contains undisclosed sponsorship, advertising, affiliate relationships or other commercial influence.

Media.com may consider:

• the content itself;
• information supplied by the reporter;
• public information about the relationship;
• information provided by the publisher or sponsor; and
• other relevant evidence.

A commercial relationship will not be presumed solely because a publisher expresses a positive opinion about a product or organization.

Media.com does not prohibit people from being paid to create content.

We require audiences to be told when it happens.

Commercial relationships should be transparent enough that people can understand the interests behind the content and decide for themselves what weight to give it.

Version 1.0 is the initial standalone Branded Content & Sponsorship Disclosure Policy.