Introduction is not the same as advice
A referral may be limited to sharing approved factual information and introducing an interested person to the service provider. Recommending a particular financial product, influencing a product decision or arranging a transaction can raise different licensing and conduct issues.
Partners should not assume that a disclaimer fixes conduct that goes beyond their approved role. The substance of the communication is what matters.
Core responsibilities
- Use only current, approved marketing material
- Describe the relationship and role accurately
- Disclose remuneration or other benefits where required
- Avoid profit, approval or preferential-treatment promises
- Escalate product, advice and complaint questions to the authorised team
- Keep required records of communications and referrals
What a partner programme should document
A sound programme begins with due diligence and a written agreement. It should define permitted markets, approved channels, restricted statements, client handover, privacy handling, training, monitoring, payment terms and termination rights.
- Who may be approached
- What information may be shared
- How consent and personal information are handled
- How promotional content is approved
- How conduct is monitored and issues are reported
A long-term partnership standard
Sustainable referral relationships are built on accurate expectations and clear responsibilities. Volume does not replace suitability, due diligence or compliant communication. Requirements can differ by jurisdiction, so legal advice may be appropriate before activity begins.