Fairness and integrity

Principle #1

Implementation guidance

1.1 Fair marketing


Promote offers clearly and fairly to customers by representing key product characteristics, including safeguards and potential risks. Avoid pressurising customers or using manipulation tactics.

A provider must treat customers fairly and act with integrity, from information and service provision through to transaction completion.

Provide objective information:

  • Offer fair and clear information about key product characteristics in your marketing materials or product promotions.
  • Don’t misrepresent your own or competing products.
  • Present offerings in a balanced way when comparing them to other products.

Disclose all material facts:

  • Do not omit, disguise or misstate the key risks.
  • Make sure that you disclose the central legal parameters related to the offering.

Do not pressurise investors:

  • Refrain from using hard sales tactics and scare-mongering at all times.

1.2 Education and support


Provide customers with relevant education or training about your products or platforms, as well as on gold as an asset class in general. Be reachable for your clients and offer support, where necessary.

Provide customer training:

  • Offer investors educational material on gold as an asset class or point them to other credible information sources.
  • Educate potential customers through online tutorials and FAQ sections on topics such as how to buy and sell gold.

Ensure staff availability:

  • Ensure that customers can contact support staff via email and phone during standard office hours, at a minimum.

1.3 Fair pricing and fees


Charge fair prices and ensure that all fees are appropriate. Provide customers with sufficient information so that they can understand and assess prices properly.

Fee types:

  • Ensure that the type of fees you charge and costs levied are fair and aligned with local market practices.
  • Treat your customers consistently, i.e. do not discriminate any customers, e.g. based on their lack of market knowledge.

Price level:

  • Ensure your charges are generally fair and aligned with local market prices for comparable products or services.


  • Disclose the price and time of executed trades.
  • Provide sufficient information to allow customers to calculate the overall premium that they will pay on top of the basis price for gold.

1.4 Fair trading and settlement


Optimise liquidity and prices for customers. Be clear about transaction completion, settlement times and terms. Minimise related risks for customers.

Counterparties and trading prices:

  • Maximise liquidity and optimise prices for investors, e.g. by trading with large and multiple suppliers.

Settlement time and risk:

  • Provide investors with transparency on settlement times and terms, such as whether positions can be closed before final settlement or what happens if a transaction fails or is cancelled.
  • Minimise settlement risks, e.g. by ensuring that operating models have been appropriately configured and reviewed.