Rules and ethics
Part of Small business grants: rules and ethics from application to award
Small business grants disclosure policy for a grant-information website
Write a disclosure policy for an England grant-information website covering advertising, affiliate links, advisers, sources, reviews and corrections.
A grant-information website should explain how it earns money, selects opportunities, handles adviser relationships and corrects mistakes. The policy must match what the publisher actually does. A generic statement cannot cure an undisclosed payment beside a recommendation.
What to take away
- A grant-information site must disclose every commercial relationship and match its policy to actual practice.
- Put disclosure near the claim, not just in a site-wide policy, so readers see it where influence occurs.
- Explain editorial selection and keep sponsored positions distinct; payment must not alter factual eligibility or verdicts.
- Name the editorial owner, keep a dated register, and provide a correction route for errors or missing disclosures.
List every commercial relationship
Record advertising, sponsorship, affiliate links, lead-generation payments, paid listings, supplier commissions, free services and ownership interests. Identify who receives the benefit and which content it can affect.
The CMA's reviews and endorsements guidance covers genuine reviews, concealed incentives and responsibilities for creators, brands and review publishers. The ASA and CAP influencer guidance hub provides advertising-disclosure resources.
Put the disclosure near the claim
A site-wide policy is useful, but readers also need a clear label where commercial influence occurs. Place the disclosure before or beside an affected ranking, link or recommendation. Do not hide it after the article or behind vague wording such as "we may work with partners".
Use plain labels that describe the relationship. The exact label should be reviewed against current ASA and CMA guidance and the presentation tested on mobile as well as desktop.
Explain editorial selection
State whether programmes are included because they meet published criteria, pay for placement or both. Keep sponsored positions visually and verbally distinct. Payment must not alter factual eligibility, deadlines or the editorial verdict.
For listicles and reviews, publish the geography, research date, inclusion method, exclusions and evidence used for every named entry. Do not sell positive reviews.
Cover adviser and lead referrals
Explain what happens when a reader submits details or contacts an adviser. Name the organisation receiving the information, the commercial payment where disclosure is required and whether the publisher has assessed the adviser's service.
Do not describe a provider as approved, accredited or government backed without an authoritative record. A paid introduction does not prove quality or grant success.
State the source and update process
Explain that official funder pages control eligibility and deadlines. Give articles a research date and recheck fast-changing schemes. Describe how readers can report an error and how material corrections are recorded.
Assign responsibility
Name the editorial owner who maintains the policy, reviews commercial relationships and resolves conflicts. Require writers and reviewers to declare relevant interests before assignment. Keep a dated register rather than relying on memory.
Suggested policy structure
Use sections for ownership, revenue, advertising labels, affiliate links, lead referrals, editorial independence, review methods, gifts or free access, conflicts, sources, corrections and contact details. Have the wording reviewed for the publisher's actual legal and commercial arrangements.
Use specific wording
Write what happened. "We receive a fee if you contact this adviser through the marked link" gives a reader more information than "some links may be monetised". If payment does not affect inclusion or the verdict, state the control that supports that claim.
Do not promise independence where the commercial team can alter rankings. Change the process first, then describe it accurately.
Keep an editorial register
For each affected article, record the advertiser or partner, benefit, agreement dates, writer, reviewer, placement, label and next check. Link the register to the publication record without exposing confidential contract terms publicly.
Review the page after any commercial change. A disclosure can become false when an affiliate agreement ends, a supplier is acquired or an editor develops a personal interest.
Provide a correction route
Give readers and named organisations a contact route for factual errors or missing disclosures. Log the report, evidence, decision, change and date. A correction should update the article, structured data and any syndicated version where practical.
The public policy should state how material corrections are shown. It should not suggest that an advertiser can suppress a supported criticism or purchase a positive amendment.
This draft contains no live internal links and remains on hold for advertising, consumer-law and data-protection review.
Before you act
- List all commercial relationships and who benefits.
- Place disclosure before or beside affected rankings.
- State if programmes pay for placement or meet criteria.
- Explain adviser referrals and any payment involved.
- Give articles a research date and recheck schemes.
- Record corrections and update the article.
Common questions
Where should a disclosure appear on a grant-information website?
A site-wide policy is useful, but readers also need a clear label where commercial influence occurs. Place the disclosure before or beside an affected ranking, link or recommendation. Do not hide it after the article or behind vague wording such as we may work with partners.
What must a site say about adviser and lead referrals?
Explain what happens when a reader submits details or contacts an adviser. Name the organisation receiving the information, the commercial payment where disclosure is required and whether the publisher has assessed the adviser's service. Do not describe a provider as approved, accredited or government backed without an authoritative record.
How should a site handle corrections and updates?
Give readers and named organisations a contact route for factual errors or missing disclosures. Log the report, evidence, decision, change and date. A correction should update the article, structured data and any syndicated version where practical. The public policy should state how material corrections are shown.