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Transparency Policy

At Omorodion Holdings Limited ("Omorodion", "we", "us", or "our"), transparency is at the center of how we market our own services and communicate with our B2B clients about their website and mobile application projects. This Transparency in Marketing and Client Communications Policy (this "Policy") sets out the principles we follow to keep our marketing honest, clearly labeled, and respectful of the people who see it, and our project communications accurate and complete.

This Policy applies to our own marketing of Omorodion's services, to the project reporting and client communications we produce in the course of our engagements, and to everyone who works for or represents Omorodion, including employees, contractors, and freelance partners. It works alongside our Terms of Use, Privacy Policy, and Code of Conduct, which address related obligations in more detail.

1. Our Commitment to Transparency

We believe marketing and client communication work best, and last longest, when they are honest. We are committed to ethical, transparent, and fair marketing practices in everything we produce, and to compliance with applicable advertising, consumer protection, and data protection law in every market where we operate. Trustworthy communication is not a constraint on good marketing - it is what makes our own brand, and the products we build for clients, worth trusting.

2. Truthful and Accurate Marketing

All advertising and marketing communications we create or publish about our own services must be clear, truthful, and free from misleading or deceptive claims. In particular:

  • claims about our capabilities, technical expertise, timelines, or past results must be substantiated by fact before they are published;

  • pricing, service scope, and contractual terms must be described completely and accurately, with no hidden costs, fine print, or unexpected conditions;

  • testimonials, case studies, and portfolio examples used in our marketing must reflect genuine, verifiable work and outcomes, not cherry-picked, exaggerated, or fabricated results, and must only be published with the relevant client's consent;

  • screenshots, statistics, and performance figures used in our marketing must fairly represent the underlying facts, without manipulation intended to mislead.
     

3. Review and Approval of Marketing Content

Before any marketing or promotional material about Omorodion is published, it goes through an internal review to confirm it is accurate, properly substantiated, and compliant with applicable law and advertising standards. This review also checks that required disclosures (see Sections 5 and 6) are present and clearly visible.

No one may bypass, rush, or otherwise circumvent this review process. Publishing marketing content without required approval, or knowingly submitting inaccurate information for review, is a violation of this Policy.

4. Fair and Honest Competitive Claims

Where our marketing compares Omorodion to a competitor, the comparison must be accurate and substantiated at the time it is published. We do not make false, misleading, or disparaging statements about a competitor's products, services, financial condition, or regulatory standing. We win business by demonstrating our own strengths, not by undermining others.

5. Disclosure of Sponsored Content, Partnerships, and Material Connections

Audiences have a right to know when content is paid, sponsored, or produced as part of a commercial relationship. Where we create or place sponsored posts, paid partnerships, affiliate links, or native advertising promoting Omorodion, we ensure it is clearly and conspicuously labeled as such (for example, "Ad," "Sponsored," or "Paid Partnership"), consistent with applicable advertising law and the disclosure requirements of the platform on which it appears.

Where content is generated in whole or in part using generative artificial intelligence, we disclose that fact where required by law, client agreement, or platform policy, and we review AI-assisted content for accuracy before publication, consistent with our Code of Conduct.

6. Transparency in Data-Driven and Targeted Advertising

Where we use audience data and platform targeting tools to market our own services to relevant business decision-makers, we do so only using data obtained and used in compliance with applicable law and the relevant platform's policies, and we provide accurate disclosures about how targeted advertising works and how it can be controlled (for example, through platform ad-preference tools).

We do not engage in deceptive targeting practices, such as concealing the commercial nature of a message or targeting audiences in a way designed to exploit a lack of understanding of how the advertising is generated or funded.

7. Client and Consumer Data Privacy in Marketing

Marketing activities that involve personal data, whether our own prospect data or data processed on behalf of a client, must comply with applicable data protection law, including the GDPR, and with our Privacy Policy. We respect individuals' privacy preferences and consent choices, honor opt-out and unsubscribe requests promptly, and do not use personal data for marketing purposes beyond what is disclosed and permitted. Misuse of personal data in connection with marketing is treated as a serious breach of this Policy.

8. Transparency in Fees, Project Costs, and Vendor Relationships

We are transparent with clients about our fees, the hosting and third-party costs we manage on their behalf, and any rebates, credits, or other value we receive from vendors or platforms in connection with client spend, in accordance with the terms of the applicable Service Agreement. Undisclosed commissions or kickbacks that could influence vendor recommendations to a client's detriment are not permitted, consistent with our Code of Conduct.

9. Accurate Project Status Communication

Clients rely on us to communicate project status, timelines, risks, and technical issues accurately and promptly. We do not conceal delays, defects, or scope changes from clients, and we escalate material issues to the client as soon as reasonably practicable rather than after the fact.

10. Enforcement and Reporting Concerns

Violations of this Policy may result in disciplinary action, up to and including termination of employment or engagement, and, where a client project is involved, corrective action with the affected client. Employees, contractors, and partners who become aware of marketing or client communications that may violate this Policy, including misleading claims, missing sponsorship disclosures, or misuse of personal data, should report it confidentially to our Compliance contact below.

Email: info@omorodion.org

Reports made in good faith are protected from retaliation, even where an investigation does not substantiate the concern. We review this Policy periodically and may update it to reflect changes in advertising law, platform requirements, or our own practices; the "Effective Date" above reflects the date of the current version.

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