Extract from ICAEW marketing ethics guidelines: WHAT FIRMS MUST NOT DO When undertaking marketing or promotional activities, firms must not bring the profession into disrepute (paragraph R115.2 of the ICAEW Code of Ethics). Specifically, firms must not do the following within their advertising (note that this is not intended to be an exhaustive list). Make disparaging statements Firms must not say anything in their promotional material that is disparaging of or discredits the practice or services of others. For example, it would not be acceptable to say we provide a better service than X firm in London even if such a statement is objectively and demonstrably true. It would, however, be acceptable to say we pride ourselves on the service we provide. Make unsubstantiated claims of size or superiority Firms should be careful not to make claims that they cannot substantiate. Firms should make it clear on what basis any claim is being made and ensure that it is justified. For example, if a firm claims to be the leading or most widely-used accountancy practice in a given area, they should make it clear on the face of the promotional material the basis or information on which the claim is made. We advise utmost caution in this respect. Make exaggerated claims Firms shall not make exaggerated claims for services offered, qualifications possessed, or experience gained. Firms should ensure that claims made are appropriately substantiated, justifiable and not misleading in any way. Make unsubstantiated comparisons Firms shall not make unsubstantiated comparisons to the work of another. Where firms intend to make comparisons, they should ensure that such comparisons: Are objective and not misleading; Relate to the same services; Are factual and verifiable (firms should have supporting documentation); and Do not discredit or denigrate the practice or services of others. Harass a potential client As outlined in paragraph R115.3 of the ICAEW Code of Ethics, services must not be promoted in such a way, or to such an extent as to amount to harassment of a potential client. The term harassment has not been defined in the code. One or two follow-up mailshots to a non-client over a reasonable period of time might not, by themselves, amount to harassment. However, repeated telephone calls or visits to a prospective client who is clearly not interested could result in a complaint. Although such a complaint would need to be supported by evidence that the recipient was subject to actual harassment, you should be sensitive to the fact that some people are more likely to feel harassed than others. Firms should also be reminded that where consent is being relied upon as the lawful basis for processing personal data, under the GDPR such consent can be withdrawn at any time and where an individual withdraws consent they should not be contacted with further marketing materials. For direct marketing, opt outs must also be clear and should be adhered to.