Formal Request to Tradedoubler

[Qui Gon Jinn]

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After careful consultation between the moderators, this is a polite formal request to Tradedoubler to ascertain which programs within your network have closed brand bidding groups, and ask to please submit these to the forum & include within the merchant information details within their own interface.

This will assist towards transparency & a fairer environment for affiliates.

Please could you also confirm that you don't do any ppc at network or employee level, or at least don't make themselves members of closed groups at the same time?

We'd be grateful if you could supply this information and help alleviate some of the issues that have arisen due to closed group activity.

Thank you for your co-operation.

[TD Nick]

The following advertisers are currently working with strategic affiliates on either their trademark and/or trademark with related keyword searches:

Dell
Apple
Amex
Ann Summers
Brittish Gas
Mcafee
Post Office
Direct line
Opodo
Figleaves
P&O
BT Shop
Post Office
AOL
Cahoot
Prudenital Health
Jessops

TradeDoubler in the UK do not undertake any paid search activity on behalf of our advertisers and neither do we own any online media or other online properties.

As I understand a few of our smaller international markets (e.g. Poland/Russia) do support advertisers in an official transparent agency format on paid search campaigns to get markets or programs kick-started but TradeDoublers group policy is to always outsource to experts, either professional SEM affiliates or professional SEM agencies.

To our knowledge, from the signed policy which you can see at the foot of this post, no TradeDoubler employee uses any form of paid search for any advertisers on our network.

However there are a few employees who started this week who have not yet signed the policy and as soon as this has been signed (next 30-40 mins) we will post back reiterating this position.

Please read our policy on our staff operating affiliate aco****s.

TradeDoublers RFP Process for Paid Search Activity

TradeDoubler are proud of being the first network to put in an official Request For Proposal process for any strategic search activity on trademark terms. Because our RFP process is only open to paid search affiliates who have also signed our Paid Search Code of Conduct we also know each and everyone of the paid search affiliates involved in groups personally.

Naturally TradeDoubler employees are not allowed to be in any brand groups or have any trademark/brand privileges whatsoever - our RFP process ensures this.

This creates a fair, transparent pitch process for all of our paid search affiliates who decide to pitch. The successful paid search affiliates also meet with the advertiser on a regular basis and typically all of the affiliates involved in the group join on weekly conference calls.

Internal policy for employees operating an Affiliate Account with TradeDoubler

TradeDoubler allows its employees to register as an affiliate with TradeDoubler and to set up their own homepages with the purpose of understanding working processes, evaluating customers, programs, graphical elements, etc. If an employee wants to work as an affiliate, all actions in this matter must be taken outside office hours.

If working as an affiliate, the employee may not use any internal information or processes, including but not limited to, information gathered from PAN, change segment, error checks and the approval process, i.e., any activity that creates an advantage vs. “external” affiliates. This follows directly from the confidentiality clause stated in the employment agreement and/or by local law. For the avoidance of doubt, the employee may still use information that “external” affiliates have access to.

If an employee or a person closely related to the employee is working as an affiliate with TradeDoubler, the employee is obligated to inform his/her Country Manager and Human Recourses Dpt about this activity. Internal information (as described above) may of course not be disclosed to relatives or other third parties.

TradeDoubler is allowed to view the accounts of the employee on a regular basis to secure that all employees comply with this policy.

While on assignment for a specific advertiser and three months thereafter, neither the employee nor any other person closely related to the employee, may work as an affiliate for that advertiser.

If the employee’s income from operating an affiliate account exceeds Euro 1.000 per month (including the income generated by the employee’s relative’s accounts), the aggregate amount shall be reported to HR on a monthly basis.

Failure to comply with this policy will be considered as disloyalty against the employer and will lead to disciplinary actions from TradeDoubler.


Internal policy for employees operating an Affiliate Account with TradeDoubler

The employee confirms that he/she has read, understood and will follow the ‘Internal policy for employees operating an Affiliate Account with TradeDoubler’ policy and the guidelines set out herein. He/she understands that failure to comply with these guidelines may lead to disciplinary action from TradeDoubler.

TradeDoubler reserves the right to change this policy when changes in law require it and when it is in the best interest of TradeDoubler and/or its employees. Changes will be notified to you and a new policy will be sent by email.

By signing this document the employee confirms that he/she has read, understood and will acknowledge the policy.

Further, the employee hereby also gives his/her consent, as required by local privacy law, to TradeDoubler to treat personal information about the employee’s affiliate account to secure that this policy is followed.

TradeDoubler: UK

Date:

Employee:

Signature

Kind regards,

Nick Roveta

[TD Nick]

Hi all,

I can now confirm all UK employees have signed the Policy.

Have a great weekened,

Nick

[bapages]

I find this poor, I would have expected a network to discourage employees from any affiliate activities as it amount to insider dealing and gaining an unfair advantage.

TradeDoubler allows its employees to register as an affiliate with TradeDoubler and to set up their own homepages with the purpose of understanding working processes, evaluating customers, programs, graphical elements, etc. If an employee wants to work as an affiliate, all actions in this matter must be taken outside office hours. Does this not lead to a conflict of interests?
If working as an affiliate, the employee may not use any internal information or processes, including but not limited to, information gathered from PAN, change segment, error checks and the approval process, i.e., any activity that creates an advantage vs. “external” affiliates. This follows directly from the confidentiality clause stated in the employment agreement and/or by local law. For the avoidance of doubt, the employee may still use information that “external” affiliates have access to. By nature of having contact with information about affiliates, merchants, stats and keywords generated portrays as insider trading to me
If an employee or a person closely related to the employee is working as an affiliate with TradeDoubler, the employee is obligated to inform his/her Country Manager and Human Recourses Dpt about this activity. Internal information (as described above) may of course not be disclosed to relatives or other third parties.

While on assignment for a specific advertiser and three months thereafter, neither the employee nor any other person closely related to the employee, may work as an affiliate for that advertiser. But can they gain access to information?

If the employee’s income from operating an affiliate account exceeds Euro 1.000 per month (including the income generated by the employee’s relative’s accounts), the aggregate amount shall be reported to HR on a monthly basis.

[drivetowin]

I doubt there are any of the major networks who can say hand on heart that none of their employees operate their own affiliate websites - in reality it is nigh on impossible to police.

[TD Nick]

I find this poor, I would have expected a network to discourage employees from any affiliate activities as it amount to insider dealing and gaining an unfair advantage.

TradeDoubler allows its employees to register as an affiliate with TradeDoubler and to set up their own homepages with the purpose of understanding working processes, evaluating customers, programs, graphical elements, etc. If an employee wants to work as an affiliate, all actions in this matter must be taken outside office hours. Does this not lead to a conflict of interests?
If working as an affiliate, the employee may not use any internal information or processes, including but not limited to, information gathered from PAN, change segment, error checks and the approval process, i.e., any activity that creates an advantage vs. “external” affiliates. This follows directly from the confidentiality clause stated in the employment agreement and/or by local law. For the avoidance of doubt, the employee may still use information that “external” affiliates have access to. By nature of having contact with information about affiliates, merchants, stats and keywords generated portrays as insider trading to me
If an employee or a person closely related to the employee is working as an affiliate with TradeDoubler, the employee is obligated to inform his/her Country Manager and Human Recourses Dpt about this activity. Internal information (as described above) may of course not be disclosed to relatives or other third parties.

While on assignment for a specific advertiser and three months thereafter, neither the employee nor any other person closely related to the employee, may work as an affiliate for that advertiser. But can they gain access to information?

If the employee’s income from operating an affiliate account exceeds Euro 1.000 per month (including the income generated by the employee’s relative’s accounts), the aggregate amount shall be reported to HR on a monthly basis.

Hi Steve,

Thank you for the comments; it also gives TD an opportunity to tackle this issue from another perspective.

The TD policy is there to prevent anyone from becoming an affiliate without informing HR, using any internal information and also working for an advertiser and being an affiliate for that advertiser.

The reality is these clauses practically make it impossible for any employee of TD to be an affiliate, which to be fair, is the way we want in the UK.

Also I accept we are going to come under more scrutiny as the UK market leader I am actually very pleased we have this policy with our staff. I would go on to say the information provided above, our position on being an employee and an affiliate, the official policy all staff sign and our Paid Search RFP process puts us in a very trusted and transparent position.

Kind regards,

Nick

[Qui Gon Jinn]

Nick,

We appreciate the comprehensive list you have so far provided, which we hope will be updated periodically & maintaining an open dialogue where some others have so far been some what vague or playing what seems a game of cloak & dagger at best, as if waiting to see what information other networks are forthcoming with. Whereby affiliates can draw their own conclusions on how much or how little a network is transparent (honest) with this simple question may reflect how transparent with other issues of more / less importance.