This work sits behind a wall for a reason. It has its own brand, its own teams and its own approval chains, and every capital-markets client is told it exists before they sign anything.
Why this sits behind a wall
A firm that advises listed companies and also runs political campaigns has an obvious problem. We would rather set out how we manage it than let a client find out from somebody else.
The practice runs under a distinct brand, with separate teams, separate systems and separate approval chains. Staff working on a campaign mandate do not work on capital-markets accounts during that mandate, and the two sides do not share monitoring dashboards, client files or correspondence.
Every capital-markets client is told this practice exists before they engage. If we take a political mandate during their engagement, they may terminate without penalty within thirty days of being informed. That right is written into the engagement letter rather than offered on request.
We accept one client per constituency, and one party per state. Not as a service promise — as a limit on how much of this work we are willing to hold at once.
The three constraints
Election Commission instruction No. 491/SM/2013/Communication of 25 October 2013 holds that social media websites are also electronic media by definition, so the pre-certification requirement applies to advertisements placed on them. The Commission's order of 20 March 2026 extends that coverage to e-papers and to bulk SMS and voice messages. We track certification status per asset, per platform, before release.
ECI 491/SM/2013 · MCMCThe Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules 2026, G.S.R. 120(E), notified 10 February 2026 and in force from 20 February 2026, place labelling duties on intermediaries. The rule that binds parties and candidates directly is ECI advisory 4/Misc/2025/SDR/Vol.XX of 24 October 2025, which carries a display-area requirement. We label to the ECI standard, because it is the stricter of the two.
G.S.R. 120(E) · ECI advisorySection 126 of the Representation of the People Act 1951 runs for the forty-eight hours ending with the hour fixed for the conclusion of poll. On the statutory text it covers display by cinematograph, television or other similar apparatus; social media is not statutorily named, and the Commission bridges that gap administratively. We treat social media as covered, and plan the calendar on that basis.
RP Act 1951, s.126
What we do
The scope is deliberately narrow. We run the listening, the rapid response and the compliance record — and we build the record while the campaign is running, not afterwards when somebody asks for it.
Field-facing
Continuous listening across the constituencies in scope, in the languages actually spoken there, with a response route that a named person controls.
Staffed by a team that works on nothing else during the mandate.
Audit-facing
The part that decides whether a campaign is defensible afterwards. Certification tracked per asset, expenditure logged as it is incurred, and every synthetic asset labelled at the point it is made.
Records are handed over complete at close-out.
The boundary
These are refusals, not preferences. We do not generate synthetic likenesses or voices of any person other than the client and their authorised representatives — never of opponents, never of journalists, never of officials — regardless of how the request is framed, and regardless of whether the output would be labelled. We do not run unattributed accounts or astroturfed networks of any kind. We do not place content during the silence period. We decline more of this work than we accept, and we say so at the first meeting so that nobody spends a month finding out.
Engagement basis
This practice is not sold on a retainer. Each mandate is scoped as a project with a defined start, a defined end and a close-out that hands the records across.
We do not take a campaign mandate on a scale that would make the firm dependent on it. A practice that needs the next election to arrive is a practice that will eventually accept the wrong brief.