After looking into this it appears that JMI VENTURES LTD is the 3rd party you are referencing. It appears it is JMI VENTURES LTD, that is in the wrong hear as I have found multiple sites that have disclosures regarding money paid for promotion. Bennie and the example below both followed the requirement of reporting the transaction. http://smallcapir.com/our-new-small-cap-feature-alert-is-a-high-growth-low-float-clean-tech-company/