Responsible

Marketing Application Manual

1st edition

Marketing to Youth

1

Introduction

Introduction

The Coca-Cola Company has always taken seriously

its commitment to market responsibly, across the

globe, across all advertising media, and across all of

our beverages. Our Company has been a leader in the

area of Responsible Marketing, particularly with

regard to the marketing practices when children

under the age of 12 years are present. Respecting the

rights of parents and caregivers to make the

appropriate choices for their children is a

cornerstone of our Responsible Marketing Policy.

Responsible Marketing is also part of the four global

business commitments which our Company

announced in 2013 to further contribute to healthier,

happier, and more active communities.

This Application Manual aims to help The Coca-Cola

Company marketers in Europe to self-regulate and

implement their marketing practices in accordance

with the letter and the spirit of the Responsible

Marketing Policy.

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TCCC

Responsible

Marketing Overall Principles

The central principle for all responsible marketing

communications is that they should be scientifically

valid, legal, transparent, truthful and comply with

locally applicable laws and regulations.

Any marketing communication must be obviously

identifiable as such and never be seen as misleading

or ambiguous.

There are 2 further tenets that guide our responsible

marketing:

1) All our marketing content, messaging, design

and placement is created for an audience of 12

years and above.

2) We will use the power of our brands to inspire

people to live healthy, active lifestyles.

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Scope of the Manual

This Application Manual is intended for use across

Europe and applies to all the activities which we carry

out in order to market our TCCC portfolio of brands.

If more strict regulations or internal guidelines exist

in a specific country, these must be applied in

addition to the global Responsible Marketing Policy

and the European Application Manual.

This Application Manual cannot cover all complex

situations. Thus, you are encouraged to apply the

spirit of the Policy whilst being mindful of unintended

consequences. Please seek counsel from internal

experts, i.e. Legal, SRA, PAC.

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TCCC

Responsible

Marketing Public Commitments

In Europe we have made external commitments on

responsible marketing. These have been done to the

European Commission and European H&W

Stakeholders through our European industry

platforms (UNESDA and EU Pledge) as well as

through national platforms to national governments

and stakeholders.

These UNESDA and EU Pledge commitments are

monitored by third party auditors and results are

reported back to the European Commission.

This industry self-regulation has delivered tangible

results in reducing the exposure of children below 12

years to marketing. Maintaining our high levels of

compliance will safeguard our ability to build our

brands with our consumers.

These self-regulatory initiatives are dynamic

frameworks. We listen and engage with our

stakeholders and where possible we evolve our

commitments to respond to changing societal

expectations.

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UNESDA

Commitments

UNESDA’s mission is to support the growth,

development and understanding of non-alcoholic

beverages at a European level.

TCCC as corporate member has made commitments

to:

• Not advertise our brands in programming aimed at

children under 12 years of age* on TV, in print, or online.

• Not offer our brands for sale in primary schools across

the 28 EU countries.

• In secondary schools, where products are offered for

sale, to sell them in unbranded vending machines and

alongside a full variety and choice of drinks formats

including water, juices and no- and low-sugar varieties.

• Not promote our brands in the digisphere on social

networks aimed at children under 12 years of age*.

• Not use imagery on our own corporate websites that

would appeal to children under 12 years of age.

* defined as more than 35% of the audience consisting of

children under 12 yrs.

See webpage: www.unesda.org/our-actions

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TCCC

Responsible

Marketing

EU Pledge

Commitments

The EU Pledge is a voluntary initiative of leading food

and beverage companies in Europe to change the way

they advertise to children below 12 years of age.

It consists of two main commitments:

• Only advertise food and beverage products that

meet common nutrition criteria OR not to

advertise any products at all, regardless of their

nutrition composition.

• No communication related to products in primary

schools, except where specifically requested by, or

agreed with, the school administration for

educational purposes.

See webpage: www.slideshare.net/WFAMarketers/the-eu-pledge

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Brands

The Policy applies to all TCCC owned brands,

regardless of product characteristics – including

water and juices.

For bottler owned / licensed brands pls. consult with

the bottler‘s legal department. To note, CCE and CCH

have also signed up to the UNESDA commitments.

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Exemplary / uncomplete list of brands

Content

1) Introduction

2) The Policy at a Glance

3) Media

4) Creative Execution

5) Promotions

6) Family Venues

7) Schools

8) Youth Education

9) Packaging

10) Children‘s Products / Brands

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The Policy

at a Glance

The Policy at a Glance

Policy details include:

• We will not target children under the age of 12

years with advertising for any brand of our

Company. This includes television, radio, print as

well as any type of digital / social media.

• This means that where data is available we will not

buy advertising (any media) if more than 35% of

the audience is comprised of children under the

age of 12 years.

• We will not show children under the age of 12

years drinking and enjoying any of our products

outside of the presence of a parent or caregiver.

• When portraying youth alone in our advertising,

either enjoying our products or not, they will not

be below 12 years of age and they will not look

visibly younger than 12 years.

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TCCC

Responsible

Marketing

When not certain if a marketing practice is consistent

with our Policy or not, use the following questions to

determine whether the practice is in line with the

spirit of the Policy.

Q1: Who is the target for this marketing activity?

Q2: What is the objective of this marketing activity?

Q3: What is the audience composition of this

marketing activity?

Q3a: If data is unavailable, would the content of the

program suggest that more than 35% of its audience

consists of children?

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Media

TCCC

Responsible

Marketing Television/ Radio/ Print

The Coca-Cola Company will not place any of our

brands‘ marketing in television, cinema, radio and

print programming made specifically for children.

This means that we will not buy advertising in

programs/ media with an audience profile higher than

35% of children less than 12 years of age.

We are sensitive to the fact that children may also be

watching programs with their family, and we make

every attempt to ensure that our advertising is

appropriate for a general audience.

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TCCC

Responsible

Marketing Digital Media

The Coca-Cola Company recognizes the growing use

of the Internet and mobile phones amongst children.

While we believe the Internet can be a wonderful

learning tool and mobile phones may be considered a

necessity, The Coca-Cola Company will not buy

advertising on Internet sites/ mobile phones directly

targeted to children below 12 years of age.

We will not have any communications predominantly

targeting children under the age of 12 on any digital

commercial media, inclusive of all TCCC brand and

corporate sites.

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Definitions :

Digital media refers to the use to advertise and sell

goods and services in electronic commerce.

It includes the placement of:

Paid Search, Display ads, Marketer-written product

reviews, Online ‘public’ classified ads, SMS/MMS ads

on mobile phones, Bluetooth, ‘Viral’ advertising,

Outdoor video, In-game advertising, Marketer-

endorsed User Generated Content (UGC), Elements

of marketer owned websites, E-mail marketing,

Banner ads, Interactive advertising, Search engine

and blog marketing, Messenger, etc. (see glossary of

terms).

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Creative

Execution

General guidance

The content for our marketing communications

should never

• Show children visibly younger than 12 years

consuming or being alone in the same visual

frame as one of our drinks.

• Give a misleading impression of the nutritional

benefit of drinks.

• Encourage or condone excessive consumption.

The amount of food & drink shown in a creative

execution must be appropriate to the meal

occasion and number of people depicted.

When showing children under 12 years of age

enjoying our products, they will always be

accompanied by an adult caregiver.

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TCCC

Responsible

Marketing Age considerations

We will not show children less than 12 years of age in

any of our advertising without an adult caregiver

being present in the setting/ storyline. This is

independent of whether or not any of our products is

consumed.

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When portraying teens enjoying any of our products

they will not be below 12 years of age and will not

visually look like they are less than 12 years old.

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Audio visual executions

As for all media, general principles and age

considerations also apply for audio visual executions.

For audio visual formats specifically, please note that

adult caregivers do not need to be present in every

visual frame of the story in which a child under 12

years appears if the following 2 conditions are

respected:

• An adult caregiver is part of the storytelling or

context.

• The children are not shown drinking any of our

products.

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TCCC

Responsible

Marketing

Use of fictional

characters

Borrowing the equity from third party fictional

characters (licensed characters, animated or non-

animated) or creating own characters that have

appeal predominantly to children under the age of 12

years and/ or run on children’s media is not permitted.

It is permissible to use fictional characters that have a

broad, general audience appeal and are run on media

that is targeted to teens and adults.

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Movie Tie-Ins

We will not partner with films for cinema if the core

target audience, as defined by local Movie

classification agencies (i.e. British Board of Film

Classification) is under 12 or if we judge the film to

have a strong appeal to under 12 year olds,

regardless of the rating.

We will only partner with films certified as having

universal appeal or requiring parental guidance (U or

PG) if they have a predominately adult audience

composition (less than 35% of viewers are under 12

years old).

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Promotions

Promotions

We will avoid any direct appeal to children to

persuade parents or other adults to buy products for

them or to do anything else that goes expressly

against the wishes or authority of a parent, guardian

or educator.

The commitment essentially means that we will avoid

to encourage “pester power”, or the power of

children to pester their parents (or other adults) into

buying a product or service.

As a matter of fact, advertising of a product through a

direct appeal to children to persuade their parents to

buy, is an illegal practice, against both the EU “Unfair

Commercial Practices” and the TV Without Frontiers

directive on television broadcasting.

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TCCC

Responsible

Marketing Promotions

As such, we will not target our advertising and

promotional materials directly to children under 12.

However, according to these guidelines, it is possible

that we make parents aware of promotional material/

merchandise, e.g. a polar bear, ball, pencils or

notebooks as giveaway with broad age appeal.

Branded merchandise that is designed to exclusively

engage children is not permitted: items that have

limited age appeal and are highly interactive for

children under 12, such as toys, coloring books, and

character items.

In any case, we recommend to consult your local PAC

/ legal counsel when considering to offer

merchandise that may have appeal to children under

12 years.

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Sampling

We will not target under 12 year olds with any of our

sampling activity. This means carefully selecting the

locations as appropriate to the adult or older teen

audience. We recommend to refrain from sampling in

close proximity to primary or secondary schools or

places primary for children.

We may choose locations that have broad family

appeal accepting that in these instances parents will

assume the gatekeeper role (e.g. supermarkets). We

will not offer samples pro-actively to under 12 year

olds and we will only hand out samples to children if

explicitly permitted by the adult caregiver.

General sampling guidelines apply (e.g. handing out

samples already open, one sample per person, small

pack sizes).

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Family

Venues

Family Venues

Family Venues are defined as venues with a specific

appeal to families. Examples are Theme Parks and

Movie Theaters as well as other Family Leisure

Venues (e.g. Swimming Pools).

Family Venues are considered to be of broad age

appeal because children must always be

accompanied/ supervised by caregivers.

For Family Venues, we will ensure to offer:

- a full range of beverages (including water, juices

and other beverages in both regular and low-

calorie/calorie free versions).

- appropriate container sizes that allow for portion

control.

Commercial advertising, branding and cobranding is

permitted as long as materials are not predominantly

appealing to under 12 yr olds.

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Schools

Our brands at schools

As a global business, we respect and recognize the

unique learning environment of schools.

As such, we are committed to a commercial-free

classroom for primary and secondary schools. This

means that we will not do any commercial advertising

in neither primary nor secondary schools.

Additional guidelines for schools activation:

1. No presence of our brands in primary schools

(for details see next page).

2. In secondary schools,

• We will offer a full range of beverages

including juices and waters.

• Vending machines will be unbranded.

• Educational messages on physical fitness

and balanced nutrition must be agreed with

school authorities.

Please consult with your local legal counsel for

country specific laws and regulations.

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TCCC

Responsible

Marketing Primary Schools

We will have no presence of our brands in primary

schools.

This includes:

- No sales of beverages unless explicitly requested

by school authorities. If products are made

available,

- they must be offered in an “appropriate

container size allowing for portion control”.

- Vending equipment must be unbranded.

- No commercial advertising in primary schools

including branding or sponsorships of football

tournaments.

If requested, we will make our full range of products

available in teacher’s lounges or areas with restricted

access to students.

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Secondary Schools

When we offer our beverages for sale in secondary

schools,

• We will make a full range of beverages available

(including water, juices and other beverages in

both regular and low-calorie/ calorie-free

versions).

• They will be offered in an “appropriate container

size that allows for portion control”. Generally

speaking, this should be no more than a serving

size.

• Vending equipment will be unbranded, i.e. free of

any trademarks, symbols or features that identify

Coca-Cola products other than waters and fruit

juices.

In secondary schools we may have educational

messages on physical fitness and balanced nutrition

if agreed with school authorities. These programs

must never be aimed at „selling beverages to

children“.

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Youth

Education

Youth Education

Our system supports education programs for children

in local communities throughout the world,

particularly initiatives focused on promoting active

healthy living. These programs for children under the

age of 12 years will be unbranded.

For the purpose of transparency, a corporate logo

can be included to inform parents, teachers and

children.

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Packaging

Packaging

We understand that we need to have commercially

attractive packaging.

For brands which are designed specifically for

children, the use of third party fictional characters

(any licensed characters, animated or not) is not

permitted as packaging decoration.

For all other brands, third party or own characters are

allowed as long as they are not predominantly

appealing to children <12yo.

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Children‘s

Products /

Brands

Marketing of Children‘s

Products / Brands

Our Policy permits us to have products and brands

specifically for children. However, the manner in

which they are marketed (including shelf presence

and packaging) must reflect the spirit of the Policy.

We will not undermine the role of caregivers/parents

in the selection of our products for their families.

However, once parents decide to bring these

products home, we understand that we need to have

products which are attractive and functionally

appropriate for children.

As such, packaging for children can be designed so

that it is available in smaller portion sizes, is easy for

children to open and drink from, and is attractive and

entertaining for children to enjoy.

Graphics and the Use of Third Party Characters:

For products and brands which are specifically

made for children , we will not use third party

characters or movie tie in’s in the design of our

marketing for children’s products. These characters

have existing high child appeal, and are likely to

interfere with parents’ decision making process. This

is against the spirit of our policy.

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FAQs

Q) Many have said that 16 is the age beneath which no

children should be marketed to. Why are you setting your

threshold at 12?

Evidence suggests that children under the age of 12 do not

understand advertising and its persuasive techniques. The

Guidelines are meant to respect the role of parent and

caregivers in making the primary decision of their children’s

consumption choices. The age threshold (under 12) has been

chosen based on overwhelming academic evidence showing

that by the age of 12 children have developed a critical

understanding of the commercial nature and persuasive

intent of advertising. Furthermore, all of the latest, most

comprehensive literature reviews (Ofcom, 2004; US Institute

of Medicine, 2005; Livingstone, 2006; McGinnis et al. 2006)

do not find any convincing evidence that advertising

influences the food preferences, requests, purchasing and

consumption behaviour of children and young people aged

12 and over. While academic research does not find evidence

of causality between advertising and diet or health for

children and young people of any age, it draws a clear

distinction between children under and over 12 in terms of

the influence of advertising on stated food preferences and

purchasing requests. It is in line with this academic

consensus that leading food and beverage companies have

decided to limit advertising to children under 12.

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TCCC

Responsible

Marketing

Q) How are you defining “marketing”?

This will, of course, include the traditional forms of

marketing communication. However, the world has evolved

and will continue to evolve in such a way that defining what

is “marketing” has become very complex and complicated.

We are putting forth this assistance manual, so that we can

provide context for our Policy and its application.

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Q) Do I need to limit my availability of products in movie

theatres that feature many films targeted to children?

Availability is not to be confused with marketing. We can

offer our full array of products in cinemas, because like

restaurants, children are likely to be accompanied with an

adult to assist in their consumption choices.

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TCCC

Responsible

Marketing

Q) How can you determine an audience’s composition?

You should do your best working with the available

information and appropriate groups to determine the

composition of an audience. Many media have tracking

mechanisms in place to determine the composition of its

audience by program. When data is not available, use your

best judgment based on the show’s content and appeal to

children in order to determine if the audience would be

comprised of children.

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Q) The 35% cut off may not be sufficient. Don’t children also

watch many other programs aimed at adults and teens?

None of us live in bubbles, including children. Parents have

said that they want to be the gatekeepers of information and

the primary decision-makers in their children’s consumption.

We want to respect the role they play and avoid any

advertising or marketing directly aimed at children. And, if a

child is watching a program intended for adults, the adults

present have the ability to provide any children with the

information they need to judge the advertising.

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TCCC

Responsible

Marketing

Q) Why is The Policy being implemented globally?

As a leader in the beverage industry, we have always tried

to take a responsible approach to marketing

communications and have had policies aimed at

responsible marketing to children for many years.

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Q) What if in doubt whether a child shown in advertising

visually looks like under 12 years?

The primary guiding principle is that the child must actually

not be less than 12 years of age.

If there is doubt whether the cast for an advertising

production looks above or below 12 years of age, the

decision should be taken pending of the scope of the

activity:

- Local: BU Marketing Director with agreement of BU head

of Corporate Responsibility

- Europe: Group Marketing Director with agreement of the

head of PAC

- Global: Ultimately, the decision would need to be taken by

the Corporate Sustainability Officer

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