Global Marketing Code for Human Food - January 2022 - EU Pledge
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Global Marketing Code
for Human Food
January 2022
Mars Global Marketing Code Introduction Marketing Communications Privacy Governance Contents Introduction A Letter from the Office of the President������������������������������������������ 03 Aim, Scope and Timing ������������������������������������������������������������������������04 Marketing Privacy����������������������������������� 15 Communications. . . . . 05 General Rules�������������������������� 06 Marketing to Children�������������07 Digital Media ��������������������������� 10 Promotions��������������������������������12 Advertising Guidelines������������13 Governance����������������������� 17 2 Copyright © 2022 Mars, Incorporated l All rights reserved
MARS Global Marketing Code Introduction Marketing Communications Privacy Governance
A Letter from the Office of the President
Dear Fellow Mars Associates,
In the spirit of continuous improvement, we are launching the fourth iteration of the Mars Marketing
Code (MMC 4.0). Through the update process, we have strengthened our responsible marketing
practices, and ensured that our practices reflect the continued evolution of consumer marketing and
digital channels. We are committed to taking a leadership position when it comes to setting standards
of responsible marketing and are proud to be recognized as such by external stakeholders. However,
we must be equally vigilant in ensuring we deliver a good understanding and compliance of our code in
order to live up to our commitments.
The core principles behind the code are as follows:
• We will not market to children under 13 years because, based on the scientific evidence, we believe they
cannot identify and understand the persuasive intent of advertising
• We equip gatekeepers, like parents, with the information they need to take decisions about what is right for
their children’s diet
• We are transparent about our code compliance internally and externally
• We actively survey other industry players’ codes and marketing behavior to ensure that we are exceeding
industry standards where it matters most
• We review and update our MMC every three years, to ensure that our commitments align with developments
in the external environment and that our code remains a ‘living document’
The new improved MMC 4.0 reconfirms these core principles and expands focus beyond marketing to children,
to encompass Mars’ wider activities to encourage our consumers to lead healthy and active lifestyles. Specifically,
the MMC 4.0 includes a number of new commitments that:
• Ensure cross-promotions, licensing agreements and partnerships with quick service restaurants support the
World Health Organization (WHO) guidance that consumers limit their intake of added sugars to no more
than 10% of their total energy intake
• Apply stricter guidelines and governance on how we use our brand characters
• Strengthen governance practices of our Mars Marketing Code
• Reflect the European General Data Protection Regulation (GDPR) in our digital marketing commitments
We want all Associates to take pride in our commitment to responsible marketing, and to help us live up to the
spirit and the letter of the code. Thank you for taking your responsibility on this front seriously and investing the
time to understand the advancements we’ve made in this refreshed version of the Mars Marketing Code.
Grant F. Reid
Office of the President/CEO
3 Copyright © 2022 Mars, Incorporated l All rights reserved
Mars Global Marketing Code Introduction Marketing Communications Privacy Governance Aim, Scope and Timing Mars, Incorporated owns many of the top chocolate, confections, chewing gum and food brands globally and has a long history of marketing its products responsibly. Our Marketing Code, first adopted in 2008 and updated in 2010 to reflect the Wrigley acquisition, reflects our corporate values and principles and our commitment to responsible marketing communications within a dynamic marketing environment. This Code is globally applicable print, mobile phone, digital, Our Marketing Code also includes and seeks to reaffirm our multimedia entertainment formats our Advertising Guidelines, which commitment to the responsible (including but not limited to DVDs, are intended to serve as further and creative use of advertising in CDs and games)), advertorials, guidance on considerations in all its forms to market our products, sponsorship, brand press releases purchasing media time or space to explain how Mars uses specific and promotions. We seek to assure for our advertising from content marketing techniques, and new that our licensees and business providers. and emerging forms of media, partners adhere to our high consistent with our commitment standards; however, Mars is not The Mars Marketing Code is to respect the privacy of our responsible for actions of non- primarily for internal use and is consumers. The Mars Marketing licensed third parties that may intended to assist all our Associates Code reflects Mars’ commitment involve our products or brands. (and especially those involved in to promote and encourage healthy The commitments in this Code marketing, sales, corporate affairs and active lifestyles globally. are in addition to all statutory or commercial/procurement) in This Code applies to all forms of requirements or self-regulatory ensuring that all our marketing marketing communications, for commitments applicable in practices are responsible, reflect food, chocolate, confections and any country. the values and concerns of our chewing gum products produced consumers and are globally and licensed by Mars, Incorporated The Mars Marketing Code is a consistent. It is the responsibility on a worldwide basis as well as living document and may require of all Mars Associates and external to the following promotional revisions from time to time to marketing communications agencies materials and activities generated ensure it is consistent with our to comply with this Code. Mars also by Mars, Incorporated: branded corporate values and principles, as supports and participates in various websites (including those run well as changes in the marketplace self-regulatory initiatives on food by third parties under a license and changes within our Company, and beverage advertising around agreement), online communities, allowing a three year transition the world to help us verify that we media advertising (e.g., broadcast, period for new acquisitions. are meeting our high standards. 4 Copyright © 2022 Mars, Incorporated l All rights reserved
Mars Global Marketing Code Introduction Marketing Communications Privacy Governance
Marketing
Communications
In This Section
General Rules ���������������������������������������� 06
Marketing to Children�������������������������� 07
Digital Media �����������������������������������������10
Promotions����������������������������������������������12
Advertising Guidelines��������������������������13
5 Copyright © 2022 Mars, Incorporated l All rights reserved
Mars Global Marketing Code Introduction Marketing Communications Privacy Governance
1. General Rules for Marketing • We will provide information to
the intended audience in the
most objective and relevant way
Communications possible, across all channels in
a transparent and accountable
manner.
• We will use adult actors with a BMI
Our products are of the highest quality and can form part greater than 18.5 in all marketing
of a healthy and enjoyable diet for consumers of all ages. communications.
In regards to children:
• Our communications will confectionery and food products • We will not direct marketing
encourage the pursuit of a healthy, globally. We will ensure this communications for our products
balanced diet and active lifestyle. information is accurate and primarily to children under 13, both
• Our communications will not guided by the core principle to in terms of ad content and media
encourage or condone excessive not mislead consumers. purchasing.
consumption of any food or drink. • Any claims will be backed up • We will direct our marketing
• Our communications will not by clear, referenced scientific communications to adults who
promote compulsive snacking or evidence, data and expert make household purchasing
create a sense of urgency. testimonials as required. decisions (gatekeepers) and young
• Our communications will • We will not develop chocolate people 13 and over, both in terms of
accurately represent the material and confectionery products ad content and media purchasing.
characteristics of the product whose single portion size exceeds • Our marketing communications
featured and not mislead 250 kcal, and will make an effort on products of interest to
consumers. to demonstrate portion size in a children under 13 will aim to allow
• We will not represent our snack visible way wherever possible. gatekeepers to make informed
food products as substitutes for • We endorse initiatives to encourage choices about whether our
meals. active lifestyles including the products are appropriate for the
• We will provide information to sponsoring of sports events. children in their care.
consumers about the importance • We endorse initiatives that • We will not use celebrities primarily
of healthy eating on our branded encourage healthy eating appealing to children under 13.
websites. including healthy eating • Licensees must direct marketing
• We will provide nutritional education programs. communications in which our
information comprised of front-of- • We will promote the oral brands or logos appear primarily to
pack energy labels and guideline healthcare benefits of chewing adults, gatekeepers and consumers
daily amounts or an equivalent sugar-free gum. 13 and over.
system on back-of-pack labels • We will inspire families to cook • We will not conduct research on
for key nutrients on all chocolate, and eat together. communications techniques with
the intention of appealing to
children under 13. We may conduct
consumer research with minors,
including children under 13, where
it is necessary to understand how
products can help address the
public health issues of malnutrition
and dental caries in positive ways.
In any research with children,
we will always use methodology
and practices that comply with
relevant guidelines and regulations
to ensure safety and will secure
informed consent of a parent or
legal guardian in advance of any
research.
6 Copyright © 2022 Mars, Incorporated l All rights reserved
Mars Global Marketing Code Introduction Marketing Communications Privacy Governance
Marketing 2. Portrayal of children
under 13 years old
3. Themes and events
relevant to children
to Children in our marketing
communications
under 13
a. We will continue to link our
a. We will not show children under products to seasonal themes and
As a responsible business, 13 consuming our chocolate events such as Easter, Christmas,
and confections products. We Valentine’s Day, Mother’s Day,
Mars has made the Chinese New Year, Back to
may show children under 13 in
decision not to market to our marketing communications School, Halloween, etc.
children under 13 years if relevant to the marketing b. Our marketing communications
message, e.g., depiction of a around themes and events which
old, based on existing family situation or activity. In are relevant to children will be
scientific consensus. such situations, a gatekeeper primarily directed to gatekeepers.
must always be shown controlling c. Other than to promote oral
access to a product. healthcare and family cooking,
b. Given the oral healthcare benefits we will not use incentives and/
of chewing we will show children or giveaway’s linked to themes
chewing sugar–free gum. and events intended solely for
c. Given the nutritional benefits children under 13.
of certain foods we will show d. We will not engage in joint
children enjoying such foods. promotions/partnerships linked
d. We will not portray children in a to themes and events where our
sedentary situation. logos would be used on material
intended solely for children
e. Children under 13 shown on
under 13.
packs, in POS material, etc.,
should not appear to be acting as
a spokesperson for the product.
7 Copyright © 2022 Mars, Incorporated l All rights reserved
Mars Global Marketing Code Introduction Marketing Communications Privacy Governance
4. Use of celebrities and licensed characters; use of trade characters;
marketing communications in films and media programming
a. Our brand characters are
not intended to appeal to
children under 13 and Character
Guidelines will be strictly
enforced across our business
and across all marketing levers
including advertising, packaging
and display, with oversight from
the Brand Board.
b. We will not use a celebrity or
licensed animated character
intended to appeal primarily
to children under 13 in our
marketing communication.
c. In order to support oral
healthcare and healthier family
cooking, we may use our
brand characters in gatekeeper
targeted campaigns.
d. Our brand characters (e.g.,
M&M’S®, DOLMIO®, Food
gang, etc.) are aimed at
gatekeepers. We reserve the
right to create new characters, excessive consumption of any i. We will not advertise in or sponsor
but will refrain from creating food or drink and will not be films or media programming
characters primarily targeted specifically designed for use where the intended audience is
at children under 13. In the solely in primary schools. primarily children under 13. For
case of the M&Ms® characters, g. We will restrict the sale of television, when the broadcasters’
we will emphasize their non-food merchandise audience assessment at the time
mature personalities and adult exclusively designed for use of the media buy indicates that
characteristics (voices, humor, by children under 13 to Mars more than 25% of the audience
mannerisms). controlled experiences of any targeted program is
e. We will not use third-party, (e.g., M&M’s® World, MPorium, composed of viewers under 13,
licensed and other characters Nascar Trailer, etc). they will be deemed to be the
that are primarily intended for h. When we license our brand primary audience. For film, we will
an under 13 year-old audience in names or logos to third apply regional rating systems as an
our marketing communications. parties, we will require that initial screen to define which films
f. Non-food promotional products any non-food promotional are rated for an audience below
for use by children under 13 products for children under 13 the age of 13.
depicting our characters, or will not encourage excessive j. We will not undertake product
licensed characters, brand consumption of any food or placement in films or media
names or logos that are drink and will not be specifically programming where children
intended to be purchased by designed for use solely in under 13 are the primary
gatekeepers, will not encourage primary schools. intended audience.
8 Copyright © 2022 Mars, Incorporated l All rights reserved
Mars Global Marketing Code Introduction Marketing Communications Privacy Governance
5. Marketing communications in schools and community
institutions, including for fundraising purposes
a. We will not place vending
machines offering our products
in primary schools (Kindergarten
to Grade 6 in the U.S.) or in
locations where the majority of
users are under 13 and are using
these facilities without adult
supervision.
b. In schools attended by children
of all ages, we will not place
vending machines in locations
intended primarily for the use of
primary school children.
c. We will not offer branded
materials for use in schools by
children under 13, except in
connection with established
educational or public service
messaging programs on
responsible disposal of littered
gum, oral healthcare and
inspiring family cooking at home.
This applies to both primary and
secondary schools. recognized organizations, we
d. We will consider donating will create branded educational
funds or products to schools programs, including sampling, With the exception of
and community institutions to promote oral care and established educational
where the school/institution responsible chewing gum
disposal to children under 13
or public service
has specifically requested this
support in writing. and teens. Prior to deploying programs, Mars will not
e. We will support education these programs, we will require offer branded educational
and public service messaging school administration approval.
g. In conjunction with recognized
materials or vending in
programs that promote
environmental awareness, oral external experts, we will create primary schools.
care, responsible chewing gum branded educational programs
disposal and healthy cooking to promote healthy cooking and
habits to children and teens eating habits to children under
that may include the use of 13 and teens. Prior to deploying
corporately branded materials in these programs, we will require
primary schools. school administration approval.
f. In conjunction with government h. We will not sponsor sports
health authorities and/or events in primary schools.
9 Copyright © 2022 Mars, Incorporated l All rights reserved
Mars Global Marketing Code Introduction Marketing Communications Privacy Governance
6. Marketing Communications a. We will advise consumers who
visit our brand and corporate
websites and use our mobile
in Digital Media applications about Mars’ policies.
We will include a link to the
“Note to Parents,” Mars Privacy
Marketing communications made through Statement, Terms of Use, Interest-
Based Advertising Policy, Web
websites, mobile applications and other digital Site Owner information and
products and services (collectively, “Digital Media”) Mars Copyright Notice, as well
will be directed to adults and teens (age 13 and as a “Contact Us” link, in the
footer of all websites and mobile
older) and not directed to children under age 13. applications owned and operated
by Mars and in the About Us
Examples of marketing communications in Digital Media are: section of branded social media
online games offered on our websites; digital advertising and content.
other branded content made available on third-party websites b. Marketing communications
and social networks; branded mobile applications; text messaging promoting Mars’ brands in
(SMS/MMS) campaigns; and internet promotions. Mars will direct other Digital Media (e.g., social
all marketing communications in Digital Media to teenagers networks) will, whenever possible,
(age 13 or older), consistent with the requirements of the U.S. law include links to information about
known as the Children’s Online Privacy Protection Act (“COPPA”). nutrition and healthy lifestyle
For European markets, or where consumers access European choices and, if Mars is collecting
based Digital Media, we will ensure the GDPR is applied in full. personal information from
See here for specific guidance. consumers, a link to the Mars
Privacy Statement.
c. We will use “neutral age screening”
(as defined by COPPA) to ensure
that we have taken all reasonable
steps to restrict children under age
16 from submitting their personal
information to Mars through
Digital Media, as well as to restrict
their ability to download branded
content, post material potentially
appealing to younger audiences
or to upload photographs or
information.
d. Each Mars-branded website or
mobile application will provide
notice to users of its commercial
marketing intent.
e. We subscribe to the WOMMA
(Word of Mouth Marketing
Association) Code of Ethics
(available at http://womma.
org/ethics). Mars will use blogs,
microblogs (e.g., Twitter), social
networks (e.g., Facebook), photo-
sharing video-sharing sites
(e.g., Instagram, Vine, YouTube)
10 Copyright © 2022 Mars, Incorporated l All rights reservedMars Global Marketing Code Introduction Marketing Communications Privacy Governance
and other Digital Media to
earn or promote customer
recommendations only from
adult and teenage consumers
and only in an open and
respectful manner.
f. Mars seeks to partner with social
media platforms and services
that offer age screening (e.g.,
Facebook by using a Facebook
app). If a social media platform
or service does not permit age
screening, Mars seeks to use
other mechanisms, such as
parental controls or notices,
in an effort to ensure that
marketing communications
in Digital Media are primarily
directed to teenagers (age 13 and
older). If audience demographic
information is available, Digital
Media purchases will adhere
to our commitment that the
audience of children under
age 13 must be 25% or less of
the total projected audience
composition.
g. Mars occasionally offers
consumers the opportunity to
post user-generated content
(UGC), such as their own
photographs, videos or reviews
of Mars products. Mars will limit
opportunities to submit UGC to
adults, or, in carefully-controlled
situations, to teens. Whenever
possible, we will use neutral age
screening to prevent children
under age 13 from posting UGC. Mars takes all reasonable steps to restrict children
Prior to submitting UGC, all
consumers will be required to under age 13 from submitting personal information
affirmatively agree (click to agree to us through Mars Digital Media platforms, including
or opt in) to submission terms. age-gating our websites, and we partner with social
media platforms to promote age screening and
parental controls.
11 Copyright © 2022 Mars, Incorporated l All rights reservedMars Global Marketing Code Introduction Marketing Communications Privacy Governance
7. Promotions a. We will not design or participate
in promotions intended primarily
g. We will not promote activities,
recipes or games that encourage
for children under 13. excessive consumption, including
b. We will not design joint ‘supersize’ offerings.
We take great care promotions with manufacturers h. We will not design or participate in
to ensure that all of of third-party products intended cross promotions of our products
primarily for children under 13. with alcoholic brands, except for
our own promotional our premium adult confectionery
c. Third-party products used
activities comply in joint promotions should and ice cream products/brands
with this Code and be appropriate for the same and Food brands.
consumers as the Mars products i. When selling Caffeine Gum, we
we encourage our offered. will be transparent on caffeine
retail customers and d. Where we directly fund inclusion, not promote the over-
promotional partners promotions with products consumption of caffeine, and will
from other categories (cross- not target consumersMars Global Marketing Code Introduction Marketing Communications Privacy Governance
8.Mars, Incorporated
Advertising Guidelines
Mars, Incorporated is committed to advertising
its products in a manner consistent with the
principles which guide us in all aspects of our
business. This impacts the content of our marketing
communications, as well as the placement of
marketing messages.
We want our marketing commitments as part of the agencies) to deliver the best
communications content to “Unstereotype Alliance” and “Free unstereotyped marketing
resonate with our consumers. the Bid” to ensure that creative content - and ensuring, as
We want it to inspire them and executions by Mars Inc. and our brands, that we only buy the
invite them to love our brands brands, whether in the advertising best, most unstereotyped work.
the way that we do. We or content we create, show all • Holding ourselves accountable
seek to do this in a way that individuals as authentic to who to all these commitments
ensures that our marketing they are and multi-dimensional. by setting clear goals and
content is appropriate for our We will do this by: measuring change annually,
consumers, and in line with • Ensuring that our casting in aiming for demonstrable
the cultural and regulatory our marketing communications change by 2020.
norms in the markets where it reflects the true diversity of the
is placed. consumer base that we sell to
As a business, we know that (gender, race, sexuality, age,
there is enormous diversity ability, religion, ethnicity, class
in society, and we want to be and more).
a leader in reflecting this in • Depicting people as
our marketing content. We empowered actors and not
believe that people should be objectifying people.
shown as who they are, not • Portraying progressive and
what box they tick. That’s why multi-dimensional personalities
Mars has committed to more and avoiding damaging
inclusive marketing that makes stereotypes.
a difference - by focusing on • Holding our agencies to account
how we represent all people that every triple bid process
through our advertising and includes one shortlisted female
branded content, both in front director.
of and behind the camera. • Challenging each other (as
We will work to deliver our advertisers and advertising
13 Copyright © 2022 Mars, Incorporated l All rights reservedMars Global Marketing Code Introduction Marketing Communications Privacy Governance
The media environment is becoming more and more complex, with more choices of content than ever before
for consumers. Our goal in our advertising is to identify media vehicles that allow us to reach our intended
audiences, in accordance with our Marketing Code and these guidelines.
The responsibility for programming or media content does not and should not lie with the advertiser.
It is not, and should not be, the advertiser’s role to dictate content standards or to exercise editorial
control. However, it is the advertiser’s right to make judgments about the suitability and appropriateness of
programming or media content as an advertising vehicle for our products.
Consequently, as a general rule, We recognize that content with Advertising should not be
advertising for our products a historical, social, humorous or scheduled during programs or
should not depict or be placed in satirical nature may touch on media in which the handling of
programs or media involving: provocative themes but may controversial subjects becomes
nevertheless be an appropriate inflammatory, unbalanced or
1. Ethnic, racial, religious or sexual vehicle for our advertising. The not factual, which depends
stereotyping or ridicule. handling of controversial subjects on the exploitation of private
2. Depictions of gratuitous or calls for particular sensitivity and grief or misfortune, or which is
excessive violence, brutality, consideration. When serious inconsistent with the core values
cruelty or suffering to people or
treatment of controversial or our Company and our brands.
animals.
subjects is handled properly,
3. Explicit sexual behavior
in a factually accurate, fair and
or inappropriate sexual
suggestiveness or innuendo. balanced manner, the media
can perform a constructive
4. Endorsement of unethical,
self-destructive or anti-social societal role which should be
behavior or values, e.g., drug or encouraged.
alcohol abuse.
5. Endorsement of excessive or
compulsive consumption of
foods or beverages.
6. Situations antithetical to The Five
Principles of Mars, Incorporated,
or to basic common sense.
14 Copyright © 2022 Mars, Incorporated l All rights reservedMars Global Marketing Code Introduction Marketing Communications Privacy Governance Mars respects the privacy rights of all of our consumers. We seek to embed respect for privacy into all aspects of our marketing initiatives and to consider and address privacy issues at every stage of the marketing lifecycle. 9. Privacy 15 Copyright © 2022 Mars, Incorporated l All rights reserved
Mars Global Marketing Code Introduction Marketing Communications Privacy Governance
All Associates who deal with consumers’ personal data
are expected to be familiar with Mars’ online Privacy
Statement, Global Digital Marketing and Social Media
Standards and local Digital Marketing Guidelines
where applicable, as well as applicable local laws and
requirements regarding the collection and use of
personal information and data security obligations.
a. All websites, mobile applications c. We will not share personal
and other Digital Media information with outside third
owned and operated by Mars parties except as described in
will prominently display the the Mars Privacy Statement.
Mars Privacy Statement. We d. We will honor any specific
encourage visitors to thoroughly commitments we make to
review the Mars Privacy consumers about how and
Statement, Terms of Use and how frequently we will contact
other special terms and rules them and promptly honor
that may apply to activities in opt-out requests according
Digital Media. Where children to local laws governing
are likely to use Digital Media, unsolicited commercial
we will ensure that the Mars communications.
policies linked to such Digital e. We adopt reasonable data
Media are in clear and plain security procedures suitable
language which children will to the sensitivity of personal
understand. information about consumers
b. When personal information is that we hold, and require our
collected for a single, one-off agents and service providers
purpose (e.g., entering an email to do the same.
address to ‘share with a friend’),
we will be transparent about
immediate deletion of this
information.
16 Copyright © 2022 Mars, Incorporated l All rights reservedMars Global Marketing Code Introduction Marketing Communications Privacy Governance
Mars strives to
comply with existing
legislation and
applicable self-
regulatory Codes
in its marketing
communications in
each market.
10. Governance
17 Copyright © 2022 Mars, Incorporated l All rights reservedMars Global Marketing Code Introduction Marketing Communications Privacy Governance
External third-party monitoring
of Mars, Incorporated’s voluntary
The Marketing Code provisions are to be commitments to assess compliance
applied in addition to laws and regional or sectorial levels with national, regional
or global industry pledge
Codes. Mars provides interactive training on the Mars
commitments takes place within
Marketing Code to empower Associates and external the framework of the International
marketing communications agencies to fully understand Food and Beverage Alliance, the
Children’s Food and Beverage
and apply the Code’s rules. The training is mandatory Advertising Initiative (CFBAI) of
for Mars Marketing Associates, and all participants the Better Business Bureau, the
receive, after successful completion of the training test, EU Pledge, and World Federation
of Advertisers. We will share data
a “Mars Marketing Code Driving License.” related to levels of our compliance
publicly.
We continue to be vigilant to ensure that we are meeting our high
Mars, Incorporated conducts
standards through Marketing Code governance procedures in all
a yearly internal compliance
regions, with a Global Governance Board and Steering Committee to
audit, including reporting to and
oversee compliance.
oversight by the Mars Board which
will be published externally.
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