Digital Guiding Principles - Responsible Marketing

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Digital Guiding Principles

Global Implementation
September 2017

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Exec Summary
• In 2012 the Alcohol Industry (including ABI) signed a commitment to the World
Health Organisation (WHO) to reduce the harmful use of alcohol

• Part of this commitment is to globally follow a standard set of “digital guiding


principles” (DGPs) when communicating with consumers—the DGPs were
launched in 2014

• A recent audit by the International Alliance for Responsible Drinking (IARD)


showed ABI has only 5% compliance (worldwide) with the guidelines

• We need to close the gap by the end of the year or face further scrutiny on our
inability to self-regulate

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What are the DGPs?
Age affirmation mechanism (age-gate)
• Whenever alcohol beverage marketing communications actively engage a user to directly interact with a brand, alcohol beverage companies
should use an age-affirmation mechanism to check that this user is over Legal Purchase Age (LPA).

Transparency
• Alcohol beverage digital marketing communications should not misrepresent their commercial purpose.

User Generated Content (UGC) Policy


• User Generated Content (UGC) posted on alcohol beverage company-controlled digital platforms should state what type of content users should
and shouldn’t display on the brand account.

Forward Advice Notice (FAN)


• Whenever alcohol beverage companies’ controlled digital platforms have the functionality to allow content sharing, alcohol beverage companies
should include a Forward Advice Notice (FAN) on the platform, clearly stating that the content should not be forwarded to anyone under Legal
Purchase Age

Responsible Drinking Message (RDM)


• Alcohol beverage digital marketing communications and/or alcohol beverage company-controlled digital platforms should include a clearly visible
Responsible Drinking Message (RDM), which explicitly advocates responsible drinking.

Privacy
• Alcohol beverage companies should display information on privacy policy.

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DGPs & RMCC
The DGPs have been covered in our Responsible Marketing and
Communications Code (RMCC), with RMCC training required annually
DGP Clauses in RMCC 2.0

Age-affirmation mechanism / Clause 2.4: “We will ensure that all AB InBev websites use an age-
Age-gate affirmation mechanism”
Clause 6.1: “All AB InBev brand and corporate websites must contain an
age-affirmation mechanism”
Clause 7: “In general: for AB InBev’s no-alcohol beer products we will
adhere to all provisions under the ‘Legal Drinking Age’ & ‘Digital’ principles”
Transparency Clause 6.2: “Content created by AB InBev must always be transparent in
showing the commercial nature of the communications”
User Generated Content (UGC) Clause 6.2: “If [user-generated] content is placed on channels that we
control (AB InBev brand and corporate sites), we will monitor it and remove
any inappropriate content within 48 hours of when it is posted”

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DGPs & RMCC (continued)
DGP Clauses in RMCC 2.0

Forward Advice Notice (FAN) Clause 2.5: “Digital communication created by or under AB InBev’s
control…shall include a reminder to the user not to send to those who are
under the legal drinking age”
Clause 6.3: “Any e-mail that is designed to be forwarded should also contain
instructions for the recipient that he or she should not forward the message to
individuals below the legal drinking age.”
Responsible Drinking Clause 1.7: “We will strive to ensure that all AB InBev advertising (i.e. print,
Mechanism (RDM) electronic, digital, out-of-home ads) and websites carry a clear, easy-to-read
responsible drinking message, where feasible”
Clause 6.1: “Websites and sponsored sites (e.g. Facebook pages, Twitter
feeds, apps, etc.) should also carry responsible drinking messages”
Privacy Clause 6.4: “We will respect strict rules about the use of consumers’ online
data for marketing and have clear data privacy statements that we encourage
our consumers to read”

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Existing AB InBev digital platforms provide examples
of how to reach DGP compliance
Budweiser UK Twitter page featuring Transparency statement Budweiser US website featuring Age-gate mechanism,
(verified Budweiser account), UGC policy and FAN (“rules of UGC policy (link to “Terms and Conditions”), Privacy
engagement”), and RDM (“Please drink responsibly”). policy link, and RDM (“Enjoy Responsibly”).

Age-gate mechanism

Stella Artois
YouTube page UGC Privacy
RDM
featuring Age-
gate mechanism

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Where are the DGPs applied?

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Click on FAN RDM Official UGC Age-Gate Privacy
boxes

Facebook Facebook Facebook Facebook Facebook Facebook


FAN RDM Official UGC Age-Gate Privacy

Instagram Instagram Instagram Instagram Instagram Instagram


FAN RDM Official UGC Age-Gate Privacy

Twitter Twitter Twitter Twitter Twitter Twitter


FAN RDM Official UGC Age-Gate Privacy

YouTube YouTube YouTube YouTube YouTube YouTube


FAN RDM Official UGC Age-Gate Privacy

Websites Websites Websites Websites Websites Websites


FAN RDM Official UGC Age-Gate Privacy

Apps Apps Apps Apps


N/A N/A
RDM Official Age-Gate Privacy
Action Plan
Zone and Market teams are responsible for ensuring DGPs adherence across all
digital platforms:

• Organise briefing session for Marketing & Corporate Affairs teams along with
Agency partners in each BU
• Check all local digital platforms for compliance against DGPs, immediately
address any gaps
• A globally administered audit will conducted across ALL Zones at the end of
October to check compliance

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APPENDIX

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DIGITAL GUIDING PRINCIPLES: ABI
COMPLIANCE GAP COMPARED TO IARD
MEMBER AVERAGE
Platform ABI Compliance Status IARD Member Average

6% fully compliant 24% fully compliant


34% had 5 of 6 safeguards 54% had 5 of 6 safeguards

6% fully compliant 5% fully compliant


12% had 5 of 6 safeguards 16% had 5 of 6 safeguards

0% fully compliant 4% fully compliant


0% had 5 of 6 safeguards 13% had 5 of 6 safeguards

0% fully compliant 21% fully compliant


17% had 4 of 5 safeguards 55% had 4 of 5 safeguards

Websites
8% fully compliant 13% fully compliant
29% had 5 of 6 safeguards 54% had 5 of 6 safeguards

Mobile 33% fully compliant 45% fully compliant


Apps 33% had 3 of 4 safeguards 66% had 3 of 4 safeguards

Notes: Results are from independent audit of 192 items across ABI social media platforms in Australia, Chile, Colombia, South Africa, France, Germany, Italy,
Spain, Netherlands, and UK; full compliance only achieved if all applicable safeguards featured; some safeguards do not apply to all social media platforms
ALIGNMENT ON KEYTHE
PRIORITIES
JOURNEY | |11
11
ACTION PLAN TO ACHIEVE
COMPLIANCE ON DIGITAL
GUIDING PRINCIPLES

Marketing to lead action plan for closing DGP gap:


Short Term
• Develop timeline for achieving full compliance by end of 2017
• Global team to set standards (w/examples) for compliance
• Cascade of DGPs to Zone Corporate Affairs and Marketing for implementation
• Local teams to engage agencies responsible for digital platforms and action changes

Long Term
• Review DGPs inclusion in Marketing Excellence Program
• Integrate to MEP 2018 update
• Review adherence to DGP as part of yearly audit

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DGPs in Detail

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Age-Gate
Purpose: Access to alcohol commercial communications should be restricted to adult
consumers only as people underage are not allowed to consume alcoholic beverages.
The Principle: Whenever alcohol beverage marketing communications actively engage a
user to directly interact with a brand, alcohol beverage companies should use an age-
affirmation mechanism to check that this user is over the country’s Legal Purchasing Age
(LPA).
In Practice:
• The implementation of an age-gate mechanism will vary widely depending on the
environment (social media / websites / apps). Please refer to the specific sections
directly.
• The age-gate should be set either at the country’s LPA or 18
• Most of the time consumers have to enter the full date of birth (DD-MM-YYYY) and select
the country of residence
• Ideally, there should be a reminder not to select ‘remember me’ if the computer is shared
with minors (on company websites)
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Transparency / Official Signpost
Purpose: Digital marketing activities shall be carried out in a transparent way in order
to avoid misleading consumers. Identifying the brand’s official accounts also helps
differentiating from the unofficial pages / fan pages which might not be implementing
the responsibility safeguards.
The Principle: Alcohol beverage digital marketing communications should not
misrepresent their commercial purpose.
In Practice:
• The official signpost which can be implemented on Facebook, Twitter, and
Instagram is needed to qualify for compliance.
• For YouTube, please refer to the dedicated section below.
• For apps, a simple sentence “This is the official app of <insert brand>” is enough.
• For websites, the official nature of the website will be made clear through the
trademark, terms & conditions, official company information etc.
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User Generated Content (UGC)
Purpose: It needs to be clear that brands do not condone any user-generated content
that would promote inappropriate or excessive alcohol consumption. Consumers need
to be informed that any irresponsible content of this sort will be taken down.

The Principle: User Generated Content (UGC) posted on alcohol beverage company-
controlled digital platforms should be moderated on a regular and frequent basis.

Examples:
• “Please see our rules for engagement: [link]”
• Or full mention of the rules in the “about” section

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Forward Advice Notice (FAN)
Purpose: Consumers need to be informed and reminded that alcohol commercial
communications should not be shared with underage people in order to protect minors.
The Principle: Whenever alcohol beverage companies’ controlled digital platforms
have the functionality to allow content sharing alcohol beverage companies should
include a Forward Advice Notice (FAN) on the platform, clearly stating that the content
should not be forwarded to anyone under LPA in the country of viewing.
In Practice - Examples:
• “Please only share our posts with those who are of legal drinking age”
• “Forward to those of legal drinking age only”
• “Please do not share or forward to anyone underage”

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Responsible Drinking Message (RDM)
Purpose: It needs to be clear that brands are committed to responsible drinking and that
they strongly invite their consumers to enjoy their products in moderation.
The Principle: Alcohol beverage digital marketing communications and/or alcohol beverage
company-controlled digital platforms should include a clearly visible RDM which explicitly
advocates responsible drinking.
In Practice: The RDM has to be at least included on the main page (social media) or the
homepage (websites & apps). It should be well visible and readable. Ideally, it should feature
on all commercial communications. For social media, the RDM can either be included in:
• Profile’s description; or
• Profile picture / cover picture
Examples:
• “Please enjoy <brand> responsibly”
• “Drink <brand> with moderation”
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Privacy Policy
Purpose: Consumers need to be transparently informed about how their data is
collected and used for marketing purposes by alcohol brands

The Principle: Alcohol beverage companies should respect user privacy.

In Practice: Brands need to communicate their Privacy Policy. Ideally, such privacy
policy should include, if relevant, information regarding direct marketing, and obtain
consent for it, along with the opportunity to opt-out of such marketing.
It can be just a link redirecting to a corporate global website with the general privacy
policy.
For Social Media platforms, the platform’s privacy policy is currently enough from a
‘DGP implementation’ perspective (pending EU data protection regulations may change
this, in which case Global would provide revised instructions).

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DGPs in Practice – Platform Examples

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Facebook – Age Gate
Default – Facebook’s age-gate should automatically kick in based on the user’s age,
but only if brand/product/company page is properly categorized as pertaining to
the alcohol industry

Instructions for setting age-gate: https://www.facebook.com/help/778445532225441

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Facebook – Transparency/Official Signpost

Official signpost

Facebook may not currently offer a straightforward way to


‘verify’ your page(s) for certain brands. Getting directly in
touch with your Account Manager at Facebook seems to
be best way to include this safeguard.

Additional information on official signpost:


https://www.facebook.com/help/1644118259243888
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Facebook – Transparency/Official Signpost
& RDM

Official signpost

Instructions for obtaining official


signpost:
https://www.facebook.com/help/7784455322
25441
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Facebook - User Generated Content Policy

Where: either as link to a


website with the policy or
directly mentioned in the
‘about’ section

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Facebook - Forward Advice Notice (FAN)
Where: on landing page
or in the ‘about’ section

Examples:
“Please only share our
posts with those who are
of legal drinking age”

“Forward to those of
legal drinking age only”

“Please do not share or


forward to anyone
underage”

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Facebook - Privacy
At this time, Facebook’s Privacy Policy is sufficient for DGP compliance as their
Privacy Policy explains how the brand’s page(s) respect the user’s privacy.

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Instagram – Age Gate

Instagram will use age data


collected from Facebook accounts.
Followers who have not disclosed
their age on Instagram will be
categorized as under-aged and
won’t be able to follow your
page(s). Instagram will ask them
for age confirmation the next time
they try to follow or visit the profile
of a gated alcohol brand account.

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Instagram – Transparency / Official
Signpost
Instagram may not
currently offer a
straightforward way to
‘verify’ your page(s) for
certain brands. Getting
directly in touch with your
Account Manager at
Instagram seems to be
best way to include this
safeguard.

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Instagram – Transparency/Official
Signpost and FAN
Where (FAN): in the
description of the
account

Examples (FAN):
“Please only share our
posts with those who are
of legal drinking age”

“Forward to those of
legal drinking age only”

“Please do not share or


forward to anyone
underage”

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Instagram – UGC

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Instagram – RDM

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Instagram - Privacy
At this time, Instagram’s Privacy Policy is sufficient for DGP compliance as their
Privacy Policy explains how the brand’s page(s) respect the user’s privacy.

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Twitter – Age Gate They will be unable to follow that alcohol
account and any others from that point
When a user first tries to follow an alcohol If they enter in a date that is below the forward as the date they enter saves to
account, this screen below pops up: legal drinking age as such: their profile:

Instructions for setting age-gate: https://support.twitter.com/articles/20169945


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Twitter – Transparency/Official Signpost,
UGC, FAN, RDM
Information
needed to
request the
official signpost
badge:
https://support.twi
tter.com/articles/2
0174631

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Twitter –Privacy
At this time, Twitter’s Privacy Policy is sufficient for DGP compliance as their
Privacy Policy explains how the brand’s page(s) respect the user’s privacy.

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YouTube – Age Gate
The age-gate needs to be set at least at the channel level for DGP compliance. But ideally, all videos
should be age-gated. Users who are not signed-in will be prompted to log-in or sign-up whenever an
age-gate is set at channel or video level.
Channels:
• Age-Gating can only be enabled on YouTube channels that have been upgraded to a Brand
Channel (to be requested through your YouTube representative)
• Process to follow: Settings – My channel – Channel settings – Conditional redirections – state
the rule “LOCATION,AGE,REDIRECT_LOCATION” (e.g. _UK,<18,_block) - Done Editing’
Videos:
• This is a special feature and must be requested specifically from your YouTube representative.
• Process to follow : log in as normal- video manager-Edit- Info and Settings – Advanced Settings’-
Age gates- Click on ‘Alcoholic Beverages’ –Save

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YouTube – Age Gate (cont.)

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YouTube – Transparency and UGC

At this time, YouTube does not allow for an official signpost to be included on a page unless you
have at least 100K subscribers. If this is not your case, a statement in the channel’s description
(when searching the channel) and the ‘about’ tab should be included. E.g. “This is the official
channel”.
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YouTube - FAN

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YouTube - RDM

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YouTube – Privacy
At this time, YouTube’s Privacy Policy is sufficient for DGP compliance as their
Privacy Policy explains how the brand’s page(s) respect the user’s privacy.

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Websites – Age Gate, UGC, Privacy, RDM

Age-gate mechanism

UGC Privacy
RDM

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Websites – Transparency, Privacy, RDM
The official nature of the website will be made clear through the trademark, terms &
conditions, official company information etc.

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Websites – FAN
Where: ideally on the main page at
the stage of the age-verification
mechanism, but can also be easily
introduced in the Terms &
Conditions or Responsibility tab.

Examples:
“Please only share our posts with
those who are of legal drinking age”

“Forward to those of legal drinking


age only”

“Please do not share or forward to


anyone underage”

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Mobile Apps – Age Gate and RDM

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Mobile Apps – Transparency

Where: it should be
well visible on the
main description of
the app (at the pre-
installation stage)

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Mobile Apps - RDM

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Mobile Apps – Privacy

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