Guidelines for Advertising and Marketingthat Affect Children

On completion of the Guidelines for
Advertising and Marketing that
Affect Children
CONTENTS
Foreword

02

Save the Children Japan was established in 1986 as a member of Save the Children, an international non-governmental organization established in 1919 and specialized in child support, and sincethen has implemented child support activities in various countries and regions throughout theworld including Japan.

Contents

03

Introduction

04

Use of These Guidelines

05

1 . Range of Application

06

Movements and activities to respect human rights has increased in recent years, and subsequent
to adoption of the UN Guiding Principles on Business and Human Rights, more and more attention
is paid to corporate responsibility in the society. It is within this context that the United Nations
Global Compact, Save the Children and United Nations Children’s Fund (UNICEF) developedChildren’s Rights and Business Principles (10 principles in total) in March 2012, based on recognition that a framework clearly defining corporate responsibility in the area of child’s rights waslacking. In May 2014, Save the Children Japan launched these principles in Japan together with
Global Compact Network Japan and Japan Committee for UNICEF.

2 . Definitions

06

Following this launch, Save the Children Japan organized study groups convening interested
business enterprises and specialists to discuss and exchange views on initiatives and challenges
related to implementation of the Principles. It was pointed out in one of these study groups that
concrete actions were necessary to put into practice Principle 6 (All business should use advertising and marketing that respect and support children’s rights). Thus Children’s Rights and Advertising/Marketing Review Committee consisting of NGOs, business enterprises, specialists and relatedorganizations was formed in September 2015 (chair: Tsuneo Matsumoto, President, National
Consumer Affairs Center of Japan), and developed the Guidelines for Advertising and Marketingthat Affect Children with the purpose of protecting child’s rights in advertising and marketing ofbusiness enterprises and promoting these entities’ contribution to healthy growth of children
across various industries..
These guidelines do not hold coercive power, rather they were developed with the aim to serve asa guide for advertising and marketing by business enterprises and related organizations. It is mysincere hope that all business enterprises and related organizations involved in advertising andmarketing review their practices from the perspective of their impact on children and takeconcrete actions to respect and promote child’s rights.
Lastly I would like to extend my deepest gratitude to Mr. Tsuneo Matsumoto and the Committee
members for their dedication and contribution.

2 - 1 Child/children
2 - 2 Advertising
2 - 3 Marketing
3 . Basic Principles

07

3 - 1 Advertising and Marketing that is Conscious of theDevelopment and Characteristics of Children
3 - 2 Respect for children’s human rights in the context of freedomof expression
3 - 3 Compliance with legislation and domestic
and international guidelines
4.Considerations regarding advertising presentations and methods

09

4 - 1 Considerations regarding advertising presentations
4 - 2 Considerations regarding advertising methods, etc.
5 . Preferred attitude of business enterprises towards advertisingand marketing directed to children

14

5 - 1 Efforts to conduct advertising and marketing thatwill not have an adverse impact on children
5 - 2 Establishing a division for dealing with complaints,
understanding and analyzing complaints,
and making continuous improvements
5 - 3 Collection and effective use of information from
related external organizations and groups
References

15

List of Committee Members

17

Kunio Senga
Managing Director of the Board, Chief Executive Officer
Save the Children Japan

02

ForewordContents

03

Introduction
Initiatives to support the healthy growth anddevelopment of children are essential to therealization of a sustainable society. Childhood
is a crucial period in terms of physical, psychological, emotional, and intellectual development. In 1989, the General Assembly of theUnited Nations adopted the Convention on
the Rights of the Child (CRC). This Convention
set forth four basic rights that applies tochildren everywhere, namely the right to life,
the right to protection, the right to grow anddevelop, and the right to participation. Japan
ratified the Convention in 1994.
It is the responsibility of governments to fulfil
their obligations under the CRC. This includes
the legislature, the administration, and the
judiciary. To protect and respect the rights ofchildren, governments have an obligation toenact legislation, strengthen supervisory
bodies, and educate businesses about therights of children.
On the other hand, the responsibilities not
only of governments, but of business havebecome the increasing focus of attention inrecent times. The UN Global Compact, which
was proposed by then Secretary General of
the United Nations, Kofi Annan, at the World
Economic Forum in 1999, calls on businesses
to uphold and implement ten principles in theareas of human rights, labor, the environment
and anti-corruption.
“Protect, Respect, and Remedy: a Frameworkfor Business and Human Rights” in 2008, andthe UN Guiding Principles on Business andHuman Rights in 2011, both presented byProfessor John Ruggie, UN Secretary-General’s Special Representative for Business andHuman Rights, have been endorsed by the
Human Rights Council. ISO26000, the International Standards Organization’s GuidanceStandard on Social Responsibility, the international standard for social responsibility fororganizations released in 2010, sets out sevencore subjects, including human rights andconsumer issues.
Amidst this growing consciousness of businessand human rights, the UN Global Compact,
UNICEF, and Save the Children joined forces in2012 to develop the Children’s Rights and04

Introduction

Business Principles (CRBP) as a guide forbusinesses to respect and support children’s
rights. The CRBP consists of ten principles for
activities in the workplace, marketplace andcommunity (see References for details).
Business Principle 6, which comes under themarketplace area, states that “all businessshould use marketing and advertising that
respect and support children’s rights,” including “ensuring that communications andmarketing do not have an adverse impact onchildren’s rights,” “complying with thestandards of business conduct in World Health
Assembly instruments related to marketingand health,” and “using marketing that raises
awareness of and promotes children’s rights,
positive self-esteem, healthy lifestyles andnon-violent values.”
Fair marketing and the provision of unbiased,fact-based information are extremely important factors in consumers’ purchasing
decisions. The United Nations Guidelines for
Consumer Protection, which were revised in2015, state that promotional marketing andsales practices should be guided by the principle of fair treatment of consumers.
Consumers International (CI), the worldfederation of consumer groups, sees marketing to children, particularly food marketing, asa priority area of its work. Children lead lives
as consumers under their parents and caregivers, but their level of experience of consumer
behavior and their ability to assess advertisingand marketing are less mature than those of
adults. Therefore, from the perspective ofprotecting children as “consumers,” businesses
are required to engage in responsible advertising and marketing that respects andsupports children’s rights. In this respect,
ISO26000 calls on business to first consider
the best interest of socially vulnerable groups,
including children, and not to engage in activities that would harm the interests of thosevulnerable groups.
The Guidelines for Advertising and Marketingthat Affect Children (“these Guidelines”)
provide a basic philosophy on advertising andmarketing that impacts on children, as well as
propose specific and practical concepts thatall business should uphold. In the developmentof these Guidelines, we referred to several
international guidelines concerning advertising and marketing that are conscious ofchildren. We also took into consideration thecurrent views on advertising and marketingand industry self-regulation in Japan. In doingso, our aim was to create guidelines that could
be applied by all businesses and organizations
that provide products and services across allindustries.

It is our hope that these Guidelines will serve
as a guide not only in the advertising andmarketing of products and services specificallydirected to children, but also for all businessenterprises to consider avoiding adverse
impact on children in all of their advertisingand marketing, and thus contribute tochildren’s healthy growth and development.

* See the References at the end of this document for the international guidelines that were referred to in the development of these Guidelines.

Use of These Guidelines
These Guidelines were developed with the aim of being utilized as a guide for advertising and marketingby business enterprises. Not only advertisers but other types of business enterprises and parties arealso involved in advertising and marketing. It is hoped that all business enterprises and related organizations involved in these activities will use these Guidelines as the basis for deciding on the contents of
their own in-house standards and voluntary regulations, and for deliberating on the systems they will
adopt within their organization.

Introduction Use of These Guidelines

05

1. Range of Application

3. Basic Principles

These Guidelines apply to advertising and marketing that are directed primarily to children. Even if
advertising and marketing is directed to groups other than children, it is possible that children may seethat advertising or be involved in the marketing, and there is potential for that advertising or marketing
to have an adverse impact on children. A certain level of consideration based on these Guidelines is also
required in such cases as well.

3-1

2.Definitions
Words used in these Guidelines shall have the following definitions.

2-1

Child/children

Refers to all persons under 18 years of age as defined in Article 1 of the Convention on the Rights of
the Child.

2-2Children go through different developmental processes at different ages, and have different characteristics at different stages of their development. Characteristics of early childhood include difficulty distinguishing between fantasy and reality, credulity (readily believing what they see and hear), curiosity, andan inclination to imitation (and experimentation). When purchasing and consuming products or services,children usually have limited knowledge, experience, and capacity to understand and evaluate information. Because of this, children are seen as being prone to believing the information contained in advertisements and as being easily influenced by advertising and marketing.
Advertising and marketing that are produced without regard to children’s development and characteristics have the potential to violate children’s rights, hinder their healthy development, or threaten theirhealth and safety. It is for this reason that special consideration towards children is needed when
producing advertising and implementing marketing.

Note

Advertising

Refers to all types of communications that a business enterprise (referring to all organizations, bothfor-profit and not-for-profit) directs towards consumers and society for the purposes of promoting sales
and increasing recognition of its products, services and organization.

Note

Specifically, this includes mass media advertising,such as television, radio, newspaper and magazine
advertising, advertising on online media such as
websites, social media, applications, videos, e-mail,and games, advertising in movie theaters, print
inserts, transit advertising (including advertisements
and digital signage on and inside buses and trains,
and advertising in railway stations), out-of-homeadvertising such as billboards, posters, flyers, direct
mail, pamphlets, free papers and magazines, POPadvertising, and displayed and distributed items(in-store advertising to sell products and/or provide
services). It also includes communication in which the
product itself acts as the medium (product naming,
packaging, advertisements and labeling on packaging, etc.) and product catalogs. Here, “website” notonly refers to websites produced and published by
the enterprise itself, but also includes advertisements
provided by web management businesses.

Advertising and Marketing that is Conscious of the Development
and Characteristics of Children

3-1-1

It is believed that children of four or five years ofage or younger have not achieved sufficientcognitive development to distinguish between
program and advertising, and that children of up toseven or eight years of age are not able to understand the persuasive intent of advertising (tostimulate a desire to buy the product or service)(APA 2004). Based on these developmental charac-

teristics of children of these ages, statutory andvoluntary regulations exist to protect children fromadvertising and marketing. For example, in Sweden
and Norway, it is prohibited by law to advertise tochildren younger than 12 years of age. The International Chamber of Commerce and other industry
organizations also have voluntary regulations andother guidelines (see References for details).

Children’s knowledge and experience abouttransactions is limited and they lack the capacity
to assess or pay for them. So that children are notdisadvantaged by the impact of advertising andmarketing, consideration needs to be given to thedevelopmental characteristics, not just of smallchildren, but all children under 18 years of age.

Ensure the accuracy and credibility of information

The display, language and presentation methods used for the information that is communicated in advertising and marketing should be easy for children to understand, and business enterprises should work toensure the accuracy and credibility of that information to ensure that the children that the advertisingand marketing are directed to will not misunderstand.

2-3

3-1-2

MarketingMarketing refers to the various activities undertaken by an enterprise directed to the marketplace with theobjectives of creating, maintaining and expanding a market (demand) and building and maintaining relationships
with consumers.

Avoid unreasonable, unfair and deceptive advertising and marketing

Business enterprises must give ample consideration to whether their advertising and marketing containany elements that are unreasonable, unfair or deceptive in light of children s development and charac-

teristics. Further, even advertising or marketing that would not ordinarily be considered unreasonable,
unfair or deceptive can potentially have an adverse impact on children, so advertisers need to takeparticular care from this perspective as well.

Note

Specifically, this includes market research aimed atunderstanding consumer needs, the planning anddevelopment of products and services to meet those06

1. Range of Application

2.Definitions

needs, setting prices, sales promotions focused on
advertising and other communication activities, andthe establishment of distribution channels.

3-1-3

Ensure safety

Advertising and marketing must not threaten children s lives or health.

3. Basic Principles

07

3-1-4

Respect for diversity

Advertisers should give ample consideration to ensuring that advertising and marketing respect diversi-

4. Considerations regarding advertisingpresentations and methods

ty, and that they do not encourage various types of discrimination or prejudice, nor force or imply various
ﬁxed notions.

3-1-5

Avoid advertising and marketing that is harmful
or infringes on human rights

Advertising and marketing must not have any adverse impact on children, such as infringing on their
human rights or rights as consumers, or hindering their healthy development. In particular, presentations of violence or excessive sexual presentations can have an adverse impact on children, dependingon their age and stage of development, so due caution should be exercised in this regard.

3-1-6

Protection of children’s personal information or their privacy

Advertising and marketing must not infringe on children’s personal information or privacy. Children’s
personal information must be handled as carefully as, if not more so than, that of adults. It should be
noted that children have difficulty understanding how their personal information will be used or thegravity of the risks of such information being leaked, so when obtaining personal information, advertisers should exercise due care, such as obtaining permission from the child’s parents or caregivers.

3-1-7

Consideration of sustainable consumption

Children are in the process of developing their ability as healthy consumers, and it is the responsibilityof adults to teach them properly about appropriate sustainable consumption so they may mature into
healthy consumers. Business enterprises, in particular, must take care not to encourage excessive
consumption by children in their advertising and marketing.

3-1-8

Respect for children’s human rights in the context of freedom of expression

Freedom of expression and freedom of speech are guaranteed for advertising and marketing under theConstitution, and creativity in this regard should be respected. However, the protection of children’s
human rights (including children’s rights as consumers) takes precedence over these freedoms. Businessenterprises should conduct their advertising and marketing on the basis of this principle.

3-3

3. Basic Principles

4-1-1

Imposition of advertising, persistent recommendation of
products and services

1

Advertisers must not excessively recommend products and/or services through such methods as forcing
children to look at advertisements or repeatedly showing them.

2

Presentations should not encourage the rushed purchase of products or services or unduly emphasize theirrarity (for example, expressions such as “one-time only offer,” “not available anywhere else,” and “limited
quantities/time”) as they have a major impact on children’s decision-making and purchasing behavior.

4-1-2

Encouraging pestering

Advertisers should avoid presentations that urge children to ask their parents or caregivers or other adults
to purchase a product or service or that encourage children to pester those adults until they agree to buy the
product or service.

4-1-3

Exaggeration or emphasis of benefits or features

1

Presentations and claims regarding the benefits or performance gained from the use of a product orservice must be based on objective facts. Also, if there is no expectation that those benefits or performance
would be gained equally by all purchasers (users), or if the benefits or performance are limited, this must
be expressly indicated using clear presentations that a child could easily understand. The same applies forcases in which there are particular conditions that must be met to achieve those benefits or performance.

2

Presenting those benefits or performance in a manner that exaggerates them or emphasizes certain parts,
or presents them in such a way that something that is not certain is made to seem definite will cause
children to hold excessive expectations or misconceptions about the product or service, so care should be
exercised.

4-1-4

Exaggeration or emphasis of pricing, or lack of clear indication ofwhat is not included in price

1

Advertisers should take care to ensure that advertising presentations that exaggerate or emphasize thatthe price of a product or service is much lower than usual, or that it is a bargain, do not make it difficult
for children to understand or mislead them into believing that the price is markedly lower than it actually
is. Also, indications of discount percentages or amounts should be given accurately as a comparison to theusual price, in accordance with the rules on price indications in the Act on Unjustifiable Premiums andMisleading Representations.

2

For anything that is not included in the initial price of the product or service being advertised (e.g., a caseor bag that is sold separately, batteries, recharger, accessories, etc.), it must be clearly indicated that suchitems must be purchased separately.

Compliance with legislation and domestic and international guidelines

If legislations or treaties that apply in Japan include provisions concerning advertising and marketing tochildren, the relevant business enterprises must comply with them. The same shall apply for guidelines
and codes of conduct established by international organizations and the like, and to voluntarystandards set by industry bodies, self-regulatory organizations, and other relevant agencies.

08

Considerations regarding advertising presentations

Business enterprises’ constructive contribution to the relationshipbetween children and their parents and caregivers

The protection, supervision and guidance of children is fundamentally the responsibility of their parents andcaregivers, nevertheless it is desirable that business enterprises contribute to the relationship between
those parents and caregivers and their children in a constructive manner. Accordingly, it is preferable that,when business enterprises consider their advertising and marketing, they also do so from the viewpoint thatparents and caregivers may be led to believe that such advertising and marketing would be detrimental totheir children’s education or that they would not want their children to see it.

3-2

4-1

4.Considerations regarding advertising presentations and methods09

4-1-5Presentations that cause fear or anxiety

Depending on the characteristics of the product or service, to avoid various dangers, there must bea clear indication in the product’s or service’s advertising that the use of safety equipment (e.g.,helmet, knee/elbow guards, safety harness, etc.) is required.

1

Violent presentations, psychotic presentations, and mock-threatening presentations may cause fear
or anxiety in children, so due care should be exercised.
32

Advertising presentations that, even if created without such an intent, cause an association withpsychotic or violent incidents or incidents that infringe on children’s rights have the potential toprovoke strong feelings of fear and anxiety in children. If such presentations have been used, advertisers are recommended to review the presentations themselves or to consider the advertising medium
used or timeslot in which the advertisement is aired.

Where necessary, advertisements should clearly indicate the target age of the product or service
being advertised.

4

If the method of use, length of time of use, or quantity per use of a product or service is explained,
the physical health and safety of children should be taken into consideration and care taken to ensurethat children’s sound lifestyle habits are not impeded.

If a child sees advertisements for products and services that are not primarily directed to children, it
may frighten or cause anxiety in him/her. If presentations of this nature have been used, advertisers
are recommended to review the presentations themselves or to consider the advertising medium
used or timeslot in which the advertisement is aired.

4-1-11

3

4-1-6

1

2

Presentations that are suggestive of discrimination,
ostracism or bullying

Advertisers must not employ presentations that appear to condone any kind of discrimination forreasons of ethnicity, culture, religion, sex, occupation or social vulnerability, i, or presentations thatare suggestive of bullying.
Presentations that suggest or imply that not buying or using a product or service will cause problems
with friendships or result in less acceptance by peers may cause emotional instability in children or
provoke rifts between friends, so advertisers should exercise care regarding such presentation.

4-1-7

Presentations that force fixed notions

Advertisers should exercise care regarding presentation that force or imply fixed notions of genderroles, family values or the like.

4-1-8

Presentations that are excessively sexual1

Advertisers should exercise due care regarding presentations that unnecessarily encourage interestin sex, or excessively stimulate sexual desire, or provide a feeling of discomfort or emotional distress,
in immature and highly sensitive children.

2

If a child sees advertisements for products and services that are not primarily directed to children,
there is still a possibility that such advertisements could excessively stimulate interest in sex or
sexual desire in that child. If such presentations have been used, advertisers are recommended toreview the presentation themselves or to consider the advertising medium used or timeslot in which
the advertisement is aired.

4-1-9

Acts or presentations that could be imitatedChildren often imitate acts and presentations that they see in advertisements either consciously or
unconsciously. In light of that possibility, when including acts or presentations in advertisements thathave the potential to be imitated by children, advertisers should take care that such acts or presentations will not have an adverse impact on children.

4-1-101

10

2

Presentations that could provoke danger or misuse

Presentations that condone or implicitly encourage smoking anddrinking of alcohol by children

Advertisers must not employ presentations that condone or implicitly encourage smoking and drinking
by children.

4-1-12Presentations that undermine children’s healthy food habits

Given the important role that diet plays in a child’s healthy development, advertising of food (all typesof food products including health food products and beverages including soft drinks) should promotechildren’s healthy, regular food habits. For this purpose advertisers should take care to ensure that they
do not employ presentations that contravene public dietary guidelines. Particular caution should be
exercised regarding the following:
Refrain from presentations that promote excessive intake of food containing harmful ingredients that
may have adverse impact on child health, and diets that are imbalanced in nutrition.
Refrain from presentations that promote eating too quickly or in large quantities, or that accept andencourage picky eating.
If an advertisement depicts people eating or drinking, refrain from presenting quantity of food or drinkthat would be considered over-eating or unreasonable dieting in children of the target age group.

4-2

Considerations regarding advertising methods, etc.

4-2-1

Excessive use of premiums and giveaways

If conducting giveaways such as gifts of the product or service or a premium, advertisers should ensurethat the presentations employed do not excessively stimulate a desire to gamble or inclination to buy
in children. Particular caution should be exercised regarding the following:
Ensure that a parent’s or guardian’s permission is obtained using proper methods when children enter
the giveaway.
Clearly indicate in the advertisement the minimum terms and conditions for the giveaway, including
the period that entries will be accepted, how many entries will win, and how and when winners will beannounced.
If detailed information about the giveaway, including terms and conditions, is to be published, clearly
indicate the medium or media on which such information will be published, when it will be published,
and other necessary details.

Advertisers should take care to ensure that presentations in advertising do not cause children to use
the product or service in a dangerous or incorrect manner.

4.Considerations regarding advertising presentations and methods

4.Considerations regarding advertising presentations and methods

11Precautions when using characters, experts, or celebrities toendorse a product or service

If certain particular conditions must be met to be eligible to enter the giveaway, such as having topurchase multiple products, indicate this clearly in a manner that children will understand prior topurchase.

4-2-5

If the announcement of winners and other results are to be made public, take care that children’s
privacy is not infringed by the publication of personal information.

When doctors, teachers, experts in the related field, or other persons that children would recognize as
being qualified, or popular celebrities or characters appear in advertisements and endorse a product orservice, care should be taken that this does not stimulate children’s excessive expectations or miscomprehensions about the features and/or quality of the product or service.

If entering the giveaway has the potential to impose a financial burden, indicate this clearly in amanner that children will understand.
Take care to avoid presentations that would mislead children that receipt of the product or service
giveaway or prize is a certainty or that the chances of receiving it are higher than they actually are.

4-2-2

4-2-6
1

When using children in advertising, advertisers should take care not to infringe on the human rightsof the child. Also, the health and safety of children should take top priority in the production of theadvertisement, including filming, and safety should be ensured.

2

Advertisers should keep the following points in mind regarding the impact on children of seeing
advertisements containing children.

Excessive inducement to join membership clubs

If making children’s membership in a club a condition of purchase of a product or service, advertisers
should ensure that the presentations employed do not excessively stimulate a desire to gamble or
inclination to buy in children. Particular caution should be exercised regarding the following:
Ensure that a parent’s or caregiver’s permission is obtained using proper methods when children join
the club.
Clearly indicate in advertising, in a manner that children will understand, the purpose for which membership details will be used.

Precautions when using children in advertisements

Exercise caution regarding presentations that may invoke an excessive desire to purchase in children
seeing the advertisement or that may have an adverse impact on children if they were to imitate theacts they see in the advertisement.
Even in cases where children appear in advertisements for and endorse products and services that are
not primarily directed to children and that children would not normally buy or use, take care that theadvertisement would not have an adverse impact on children seeing the advertisement.

If joining the club has the potential to impose a financial burden, indicate this clearly in a manner thatchildren will understand.

4-2-7
4-2-3

Unrealistic presentations using special techniques

Given today’s circumstances, in which various special techniques to enhance the effectiveness of advertising are being developed every day, if such techniques are to be used in advertising directed to children,
consideration must be given to the developmental characteristics of children, namely that they areeasily influenced by advertising, easily believe things they see and hear, and are highly sensitive.
Caution must be exercised when using special techniques to ensure that they do not cause children to
assume fantasy worlds to be reality and that they do not stimulate children’s unrealistic expectationsof the product or service.

4-2-4

Precautions for advertising and marketing in places where children
receive education and on their school commuting route

Business enterprises should take care to avoid advertising or marketing of products and services thatwould hinder the healthy development of children in schools and other places where children receive
education and on their routes to and from school. The same also applies to acts resembling sales
promotions of products and services through educational programs and various social contribution
activities.

Clear distinction between program/editorial content and advertising

If advertising exploits the fact that small children have not achieved sufficient cognitive development todistinguish between program/editorial content and advertising to make them think that the advertisement is part of or an extension of the program or editorial content, it has the potential to mislead them.
For this reason, advertisers need to strive to make children understand that their advertisements are
separate from the program or editorial content. Further, regarding techniques in which a particular
product is placed in the program or article for endorsement, care should be taken with the presentationand composition of that placement to ensure that children can understand that the endorsement of the
product is separate from the program or editorial content.

12

4.Considerations regarding advertising presentations and methods

4.Considerations regarding advertising presentations and methods

13

5. Preferred attitude of business enterprises

towards advertising and marketing directed to children

References
International Guidelines, Standards, Documents, etc. Related to These Guidelines
UNICEF, UN Global Compact, Save the Children：Children’s Rights and Business Principles (CRBP): 2012

5-1

Efforts to conduct advertising and marketing that will not have an
adverse impact on children

Gaining the trust of consumers through advertising and marketing is an issue of extreme importancefor business enterprises. In particular, in terms of the relationship between children and advertising, by
not conducting inappropriate advertising that would have an adverse impact on children, business enterprises can indicate their stance of respecting the rights of children.
It is important that businesses endeavor to identify likely problems and potential challenges prior to
conducting advertising and marketing, and to resolve those problems and challenges. If a problem arises
as a result of an advertisement, businesses should take appropriate action, such as immediately canceling or correcting the advertisement or marketing.

5-2

Establishing a division for dealing with complaints, understanding
and analyzing complaints, and making continuous improvements

Complaints and opinions from consumers (including children) concerning advertising and marketing are
an important source of information about how those advertising and marketing are being perceived bysociety. Businesses need to accept complaints, understand and analyze complaints and opinions
expressed by consumers who are concerned about advertising or marketing hindering children’s healthy
development or having an adverse impact on children, and strive to make continuous improvements totheir advertising and marketing by establishing a division for handling complaints and opinions fromconsumers (customer service office, etc.) or using an outside organization.
Further, advertising- and marketing-related divisions should proactively coordinate with the complaints
handling division and, where necessary, incorporate the views of consumers in advertising production
and marketing, as well as strive to avoid the recurrence of inappropriate advertising presentations.
Businesses are asked to refer to the JIS standard on responses to consumer complaints (JIS Q10002)(see References for details).

5-3

Collection and effective use of information from related externalorganizations and groups

Consumer complaints and opinions about advertising are made not only to the consumer service
divisions of businesses, but also to a variety of external related organizations and groups. These include
industry organizations, advertising review bodies, government agencies, consumer affairs centers,
consumer groups, and media companies. Businesses need to proactively collect such external information and, if it is determined that there have been inappropriate presentations or other problems, takesincere action in response, while at the same time using that information in its efforts to make continuous improvements.
Effective means of achieving this include placing monitoring requests with consumer groups andconducting hearings of related external organizations and groups. Another method worth considering
is to obtain advice from a specialist perspective, by seeking the opinion of advertising review bodies
prior to launching advertising or marketing, and consulting with experts in children’s development andpsychology.

Principle 1

All business should meet their responsibility to respect children’s rights and commit to
supporting the human rights of children

Principle 2

All business should contribute towards the elimination of child labor, including in all
business activities and business relationships

Principle 3

All business should provide decent work for young workers, parents and caregivers

Principle 4

All business should ensure the protection and safety of children in all business activities
and facilities

Principle 5

All business should ensure that products and services are safe, and seek to support
children’s rights through them

Principle 6

All business should use advertising and marketing that respect and support children’s
rightsPrinciple 7

All business should respect and support children’s rights in relation to the environment
and to land acquisition and use

Principle 8

All business should respect and support children’s rights in security arrangements

Principle 9

All business should help protect children affected by emergencies

Principle10

All business should reinforce community and government efforts to protect and fulfil
children’s rights

International Chamber of Commerce (ICC)
Consolidated Code of Marketing and Advertising Communications Practice 2011 revision
World Health Organization (WHO)A Framework for Implementing the Set of Recommendations on the Marketing of Foods andNon-alcoholic Beverages to Children: 2012
Set of Recommendations on the Marketing of Foods and Non-Alcoholic Beverages to Children: 2010
ISO26000 (International Standards Organization’s Guidance on Social Responsibility): 2010
United Nations Guidelines on Consumer Protection 2015 revision14

5. Preferred attitude of business enterprises towards advertising and marketing directed to children

References

15

Children’s Advertising Review Unit (CARU)
Self-Regulatory Program for Children’s Advertising: 2014
ISO 10002:2004 (JIS Q10002:2005; Quality management – Customer satisfaction – Guidelines
for complaints handling in organizations)
American Psychological Association (APA)
Report of the APA Task Force on Advertising and Children: 2004

List of MembersChildren’s Rights and Advertising/Marketing Review Committee
Position

Name

Affiliation

Chair

Tsuneo Matsumoto

National Consumer Affairs Center of Japan, President

Deputy Chair

Hidemi Tomita

Lloyd’s Register Quality Assurance Limited,
Senior Project Principal

LeaderIsao Hayashi

Ad Legal Office Chief(Former Deputy Secretary-General of Japan Advertising Review Organization)

MemberEmiko Amano

Kanto Gakuin University Faculty of Business Administration,
Associate Professor

MemberNaoko Imaizumi

Japan Advertising Review Organization,
General Management Committee

Member

Keiichi Ujiie

Ushio Inc., Executive General Headquarters Personnel and
Administration Strategy Division, Risk Management Office, CSR Manager

MemberKeisuke Ota

Global Compact Network Japan, General Manager

MemberEmi Kato

Parent and Child Consumer Education Support Center, Director

MemberTsuneyuki Kobayashi

International Chamber of Commerce Japan Committee,
Secretary-General

MemberKiyomi Shimizu

Association of Experts on Consumer Affairs, Executive Director

MemberMitsu Shippee

Sony Corporation, CSR Section,
Corporate Communications and CSR Department Senior Manager

MemberMariko Tokoro

Japan Society of Child Science, Trustee

MemberYouzou Nakao

Ajinomoto Co., Inc., CSR Department General Manager

MemberYukiko Furuya

Consumer Conference for Sustainability, President

Member

Hidekazu Hosokawa

Lee Japan Co., LTD., Director

Member

Hideki Matsuoka

Asia-Pacific Human Rights Information Center (Hurights Osaka),
Researcher

MemberKunio Senga

Save the Children Japan,
Managing Director of the Board, Chief Executive Officer* Note that Committee Members’ positions are as of the time of issuance of the Guidelines – October, 201616

References

List of Committee Members

17Issued by: Save the Children Japan

Cooperation : Global Compact Network Japan
Contact: Save the Children Japan
Corporate Partnership Department
http://www.savechildren.or.jp

November 2016