Mars Marketing Code for Human
Food Governance Report
2018© COPYRIGHT MARS INCORPORATED | CONFIDENTIAL

Introduction

Our Responsible Marketing
Commitments

How we update and train on
our Code

How we govern responsible
marketingOur compliance results

Continuous improvement

1.
Introduction
It is our honor to present Mars’ first annual governance report that tracks our progress in implementing the Mars Global Marketing Code for Human Food (‘the Code’). Since the launch of
our Code in 2007, we have been recognized as an industry leader, including for our commitment to not market to children under 12 years old.
The Code guides how Mars and its brands communicate and interact with consumers. It is grounded in our Five Principles and enables us to drive positive change in responsible marketing
across our industry.
Mars’ number one ranking in the Marketing category in the 2018 Global Access to Nutrition Index testifies to the strength of the commitment Mars has made.
Our ambition is to continually evaluate and improve upon our governance practices related to the Code. In 2015, we embarked on a journey to tighten our internal and external governanceof the Code to help ensure compliance and enable confident communication of our commitments to our Mars Associates, to our consumers and to key external stakeholders.
This report provides more detail on Mars’ approach to governance of the Code, , our initial success, as well as areas for us to improve. We are encouraged by our 2017 results and thelessons that this process has uncovered, which will enable us to enhance our responsible marketing efforts. It is our hope that the findings shared here will contribute to the growing
understanding of the importance of responsible marketing practices and spark further action across the industry.

The Mars Global Marketing Code for Human Food Governance Board

Jacqui Stephenson ,Global Responsible
Marketing Officer,
Mars Wrigley Confectionery

Orla Mitchell ,Global Chief Marketing
Officer, Wrigley
Mars Wrigley Confectionery

Clarence Mak ,Global Chief Marketing
Officer,Mars FoodBlas Maquivar ,President, Global Chocolate
Business Unit
Mars Wrigley Confectionery

2

Rankin Caroll ,President, Global Fruity
Confections Business Unit
Mars Wrigley Confectionery

Jim Murphy,
Global Chief Customer
OfficerMars Wrigley Confectionery

Introduction

Our Responsible Marketing
Commitments

How we update and train on
our Code

How we govern responsible
marketingOur compliance results

Continuous improvement

2.
Our Responsible Marketing Commitments – the Mars Global Marketing Code for Human Food
The Mars Global Marketing Code for Human Food is Mars’ industry-leading commitment to address and govern marketing issues. The Code sets out the standards that guide the way that Mars and its
brands communicate and interact with consumers. It is is grounded in our Five Principles and sets expectations in terms of our engagement and behaviour towards our consumers.
The purpose of the Code is to serve as a framework through which Mars uses marketing to drive positive change, and industry peers for what we believe to be right for consumers. We base these beliefs,
as we do with all of our positions at Mars, on strong science, consumer insight and a sensitivity of concerns in the external world.

Placement commitments
The keycommitments of
the Mars Global
Marketing Code for
Human Food

Applicable to all
global marketing
communications

No marketing
communications
directly targeted tochildren under 12/
13 for digital

No data collection
for children under
16 years oldContent commitments

No placement ofvending machines
or event
sponsorship inprimary schools

25% audiencethreshold(industry-leading)

43

Encourage healthy
lifestyles and notcondone excessive
consumption

Advertising
No use of celebrities
consistent with theor licensed
Five Principles andcharacters which
our advertisingappeal to children
guidelines
under 12

Strict governanceof our brandcharacters – only
directed at adults

No give-aways or
incentives linked
to childish themes

Responsible
promotions designthat doesn’t target
childrenIntroduction

Our Responsible Marketing
Commitments

How we update and train on
our Code

How we govern responsible
marketingOur compliance results

Continuous improvement

3.
How we update and train on the Code
▷ UPDATING OUR CODE
The Code is a living document, which we revise every three years, to ensure that it is consistent with our corporate values and principles, as well as changes in the marketplace and within our
Company. Based on our rigorous governance process, we are able to identify areas for improvement. This is combined with our consumer-focused approach which ensures that we are aware ofevolving stakeholder and consumer expectations of what constitutes responsible marketing.
In 2018, we launched the fourth iteration of the Code, which strengthens our responsible marketing practices and ensures that they reflect the continued evolution of consumer marketing anddigital channels.
The Mars Marketing Code ‘Drivers License’▷ TRAINING OUR ASSOCIATES & PARTNERS TO APPLY OUR CODE
We ensure that all relevant Associates and agency partners are aware of our responsible marketing commitments,
understand their responsibility to comply with them and are trained to deliver on them. Training on the Code is a key part of
the Mars University Learning Program, and is delivered online and during our annual marketing meetings. Training materials
are updated and cascaded globally each time we update the Code, included clear communication of commitments that havebeen updated. To support training and compliance, we create detailed guidelines and case studies that are easily accessible,
to help Associates understand the practical application of our Code and learn from real-life scenarios.

To ensure that our Associates and agency partners who work onmarketing execution understand our commitments in the Code, wehave established a mandatory ‘Drivers License’. The Drivers License isawarded and renewed annually after passing an online test, which allMarketing, Sales, and Corporate Affairs Associates, as well as theiragency partners, retake each year.

▷ A NOTE FROM OUR AGENCY PARTNERS ON USING OUR COMPLIANCE INSIGHTS TO EVOLVE AND IMPROVE

MEDIA CONTENTMEDIA PLACEMENTMEDIA PLACEMENT“Our skilled compliance team reviews media content releasedby Mars. We conduct rigorous quarterly reviews of our audit
data, ensuring that our audits capture the ever-evolving
nature of responsible marketing at Mars. Our findings areanalysed, disseminated amongst Associates, and used tofurther shape the Code, ensuring that Mars is always doing theright thing for its consumers.”“We work vigilantly with our media partners to monitor andtransparently report the placement of Mars content to ensure
the highest levels of compliance. We view this as an essential
part of our role as an agency and by publishing these results it
is our goal to set the highest standards for ourselves and theindustry.”“We are committed to full accountability regarding thecompliance of our media-buying to the Code. We work closelywith Mars Associates to ensure that content is placed onchannels that comply with Mars’ responsible marketing
criteria. Self-reporting our compliance helps us by highlighting
the regions and the channels in which we can improve in the
future.”4

Introduction

How we update and train on
our Code

Our Responsible Marketing
Commitments

How we govern responsible
marketingOur compliance results

Continuous improvement

4.
How we govern responsible marketing▷ RESPONSIBLE MARKETING GOVERNANCE STRUCTURE

Governance of the Code has driven transparency and accountability to ensure that we ‘walk the
talk’ regarding our responsible marketing commitments through all of our marketing
communications. Our drive towards a wide-reaching governance model enables us to conduct our
responsible marketing processes uniformly across our Confectionery and Food segments , and topractice transparency in our compliance reporting.

The importance of responsible marketing to Mars is reflected by the Governance structure
we have put into place. The Governance Board has responsibility for the supervision andmanagement of our marketing practices in line with the Code. They are supported in
implementing this responsibility by a Steering Team, with members representing functions
relevant to Mars’ responsible marketing commitments, as well as a network of regional
Ambassadors within Mars Wrigley Confectionery.

Our responsible marketing governance structure (as shown on the right) reflects the importance weascribe to good governance. It involves a representative selection of functions which manage ourmarketing activities and approach to responsible marketing, as well as the highest levels of Marsleadership, to ensure accountability and transparency.

Mars made an industry-leading commitment to establish a streamlined governance framework
formalizing existing ad hoc governance processes and driving increased compliance with our
responsible marketing commitments.
We have developed a comprehensive and holistic approach to governance centered around five
work streams.

WORKSTREAMSOF RESPONSIBLE
MARKETING
GOVERNANCE

Third party
audit & annual
review

Internal &External
Communication

Regional
governance& escalation

Enhanced
DigitalGovernance

Reviewing
and updating
the Code5Introduction

Our Responsible Marketing
Commitments

How we update and train on
our Code

How we govern responsible
marketingOur compliance results

Continuous improvement▷ THIRD PARTY AUDIT AND ANNUAL REVIEW METHODOLOGYTo ensure effective implementation of our Code*, we conduct third-party auditing across our
top advertising spend markets:
•
•
•
•
•
•

Australia
CanadaChina
FranceGermany
India

•
•
•
•
•

Middle East & North
AfricaMexicoNetherlands
New Zealand
Poland•••••Russia,Spain
Switzerland
the UK
the USCONTENT COMMITMENTS COMPLIANCE AUDIT: Ebiquity was appointed as the third-party
auditor to assess the compliance of our marketing communications and media content acrossprint, TV, digital, social media and posters. They perform 29 compliance checks to ensure thecontent of our marketing communications, not just their placement, is compliant with the
Code.
PLACEMENT COMMITMENTS COMPLIANCE AUDIT: We also work with MediaCom andStarcom, our media planning and buying agencies, to collect data on our compliance with ourcommitment not to place our marketing communications on channels where children under 12
years old make up more than 25% of the total audience (and children under 13 on digitalplatforms). We developed a scorecard to be completed by all 15 markets which includes thepercentage compliance and number of breaches per channel, across six types of media
channel.

CONTENT COMPLIANCE CHECKS

Ebiquity performs compliance checks according to the principles set out in the Mars Marketing
Code that have been translated into 29 indicators such as whether celebrities or licensed
animated characters that primarily appeal to children under 12 years are being shown. For
each piece of marketing communication and media content across 17 markets and 5 channels,
Ebiquity’s multi-lingual monitors check for the presence or absence of each indicator, give an
overall compliance score and categorize results for each country by segment, brand, product,channel, media and theme. Quarterly reports provide full details of all areas of noncompliance, including commentary on any debateable issues enabling Mars to respond quickly
to marketing activities that contravene the principles of the Code.

In order to strengthen our methodology, from next year, we plan for an independent, thirdparty audit to be carried out in randomized markets. We will compare the third-party data withthe data of the buying agencies to ensure that we are providing an accurate, transparent
picture of compliance at Mars.

* The audit is against our own self-regulatory Code, and not an audit of our compliance to the law.

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Introduction

Our Responsible Marketing
Commitments

How we update and train on
our Code

How we govern responsible
marketingOur compliance results

Continuous improvement▷ CASE STUDY: ENSURING BRAND SAFETY ON DIGITAL CHANNELS
THE CONTEXTIn November 2017, an issue was discovered in the UK with Mars advertisement placement on Google platforms adjacent to highly inappropriate content, including extreme violence, sexualised
imagery of children and religious extremism. The issue was in direct violation of our Code’s ‘Advertising Guidelines’. This incident was not isolated as similar breaches had also occurred in
December 2016 and March 2017. The breach in question would not have been avoided through application of technologies that we already employ – ad verification – due to technical limitations
Google and YouTube put on these third-party services many marketers employ.
THE ACTIONS WE TOOKThe first step was to ensure the safety of our brands by pulling all media investments from YouTube until we could find a workable solution with Google. In order to do the right thing, thismeant that starting on Thanksgiving weekend, between November 2017 and March 2018, we did not place any advertising on YouTube and only allowed advertising on select Google channels
for which we could verify our brand safety.

We then took the following steps, after spending considerable amount of time with our agencies and industry peers to chart a path forward:
1. Benchmarked the reach of the breachto Mars (media investment, media
reach, campaigns and brands involved)

2. Risk-assessed Google’s products
across the globe and authorised theresuming of less risky and essential
media investments for select business
units

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3. Identified the steps we needed totake and articulating the asks of Google
for better ensuring the responsibility
and safety of our advertising
placement.

4. Developed and executed a strategy
for action to ensure 1) compliance by
our agency given the current situationand 2) collaboration with Google toresolve the issue in a sustainable
manner

THE OUTCOMES WE ACHIEVED
As a result of Mars’ and the advertising community’s engagement, Google committed themselves to making brand safety their top priority for 2018. In that they are making four significant steps toaddress the issue:• Providing better controls for content and comments through technology, new employees, and partnering with subject area NGOs/experts• Limiting the number of channels that can place advertising and focusing technology and employees monitoring to those spaces• Manually reviewing certain types of ad placement• Providing clear classification for content categories to identify the levels of brand risk
Moreover, through our proactive approach to them, Google have also made a number of steps to ensure we continue to be involved with future safeguarding of advertising placement:• Google have invited us to act as third party verification partners through their beta testing period• Google are involving Mars in a future Brand Safety Council

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Introduction

Our Responsible Marketing
Commitments

How we update and train on
our Code

How we govern responsible
marketingOur compliance results

Continuous improvement

5.
Our Compliance Results▷ ASSESSING GOVERNANCE PROGRESS IN 2017
GOVERNANCE PILLAR & COMMITMENT

2017 PROGRESSREVIEWING AND UPDATING OUR CODE
Review, strengthen and update our Code in line with the continued evolution of
consumer habits and marketing practices

Stronger and updated commitments in fourth iteration of the Code, published in 2018

ENHANCED DIGITAL GOVERNANCE
Establish specific commitments to ensure our Digital marketing communications reflect
the evolving Digital Marketing ecosystem

General Data Protection Regulation (GDPR) compliance and a commitment to stop collecting datafrom under 16 years old globally incorporated in the fourth iteration of the Code published in 2018

INTERNAL & EXTERNAL COMMUNICATION
Roll out internal communication and training on the MMC, combined with external
engagement to level the responsible marketing playing field

841 people (531 Associates, 310 agency team members) have passed their Driver’s License andtaken the eLearning moduleMars is recognized as leader in responsible marketing in 2018 Access To Nutrition Index ranking

LOCAL & REGIONAL GOVERNANCE
Establish local governance processes and escalation channels to ensure systematized
governance throughout the global organization



MMC Ambassadors appointed across Mars Wrigley Confectionery in every major market
Creative Content Review rolled out across all packaging activations in Confectionery
Periodic Marketing Review (PMR) meetings in place in key markets

THIRD PARTY AUDIT & ANNUAL REVIEW
Conduct a third-party audit of Mars’ level of compliance with responsible marketing
commitments

Completed the first annual audit results with 97% compliance for media content and 95.8%
compliance for media placement, weighted by media spend.

▷ EXPLAINING THE RESULTS FROM THE THIRD PARTY AUDITIn the following pages, we present the results from the 2017 third party compliance audit. The results are split into two groups – reflecting Mars’ compliance with our responsible marketing
commitments on the content and placement of our marketing. These reflect the two types of responsible marketing commitments which we make in the Code:• Placement: not to place our marketing communications on channels where children under 12 years old make up more than 25% of the total audience (and children under 13 on digitalplatforms). The result represent the % of our marketing communications which was placed in media in compliance with this commitment.
• Content: to develop marketing communications content which aligns with our commitments within the Code, represented by 29 compliance checks, including theme and content targeting, theuse of brand, licensed characters and celebrities, representation of consumption, the portrayal of children, application of our advertising guidelines and digital and privacy. Similarly withplacement, the results represent the % of the reviewed marketing communications which were deemed compliant.
In addition to showing our global compliance, in both cases we also break down our compliance results by Mars Segment, region and type of media or section of our Code.

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Introduction

Our Responsible Marketing
Commitments

How we update and train on
our Code

How we govern responsible
marketingOur compliance results

Continuous improvement▷ MEDIA PLACEMENT COMPLIANCE 2017
BY REGIONOVERALL COMPLIANCE

2.0%
North
America

98.0%

Europe98.3% 1.7%

Latin
AmericaCompliant

99.1%

FOOD

99.7% 0.3%

93.9% 6.1%

92.1% 7.9%

Non-compliant
BY CHANNELBY SEGMENT

0.9%

97.9% 2.1%

MiddleEast &
Africa

2.0%

98.0%

CHOCOLATE*

2.1%

97.9%

WRIGLEY*

Non-compliant
Compliant

9*The compliance numbers for Chocolate and Wrigley are reported separately as the audit was conducted before the merging of the two Segments into Mars Wrigley Confectionery

National digital

94.7%

5.3%

Publishing

99.2%

0.8%

Shopper digital

98.7%

1.3%

Social media

99%

1%

TV/Cinema/Radio

99.2%

0.8%

Posters & billboards

97%

3%

Asia
Pacific

Introduction

Our Responsible Marketing
Commitments

How we update and train on
our Code

How we govern responsible
marketingOur compliance results

Continuous improvement▷ MEDIA CONTENT COMPLIANCE 2017
BY REGIONOVERALL COMPLIANCE

3%
North
America

Europe96% 4%

97% 3%
Middle East
& Africa

Latin
America

100% 0%98% 2%

89% 11%

97%
CompliantNon-compliant
BY MARS MAREKTING CODE SECTION

BY SEGMENT

2.8%

97.2%

FOOD

2.1%

97.9%

CHOCOLATE*

4.7%

Advertising guidelines

99%

1%

Characters & Celebrities

97%

3%

Digital & Privacy

74%

26%

Targeting children

96%

4%

Portrayal of children/adults

99%

1%

Responsible
promotions/consumption

97%

3%

Non-compliant

95.3%

WRIGLEY*

Compliant

10*The compliance numbers for Chocolate and Wrigley are reported separately as the audit was conducted before the merging of the two Segments into Mars Wrigley Confectionery

Asia
Pacific

Introduction

Our Responsible Marketing
Commitments

How we update and train on
our Code

How we govern responsible
marketing

The rigorous audit of our responsible marketing commitments has quantified the successful
implementation of our Code, while identifying areas for improvement and helping to further
drive compliance. Through our first annual audit, we’ve taken away key learnings which we’ll
address throughout the year and report on progress in our next report.

Over the past decade, continuous evaluation and improvement has been an important founding
principle of our Code. Continually strengthening our governance process gives us confidence that
we are successfully enacting responsible marketing in practice as well as in theory. In the spirit ofcontinuous improvement, we will take these on board, while continuing to hold ourselves
accountable to our commitments in a transparent manner.

Remove ambiguity from the Code for ease of application▷ EVOLVING MARS’ APPROACH TO RESPONSIBLE MARKETING

One of the findings of our audit uncovered that certain phrasing of our commitments in the
Code was ambiguous, leading to confusion of how they should be applied in practice. Thanks
to this learning, the new iteration of the MMC has helped clarify exactly what is expected ofassociates in areas of ambiguity.

•

Our desire to be a leader in responsible marketing means that we constantly strive to expand
what it means to be a responsible marketer. We recognise that the power of marketing topositively influence society and challenge perceptions of stereotypes which have been
established throughout the years. For this reason, we have committed to #Unstereotype Allianceand Free the Bid initiatives to promote and champion diverse and inclusive marketing
communications.

Content creation on social media platforms

The dynamic, reactive and immediate nature of social media marketing means that content is
produced and released in a different way to traditional forms of marketing. For example, ourbrands promote recipes featuring Mars products on their social media channels where this is
not done as frequently in traditional media. Having discussions with our social media teams
and providing guidance on how best to market responsibly on social channels has
strengthened our position. We are adapting to working within a social media framework, while
keeping our responsible marketing commitments front-of-mind.

•

Moreover, recognising the evolving nature of Digital, we are building an influencer strategy, toensure that Mars Associates practice the responsible use of influencer marketing. This includes
extensive guidelines for our Associates, providing best practices for transparent disclosure of our
influencer relationships by both our brands and the influencers we choose to partner with.
Finally, we are developing guidance on how to responsibly use marketing communications within
the gaming industry. These developments, some in addition to our most recent version of theCode released in 2018, were a result of our strengthened system of governance.

Use of our brand characters

We view our brand characters as valuable marketing assets, so it is important to us that they
are used responsibly. Our audit showed that compliance with our strict Character Guidelines
could be improved, for example in the way characters are used on social media, in order toensure they are not targeted towards children. It has initiated a discussion with our marketing
teams regarding how best to use our brand characters, and case studies from our audits havebeen used to drive higher compliance in the future.

•▷ ONGOING ROLL-OUT OF OUR GOVERNANCE STRUCTURE
We want responsible marketing to be second nature to our Associates. That is why we are (1)increasing our network of Code Ambassadors, (2) improving and updating our mandatory
responsible marketing training programme, and (3) expanding our Creative Content Review
system to all segments of the business, to facilitate systematic approval of all marketing
materials.

Regional applicability of the CodeThe audit was instrumental in teaching us about the cultural nuances of the application of ourCode in different regions. Adhering to cultural sensitivity is another layer of compliance which
has been taken into account as a result of the 2017 audit. Though our advertising guidelines
apply globally, marketing materials can have different connotations in different markets,meaning the guidelines have to also be viewed through a cultural sensitivity lens. For example,
the way that certain animation is adult-targeted in China. Auditing our activities has
encouraged us to reach out to several different markets to learn what compliance to ouradvertising guidelines means for each of them.

Continuous improvement

6.
Continuous improvement▷ KEY LEARNINGS•Our compliance results▷ FURTHER STRENGTHENING OUR THIRD-PARTY AUDITS
During 2017, we monitored the compliance of our media placement through rigorous selfreporting by our media buying agencies. In order to strengthen our findings, we plan for an
independent, third-party audit to be carried out in randomized markets. We will compare thethird-party data with the data of the buying agencies to ensure that we are providing an accurate,transparent picture of compliance at Mars.

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