Distilled Spirits Council’s Guidance Note on Responsible Digital Marketing Communications

Introduction

This Guidance Note for responsible digital marketing communications is an integral part
of the Distilled Spirits Council’s Code of Responsible Practices for Beverage Alcohol
Advertising and Marketing and should be read in conjunction with its provisions.

The members of DISCUS recognize the increasingly important role of digital marketing
and believe it provides valuable and appropriate tools to reach adult consumers. As an
extension of our commitment to market our brands responsibly to adults and to respect
their privacy, we have developed additional principles relevant to digital marketing to
reach users of legal purchase age.

Digital marketing activities are in a stage of evolutionary development, where new trends
are likely to occur rapidly. This Guidance Note will therefore be reviewed on a regular
basis and updated whenever necessary.
Scope
The Guidance Note applies to branded digital marketing communications (paid and
unpaid) of DISCUS member companies, including but not limited to communications on
websites such as social network sites and blogs, as well as mobile communications and
applications.
Basic Principles
1. Digital marketing communications are intended for adults of legal purchase age.

2. Digital marketing communications should be placed only in media where at least
71.6% of the audience is reasonably expected to be of the legal purchase age.

3. Digital marketing communications on a site or web page controlled by the brand
advertiser that involve direct interaction with a user should require age affirmation
by the user prior to full user engagement of that communication to determine that
the user is of legal purchase age.

4. User-generated content on a site or web page controlled by the brand advertiser
must be monitored and moderated on a regular basis.

5. Digital marketing communications that are intended to be forwarded by users
should include instructions to individuals downloading the content that they should not forward these materials to individuals below the legal purchase age.

6. Digital marketing communications must respect user privacy.

7. Digital marketing communications and product promotions must be transparent as
brand marketing by being identified as such.
Definitions and Guidance to Implement Principles

1. Direct interaction is a two-way communication between the user and the brand
advertiser on a site or web page controlled by the brand advertiser. It occurs when
the user affirmatively interacts with the brand advertiser, such as responding to a
direct communication from the brand advertiser.

2. Age affirmation is a process or a mechanism by which users provide their full
date of birth (month, day and year) and, when appropriate, country of residence
to affirm they are of legal purchase age. Age affirmation mechanisms may vary
depending upon available technology and examples could include, among other
things, an age affirmation page, an email or instant messaging age affirmation, or
the use of a site’s “registered user” database of users of legal purchase age.

If a user enters a date of birth that indicates they are under the legal purchase
age, access to a member-controlled website should be denied and visitors
should be given an appropriate message and/or directed to an information
website on responsible drinking, such as those found at The Century Council’s
webitse (http://www.centurycouncil.org) or on the site itself.

3. User Generated Content (UGC) is material (including text, pictures, audios, and
videos) that has not been created by the brand advertiser, but by a user. UGC
that appears on a site or web page controlled by the brand advertiser should be
monitored each business day or, at a minimum, every five business days. When
content is determined to be inappropriate, the inappropriate material should be
removed promptly. A disclaimer should appear saying that all inappropriate
content generated by users will be removed from the site or web page over which
the brand advertiser has control.

4. “Forwardable” content is any branded digital content placed on a site in a
manner that is designed or enabled to be shared, such as with a share, download
or email “button click.” Such content should include instructions to individuals
downloading the content that they should not forward these materials to
individuals below the legal purchase age.

5. Social Responsibility Statements should be included in all digital marketing
communications where practicable.

6. Privacy policies govern the collection of personal information from adults of legal

purchase age and encompass any direct digital marketing or advertising whether
conducted through a social networking site, website or other digital channel and
must ensure the following:

• Prior to the collection of any information, the brand advertiser will require that
individual to affirm that they are of legal purchase age and user information
only can be collected from those individuals who are of the legal purchase age.
• The brand advertiser shall employ a mechanism for a user to “opt-in” before
receiving a direct digital marketing communication and to “opt-out” to
discontinue receiving such direct communications.
• Clear information must be provided about collection and use of personal data.
Under no circumstances will the information collected be sold or shared with
third parties unrelated to the brand advertiser.
• Users should be encouraged to read the privacy statement before submitting
their information.
• Measures will be taken to keep user information secure and protected from loss
or theft.

Effective September 30, 2011