Mars Marketing Code for Human Food2019 Governance Report

This report is based on 2018 audit results

Copyright © 2019 Mars, Incorporated 1

3 Introduction

4 Why We Market Our Products Responsibly

5 Our Responsible Marketing Commitments

6 Third-Party Audit and Annual Review Methodology

7 2018 Audit Results

10 Case Study: Defining Our Work on Inclusive Marketing

11 Our Ongoing Journey: Audit Learnings and Areas for Improvement

13 Appendix

Contents

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Introduction

It is an honor to present Mars’ second annual governance report that tracks our progress in implementing the commitments in the Mars Global Marketing Code for Human Food (‘the Code’). The Code guides how Mars and its brands communicate and interact with consumers. It is grounded in our Five Principles and our purpose: The world we want tomorrow starts with how we do business today.

At Mars, we are proud to be a leader in responsible marketing. Our 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. However, we are not complacent and our ambition is to continually evaluate and improve our commitments and governance practices related to the Code.

We are continuing the journey we embarked on in 2015 to tighten our internal and external governance of the Code to help ensure compliance and enable confident communication of our commitments to our Mars Associates, to our consumers and to external stakeholders.

This report provides more detail on how Mars governs and audits our responsible marketing practices, gives an update on our compliance and progress, areas for improvement we identified last year, as well as learnings from this year’s results.

We are encouraged by our results and the lessons 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.

Copyright © 2019 Mars, Incorporated

Jacqui Stephenson , Global Responsible Marketing Officer,

Mars Wrigley

3

Why We Market Our Products Responsibly

Marketing, through its reach, trend-setting andbehavior-change capabilities, shapes consumer tastes,perceptions and actions daily. This powerful force can beused to influence and represent society positively, butcan also have unintended consequences, especially onvulnerable audiences like children who are not awarethey may be the target of marketing.

Marketing is one of the ways that companies like Marsinteract with consumers and determines how our brandsand products show up to the world. In line with ourpurpose that ‘The world we want tomorrow starts withhow we do business today’ and our Five Principles, webelieve that marketing should be done responsibly.

Mars has made a range of commitments to do this. Werestrict our marketing activities to protect children under12 years old as a vulnerable audience, and have made anumber of commitments to progress the Diversity &Inclusion agenda in marketing. Ultimately, we want toensure that we are responsive to consumer expectationsin relation to responsible marketing, which is why weconstantly re-evaluate and seek to improve ourapproach.

Using the power of marketing for good

Protecting children as a vulnerable audience

Being responsive to consumer expectations

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Our Responsible Marketing Commitments – Mars Global Marketing Code for Human FoodThe Mars Global Marketing Code for Human Food isour industry-leading commitment to address andgovern marketing issues. The Code sets out thestandards that guide the way that Mars and its brandscommunicate and interact with our consumers. It isgrounded in our Five Principles and sets expectationsfor our engagement and behavior towards ourconsumers.

The purpose of the Code is to serve as a frameworkthrough which we set boundaries for our marketingwhile driving positive change, and setting an examplefor industry peers for what we believe to be right forconsumers. We base these beliefs, as we do with all ofour positions at Mars, on strong science, consumerinsight and a sensitivity for the concerns ofstakeholders.

The Key Commitments of the Mars Global Marketing Code for Human Food

Content Commitments

Placement Commitments

For further information on our responsible

marketing commitments, please refer to the full

Mars Marketing Code for Human Food.

Applicable to all global marketing communications

No marketing targeted primarily to children under

12 years old(13 for digital)

No placement of vending machines

or event sponsorship in

primary schools

25% audience threshold

No data collection from children under

16 years old

Encourage healthy

lifestyles and not condone

excessive consumption

No use of celebrities or

licensed characters primarily

appealing to children under 12

Strict governance of

our brand characters - only

directed at adults

No child-appealing promotions, advergames, giveaways or purchasing incentives

Advertising consistent with

the Five Principles and

our advertising guidelines

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To ensure effective implementation of our Code, we conduct third-party auditing across our top advertising spend markets:

PLACEMENT COMMITMENTS COMPLIANCE AUDIT: We work with MediaCom and Starcom, our 2018 media planning and buyingagencies, to collect data on our compliance with our commitment not to place our marketing communications on channels wherechildren under 12 years old make up more than 25% of the total audience (and children under 13 years old on digital platforms). Wedeveloped a scorecard that is completed by MediaCom and Starcom, which includes the percentage compliance and number ofbreaches per channel, across six types of media channels.

CONTENT COMMITMENTS COMPLIANCE AUDIT: Ebiquity is the third-party auditor that assesses the compliance of our marketingcommunications and media content across print, TV, digital, social media and posters with our commitment to not develop contentwhich appeals primarily to children under 12 years old (13 on digital channels). Every quarter, they perform 29 compliance checks toensure the content of our marketing communications, not just their placement, is compliant with the Code.

• Australia • Canada• China• France• Germany • India

• Middle East & North Africa• Mexico • Netherlands• New Zealand• Poland

• Russia• Spain• Switzerland • United Kingdom• United States

Third-Party Audit and Annual Review Methodology

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98.4%

1.6%

Compliant Non-compliant

97.6% 98.5%

2.4% 1.5%

FOOD MARS WRIGLEY

Non-compliant

Compliant

Placement Commitments Compliance Results – 2018

BY SEGMENT BY CHANNEL

National Digital 97.9% 2.1%

Publishing

Shopper Digital

Social Media

TV/Cinema/Radio

Posters & Billboards

99.1%

99.3%

99%

99.5%

84%

0.9%

0.7%

1%

0.5%

16%

OVERALL COMPLIANCE BY REGION

98% 2%North America

Latin America

Europe

Middle East & Africa

Asia Pacific

92% 8%

100% 0%

99% 0%

98% 2%

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Content Commitments Compliance Results – 2018

95.0%

5.0%

Compliant Non-compliant

BY SEGMENT

OVERALL COMPLIANCE BY REGION

98% 95%

2% 5%

FOOD MARS WRIGLEY

Non-compliant

Compliant

BY MARS MARKETING CODE SECTION

Advertising Guidelines 100% 0%

Characters & Celebrities

Digital & Privacy

Targeting Children

Portrayal of Children/Adults

Responsible Promotions/Consumption

98%

97%

97%

100%

98%

2%

3%

3%

0%

2%

91% 9%North America

Latin America

Europe

Middle East & Africa

Asia Pacific

72% 28%

99% 1%

98% 2%

96% 4%

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Our Progress on Areas of Improvement Identified in Last Year’s Audit

Over the past year, we have continued to improve the governanceof our marketing commitments by driving forward the roll-out of ourin-market governance structure. We have now increased ournetwork of Marketing Code Ambassadors to cover the geographieswhere 81% of our media spend takes place. The role of ourAmbassadors is to support the marketing teams to correctly applyour commitments in the market or region of their responsibility.They also act as a first level of escalation of questions and issues,evaluating whether the proposed marketing content is compliantwith our Code before passing it onto the global level.

To address areas where compliance with our strict CharacterGuidelines could be improved, we have taken steps to ensure thattheir governance is further strengthened so they do not targetchildren. Over the past year, the M&M’s Brand Board worked toreview the use of our characters very closely. This has resulted in, forexample, a substantial redesign of the merchandise that we sell inM&M’s World and duty-free stores. Our merchandise analysis has ledto the discontinuation or redesign of 1,600 items. We continue toclosely monitor and improve the application of the CharacterGuidelines in all our marketing activities across channels.

Ongoing roll-out of our governance structure Strengthening our governance of brand characters

Evolving Mars’ approach to responsible marketing

Recognizing the increasing importance and more complex nature ofresponsible marketing on digital channels, we have taken substantialsteps over the past year to strengthen our governance in this spaceand the partnerships we have with digital platforms where ourmarketing appears. We have developed a comprehensive set ofinfluencer marketing guidelines which outline in detail how ourmarketers should evaluate influencers they are consideringpartnerships with and disclose our engagement with them in themost transparent manner, aligned with global best practices.

Strengthening our governance of social media content

The dynamic, reactive and immediate nature of social mediamarketing means that content is produced and released in adifferent way to traditional forms of marketing. To ensure that thecontent on our social media channels complies with ourcommitments both in terms of appeal and targeting, we havestreamlined significantly the creation of social media content. Wehave put in place a global team structure and process through whichcompliant post suggestions are disseminated to markets to betailored to their own context and needs.

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Defining Our Work on Inclusive Marketing

As one of the world’s top advertisers, Mars knows the power of marketing. We believe that truly great creativeshould be representative of how we see the world and, in some cases, the change we want to see in it. However,while we’ve been the most awarded advertiser at the Cannes Lions International Festival of Creativity for the lasttwo years, the truth is we have more work to do through our marketing and advertising to better reflect society.Our brands should speak to, and celebrate, the diversity of the audiences who enjoy them.

The actions we took

First, we needed to know where we stood. Since 2017, we’ve partnered with the Geena Davis Institute on Genderin Media to better understand how we portray gender and stereotypes in our advertising. This research leveragedthe Institute’s proprietary GD-IQ (Geena Davis Inclusion Quotient) machine learning tool to analyze more than 200Mars global television adverts across various Chocolate, Gum, Fruity Confections, Petcare and Food brands.

What we found out

While Mars is shown as better than the industry baseline, the findings revealed deficiencies related to genderrepresentation:

• Ratio of 3:2 of number of men vs. women in our advertising• Men are nearly twice as likely to be shown working than women• 22% of male characters are shown as leaders in our advertising vs. 17% of female characters• More male than female characters are depicted with an occupation in our ads – 26% vs. 11%, respectively

What we’re doing about it

Although we perform marginally better than many of our peers, it is clear that we still have a lot of work to do. Thisis why we shared these results publicly at the Cannes Lions Festival in 2019, to prove our commitment to drivechange. This included interviews with trade media and speaking on two panels on Diversity & Inclusion at thefestival, driving a media reach of 1.62m and social reach of 290k. We then leveraged insights from the Institute'sresearch to approach our advertising with a new lens – to start addressing gender representation andstereotyping in our own advertising. Part of this work will include the development of a comprehensive plan, inpartnership with our agencies, the Geena Davis Institute and the Unstereotype Alliance. Our mission is to find outhow we can continue to make our marketing more inclusive, leveraging the power of our brands and help uscreate the world we want tomorrow.

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Our Ongoing Journey

Latin America is a key area of focus for improvedgovernance

The audit results demonstrate that one of our markets in Latin Americahas a lower rate of compliance, particularly on their governance aroundour content commitments. Our target for compliance in all areas is aminimum of 95%. The issue that the audit results brought to light is thatthere is insufficient compliance with the use of our characters andchild-appealing content. This level of non-compliance is of high priorityfor us to resolve. Since 2017, we’ve trained the marketers more closelyon the various guidelines we have created to facilitate the practicalapplication of our commitments. We expect that this training will filterthrough in higher compliance results in the region moving forward. Inaddition, in 2019, we will work with our Responsible MarketingAmbassador, as well as market and marketing leadership in the regionto understand the root of the issue, in order to ensure that all of ourmarketers understand how to seek guidance and escalate issues whenunsure about the compliance of proposed content.

Key learnings from 2018 audit – areas for improvement

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How we are addressing non-compliant cases raised by the third-party audit: Through our robust global governance structure, which is presented in more detail in our 2018 report and the Appendix to this year’s report, we review audit results on a quarterly basis and discuss recurrent themes of non-compliance that need to be addressed. We then develop remediation tools that are rolled out through our governance processes in order to provide clarity to local teams on non-compliant content and placement, and guidance on how to address these issues.

Evolving our placement audit methodology

In our effort to continually evaluate and improve upon our governancepractices, we had a third-party validator review the audit methodologyfor our media placement commitments. Nielsen, the third-partyvalidator we retained, identified digital media as an area in which theapproach to measuring compliance can be strengthened, given itsmore complex nature. Based on Nielsen’s recommendations, we will beworking on evolving our placement audit methodology for digitalmedia in order to ensure it is as robust as possible. The auditmethodology for traditional media will remain the same, given themore established nature of placing ads and measuring exposure ontraditional channels such as TV and radio. The new methodology will beapplied to our 2020 media placement audit.

Examples of non-compliant casesKey learnings from 2018 audit – areas for improvement

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Potential encouragement of excessive consumption on social media

The audit of our marketing content this year showed that ourmarketers often use images that show an abundance of productwhen promoting our chocolate and confectionery brands on socialmedia. Though not intentionally encouraging overconsumption, theaudit has demonstrated a need to be more aware of the types ofimages marketers post on social media and the possible impliedmessage of the content. We are working to educate marketers on thisissue – making them aware of the specific guidelines we have toensure our messages do not inadvertently promote overconsumptionthrough the amount of products they show relative to the number ofpeople in the photo. Now that we have a global team for centralizedsocial media content creation and roll-out to our markets, we are alsoestablishing a more streamlined governance process to ensure thatsocial media content is compliant with our commitments.

Portrayal of children on their own

Our 2018 content audit also uncovered a challenge in the waychildren are portrayed within the activation of the Uncle Ben’s familycooking program (Ben’s Beginner’s) on social media as well as withinsome Orbit social media content. The activations sometimes includedphotos of children on their own, interacting with our products.Having identified the source of the challenge, we are putting in placesolutions which include upskilling marketers on how to better complywith our commitments and ensure that parents are always present inpictures with children under 12 years old.

Appendix

In this section, you can find further information on our approach to Responsible

Marketing Governance at Mars

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How We Govern Responsible Marketing

Mars made an industry-leading commitment to establish astreamlined governance framework formalizing existinggovernance processes and driving increased compliancewith our responsible marketing commitments.

We have developed a comprehensive and holistic approachto governance centered around five work streams.

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

Our responsible marketing governance structure (as shownon the right) reflects the importance we ascribe to goodgovernance. It involves a representative selection offunctions which manage our marketing activities andapproach to responsible marketing, as well as the highestlevels of Mars leadership, to ensure accountability andtransparency.

Workstreams of Responsible Marketing Governance

The importance of responsible marketing to Mars is reflected by the Governance structure we have put into place. The Mars Global Public Policy Group has responsibility for the supervision and management 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.

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