New Food, Beverage Initiative to Focus Kids' Ads on Healthy Choices; Revised Guidelines Strengthen CARU's Guidance to Food Advertisers

ARLINGTON, Va., Nov. 14 /PRNewswire/ -- The Council of Better Business Bureaus (CBBB) and the National Advertising Review Council (NARC) today announced two significant developments in the self-regulation of advertising directed to children under 12:

First is the establishment of the Children's Food and Beverage Advertising Initiative (Initiative), a voluntary self-regulation program with 10 of the largest food and beverage companies as charter participants. The Initiative is designed to shift the mix of advertising messaging to children to encourage healthier dietary choices and healthy lifestyles. Charter participants are Cadbury Schweppes USA; Campbell Soup Company; The Coca-Cola Company; General Mills, Inc.; The Hershey Company; Kellogg Company; Kraft Foods Inc.; McDonald's; PepsiCo, Inc. and Unilever. It is estimated that these companies account for more than two-thirds of children's food and beverage television advertising expenditures.

Second is the approval of significant revisions to the Self-Regulatory Guidelines for Children's Advertising. The revised Guidelines strengthen the ability of the CBBB's Children's Advertising Review Unit (CARU), which monitors all advertising directed to children under 12, to provide guidance and oversight to all industry sectors.

Both the Initiative and the revisions to the Guidelines evolved from the in-depth review of the Guidelines undertaken by NARC and led by Joan Z. (Jodie) Bernstein, a former director of the Federal Trade Commission's Bureau of Consumer Protection.

"These are important developments. The Initiative represents an innovative effort to promote healthier dietary choices and lifestyles to children. I commend these 10 companies for coming together in a meaningful new program that will have strong oversight," Ms. Bernstein said. "In addition, the revised Guidelines will assist CARU to continue to hold all advertising to children under 12 to high standards. Together, these efforts are a great step forward."

  Under the terms of the Initiative, participating companies commit to:

  * Devote at least half their advertising directed to children on
    television, radio, print and Internet to promote healthier dietary
    choices and/or to messages that encourage good nutrition or healthy
    lifestyles.

  * Limit products shown in interactive games to healthier dietary choices,
    or incorporate healthy lifestyle messages into the games.

  * Not advertise food or beverage products in elementary schools.

  * Not engage in food and beverage product placement in editorial and
    entertainment content.

  * Reduce the use of third-party licensed characters in advertising that
    does not meet the Initiative's product or messaging criteria.

Each participating company will submit to the CBBB a commitment, tailored to the company's product portfolio, that complies with the principles of the Initiative. Company commitments that identify better-for-you dietary choices must be consistent with established scientific and/or government standards. The CBBB expects the program to be up and running within the next six to nine months.

"Self-regulation works best when backed by strong and effective accountability," said Steven J. Cole, CBBB President and CEO. "We will closely monitor adherence to the participant commitments. This program is an excellent example of how voluntary self-regulation and the BBB advance marketplace trust."

C. Lee Peeler, Executive Vice President, Advertising Self-Regulation, CBBB, and President and CEO, NARC, will lead the Initiative. The Initiative will be further supported by experts in nutrition and media research. Program staff will monitor companies' compliance with their commitments and will maintain a publicly accessible Website that details their findings.

"We hope the experience we gain implementing the Initiative will provide a basis for enhancing the program and expanding it to other companies across the food and beverage industry," said NARC Board Chairman Nancy Wiese, an Association of National Advertisers Board member and the Vice President, Worldwide Brand Marketing/Advertising at Xerox. "We also plan to coordinate this effort with the Ad Council's Coalition for Healthy Children, which is simultaneously developing a consistent set of good nutrition and healthy lifestyle messages."

The Guidelines Review process brought together more than 40 leading children's advertisers across industry sectors -- broad participation that demonstrates the children's advertising industry's strong support for self- regulation. The revised CARU Guidelines have been expanded to:

  * Provide new authorization for CARU to take action on advertising
    targeted to children that is "unfair," in addition to advertising that
    is misleading.

  * Specifically address "blurring," or advertising that obscures the line
    between editorial content and advertising messages. A new provision,
    which applies across all media, prohibits advertising that "blurs the
    distinction between advertising and program/editorial content in ways
    that would be misleading to children."

  * Specifically address the use of commercial messages in interactive
    games, sometimes referred to as advergaming. The revised Guidelines
    require that "if an advertiser integrates a commercial message into the
    content of a game or activity, then the advertiser should make clear, in
    a manner that will be easily understood by the targeted audience, that
    it is an advertisement."

The revised Guidelines also strengthen CARU's guidance to food advertisers in a number of areas, such as clarifying that children's food advertising should not depict over-consumption or discourage or disparage healthy lifestyle or healthy dietary choices.

Additionally, Ms. Wiese said, "the Guidelines review process has identified areas that require continued review. The NARC Board has requested further discussion of the issues of product placement in children's programming and the advertising of telephone services to children."

To access a copy of the revised CARU Self-Regulatory Guidelines for Children's Advertising, please visit http://www.caru.org/

About the CBBB

Founded in 1970, the CBBB is the national organization for the Better Business Bureau system. The BBB system is dedicated to fostering trust between businesses and consumers in both the traditional and online marketplace. The first BBB was founded in 1912 -- today, the BBB system is comprised of 129 local Better Business Bureaus (BBBs) across the US and Canada, and serves millions of consumers, nearly 400,000 small and medium business members, and hundreds of national and multi-national corporations based in North America. The BBB system has grown to become the most trusted name and recognized advocate for promoting ethical business and advertising practices, providing more than 90 million instances of service to consumers and businesses in 2005. For more information on the BBB system, visit http://www.bbb.org/.

About NARC

The National Advertising Review Council (NARC) was formed in 1971 by the CBBB, the Association of National Advertisers, Inc. (ANA), the American Association of Advertising Agencies, Inc. (AAAA), and the American Advertising Federation, Inc. (AAF). Its purpose is to foster truth and accuracy in national advertising through voluntary self-regulation. NARC is the body that establishes the policies and procedures for the CBBB's National Advertising Division (NAD) and Children's Advertising Review Unit (CARU), as well as for the National Advertising Review Board (NARB). NAD and CARU are the investigative arms of the advertising industry's voluntary self-regulation program. Their casework results from competitive challenges from other advertisers, and also from self-monitoring traditional and new media. The National Advertising Review Board (NARB), the appeals body, is a peer group from which ad-hoc panels are selected to adjudicate those cases that are not resolved at the NAD/CARU level. This unique, self-regulatory system is funded entirely by the business community; CARU is financed by the children's advertising industry, while NAD/NARC/NARB's sole source of funding is derived from membership fees paid to the CBBB. For more information about advertising self regulation, please visit http://www.narcpartners.org/.

           Children's Food and Beverage Advertising Initiative
          Self-Regulatory Guidelines for Children's Advertising
                                Fact Sheet

  * Advertising Industry Self-Regulation -- The National Advertising Review
    Council (NARC) was formed in 1971 by the Association of National
    Advertisers, Inc. (ANA), the American Association of Advertising
    Agencies, Inc. (AAAA), the American Advertising Federation, Inc. (AAF),
    and the Council of Better Business Bureaus (CBBB.) Its purpose is to
    foster truth and accuracy in national advertising through voluntary
    self-regulation. The Children's Advertising Review Unit (CARU) monitors
    advertising to children under 12 across all industry sectors.

  * CARU's Self-Regulatory Guidelines for Children Advertising -- CARU's
    Guidelines were first adopted in 1974 and provide both general and
    specific guidance to children's advertisers across business sectors.

  * The Guidelines Review Working Group -- The 2006 Guidelines Review
    process brought together leading children's advertisers across industry
    sectors in a working group led by Joan Z. (Jodie) Bernstein, a former
    director of the Federal Trade Commission's Bureau of Consumer
    Protection. Representatives of more than 40 companies participated in
    the process.  The process produced a new self-regulatory program -- The
    Children's Food and Beverage Advertising Initiative -- and key revisions
    to the CARU Guidelines.

  * The Children's Food and Beverage Advertising Initiative -- A voluntary
    self-regulation program created by the Council of Better Business
    Bureaus with 10 of the largest food and beverage companies as charter
    participants.

  * Initiative Charter Companies -- Cadbury Schweppes USA; Campbell Soup
    Company; The Coca-Cola Company; General Mills, Inc.; The Hershey
    Company; Kellogg Company; Kraft Foods Inc.; McDonald's; PepsiCo, Inc.
    and Unilever.

  * Initiative Goals -- The Initiative is aimed at shifting the mix of
    advertising messaging directed to children under 12 to encourage
    healthier dietary choices and healthy lifestyles.

  * Initiative Overview -- Participants commit to devote at least half their
    advertising directed to children under 12 to promote healthier dietary
    choices and/or to messages that encourage good nutrition or healthy
    lifestyles. Healthier-product pledges must be consistent with
    established scientific and/or government standards, including USDA
    Dietary Guidelines and My Pyramid, and FDA standards for health claims.

  * Initiative Specifics -- Participating companies commit to:

    -- Limit products shown in interactive games to healthy dietary choices,
       or incorporate healthy lifestyle messages in the games.
    -- Not advertise food or beverage products in elementary schools.
    -- Not engage in product placement of food and beverage products in
       editorial and entertainment content.
    -- Reduce the use of third-party licensed characters in advertising that
       does not meet the Initiative's product or messaging criteria.

  * Initiative Implementation -- The Initiative will be administered by the
    CBBB with the assistance of experts in nutrition and media research. The
    CBBB expects to have the program up and running within six to nine
    months.

  * Initiative Staff -- C. Lee Peeler, Executive Vice President, Advertising
    Self-Regulation, CBBB, and President and CEO, NARC, will lead the
    Initiative.  Initiative staff will:

    -- Review each company's specific commitment.
    -- Monitor companies' commitments.
    -- Respond to questions from the public.
    -- Report on the program's activities.
    -- Maintain a Website that will provide the public with information
       about each company's Initiative.

  * Key Revisions to the CARU Guidelines -- The revised Guidelines:

    -- Provide authorization for CARU to take action on "unfair" advertising
       targeted to children, broadening CARU's oversight.
    -- Specifically address "blurring," or advertising that obscures the
       line between editorial content and advertising messages.
    -- Specifically address the use of commercial messages in online
       interactive games, sometimes referred to as advergaming.
    -- Strengthen CARU's guidance to food and beverage advertisers.

  * Going Forward -- The NARC Board has requested further discussion of the
    issues of product placement in children's programming and the
    advertising of telephone services to children and will continue its
    review of children's food advertising issues as it gains experience with
    the Children's Food and Beverage Advertising Initiative.


           Children's Food and Beverage Advertising Initiative
          Self-Regulatory Guidelines for Children's Advertising
                                   Q&A

  What are the CBBB and NARC announcing today?

We're announcing two significant new self-regulatory efforts -- the establishment of the Children's Food and Beverage Advertising Initiative (Initiative) and revisions to the Self-Regulatory Guidelines for Children's Advertising (Guidelines.)

The Initiative is an ambitious new industry self-regulatory program aimed at shifting the mix of advertising messaging to children to encourage healthier dietary choices and healthy lifestyles.

Currently, 10 of the nation's largest food and beverage companies have pledged their support. Charter participants are Cadbury Schweppes USA; Campbell Soup Company; The Coca-Cola Company; General Mills, Inc.; The Hershey Company; Kellogg Company; Kraft Foods Inc.; McDonald's; PepsiCo, Inc. and Unilever.

Revisions to the Guidelines broaden and strengthen the Children's Advertising Review Unit (CARU), which monitors all advertising to children under 12.

The CBBB and NARC had earlier announced a review of the Guidelines. Is the Initiative a product of the same review?

Yes. The Initiative is a new self-regulatory effort for food and beverage companies and it evolved from the same review. The Guidelines are applied to all children's advertisers across all industry sectors.

How did the Guidelines review process work?

The review process was led by Joan Z. (Jodie) Bernstein, a former director of the Federal Trade Commission's Bureau of Consumer Protection. All CARU supporters were invited to participate in discussion and debate of the Guidelines. Representatives of more than 40 companies contributed to the process.

Did groups representing children, public interest groups, or government agencies participate?

At the outset, the working group leader met with a number of outside organizations. The working group also benefited from the testimony at several federal workshops and reviewed and considered several reports on children's advertising, including reports from the Institute of Medicine and the Kaiser Family Foundation.

Will the Initiative make a difference in the kind of ads children see?

Yes. Participants commit to devote at least half their advertising directed to children under 12 to promote healthier dietary choices and/or to messages that encourage good nutrition or healthy lifestyles. That percentage represents a floor, not a ceiling; some companies may do more. The percentage may increase over time.

Is there more to a company's commitment?

Yes. Each company's commitment also addresses interactive games, product placement and the use of third-party licensed characters. Participating companies have agreed to:

  * Limit products shown in interactive games to healthier dietary choices,
    or incorporate healthy lifestyle messages into the games.
  * Not engage in food and beverage product placement in editorial and
    entertainment content.
  * Reduce the use of third-party licensed characters in advertising that
    does not meet the Initiative's product or messaging criteria.

  What about advertising in schools?

Participating companies have also agreed not to advertise food or beverage products in elementary schools.

Is the Initiative limited to these 10 companies?

No. Any food or beverage advertiser may join. NARC intends to continue its review to seek ways to expand the program.

Is the Initiative supported by nutrition-based principles?

Yes. The Initiative requires participating companies to shift the mix of advertising directed to children under 12 to encourage healthier dietary choices and lifestyles. Company commitments that identify healthier dietary choices must be consistent with established scientific and/or government standards. Such standards include:

  * FDA-defined "healthy" foods.
  * Products that meet the FDA or USDA criteria for claims of "free," "low,"
    or "reduced" calories, total fat, saturated fat, sodium or sugar.
  * Products that qualify for the USDA "Healthier Schools Challenge."
  * Principles addressing recommended consumption by children under 12 under
    USDA Dietary Guidelines and My Pyramid.
  * Products representing portion-control options, such as 100-calorie
    packs.

Some of the participating companies have already announced big changes in food production and marketing. How is this different?

This is the first time that companies representing more than two-thirds of television food and beverage advertising to children have made a public commitment to devote a significant share of their advertising to nutrition and fitness. In addition, this program has independent third-party administration and enforcement -- both essential to the effectiveness of the program. The CBBB will perform that function here as it has in other instances.

When does the Initiative begin?

The CBBB expects the program to be up and running within the next six to nine months.

Who will decide whether a company is meeting its commitments?

Initiative staff will monitor companies' compliance with their commitments and will maintain a publicly accessible Website that details their findings. Initiative staff also will take consumer complaints.

What will happen if a company doesn't meet its commitment?

A company that does not meet its commitment may be expelled from the program and, in appropriate circumstances, be referred to appropriate regulatory authorities, such as the Federal Trade Commission.

Can you provide an example of appropriate messaging?

Each company will craft its own commitment. One source for such messaging could be the Ad Council's Coalition for Healthy Children, which is developing a consistent set of good nutrition and healthy lifestyles messages.

How do the Guidelines revisions affect the children's advertising industry?

The Guidelines, originally adopted in 1974, establish high standards for the advertising industry to assure that advertising directed to children under the age of 12 is truthful and not inappropriate for its intended audience.

The revisions broaden the responsibility of the Children's Advertising Review Unit (CARU) and strengthen CARU's guidance to advertisers. The revised Guidelines:

  * Provide authorization for CARU to take action on "unfair" advertising
    targeted to children, broadening CARU's oversight.
  * Specifically address "blurring," or advertising that obscures the line
    between editorial content and advertising messages.
  * Specifically address the use of commercial messages in online
    interactive games, sometimes referred to as advergaming.
  * Strengthen CARU's guidance to food and beverage advertisers.

Do the revised Guidelines address emerging forms of advertising like buzz, viral and mobile marketing?

Yes. The Guidelines apply to all advertising directed to children under 12, regardless of the medium or venue, as long as it's national (or broadly regional) in scope. CARU has already investigated some instances of advertising to children of services that can be purchased over mobile telephones.

Do you anticipate further revisions to the Guidelines?

Yes. It's important that the Guidelines remain current with developments in the marketplace. The NARC Board of Directors has requested further discussion of the issues of product placement in children's programming and the advertising of telephone services to children.

           Children's Food and Beverage Advertising Initiative

  Introduction

Companies engaged in advertising and marketing food and beverage products have developed this self regulatory initiative for advertising such products to children under 12. The goal of this initiative is to use advertising to help promote healthy dietary choices and healthy lifestyles among American children. While it remains the primary responsibility of parents to guide their children's behavior in these areas, industry members are voluntarily pursuing this initiative as a means of assisting parents in their efforts.

Core Principles

Companies participating in this initiative will publicly commit to advertising that will further the goal of promoting healthy dietary choices and healthy lifestyles to children under 12. These commitments will be set forth in an individual "Pledge" for each participant. Because companies and their product lines vary, company commitments will also vary. However, all commitments will be consistent with the following core principles:

  * Advertising Messaging.  Participants will devote at least 50%(1) of
    their television, radio, print and internet advertising primarily
    directed to children under 12(2) to advertising that will further the
    goal of promoting healthy dietary choices and healthy lifestyles.  This
    will be achieved in one of two ways (or some combination of both):

   (1) By advertising products that represent healthy dietary choices in
       accordance with company developed standards that are consistent with
       established scientific and/or government standards.  Examples of
       possible standards include:

       -- FDA defined "healthy" foods [21 CFR 101.65(d)(2)]
       -- Products that qualify for an FDA authorized health claim [21 CFR
          101.70-101.83]
       -- Products meeting FDA/USDA criteria for claims of "free," "low," or
          "reduced" calories, total fat, saturated fat, sodium or sugar
       -- Products that qualify for the USDA Healthier School Challenge
          Program criteria for Sales/Service of A La Carte and/or Vended
          Items
       -- Principles addressing recommended consumption by children under 12
          under USDA Dietary Guidelines and My Pyramid
       -- Products representing a portion control option, such as products
          advertised and sold in a package size of 100 calories or less

                                    or

   (2) By advertising that prominently includes healthy lifestyle messages
       designed to appeal to the intended audience, such as:

       -- messaging that encourages physical activity
       -- messaging that encourages good dietary habits, consistent with
          established scientific and/or government standards such as USDA
          Dietary Guidelines and My Pyramid

  * Use of Licensed Characters.  Participants will commit to reduce their
    use of third-party licensed characters(3) in advertising primarily
    directed to children under 12, unless such advertising complies with the
    messaging options set out above.  Each participant will state in its
    commitment the percentage reduction in its use of licensed characters.

  * Product Placement.  Participants will commit to not paying for or
    actively seeking to place their food or beverage products in the
    program/editorial content of any medium primarily directed to children
    under 12 for the purpose of promoting the sale of those products.

  * Use of Products in Interactive Games.  Participants will commit that, in
    any interactive game primarily directed to children under 12 where the
    company's food or beverage products are incorporated into the game, the
    interactive game must incorporate or be accompanied by products
    representing healthy dietary choices under #1 above or healthy lifestyle
    messaging under #2 above.

  * Advertising in Schools. Participants will commit to not advertising food
    or beverage products in elementary schools.(4)

  * Implementation.  Participants will formalize and publish their Pledge
    approximately 6 to 9 months following the establishment of the
    Monitoring/Enforcement entity described below.  The Pledge will include
    an implementation schedule for each commitment made by the participant.

  Monitoring/Enforcement

Company Pledges, including the specific commitments that will identify the healthy dietary choices criteria, will be established in consultation with a new program administered by the Council of Better Business Bureaus.

The new program will be responsible for monitoring company commitments. Monitoring will include the review of advertising materials, product information, and media impression information (submitted on a confidential basis) to confirm participant compliance. The program will also respond to public inquiries relating to compliance.

The new program will develop procedures that provide for the expulsion of a company that does not comply with its Pledge after being given notice and an opportunity to bring its conduct into compliance, and notice of any expulsion to regulatory authorities such as the Federal Trade Commission under appropriate circumstances.

The new program will publicly issue reports detailing its activities, including any expulsions or notices of such to regulatory authorities.

The new program, in consultation with the participants, will periodically review its procedures and the overall impact of this initiative. The first such review shall be started after the new program has been operational for at least 3 years.

           Children's Food and Beverage Advertising Initiative
                              Company Quotes

Cadbury Schweppes USA: "At Cadbury Schweppes, we have built lasting relationships with our consumers for more than 200 years by creating brands people love and operating ethically and responsibly. Our involvement in this Initiative reflects our values and our longstanding commitment to market our products in a responsible manner, and we are proud to work with our industry peers to continue exploring constructive solutions to consumer food issues."

  -- Gil Cassagne, President  & CEO, Cadbury Schweppes Americas Beverages
  -- Brad Irwin, President, Cadbury Adams USA

Campbell Soup Company: "For generations Campbell's soups have nourished America's children. As one of the first companies to use advertising to promote our brands to America's families, we have long supported responsible advertising practices -- especially with regard to how our brands are portrayed to kids. Campbell pledges to support these voluntary guidelines, which we believe will help families make better informed food choices. We are delighted to be a charter participant in this important CBBB initiative and welcome other food and beverage companies to join us in turning these guidelines into daily practice."

-- Paul Alexander, Vice President - Global Advertising, Campbell Soup Company

The Coca-Cola Company: "Coca-Cola North America supports this effort for a number of reasons; chief among them is the Initiative's goal of ensuring that America's kids are receiving balanced messages that promote healthy choices and active lifestyles. We are committed to improving childhood nutrition and hydration, and will continue to focus future innovation and marketing on developing products that meet their needs while also abiding by these practical guidelines. We are proud to be a part of this industry-wide effort to strengthen self-regulatory practices and ensure their effectiveness."

-- John Hackett, Senior Vice President, Marketing, Coca-Cola North America

General Mills, Inc.: "General Mills is proud to have helped advance the Children's Food and Beverage Advertising Initiative. This Initiative underscores our strong commitment as a company to helping children and their families make healthy dietary and lifestyle choices. It also reflects the commitment of our industry to strong and effective self-regulation. We believe we can be part of the solution, and this is an important step forward."

-- Mark Addicks, Chief Marketing Officer, General Mills

The Hershey Company: "The Hershey Company is proud to join the CBBB in promoting healthy diets and healthy lifestyles for children. Our company has a long history of supporting youth fitness and encouraging responsible snack consumption. The Initiative being announced today is a significant step forward in both of these areas, providing parents and children with the information they need to live healthier lives."

-- Tom Hernquist, Sr. Vice President, Global Chief Growth Officer, The Hershey Company

Kellogg Company: "We have a longstanding commitment to responsible advertising. We are proud to be a charter member of this important Initiative and continue to play an active role in industry efforts to further strengthen the self-regulatory process."

-- Jeff Montie, President of Kellogg North America and Executive Vice- President of Kellogg Company

Kraft Foods Inc.: "This Initiative is consistent with what parents want from food and beverage companies today. That's why Kraft has been focusing our kids marketing on better-for-you products and healthy lifestyles. And, we're pleased to take the next step with our peers to voluntarily change the way leading food and beverage companies talk to America's children."

-- Lance Friedmann, Senior Vice President of Health & Wellness and Sustainability, Kraft Foods Inc.

McDonald's: "McDonald's is pleased to join in this voluntary Initiative to address the important subject of children's well-being. We support this self- regulatory approach and the significant accomplishment of defining a common criteria around which the industry can work. We have been actively engaged in working with NARC and the CBBB to develop this leadership program. This is another step in McDonald's ongoing efforts to address our customers' lifestyle needs by offering even more menu choice, providing accessible nutrition information and being an advocate for activity and fitness."

-- Bill Lamar, Chief Marketing Officer, McDonald's USA

PepsiCo, Inc.: "This initial move is a common sense solution for children to understand the right messaging on healthy products and more active lifestyles. We're committed to continue the work with our industry partners and the CBBB to ensure that this Initiative is effective in its effort to enact the highest of standards for children's advertising."

-- Antonio Lucio, Senior Vice President, Chief Innovation and Health & Wellness Officer, PepsiCo

Unilever: "At Unilever, we recognize that how we market our products is equally as important as the principles by which they are developed. We have an opportunity as an industry to be an agent of change and to take proactive steps to address and promote health and wellness among our consumers and customers. Our commitment to the Children's Food and Beverage Advertising Initiative is a clear example of putting into action our company mission of adding vitality to life. Our goal is to help all of our consumers to feel good, look good and get more out of life. We are committed to working with all of our constituents on this important initiative to share knowledge and to promote best practices in this area."

  -- Michael B. Polk, President, Unilever U.S.

  (1) This minimum percentage may be increased over time.
  (2) Measured in media impressions at the time the advertising is
      purchased, as determined by reliable third party data such as Nielsen
      ratings for TV, radio and Internet, and PIB (Publisher's Information
      Bureau) and MRI (Mediamark Research Inc.) data for print advertising.
      The 50% commitment will be calculated separately for each advertising
      medium.  Measurement for advertising on company owned websites will be
      determined in accordance with standards established as part of the
      company's Pledge.
  (3) This commitment does not apply to the use of licensed characters on
      packaging, provided the packaging does not appear in advertising
      directed to children under 12.  The limitation also does not apply to
      the use of company-owned characters.
  (4) This limitation will not apply to displays of food and beverage
      products, charitable fundraising activities, public service messaging,
      or items provided to school administrators.