Social Media

1.0 Purpose

Anderson Direct Marketing (ADM) is committed to transparency and honesty in all of its advertising messages, promotional communications, opinions and general information made available to the public. Therefore, ADM hereby adopts this Digital Social Media and Endorsement Policy (this “Policy”).

This Policy applies to all ADM [employees][Independent contractors, agents, speakers, writers, bloggers, talent, endorsers and any other individual or entity engaged in promotional activities on behalf of ADM, whether they are engaged by ADM directly, or through an agency, representative of an agency, subsidiary, or franchise] (collectively referred to herein as “Endorsers”).

This Policy is intended to outline the policies and procedures of ADM with respect to any and all advertising messages, promotional communications, opinions and general information made by Endorsers. It is also intended to address endorsements and testimonials made by Endorsers about ADM, and/or its products and services and clients, whether those endorsements and testimonials are made through “traditional media,” such as television commercials or print ads, and “new media” or “social media,” such as websites, blogs, mobile applications or any other form of media that may be used by advertisers. Endorsers are legally responsible for their opinions, comments or content. Individual Endorsers can be held personally liable by third parties for any commentary deemed to be defamatory; obscene; proprietary to, or owned by, others; or libelous to ADM, its suppliers/partners or any other person or entity. For these reasons, Endorsers should exercise caution with regard to exaggeration, colorful language, guesswork, obscenity, materials used in content, conclusions, images and/or video, and derogatory remarks or characterizations. In addition, Endorsers should at all times be mindful that, given advances in technology, opinions, comments or content will remain public, and will be archived, stored and retrievable, indefinitely.

 2.0 Standards of Conduct

With respect to statements or other claims made in advertising messages, promotional communications, opinions and general information concerning ADM and/or its products or services or clients, Endorsers must adhere to the following principles:

a. Endorsers may only make statements that reflect their honest beliefs, opinions, or experiences. b. Endorsers may not make deceptive or misleading claims about ADM’s products or services or clients, or about ADM’s competitors’ products or services. c. Endorsers may not make any claims about ADM’s products or services, or ADM’s competitors’ products or services, that are not substantiated (i.e., adequate proof exists to back up the claim). d. Endorsers may not engage in any communication that is defamatory or infringes upon the ADM intellectual property, or privacy and publicity rights of others. For example, Endorsers may not post content (photos/videos) without written permission from the person who owns the photo or video as well as any persons depicted in the photo or video. e. Endorsers may not offer for sale, or solicit, products or services on behalf of ADM. f. Endorsers may not make offensive comments that have the purpose or effect of creating an intimidating or hostile environment, including telling lies or spreading rumors about ADM or its other Endorsers, officers, directors, shareholders or competitors. g. Endorsers may not use ethnic slurs, personal insults, obscenity, or other offensive language. h. Endorsers may not make any comments or post any content that in any way promote unsafe activities that could lead to an unsafe situation involving ADM’s customers or other individuals. i. Endorsers must adhere to the posting guidelines and Terms of Use on any site on which they post content on behalf of ADM.

3.0 Disclosure Requirements

a. Endorsers must disclose all material connections to ADM in all advertising messages, promotional communications, opinions and general information concerning ADM and/or its products or services, when it is not already apparent to the reasonable consumer that a material connection exists between ADM and Endorsers.
b. A “material connection” is one that could influence the weight or credibility a reasonable individual would give to the communications or messages made by the Endorser. Such connections may be in the form of (a) consideration (such as cash, prizes, “points,” or free or discounted products or services) provided by the ADM (or any of its agents acting on its behalf) to the Endorser, or (b) a relationship between the ADM and the Endorser (such as employment or contractual relationships). The disclosure of such material connections must include (a) the form of the consideration given to the Endorser and (b) the relationship between the Endorser and ADM.
c. Endorsers, who post their own opinions, comments or content about ADM, and/or its products or services, must disclose that their views do not necessarily represent those of ADM.
d. All disclosures must be made clearly and conspicuously, with appropriate consideration given to the limitations and nature of the platform being used.

4.0 Third Party Endorsers

Endorsers that employ or contract with third parties to have such third parties deliver advertising messages or other promotional communications to consumers (e.g., advertising agencies and blogger networks) are also required to cause those third parties to agree to this Policy before engaging them to communicate to consumers about ADM and/or its products or services.

5.0 Trademarks and ADM Intellectual Property

Any trademarks, logos or other proprietary materials that may be provided to or acquired by an Endorser from or about ADM shall only be used in accordance with any guidelines provided by ADM. Endorsers shall not post any such materials without explicit written permission from ADM.

6.0 Confidentiality

Endorsers may not disclose ADM’s proprietary, confidential, or trade secret information, including but not limited to disclosing or otherwise revealing ADM development plans, policy, inventions, strategy, financials, or products that have not already been made public by ADM or personally identifying information including email addresses, street addresses and private facts about any person. Endorsers should also contact ADM for clarification on whether specific information has been publicly disclosed before commenting, blogging or uploading content.

7.0 Press Inquiries

Endorsers’ endorsements and testimonials may generate media coverage. Media inquiries of any kind, whether from online (news engines, bloggers) or mainstream (newspapers, magazines) media outlets, must be referred to ADM using the Notice information below. Endorsers may not engage in any discussions or correspondence with any members of the media without first consulting with, and receiving permission from, the appropriate authorized ADM representative.

Lauren Gulley
Marketing Manager
Anderson Direct & Digital
858-413-0300
lgulley@andersondd.com

8.0 Notice

Any questions concerning the contents of this Policy should be referred, in writing, to:

Rebecca Masey
Human Resources Manager
Anderson Direct & Digital
858-413-0300
rmasey@andersondd.com

9.0 Right to Modify Policy

ADM reserves the right to amend this Policy at any time. In the event of a dispute as
to the interpretation of this Policy, ADM’s interpretation shall be final.

10.0 Effective Date

This Policy is effective immediately and was last updated 11/14/2011.