Rules Responsible Commercial Communication November 2008

Rules on Responsible Commercial Communication
Foreword Most people consume beer and alcoholic beverages in a responsible way,
but a minority drink irresponsibly – possibly consuming alcohol for the
wrong reasons, or simply drinking too much or too often. Their behavior
matters because irresponsible consumption may harm the individual
drinker and his or her environment.
This manual is designed to ensure that all of our brand communication

activities (in relation to all our company owned brands) do not promote
irresponsible alcohol use. It explains our rules on responsible commercial
communication in the context of Heineken’s alcohol policy. These rules are
not new; they were first created in the 1960s, but have been updated and
amended many times since. They form the basis of our commercial com-
munication code.
In the past, codes of this kind have been criticised for being too theoretical
or too difficult to follow on a day-to-day basis. To overcome this problem, the
manual explains the background to the rules and uses real Company brands
TV commercials, print campaigns and promotional materials to show how
the rules can be applied in practice.
It is important that we comply strictly with these rules because we are

committed to playing our part in reducing alcohol abuse. This manual
provides some additional rules compared to the previous edition to further
ensure compliance. This is why we urge you to read this manual carefully,
discuss all the rules with your internal team and with your external
consumer communication agencies to ensure everyone understands them
and, most importantly, applies them consistently every day.
Stefan Orlowski Sean O’Neill

Group Commerce Dir. Group Corporate Relations Dir.
Heineken Heineken
November 2008 November 2008
2 Rules on Responsible Commercial Communication

Contents Introduction .................................................................................. 4
Rules on Responsible Commercial Communication ............................... 6
1. Scope ................................................................................. 7
2. Basic principles ..................................................................... 8
3. Responsible drinking .............................................................. 10
4. Minors ................................................................................ 13
5. Driving ................................................................................ 16
6. Performance and workplace .................................................... 18
7. Anti-social behavior ............................................................... 20
8. Health aspects and alcohol content ........................................... 22
9. Social & sexual success .......................................................... 24
10. Sports ................................................................................. 27
11. Free samples ........................................................................ 29
12. Compliance .......................................................................... 31
Annex: Commercial communication approval form ............................... 32
For more information (contact persons) .............................................. 33

Introduction We aim to strengthen our brands by developing original, effective
and inspiring commercial communication, while also ensuring
that Heineken sets the highest standards for ethical behavior and
corporate responsibility.
To achieve this balance, all our commercial communication must stay within
the boundaries of what we consider to be responsible and appropriate, while
still retaining their power and capacity to engage. Above all, we want to avoid
irresponsible communication – communication that gives consumers any
encouragement or excuse to misuse our products. This code can help us all
achieve our objectives.
Self-regulation
Rigorous and structured self-regulation is vital. It helps us to protect our brand
reputation and safeguard the freedom of expression in commercial communi-
cation we and others in our industry currently enjoy. For this reason, these rules
cover a wide range of topics, including responsible drinking, the use of alcohol
by minors under the legal purchasing age, drink-drive issues and associations
with sports, health and social success.
Norms and standards concerning decency and moral standards can vary across
different markets and cultures; so dealing with many of the issues relating to
responsible communication takes us into grey areas. This manual provides
detailed explanatory notes and case studies to help you understand how we
draw the line between acceptable and unacceptable. It also contains guidance
about how to plan and develop new communication in order to avoid ‘censor-
ship’ or rejection.
The basic principles are clear. Responsible drinking should be portrayed as,
for instance:
• a pleasurable personal and social experience;
• a source of enjoyment and relaxation;
• one aspect of a positive lifestyle;
• connected to celebratory events.
In addition, any actors or models used in our communication should be, and
look, at least 25 years old.
Of course, ethics and responsibility are about principles, not just rules – so this
manual sets out to help you understand the spirit of our vision on corporate
responsibility, as well as the actual letter of these rules. For this reason, we’ve
included definitions and explanations of the individual Heineken rules covering
a range of topics. Each section is structured in the same way:
왘 an extract from the rules appears at the top of the page;
왘 detailed explanatory notes on the particular rule are provided, along with
test-yourself questions;
왘 examples showing how Heineken has interpreted these rules are also
included.

Introduction Promotions
Like all other commercial communication for other products, promotions
should:
• always be developed, implemented and managed responsibly;
• always comply fully with applicable laws, regulations and self-regulatory
codes;
• never be aimed at minors (or people under the legal purchasing age,
if higher);
• never encourage violent, aggressive, dangerous, anti-social or illegal
behavior;
• never encourage over-consumption based on low-price, discounted
or free beer;
• never encourage drink driving or alcohol misuse;
• never demean any group in society or offend accepted standards of
taste and decency.
Given the global nature and structural complexity of the beverage alcohol
industry and the restaurant, retail, bar and hospitality business, Heineken may
not always be involved in or aware of promotional activities that involve our
products. This obviously affects our ability to control the content and tone of
such activities, so a great deal of responsibility falls on the operator or owner
of a venue where promotional event takes place.
Nevertheless, we recognise that it is in our best interest that our products

and all other alcoholic beverages are promoted responsibly. We have made a
commitment to work with relevant organisations, so that the rules covering
promotions and free sampling are communicated effectively in many different
sectors – for example, retail and horeca.
Because we believe promotions are both an important and unique form of

commercial communication, we have included specific explanatory notes in
this manual to address the issues they present.

Rules on 1. Scope
2. Basic principles
Responsible 3. Responsible drinking
Commercial 4. Minors
5. Driving
Communication 6. Performance and workplace
7. Anti-social behavior
8. Health aspects and alcohol content
9. Social & sexual success
10. Sports
11. Free samples
12. Compliance

1 Scope
Throughout this manual, we have defined ‘commercial communication’ as:

‘All brand advertising and marketing communication to consumers, regard-
less of the medium used, such as broadcast media, internet (including our
promotions on third-party websites), SMS messaging, labeling, merchandising,
packaging, print media, point-of-sale material, premiums, promotions, public
relations and sponsorships’.
Commercial 왘 non-advertising materials or statements to the media, government

communication agencies or the public about issues of societal concern, for example the
does not include: risks or benefits related to the consumption of alcoholic beverages;
왘 educational messages about responsible drinking or the role of alcohol
in society.
Remember – our rules on corporate responsibility and responsible com-

mercial communication apply to all brands owned by Heineken operating
companies.
Explanatory notes General
왘 All commercial communication should comply with the letter and spirit of
local, regional and national laws, as well as other relevant regulations (for
example, TV and cinema advertising, sponsorship and internet regulations).
왘 Although statements to the media are not technically covered in this manual
they also must conform to its rules. (For example, try to avoid imprecise
terms such as ‘young consumers’ which are intended to refer to young
adults above the legal purchasing age, because they may be misinterpreted
by the media as referring to younger people than intended.)
왘 All Heineken corporate and brand-related websites should ask for confir-
mation of age on the homepage; inviting users to enter their date of birth
and consequently refusing access to those below the legal purchasing age.
왘 Familiarize yourself with all applicable internet regulations.
왘 These rules apply to all communication channels and all media, including
the internet and digital media of any kind that are used to transmit com-
mercial alcohol-related marketing communication to our customers.
왘 When we market brands owned by third-parties, we will comply with the

Scope
marketing rules set by the respective brand owners; in the same way, we will
demand that third-parties that market our brands, comply with our rules on
responsible commercial communication. However, we will also whenever
possible apply our own commercial communication rules when we control
the marketing of third party brands.

2 Basic principles
Our commercial 왘 be legal, decent, honest and truthful; conforming to accepted principles
communication of fair competition and good business practice;
must: 왘 be prepared with due regard for our social responsibility and based on
principles of fairness and good faith;
왘 never impugn human dignity and integrity or be unethical in any way.
Explanatory notes 1. General
왘 Always avoid the use of stereotypes and humor related to age, disability,
gender, race, nationality, religion or sexual orientation.
왘 The purpose of any commercial communication should be to promote a

particular brand; not the effects of alcohol. We need to be acutely aware
that alcoholic beverages are fundamentally different from many other
products, placing us under an even greater obligation to behave sensitively
and responsibly. These principles are ‘basic’ in the sense that they apply to
commercial communication in general (regardless type of product).
왘 ‘Legal’ and conforming to ‘principles of fair competition and good business

practice’ means that commercial communication should comply with both the
letter and spirit of all local, regional and national rules, regulations, laws and
business practices in the country where the communication is disseminated.
왘 Bear in mind that a print campaign or TV commercial may also be watched by

consumers outside the target group for which it is intended.
Basic principles
왘 Definitions of what is ‘decent’ and ‘acceptable’ vary from culture to culture,

even between age groups. The context is often all-important: treatments
which could be considered offensive by an older audience may be accept-
able if targeted carefully for a younger audience above the legal purchasing
age – but you should try to avoid offending anyone.
왘 ‘Decent’ is also closely linked to concepts such as violence, or dangerous, unethical

or irresponsible behavior. These should be avoided at all times and so should the
gratuitous and demeaning use of sexual imagery, messages and innuendo.
왘 ‘Honest’, ‘truthful’, ‘fairness’ and ‘good faith’ relate to the integrity of our messages:
we should never lie or present facts about our products that are untrue.
왘 ‘Ethical’ means that our actions must be true to the spirit of our rules on
responsible commercial communication. It is unethical to try to find loopholes
and ways around these rules, or to act in defiance of generally held moral
principles, even if such actions are not expressly prohibited by these rules.
왘 Respecting ‘human dignity and integrity’ means that people should never
be portrayed in a degrading way or asked to degrade themselves.

왘 Humor should be used with care. What is considered humorous in one
country may be deeply offensive in another. Ideas about what is and is not
humorous also vary within a single country or culture, between different
generations for example. Humor should never be used as justification for
acting in a way which is contrary to the letter or spirit of these rules.
2. Regarding promotions
왘 No one should be prohibited from participating in any promotion on the

basis of their race, sexual orientation, religion or political inclination.
왘 The price and alcoholic content of any promoted beverage must be commu-
nicated to all participating consumers before promotional activities start.
Test questions on If you answer ‘no’ to any of these questions, rethink your concept; it may not
basic principles comply with the letter and spirit of these rules:
1 Would you be comfortable to see your partner or a family member portrayed

in this way?
2 Do you think your concept would receive a positive reaction from the public
if a newspaper published an article explaining its content?
3 Would you be happy to stand up in court and defend your concept as legal,
decent, truthful and honest?
Basic principles
Example
In this Amstel commercial, you see three guys in a bar having discussions about
a woman. They are in doubt whether she is in fact a woman, or a transvestite.
In order to check this, one of the men walks up to her, and asks her a question
about soccer (when is a player off side). The woman immediately gives the
correct answer, which leads the men to the conclusion that it has to be a trans-
vestite, hence a man.
Although this commercial was well received as humor in the Netherlands, it was
received badly in Spain. This is an example where the different cultural per-
spectives were not taken into account, and it also shows that humour does not
solve this. What is funny in one cultural setting, can be insulting in another.

3 Responsible drinking
Our commercial 왘 encourage or condone excessive or irresponsible consumption;

communication 왘 present abstinence or moderation in a negative way;
must never: 왘 allude to, or suggest any association with, illegal drugs or the drug culture;
왘 feature drunk people or imply in any way that drunkenness is acceptable.
왘 We will not portray irresponsible drinking, because to do so would compro-

mise our efforts to promote positive drinking patterns and to help prevent
abuse. It would not only damage our brands and our corporate credibility,
but might also put the self-regulation system at risk.
왘 Never encouraging ‘excessive or irresponsible consumption’ means that

our communication must not encourage people to drink beyond safe
personal limits or in an anti-social manner. Consumers must never be
encouraged (or shown in our communication) to exceed sensible drinking
guidelines or drink sufficient volumes to lose their self-control.
Responsible drinking
왘 In practice, this means that our commercial communication should be

about creating a positive brand experience, rather than encouraging
consumers (through images, actions or words) to drink large amounts or
exceed their limits. They should not show or describe people drinking
large numbers of drinks, large volumes of beer or consuming alcohol at
high speed.
왘 Showing people drinking from the bottle may be acceptable if this is the
normal way to consume the featured product (for example a Heineken
‘Longneck’), but our communication must not imply that a bottle is being
emptied in a single draught. The angle of the bottle should suggest that
the drink is being sipped slowly.
왘 People should not be ‘challenged’ to drink: we must show respect for

‘abstinence and moderation’. People who choose not to drink or who
drink limited amounts, should not be disparaged, ridiculed or portrayed
in a negative light – for example, as ‘uncool’.
왘 Avoid showing, suggesting or encouraging regular solitary drinking.

Ask yourself: is the inclusion of a solitary drinker really essential to
communicate the brand values and benefits? If your communication
focuses on ‘personal enjoyment’ there may be a valid reason to show
someone drinking alone.
왘 We include responsible drinking messages on Heineken and Amstel

websites while also encouraging local websites to carry responsibility
messages as well.

왘 All back labels on Heineken and Amstel packages must include a reference
to the website Enjoy Heineken Responsibly/Enjoy Amstel Responsibly or to
Heineken.com where consumers can find a link to these sites or to another
local Heineken website that contains the same link or responsibility
message.
왘 Do not organise ‘drinking games’ that encourage excessive or irresponsible

consumption – for example, activities that involve either ‘speed incentives’
or require participants to drink an excessive amount of alcoholic beverages
within a short period of time.
왘 Do not serve consumers who appear to be uncontrollably excited, drunk

or aggressive and/or who engage in anti-social behavior. Ensure staff
are fully briefed about how to manage consumers who appear drunk,
aggressive or anti-social.
왘 Do not put pressure on people to participate in promotional activities.
왘 Display an appropriate and clearly visible responsible drinking message.
왘 Make sure that no promotional activities or elements encourage excessive

or irresponsible consumption – for example, content, language, behavior
of promotional teams, prices and timing of events.
왘 If a promotion or incentive includes a multi-purchase element make sure

that consumers are not encouraged to drink over the national recommen-
dation for sensible drinking.
왘 Promotional activities and messages should never encourage consumers

to engage in risky or potentially dangerous activity.
Test questions on If you answer ‘no’ to any of these questions, rethink your concept; it probably
responsible drinking does not comply with the letter and spirit of these rules:
1 Would you feel comfortable to behave this way yourself?

2 Would you be happy to see your partner or a family member
behave this way?
3 Would you feel comfortable to be involved in this situation?

Example
This is an advertisement for Brava in Colombia. The slogan reads ‘Brava te sube,
no te vas a querer bajar’, which translates as ‘Brava lifts you up, you don’t want
to get down’ which is usually interpreted as ‘Brava gets you drunk’.
In our view, this is a clear example of unacceptebable advertising – especially

when you consider that the communication is widely published and accessible
to people of all ages.

4 Minors
Our commercial 왘 never target minors (i.e. people younger than 18 years or under the legal
communication purchasing age (LPA) , when LPA is higher than 18 years);
must: 왘 only promote beer through media, programs and events where at least
70% of the audience are reasonably expected to be people older than 18
or above LPA (when LPA is higher than 18 years);
왘 feature people who are at least 25 years old and act and appear their age.
왘 Do not use objects, images, styles, symbols, colors, music, fictitious charac-
ters or real figures (including (sport-)celebrities) that appeal primarily to
children or adolescents.
왘 Do not use familiar brands, for example names, logos, games, games
equipment or other items, that appeal primarily to children or adolescents.
왘 We must investigate the expected audience composition when making

media placement decisions, whether for television, radio, internet, webites,
sms messages or in print advertising. To make sure we comply with 70% rule
we must consider the actual or expected audience, rather than the target
audience. This can be accomplished in many countries through available
media research for the media in question. If there is no research available
for the precise media, program or internet site, you should look to research
on comparable media programs or websites.
왘 Outdoor print campaigns – for example, billboard advertisements – should

be located at least 500 feet/150 metres from elementary or secondary
schools, places of worship or public playgrounds.
왘 In the case of sponsored public events, specifying restrictions on admission

in any contract agreed with an event organiser is a good way of checking
audience composition. Wherever it is not known in advance what the actual
audience age composition will be, we must check prior similar events’s
audience age composition to be sure that it complies with the 70% rule.
왘 For cinema advertising, the rating given by the local film classification
board is only a guideline; always use the 70% rule.
Minors
2. Regarding internet & related technologies
왘 When designing internet communication, particular attention needs to be

paid to avoiding minors. Internet ads, sms messaging and internet sites, their
content and related technologies should be designed for adults. As well as
your company and brand websites, promotions on third-party websites must
also comply with these rules. Content that may be especially attractive to
minors must be avoided.

Where it is necessary to use animations or games, screensavers etc.,
they should clearly be adult-orientated:
왘 All brand internet sites must state clearly that entry is restricted to people
over the legal purchasing age in the country of consumer access only and
prohibited to anyone younger than 18 years (or the LPA in the country of
access if older). Users must be required to enter their date of birth, and
access must be denied to anyone who enters an ‘underage’ birth date.
왘 When advertising or sponsoring third party websites, the websites must

comply with the 70% rule.
3. Regarding sponsorships
왘 Sponsorship of activities or events that will include people under the legal
purchasing age is a particularly sensitive area. You should be aware that
sponsorship of this kind may provoke negative public reactions if people
under the legal purchasing age participate. As a general rule:
컄 Do not sponsor activities or events if people under the legal purchasing
age are reasonably expected to make up more than 30% of those partici-
pating or viewing. If in doubt, do not sponsor.
왘 Negotiate with merchandisers to determine whether or not items should

carry your brand or company logo. Do not use an alcohol brand (logo) on
items intended for minors. Consider producing the same item with and
without your logo and always use your common sense.
왘 Do not proceed with a promotional activity if it is reasonably expected that

more than 30% at the promotion site will be under the legal purchase age.
If in doubt, do not go ahead.
왘 Consider using display material to inform consumers that alcoholic

beverages are only available to people above the legal purchasing age.
왘 If in doubt, always ask participants for proof of age – but be aware of

national laws and regulations regarding identity and proof of age requests.
Minors
왘 Make sure that the content of promotional materials and activities do no

appeal primarily to people under the legal purchasing age – check content,
language, imagery, music, celebrity endorsements and other elements.

minors comply with the letter and spirit of these rules. The tests should be applied to both
the message and the medium:
1 Do you think your child or a friend’s child may be tempted to re-enact

the concept in real life?
2 Would you be comfortable describing your concept to parents at your
children’s school or your local high school?
Example
In this Sloeber commercial (a Belgian beer brand), three beer bottles are doing
a striptease act. The bottles are represented as persons, dancing and acting like
cartoon figures would. This commercial is not in line with our rules, because the
concept is highly likely to attract minors.
Minors

5 Driving
Our commercial 왘 depict or encourage consumption of alcohol while driving motor vehicles
communication of any kind – including speedboats, jet-skis, snow mobiles or aircraft;
must never: 왘 relate to events connected with motor vehicles – including advertising
displays at motor racing circuits.
왘 Drinking and driving do not mix and we must avoid creating any associ-
ation between these activities. Sponsorship of public transport and taxis
is permitted only when combined with a ‘don’t drink and drive’ message.
However, when a communication is specifically targeted at highway users
(for example billboards alongside the highway connecting cities) a clear
‘don’t drink and drive’ or ‘enjoy Heineken responsibly’ message is obligatory
When an event organiser provides transport at events which we sponsor,
our logo may appear on any vehicles used.
왘 We do not sponsor car or motorcycle racing and do not want to be associ-

ated with these activities. For example, despite the high audiences, prestige
and excitement they generate, we do not sponsor or act as official supplier
to Formula 1 events.
왘 The branding of our own trucks and vans is permitted.
왘 Never produce communication that suggests drinking even a single beer

before driving is acceptable or can do no harm. Apart from the liability
issues, our consistent position must be ‘don’t drink and drive’.
왘 Do not give away or sell branded items linked to driving.
왘 If your ad features an individual arriving at a party or driving a vehicle

before entering a bar, you must make it clear that he or she will not be
driving later – for example, by showing the featured individual taking
a taxi or handing car keys to a non-drinker. It is best to avoid showing
people driving in ads, so consider the alternatives – most concepts work
just as well if people are show arriving at locations by taxi or on foot.
Driving
왘 Be particularly vigilant about the participation of consumers who may drive

following promotional activities – for example, after a supermarket tasting.
왘 Consider displaying a ‘don’t drink and drive’ message.
왘 Be careful when considering or participating in promotional activities

taking place at venues closely linked with driving – for example highway
restaurants or stores.

driving comply with the letter and spirit of these rules:
1 Is the portrayal of driving really essential to communicate our brand values

and product benefits?
2 If the concept was real, would all featured individuals be free of the risk of
harming themselves or others?
Example
This is an example of SAB’s drink and live responsibly campaign. Heineken

has an equivalent campaign in the Netherlands, the BOB campaign,
using humor and a recognizable logo with a new term (to ‘bob’) to make
people aware of their responsibility not to drink when they drive.
Driving

6 Performance and workplace
Our commercial 왘 create the impression that consumption of our alcohol products enhances
communication mental and physical ability or performance;
must never: 왘 suggest that consumption of our alcohol products is acceptable before or
during the operation of potentially dangerous machinery; or while under-
taking any potentially hazardous recreational or work-related activity in
or near the workplace.
Performance and workplace
왘 Never suggest that drinking alcoholic beverages enhances either mental

ability (concentration, intelligence or alertness for example) or physical
capability (strength or stamina for example).
왘 Do not show people drinking alcoholic beverages at work, in a bar or over

lunch, when it is clearly apparent that they have to return to work. If your
concept requires a business setting, make it clear that any action takes
place at the end of a working day.
왘 Activities that are not normally considered dangerous may become so if

people undertake them after drinking. Avoid associating alcohol consump-
tion with activities of this kind – for example, the felling of trees or the use
of drills and other tools.
왘 Avoid associating alcohol consumption with potentially dangerous activities.

If any association is made, it must be made clear that drinking takes place
after the activity is completed and that the activity will not be resumed after
drinking.
왘 Make sure promotions do not feature or encourage any hazardous activities.
Test questions on If you answer ‘yes‘ to any of these questions, rethink your concept; it may not
performance and workplace comply with the letter and spirit of these rules:
1 Does the language or imagery used suggest that drinking alcohol enhances
mental ability or capacity?
2 If the concept was real, would any featured individuals be at risk of harming
themselves or others?
3 Could a rational viewer conclude that any activities featured in the concept
would not have taken place if alcohol was not being consumed?

Example In our view, this ad for Anheuser-Busch’s Bud Light undermines workplace
prevention efforts by offering an excuse to leave work early to join friends at
a bar, hence it would not conform to our rules. Although the tiny print at the
bottom that says ‘Responsibility Matters’, we still consider this ad unacceptable.
Performance and workplace
This ad appears in the April 2005 issue of US magazine Shape, a magazine

for fitness and nutrition conscious young women.
Full text of the ad:

‘Want to leave work early for a cold Bud Light? This will help. Can we make
your night out better? Sure. When your friends have ducked out of work early
and are waiting for you at the bar, it’s time you do the same. Cut this out,
tape it to your door, and don’t wait for the phone to ring.’

7 Anti-social behavior
Our commercial 왘 suggest, feature or imply any association with violent, aggressive, illegal,
communication dangerous or anti-social behavior.
must never:
For this reason, we will not sponsor events that are associated with violence
or aggression and which may endanger third parties.
왘 Violence and aggressive behavior are issues in many countries and alcohol
misuse is often mentioned in connection with both. Although no causal link
has been established by research, we must still actively avoid any associa-
tion with violence. Alcohol reduces inhibitions and some people use alcohol
abuse as an excuse for their own misbehavior.
왘 Commercial communication must not feature violence or create an aggres-

sive atmosphere. Nothing in our commercial communication – words,
actions or images – should associate drinking with violent, aggressive,
dangerous or anti-social behavior; or suggest that we encourage or condone
such behavior. If you are unsure whether your communication is in line with
the code, always err on the side of caution. Anti-social behavior is defined
Anti-social behavior
as any action that, directly or indirectly, may cause other people distress,
annoyance or inconvenience.
왘 In sponsorship activities, avoid any obvious, direct or symbolic links between

alcohol consumption and actual or possible inappropriate behavior.
왘 Make sure that promotional activities do not encourage or can be associated

with violent, anti-social or aggressive behavior.
anti-social behavior comply with the letter and spirit of these rules:
1 Would you be happy to engage in the featured activity after drinking and
not consider it dangerous or irresponsible to do so?
2 Would you be comfortable defending any featured activity as ‘safe’, even
if someone mimicked it in future?
3 Would you feel comfortable if a partner or friend engaged in this activity
after drinking alcohol?

Example
Anti-social behavior
In this Miller Lite commercial two women argue about whether it is the
great taste that makes Miller Lite so fantastic, or the fact that it is less filling.
Their argument gets out of hand and results in a physical fight, and while
intended to be humorous, associates a brand with violent and anti-social
behavior that is portrayed as sexy and funny. Therefore, this example verges
on the border of non-compliance with our rule on anti-social behavior, and
we would discourage such an advertisement.

8 Health aspects and alcohol content
Health aspects and alcohol content
Our commercial 왘 suggest that our products can prevent, treat or cure any human disease
communication – or even associate them with such properties;
must never: 왘 claim that alcohol has therapeutic qualities, or that it is a stimulant,
sedative or means of resolving personal conflicts;
왘 create confusion or misunderstanding about the strength of our brands
or their alcohol content;
왘 present the high alcohol content of any beverage as a positive attribute,
or imply that consuming beverages with low alcohol content is a way to
avoid alcohol abuse;
왘 associate alcohol with pregnancy.
왘 Beer is a beverage that gives pleasure; it must never be presented as

having therapeutic, sedative or stimulant properties. Our commercial
communication must not create the impression that it offers an easy
solution to unwanted physical or emotional experiences.
왘 Although scientific research suggests that moderate alcohol consumption

may have some health benefits, we must not use this in product advertising.
Avoid all claims or suggestions that specific products or alcoholic beverages
in general have positive health effects.
왘 Alcohol content and product strength should never be presented as the

primary benefit of consuming any product, or form the main theme of
the communication. If relevant, a simple statement of alcohol content is
acceptable.
왘 Never make positive claims about alcohol content or suggest that a drink is
preferable to another because it is stronger. Similarly, avoid suggesting that
a drink’s relatively low alcohol content means that it can be drunk in quanti-
ties or in circumstances where a stronger beverage might be inappropriate.
Although the consumption of low content alcohol beverages can fit into a
more responsible drinking pattern, never suggest that drinking low content
alcohol beverages is a way to avoid abuse of alcohol.
왘 Corporate communication without any commercial intentions may refer to

the positive health aspects of moderate beer consumption but should always
acknowledge that irresponsible consumption can have adverse effects.
왘 Be cautious when other parties (for example, brewers’ trade associations

of which Heineken is a member) propose to refer to positive health effects
in their communication. When talking about positive effects, always
acknowledge that irresponsible consumption can have negative effects.
왘 Never show pregnant women drinking in ads or any other commercial com-
munication. Never target commercial communication at pregnant women.

Health aspects and alcohol content
왘 Do not use drink-delivery methods or any gimmicks that may confuse or

mislead consumers about the amount of alcohol they are consuming – for
example, alcohol sprays or vaporisers.
왘 Make sure that promotional activities never suggest a beverage can prevent,
treat or cure a human disease.
Test questions on If you answer ‘no’ to these two questions, rethink your concept; it may not
health aspects and comply with the letter and spirit of these rules:
alcohol content
1 Is the wording of every claim made in your communication 100% accurate?
2 Would the alcoholic content of the product be clear to any rational person
reading or watching the communication?
If you answer ‘yes’ to these questions, rethink your concept, it may not comply
with the letter and spirit of these rules:
1 Does the communication suggest that any product has a health or

sedative benefit?
2 Does the communication associate pregnancy with drinking?
Example
In this advertisement for Amstel Light a reference is made to low carbs, which
result in lower calories. This is in line with our rules, because it is not suggested
that the beer is healthier because of the lower percentage of alcohol.

9 Social & sexual success
Our commercial 왘 create the impression that the consumption of alcohol contributes
communication towards, or is a pre-requisite for, social or sexual success;
must never: 왘 suggest any association with sexual success or enhanced sexual
performance;
왘 breach generally prevailing standards of taste and decency
or otherwise impugn human dignity or integrity.
왘 EU-legislation prohibits advertising that suggests alcohol consumption

contributes towards social or sexual success. This legislation covers all
EU countries, irrespective of whether or not there is evidence of public
concern about the issue. We believe that compliance with this rule is vital
(globally as well) if we are to retain the confidence of both the public and
Social & sexual success
regulators in the self-regulation process.
왘 Showing attractive people or featuring scenes in which men and women

socialise is entirely acceptable. Alcohol forms a fundamental part of the
social fabric in most western countries and has a long history as a ‘social
lubricant’.
왘 ‘Social success’ means:

컄 gaining status in the form of promotion, wealth, friends, possessions
and popularity;
컄 gaining other people’s admiration or recognition of one’s achievements.
왘 Most commercial communication features social environments because

these offer a natural setting for alcohol consumption – but make sure
you never suggest that drinking our beers will improve social success.
왘 ‘Aspirational’ advertising, which presents a brand or product as a com-

plement to good living, social accomplishments or good taste, does not
contravene these rules. Beer may be associated with or used as part of
a celebration.
왘 Communication in which successful people endorse a brand should not

imply that buying these brands will help the purchaser to replicate the
endorser’s success.
왘 Before you create a concept with a sexual theme ask the question: is this
really the only way to communicate brand values and product benefits?
Always look for other ways to get your message across.

왘 Although the term ‘sexual success’ is open to a number of different and not
always mutually exclusive interpretations, our commercial communication
should not:
컄 suggest that drinking or serving a specific brand, or alcoholic beverages
in general, will make anyone more sexually attractive;
컄 present any alcoholic beverage as an aid to seduction or a way to reduce
sexual inhibitions;
컄 portray drinking as a prelude to sexual intimacy;
컄 suggest that the consumption of alcohol enhances sexual performance;
컄 present alcoholic beverages as an ‘accessory’ to sexual activity – by
showing people drinking before, during or after sex, for example.
In addition to the rules covering ‘sexual success’ you should also be aware of
three other important constraints:
컄 the bounds of good taste should not be exceeded;
컄 although ‘sex’ is widely used in marketing many products, it should not
be the focus of ads by Heineken;

컄 our advertising should never have special appeal for those below the
legal drinking age.
왘 Make sure promotional activities do not link the consumption of alcoholic

beverages with increased social and/or sexual success.
social & sexual success comply with the letter and spirit of these rules:
1 Would you feel comfortable watching this communication with your

children, parents or grandparents?
2 Will men and women really interpret the communication in a positive way?
3 Do you want your children to consider the behavior or situation featured in
this communication as ‘normal’ while they are growing up?

Example
This advertisement for Beck’s appears to be aimed at the gay community and
arguably leaves you with the impression that drinking Beck enhances both
your sexual attractiveness and sexual desire. Therefore it would not conform
to our rules.

10 Sports
왘 Our commercial communication should not create the impression that

consumption of alcohol enhances athletic performance.
왘 Sponsorships of individuals and/or teams are only allowed when
combined with a responsibility programme.
왘 The rule on sponsorships applies to all brands except the Heineken brand,
since the Heineken brand is not allowed to sponsor teams and/or individuals
at all. Please also refer to the Heineken Rule Book, under Group Commerce,
category Brands, section Sponsoring Rules (incl. brand experiences), rule nr. 6.
왘 Never suggest that drinking alcohol beverages improves mental or physical

performance; or that the consumption of alcohol produces positive results
– for example, a win for the team.
왘 Our commercial communication should only ever feature alcohol con-

sumption taking place take after sporting activity – never before or during.
왘 Do not mix scenes of sports with scenes of beer consumption.
왘 Take care when deciding which sports to feature in your commercial

communication – assess whether the activity is truly adult, both in terms
of those participating and those watching or reading the communication.
왘 Do not sponsor events or sports merchandising activities that appeal espe-

cially to minors (or to people under the legal purchasing age, if higher).
왘 Remember – many people do not believe that sporting celebrities should

endorse the consumption of alcohol, while the use of sports celebrities
who appeal primarily to people under the legal purchasing age is forbidden.
왘 Associations with violent sports such as boxing should be avoided. While we

recognise that what is considered appropriate in one country may be deemed
inappropriate in another, we must always bear in mind that a concept may
gain international exposure, even if that was not originally intended.
Sports
왘 Do not encourage or promote drinking before or during sporting activity

of any kind.
왘 Do not display our brands on children’s clothing; it should be clearly

mentioned in any contract that brands are to be displayed on clothing
for adults only (or to above the legal purchasing age, if higher).

sports comply with the letter and spirit of these rules:
1 Are you sure that at least 70% or more of the audience for this commu-
nication can reasonably expected to be above the legal purchasing age?
2 Are you sure that no rational person can conclude that your communication
promotes the consumption of alcohol while participating in a sport?
3 Are you sure that no rational person can conclude that drinking the
featured alcoholic beverage will help them to win?
Example
This Carlsberg tv-commercial shows three men riding a ski lift down a
mountain. They decide to race down instead, the last man down to pay for
the beer. They jump from the moving ski lift and race down the mountain,
knocking over a man in their path, who then slides down helplessly after
them, the joke being that since he arrives last, he should pay for the beer.
This advertisement shows potentially dangerous behavior in sports,

Sports
and fails to establish clearly that the men have finished skiing for the day
before drinking. Therefore, it would not conform to our rules.
The commercial was eventually withdrawn by Carlsberg.

11 Free samples
The distribution of 왘 free samples may not be offered to minors (or to people under the legal
free samples is subject purchasing age, if higher);
to the following rules: 왘 free samples may not be offered in public places;
왘 free beer may only be offered in designated hospitality areas.
Explanatory notes General
왘 The distribution of free samples must comply with:

컄 local laws and regulations;
컄 existing sales promotion guidelines.
왘 The environment in which samples are offered must also be reviewed

because a distinction is made between on-trade and off-trade locations.
The following rules apply:
On-trade (already a 컄 one measure only (a standard unit);

controlled environment): 컄 samples must be consumed at the point of distribution.
Off-trade: 컄 one appropriate drink (sufficient to demonstrate the brand’s taste

and color attributes);
컄 anyone tasting our brands must be warned that the sample
contains alcohol and provided with information about its strength;
컄 anyone tasting a sample must comply with legal purchasing and drinking
age requirements;
컄 if the sample is not consumed at the point of distribution recipients
must be advised that it is for their consumption only and that they
should not consume it before driving or give it to minors (or to people
under the legal purchasing age, if higher).
왘 Sampling is about offering consumers a positive brand experience that

Free samples
makes them want to buy our products. Offering any consumer more
than one drink could be counterproductive and encourage irresponsible
drinking.
왘 Alcoholic drinks should never be offered to minors (or to people under the
legal purchasing age, if higher), even with parental consent.
왘 It is advisable to include one non-alcoholic product in sampling promotions.

free samples comply with the letter and spirit of these rules:
1 Are you proud of the way this sampling event is being conducted?
2 Would you be happy to invite observers and journalists to this event?
3 Are you completely satisfied that the free drink you are offering is not
encouraging irresponsible drinking?
Example
This promotion poster shows and promotes irresponsible drinking, therefore

it would not conform to our rules.
Free samples
The text reads: ‘Bacardi will be painting the town red this Halloween.
The Bat Girls will be at the bars of Wanchai and TST from 10pm - 2am, trying
to drown people in free-pour lay-backs. Don’t want to be seen red-faced?’

12 Compliance
Ensuring compliance The instructions set out below should ensure that all Heineken Operating
with the rules for Companies comply with our rules on responsible commercial communica-
responsible commercial tion. These rules apply to all brands owned by Heineken group companies.
communication Additional marketing rules are in place for the Heineken and Amstel brands.
왘 For all commercial communication, approval should be registered by

filling in the commercial communication approval form. Retention of this
form is obligatory.
왘 In case of any complaints received from (non-)governmental organisations,

consumers or official complaint bodies with respect to a particular com-
mercial communication, all related correspondence should be properly
stored.
왘 All complaints should be registered for audit purposes.
왘 In order to keep all employees in your marketing and sales department

fully informed about our rules on responsible commercial communication,
refresher courses on these rules should be organised annually.
Explanatory notes 왘 For all commercial communication (including national television and cinema
commercials, radio, print, outdoor campaigns, internet communication,
local promotions and sales activities)
approval is required from the Commercial director of your company.
The Commercial director should assess whether the type of commercial

communication is compliant to these rules. When in doubt, or when other-
wise considered necessary, the Commercial director should involve the legal
department and/or contact the Heineken Corporate Affairs department in
Amsterdam (or the corporate relations manager when applicable).
왘 An example of a commercial communication approval form can be found in

Compliance
the Annex.

Annex Commercial communication
approval form
Name Opco:
Type of activity:
(TV commercial, advertisement campaign, promotion, or other?)
Name person in charge:
Function:
(commercial director)
Please fill in the questions below
1 Does this commercial communication activity depict, encourage or

condone:
왘 excessive or irresponsible drinking;
왘 drinking in the context of driving motor vehicles of any kind?
2 Does this commercial communication activity target persons above

the applicable legal age for purchasing beer?
3 Are all persons in the commercial communication at least 25 and

do they act and look their age?
4 Does this commercial communication:

왘 create the impression that drinking enhances mental of physical
ability or (athletic) performance?
왘 associate drinking with violent, aggressive, dangerous or anti-social
behavior?
왘 associate drinking with pregnancy, or portray alcohol as a product
beneficial to health?
5 Does this commercial communication create the impression that

drinking beer leads to sexual or social success?
Time and date:
Approved by (signature):

For more Sandrine Huijgen Aart A.W. van Gestel
Group Commerce Group Corporate Relations
information P.O. Box 28 P.O. Box 28
1000 AA Amsterdam 1000 AA Amsterdam
The Netherlands The Netherlands
Tel: +31 (0)20 5239 442 Tel: +31 (0)20 5239 267
sandrine.huijgen@heineken.com aart.vangestel@heineken.com

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Rules on Responsible Commercial Communication

This manual is designed to ensure that all of our brand communication

It is important that we comply strictly with these rules because we are

Stefan Orlowski Sean O’Neill

2 Rules on Responsible Commercial Communication

Rules on Responsible Commercial Communication ............................... 6

2. Basic principles ..................................................................... 8

3. Responsible drinking .............................................................. 10

6. Performance and workplace .................................................... 18

7. Anti-social behavior ............................................................... 20

8. Health aspects and alcohol content ........................................... 22

9. Social & sexual success .......................................................... 24

10. Sports ................................................................................. 27

11. Free samples ........................................................................ 29

12. Compliance .......................................................................... 31

Annex: Commercial communication approval form ............................... 32

For more information (contact persons) .............................................. 33

3 Rules on Responsible Commercial Communication

4 Rules on Responsible Commercial Communication

Nevertheless, we recognise that it is in our best interest that our products

Because we believe promotions are both an important and unique form of

5 Rules on Responsible Commercial Communication

6 Rules on Responsible Commercial Communication

Throughout this manual, we have defined ‘commercial communication’ as:

Commercial 왘 non-advertising materials or statements to the media, government

Remember – our rules on corporate responsibility and responsible com-

Explanatory notes General

왘 Familiarize yourself with all applicable internet regulations.

왘 When we market brands owned by third-parties, we will comply with the

7 Rules on Responsible Commercial Communication

Explanatory notes 1. General

왘 The purpose of any commercial communication should be to promote a

왘 ‘Legal’ and conforming to ‘principles of fair competition and good business

왘 Bear in mind that a print campaign or TV commercial may also be watched by

왘 Definitions of what is ‘decent’ and ‘acceptable’ vary from culture to culture,

왘 ‘Decent’ is also closely linked to concepts such as violence, or dangerous, unethical

8 Rules on Responsible Commercial Communication

왘 No one should be prohibited from participating in any promotion on the

1 Would you be comfortable to see your partner or a family member portrayed

9 Rules on Responsible Commercial Communication

Our commercial 왘 encourage or condone excessive or irresponsible consumption;

Explanatory notes 1. General

왘 We will not portray irresponsible drinking, because to do so would compro-

왘 Never encouraging ‘excessive or irresponsible consumption’ means that

왘 In practice, this means that our commercial communication should be

왘 People should not be ‘challenged’ to drink: we must show respect for

왘 Avoid showing, suggesting or encouraging regular solitary drinking.

왘 We include responsible drinking messages on Heineken and Amstel

10 Rules on Responsible Commercial Communication

왘 Do not organise ‘drinking games’ that encourage excessive or irresponsible

왘 Do not serve consumers who appear to be uncontrollably excited, drunk

왘 Do not put pressure on people to participate in promotional activities.

왘 Display an appropriate and clearly visible responsible drinking message.

왘 Make sure that no promotional activities or elements encourage excessive

왘 If a promotion or incentive includes a multi-purchase element make sure

왘 Promotional activities and messages should never encourage consumers

1 Would you feel comfortable to behave this way yourself?

11 Rules on Responsible Commercial Communication

In our view, this is a clear example of unacceptebable advertising – especially

12 Rules on Responsible Commercial Communication

Explanatory notes 1. General

왘 We must investigate the expected audience composition when making

왘 Outdoor print campaigns – for example, billboard advertisements – should

왘 In the case of sponsored public events, specifying restrictions on admission