Advertising Policy

1. Introduction
PVM is committed to responsible advertising placement in any programming or media directed to children under 12 years of age. Any placement and programming will be appropriate for the intended target audience and will adhere to the guidelines set forth in this policy.

2. Purpose
This policy will provide guidelines as to how to responsibly advertise to children under 12 years of age.

3. Scope
This guideline applies to all advertising directed to children under 12 years of age.

4. Advertising to Children Guidelines

4.1. PVM supports responsible marketing where children are concerned and is a member of the Better Business Bureau’s Children's Advertising Review Unit (CARU). PVM agrees to adhere to the marketing guidelines established by CARU, which are attached as Appendix 1.

4.2. PVM is committed to advertising its products within the framework of the overall diet, appropriate energy balance, and eating occasion depicted. To accomplish this goal, confectionary advertising:

• Will feature a reasonable portion size for the situation depicted.
• Will portray the advertised product as a snack, treat or dessert and not as a substitute for a meal.
• Will not disparage healthy lifestyle choices or the consumption of foods recommended for increased consumption by current USDA Dietary Guidelines for Americans and My Pyramid, as applicable to children.

4.3. PVM is committed to providing information to children under 12 about healthy dietary choices, portion control and energy balance by:

• Offering and promoting smaller serving packaging to encourage portion control.
• Sponsoring healthy lifestyle activities such as sporting events, school or community health fairs, nutrition education programs, and physical education programs.

4.4. PVM will not use third-party licensed characters in advertising in a manner that suggests or promotes excessive consumption or blurs the distinction between and advertisement and a television program, movie or other entertainment content.

4.5. PVM will include nutrition information on all packaged confectionery products as required by law and will also provide this information on our product websites.

4.6. For any of PVM’s product websites that have online interactive games primarily directed to children under 12 years of age where our products are incorporated into the game, the online interactive game will either: (a) include links to information about healthy lifestyles, healthy dietary choices, and/or energy balance or (b) otherwise incorporate such messages in the online interactive game. The links and content will be designed to appeal to and be understood by the target audience.