Since 1934, Heaven Hill Brands has been a leading producer of beverage alcohol. Our company embraces independence, quality and tradition as hallmarks of our reputation. Since our founding, Heaven Hill has engendered an attitude of responsible consumption and social responsibility among our employees, agents and partners with regard to promoting and marketing our broad portfolio of brands around the world.
This is Heaven Hill's Corporate/Social Responsibility Statement (CSRS). It codifies in formally recognized policy the set of beliefs we have followed in spirit since 1934.
Beverage alcohol is an important element in communities and social relationships throughout the world. When consumed responsibly, our products contribute to memorable experiences and social activities. As a result, it is important to promote our products in a manner consistent with responsible consumption.
Heaven Hill will comply with applicable government and industry standards regarding marketing and communications domestically and internationally. In many cases, relevant standards are established by a trade organization representing the interests of the industry. However, when regulations in localities or cultures exceed those outlined in this CSRS in stringency or scope, all Heaven Hill employees, representatives and agents will abide by those regulations. Conversely, where standards for the beverage alcohol industry have not been established, this CSRS will act as the standard.
While this CSRS cannot address every present and future circumstance, Heaven Hill will abide by it in spirit where applicable. All employees, representatives and agents of Heaven Hill are expected to comply with both the letter and the spirit of the CSRS.
In the case of the U.S., Heaven Hill recognizes the Distilled Spirits Council of the United States (DISCUS) "Code of Responsible Practices for Beverage Alcohol Advertising and Marketing," adopted in October 2003, as the "industry standard." The DISCUS Code represents a common standard for the U.S. beverage alcohol industry to respect.
This CSRS applies to all corporate and brand marketing, advertising, sales and communication materials, packaging and activities for consumer and trade purposes. It is a guideline for all employees, representatives and agencies of Heaven Hill to follow in promoting our products.
We will seek to discourage underage drinking, including through observing the following principles:
We will seek to discourage irresponsible drinking, including through observing the following principles:
In the conduct of on-site and other promotional events,
Heaven Hill will not use depictions of violence, abuse, illegal activities or dangerous behavior in association with any marketing or advertising programs.
We will monitor all advertising and marketing messages to ensure sensitivity to foreign and domestic considerations. While defining "offensive" in other cultures is often challenging, we will make reasonable efforts to abide by generally accepted standards of decency.
We will seek to discourage drinking and driving, including through observing the following principles:
The alcohol content of our products should be clearly and plainly visible on their labeling.
Review of marketing materials for compliance must be completed upon final approval by responsible marketing personnel. Compliance with this CSRS is mandatory and will be monitored continually.
Our advertising and public relations agencies must observe this CSRS throughout the creative process.
As an additional safeguard, Heaven Hill will maintain a system for unbiased review of marketing materials by a senior non-marketing executive designated as the Internal Marketing Monitor.
The Internal Marketing Monitor will be appointed by the President to review marketing materials on a semi-annual basis. The post-completion review will take place after the annual sales meeting, which offers a full accounting of upcoming calendar year marketing activities. The meeting historically takes place in December of each year. An interim review of marketing materials will be completed upon the close of the calendar second quarter. The Internal Marketing Monitor will issue a report regarding compliance concerns or approval based on CSRS requirements within thirty days of each review date.
The Internal Marketing Monitor's recommendations will be directed to the head of the Marketing Department for proper disposition and a further report to the President.
The Internal Marketing Monitor is not responsible for auditing promotional or on-premise activities.
Any complaint received regarding an alleged code violation of this CSRS will be directed to the Corporate Communications Department for review and investigation using marketing strategy personnel and resources responsible for development of concept. Responses would include a summation of the responsible materials with a determination of remedial action (continued use, modification or discontinuation). Within one month, the complainant will receive a written response from Heaven Hill Corporate Communications. The complainant will be invited to respond to Heaven Hill's actions by accepting the determination or requesting further comment or external review.
Upon request for external review, Heaven Hill will then submit, under the federal Alcohol and Tobacco Tax and Trade Bureau (TTB) guidelines for "Alcohol Beverage Advertising Program", all due diligence relative to the inquiry (as outlined in the TTB Industry Circular 2004-6). Further, Heaven Hill will continue voluntarily to submit advertising to the "pre-clearance review program" where necessary.
In addition to the internal and alleged code violation process, Heaven Hill will continue to respond and cooperate with the DISCUS code and TTB initiated investigations, as needed. The company maintains an ongoing dialogue with the DISCUS Code Review Board as a third party review mechanism for the beverage alcohol industry.
Heaven Hill bases its reviews on the DISCUS code and TTB regulations.
Heaven Hill provides the federally-required "mandatories," which provide mailing addresses on advertising and marketing materials, along with a "Social Responsibility" section on the corporate website for communication of complaint procedure protocol. Branded websites offer "Contact Us" e-mail and federally required "mandatories" for direct correspondence. All branded "Contact Us" e-mails are handled under the Alleged Code Violation Complaint Procedures.
