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TEAM CODE OF CONDUCT

This Code of Conduct applies to all individuals and business that engage in promotional activities on behalf of Pacific Gold or otherwise have a material connection to Pacific Gold, including employees, agents, contractors, bloggers, celebrity endorsers, brand creator, brand ambassadors, and all other social media influencers, whether they are engaged by Pacific Gold directly or indirectly through an agency (“Influencers” or “You”).  As an Influencer, you must clearly and prominently disclose your relationship with Pacific Gold. Your disclosure obligations apply equally to personal blogs, websites, social network pages or posts, and other media.

The following guidelines explain how to comply with Pacific Gold and Federal Trade Commission requirements for making truthful endorsements.

1.  DISCLOSE MATERIAL CONNECTIONS WITH PACIFIC GOLD  

Who: You have a material connection to Pacific Gold if:

  • You are paid or compensated by or on behalf of Pacific Gold

  • You are given something for free or a discount

  • You are an employee, agent, or contractor, or are related to an employee, agent, or contractor of Pacific Gold

  • You have any other connection that could impact the weight a person gives your opinion, including participation in the “Pacific Gold Creator Program” or the “Pacific Gold Influencer Program”

Media Channels: The disclosure requirement applies to any materials created, contributed, distributed, commented on, or modified by you on all media, including:

  • Social media (Facebook, Twitter, Instagram, Snapchat, Pinterest)

  • Video platforms (YouTube, Vimeo, Vine, Periscope)

  • Third-party forums and review sites (Reddit, Yelp)

  • Personal blogs and Tumblr

  • Third-party affiliate marketing sites

  • Interviews/media appearances (if not clear you are being compensated or have a relationship with Pacific Gold)

Types of Communication:  The disclosure requirement applies to any communication that could be interpreted to promote or highlight the benefits of Pacific Gold or its products.  The requirements can apply even if you do not actually write about Pacific Gold (e.g., merely posting a photo showcasing a Pacific Gold product on social media is enough).  Here are common examples where disclosure is required:

  • Communications encouraging someone to buy a product or otherwise engage with Pacific Gold

  • Posting on social media in connection with the Pacific Gold Creator Program or Pacific Gold Influencer Program and/or using the #AsGoodAsItGets or tagging @PacificGoldSnacks

  • Content you share from PacificGoldSnacks.com, including products and articles, as well as content you share from any Pacific Gold social media channel

  • Sharing third-party content that is arguably favorable to Pacific Gold such as media stories that discuss the brand

  • Content you create on your own personal blog or video site that includes information about and promotes Pacific Gold

  • Selfies, videos, or other content prominently showcasing a Pacific Gold product, retweeting an endorsement, or any other depiction that could be construed as promoting the brand   

2. ENSURE YOUR DISCLOSURE IS CLEAR AND PROMINENT ON EACH POST ON WHICH YOU ENDORSE A PRODUCT  

How to disclose:  Disclosures should be easy to see and understand.   In other words, it should be clear to the audience that you have a connection with the company.  A simple statement about your relationship is often the best option. Another option is to incorporate the disclosure into your post.  On social media you can use shorter disclosures if necessary. See below for examples of good disclosures (disclosures should be tailored to the nature of your relationship):

  • Blogs, Editorial and Product Reviews, Comments in Online Discussions

    • I am a Pacific Gold brand influencer or I am a Pacific Gold brand creator

    • I received free product from Pacific Gold

    • Thanks Pacific Gold for the free product

    • I work for Pacific Gold

    • I was paid by Pacific Gold

    • I am paid by Pacific Gold for each click

  • Social Media (e.g., Twitter)

    • #PacificGoldInfluencer or #PacificGoldCreator

    • #ad

    • #sponsored

    • #promoted

Location of Disclosure:  Follow these guidelines for placement of the disclosure:

  • Disclosures should be located at the beginning, next to, or on top of any applicable communication.

  • For social media, the disclosure should be in each post (e.g., #ad).

  • For video, the disclosure should appear in the video and must be on the screen for long enough to be noticed, read, and understood.  For long videos, the disclosure should be repeated. Merely including the disclosure in the description of the video is not sufficient.

  • If you cannot include or fit a disclosure in your posting, please do not use that platform.

Size of Disclosure:  The disclosure should be in large enough font for the audience to read and understand it.  The disclosure should also be visible regardless of whether viewing online or on a mobile device.  

3. STATEMENTS MUST REFLECT YOUR HONEST OPINIONS, BELIEFS, OR EXPERIENCES AND MUST NOT BE FALSE, MISLEADING, OR UNSUPPORTED

  • Do not make false or misleading claims about a Pacific Gold product or service (e.g., if you thought a product was bad, don’t say it was great)

  • Do not make a claim that cannot be supported (e.g., Pacific Gold has a particular health benefit).

  • Don’t hold yourself out as an expert if you are not one

  • If you create and distribute advertising or promotional material for Pacific Gold, make sure that is not disguised to look like editorial, news, entertainment, or other non-advertising content

  • Ensure all product demonstrations are truthful, fair, and accurate

  • Discontinue statements if your communication is no longer true or accurate

  • Exercise caution when making conclusory or comparative statements (e.g., better than a competitor)

  • Do not make false or misleading claims about a competitor’s product or service

  • Consider what the reasonable consumer would expect your message to mean, taking into account who you are, how you say it, and assuming the reasonable consumer is not well-educated or well-informed

4.  THINK BEFORE YOU POST

  • Avoid controversial or potentially damaging statements about the Pacific Gold brand

  • Follow the relevant website’s posting requirements and terms of use

  • If applicable, state that your view is your opinion and not representative of Pacific Gold’s view

  • Do not make, use, or distribute any offensive comments or sexually explicit material

  • Do not disparage, libel, slander, or defame any person, entity, product, or service including a competitive product or service

  • Do not promote any unsafe or illegal activities, including drugs, tobacco, alcohol, guns, or illegal gambling and wagering

  • Do not link to any content or website that violates this Code of Conduct

5. YOUR POSTS ARE SUBJECT TO REVIEW BY PACIFIC GOLD  

Pacific Gold periodically reviews materials created by Influencers.  If you violate this Code of Conduct, we will remind you about your obligations and Pacific Gold may terminate your relationship with Pacific Gold at its discretion.