FOR TALENT, BLOGGERS, INFLUENCERS AND OTHER ENDORSERS
Last updated: October 17, 2017
To help you comply with applicable laws and to protect the reputation of The Honest Company, Inc. (“Honest”), this policy outlines standards of conduct you must follow if you choose to discuss Honest or its products or services in any public forum (including social media, blogs, chat rooms, talk shows, and public appearances). These standards apply to bloggers, influencers, Tweeters, talent, spokespersons, endorsers, Honest employees and other individuals who have a “material connection” to Honest.
You have a “material connection” to Honest when you receive compensation, gifts, free products, samples, prizes, event tickets or access, rewards, marketing opportunities, contest/sweepstakes entry or any other incentive from Honest (or any agents acting on its behalf). These standards are based on the Federal Trade Commission’s Endorsement Guides Concerning the Use of Endorsements and Testimonials in Advertising and the FTC’s related tips and guidelines at https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking. Please review these documents and the standards below carefully.
DISCLOSE YOUR MATERIAL CONNECTION TO HONEST
Clearly and conspicuously disclose the material connection you have to Honest in each of your communications about Honest (whether online or offline, and across all platforms and channels). To be “clear and conspicuous,” a disclosure should catch the user’s attention, be placed where it is not likely to be missed, and be worded in a way that’s understandable to the ordinary reader:
- Disclosure should be close to the endorsement
- In a font that is easy to read
- In a shade that stands out against the background
- For video ads, on the screen long enough to be noticed, read and understood
- For audio disclosures, read at a cadence that is easy for consumers to follow and in words consumers will understand.
Examples of disclosures (vary by context):
- “As a brand ambassador for Honest, I . . . ”
- “[Name] is a paid endorser of Honest.”
- “I received free product from Honest to talk about . . .”
- “I received complementary products from Honest to review my experience”
- “Honest paid me to try and . . .”
- “Sponsored by Honest”
- “Honest gifted me this product to try and ...”
- “Thanks Honest for the free product”
- “Thanks Honest for gifting me with [ABC] product”
- When posting or re-posting on social media channels with limited space, use appropriate hashtag(s), such as “#sponsored,” “#ad,” “#paid,” “#Honest–Ambassador”.
- Don’t hide or bury your disclosure in footnotes, in blocks of text that people are not likely to read, or in hyperlinks or in the space that is not visible.
- Do not bury these hash tags in a string of multiple hashtags or links.
- Disclosure should be visible without having to click “more”. I.e. if you make an endorsement on Instagram via picture or in the first three lines of the description, your disclosure should be visible without having to click “more.”
- If your post is lengthy and your endorsement or testimonial message or content appears far down in the post, your disclosure doesn’t have to appear at the beginning. However, it should be placed very close to, or made a part of, the endorsement or testimonial message to which it relates.
- The following disclosures on social media posts are NOT sufficient: “#thanks” “#spon” “#collab” “#ambassador” (Note: Ambassador alone is not enough, must include “#Honest-Ambassador”)
- If you make an endorsement on Snapchat or Instagram Stories, you should superimpose your disclosure over the image(s) on those platforms. The disclosure should be easy to notice and read in the time that your followers have to look at the image.
- Tagging a @Honest or @Honestbeauty in your social posts counts as an endorsement, and requires disclosure if you have a material connection to Honest
- Don’t rely on built in disclosures on a social media platform or on disclosures in your social media profile.
- Always make your disclosures in the same language you used to communicate your related testimonial or endorsement.(i.e., if your testimonial is in Spanish, your disclosure should also be in Spanish)
- Your disclosures should be viewable on all devices, including mobile devices, and should not rely on features that are commonly blocked by user settings (e.g., pop-up blockers).
- If your post includes video and you include an audio disclosure, keep in mind that many users watch videos without sound. A disclosure made in both audio and video is most likely to be noticed. Visual disclosures in videos should remain on the screen long enough to be noticed and read, and should be presented in an easy-to-read font that clearly stands out from the background. Audio disclosures should be read at a cadence that is easy to follow. Disclosures always should be made in the video content itself; not just in the written description of the video that accompanies your post. You may need to repeat disclosures multiple times in longer testimonials. For example, in ongoing video commentary about Honest products, you should make periodic disclosures every 3-5 minutes. Alternatively, you could have a static or scrolling clear and conspicuous disclosure throughout the entire stream.
- If you receive a contest or sweepstakes entry in exchange for posting content that constitutes an endorsement or testimonial, you post should include the hashtag “#Contest.”
- If you are an employee of Honest and you post (or share a post) about Honest products or services (whether or not at the direction of Honest), including on a review site, you should disclose your employment relationship with Honest in your post. The disclosure can be made by using the words “my company” or “employer’s” in the caption or body of the message. Examples: “Check out my company’s new product...” or “Check out my employer’s great new offer.” Or “#Honest–employee”
TELL THE TRUTH
- Only make statements that reflect your honest beliefs, opinions, or experiences with Honest and its products and services. Do not give an opinion regarding Honest’s products and services if you have not tried them.
- Do not make (or share) false, deceptive, or misleading claims about Honest, Honest’s products or services, Honest’s competitors, or Honest’s competitors’ products or services.
- Do not make unsubstantiated claims about the performance of an Honest product or service.
FOLLOW THE RULES
- Adhere to the posting guidelines and comply with all other applicable rules, requirements, and terms and conditions in any agreement you have entered in to with Honest and on any site or platform on which you post content.
- Do not disclose or discuss any confidential information, unauthorized content, or any proprietary, non-public information about Honest, its customers, employees, business partners or suppliers.
- Only use the Honest intellectual property in accordance with the directions, guidelines, and specifications of Honest.
DON’T USE INTELLECTUAL PROPERTY WITHOUT PERMISSION
- Do not use any names, trademarks, logos or other intellectual property or materials that belong to Honest without Honest’s written approval.
- Do not use any names, trademarks, logos or other materials that belong to any third party without explicit written permission from the owner of such material.
- Do not use illustrations, photos or video content (including memes) without written permission (a) from the owner of the content, (b) from any persons depicted in the content (subject to the below provision), and (c) for any music heard in the content.
- Do not reference or depict any person (including any celebrity) in any content unless (a) you have explicit permission from such individual, or (b) Honest has otherwise approved the reference/depiction.
AVOID INAPPROPRIATE CONTENT
Do not:
- depict nudity or lewd content of any sort;
- incite, advocate, or express pornography, obscenity, vulgarity, profanity, hatred, bigotry, racism, or gratuitous violence, or include any other offensive content;
- promote excessive consumption of alcoholic beverages or promote any illegal drug use;
- misrepresent the source of anything in your post, including impersonation of another individual or entity; or
- provide or create links to external sites that violate this policy or any other Honest policy.
Honest may regularly monitor the Internet and other media sources. Honest reserves the right to suspend or terminate its relationship with you if Honest determines (in its sole discretion) that you have violated this policy.
If you have any questions about this policy, please contact Brenna Israel Mast (BIsrael@honest.com).
This policy is effective immediately and was last updated on the date indicated above. Honest reserves the right to amend this policy at any time.
