Ausnutria’s Policy for the Marketing of Infant Foods
Ausnutria is dedicated to develop and provide healthy and safe nutrition for normal growth and development of infants and young children worldwide. Especially for infants and young children who cannot receive breastfeeding due to medical, familial, practical or other reasons.
Years of research and study tell us children who are well-nourished from the very start are more likely to lead healthy lives. Our objective is to advance the science of pediatric nutrition and to use this science to improve the nutritional status of infants and young children.
We develop product formulations using existing (paediatric) science and our own research. Our own research brings new knowledge about safety, quality and efficacy of new ingredients, new technologies and new product formats which we will transfer into our innovations. We continuously innovate so that infants, young children, their parents and Health-care Professionals are served in the best way.
Ausnutria underlines that breastfeeding is the best choice for infants from 0-6 months and supports prolonging breastfeeding to two years of age.
Ausnutria also underlines and contributes to the provision of quality information regarding infant feeding. In this way mothers can make an informed decision about the healthy nutrition of their child. To encourage healthy and safe nutrition for infants, Ausnutria acknowledges the importance of, and commits to the principles of the International Code of Marketing of Breast-Milk Substitutes adopted on 21st May 1981 (the WHO Code) and the subsequent relevant resolutions of the World Health Assembly (WHA).
This Ausnutria Policy (the Policy) about the Marketing of Infant Foods will make transparent and fulfill the implementation of the aims and principles of the WHO code to optimize healthy and safe nutrition of all infants over the world.
Inspired by the WHO code, the Policy determines the minimum set of rules for the marketing of Ausnutria’s global KIBU brands (not private label brands manufactured by Ausnutria) of infant foods in all countries Ausnutria and distributors are active in. The marketing of infant foods is subject to relevant local laws, regulations, practices or government-issued codes. The Policy is not a substitute to these regulations and/or practices. Where local laws and regulations for implementing the WHO Code are more stringent than the Policy, the local measures will be followed.
“The Policy determines the minimum set of rules for the marketing of Ausnutria’s global KIBU brands.”
Scope
This Policy is applicable to all marketing activities for Ausnutria’s global KIBU brands (Kabrita) that are distributed in more than 1 country.
Covered Products
All infant and follow-up formula products as part of Ausnutria’s global KIBU brands, distributed by Ausnutria or it’s distributors.
| Ausnutria: | All legal entities that are directly or indirectly owned by Ausnutria Dairy Corporation Ltd. (listed at the Hong Kong Stock Exchange with number 1717) including joint ventures in which those legal entities participate. |
| Ausnutria global KIBU brands: | The global Kabrita International Business Unit (KIBU) brands owned by Ausnutria. |
| Breast milk substitutes: | Any food being marketed or otherwise presented as a partial or total replacement for breast milk, whether or not suitable for that purpose. |
| Covered products: | Infant formula and follow-up formula marketed under Ausnutria global brands. |
| Digital marketing: | The promotion of brands to connect with potential customers using the internet and other forms of digital communication (such as social media). |
| Employee: | A person employed under permanent or temporary contract with Ausnutria. |
| Excludedproducts: | Complementary foods for infants and youngchildren. |
| Follow-up formula: | Breast milk substitutes for infants from 6 to 12 months. |
| Healthcare Professional (HCP): | Natural person who provides preventive, curative, promotional or rehabilitative healthcare services to people in a systemic way. Healthcare Professionals may work in all branches of healthcare like medicine, dentistry, midwifery, pharmacy, nursing, etc. |
| Healthcare System: | Organisation of people, institutions and resources that deliver healthcare services to meet the health needs of the target audience. |
| Infant formula: | Breast milk substitutes for infants from 0 to 6 months. |
| Infants: | Babies with an age of 0 till 12 months. |
| Joint ventures: | Cooperation between two companies by means ofa new company, however both original companiesalso continue to exist. |
| Marketing: | Product promotion, distribution, selling, advertisement, product public relations and information services. |
| Point of sales advertisement: | Sales displays, Sales promotions and Sales Premiums |
| Private label brands: | Brands owned by third parties. |
| Sample: | Single or small quantity of product provided without costs. |
| Third party distributor(s): | A legal entity not being part of Ausnutria that sells and market Covered Products. |
Guiding Principles
- Breast milk is the best nutrition for infants.
- Parents have the right to make informed choices based on independent advice.
- We adhere to the Ausnutria Policy and also comply with local legislation and codes.
- Our labels provide clear and coherent information.
- Our interaction with Healthcare Professionals is subject to strict conditions.
- Our information materials for Healthcare Professionals are based on solid and sound science.
- The Covered Products will not be promoted to consumers.
- Our compliance is ensured by continuous monitoring.
- Our performance management system encourages compliance.
- We deploy messaging consistent and compliant with our brand identity.
Do's and Don'ts: General Public and Mothers
Do:
- Support the following public health recommendation: Breastfeed until 6 months and encourage to prolong breastfeeding to two years of age.
- Comply with local legislation and guidelines (like Codes of conduct). All marketing materials and activities should comply with the provisions of the local legislation and the Code of the country where the product is placed on the market.
- Supply clear and valid, evidence-based statements and claims, which are approved by law and, depending on the claim, have been validated and approved by the Global Marketing and Global Regulatory Affairs Department.
- Advertise products which do not fall under the scope of this Policy and are compliant with local legislation.
- Respond properly to consumer complaints and questions, and follow this Policy and local legislation when responding.
- Publish scientific and factual information on infant and follow-up formula. Avoid mentioning product names and make no comparison with breast milk.
- Market products in line with the label claims and statements approved by the responsible departments.
- Continuously check and verify digital marketing content posted by Ausnutria.
Do not:
- Advertise or promote Covered Products.
- Use claims which suggest to cure, treat or prevent diseases and do not use implied health claims unless allowed and/or justified by local legislation or authority.
- Use depiction of organs unless allowed by local legislation or authority.
- Distribute free or low cost samples of Covered Products directly or indirectly to the general public unless specifically permitted.
- Distribute gifts that directly promote Covered Products to the general public.
- Use point of sales advertisement for the Covered Products.
- Seek direct or indirect contact of any kind with pregnant women with the intention to directly market Covered Products.
- Important notice: breastfeeding is the best choice for your infant.
- Seek professional advice before changing your baby’s diet, especially if your changing from breastfeeding to bottle feeding.
DO include a statement on all follow-upproducts that the use of complementary food is required.
DO include approved nutrition & health claims by the Global Marketing and Global Regulatory Affairs Department.
DO include instructions for appropriate preparation, and a warning against the health hazards of inappropriate preparation.
DO always use pictures/photos that are part of our brand library and which comply with local legislation (babies >6 months). Visuals may only include nutrition and health claims that are allowed. In some countries visuals/icons that are registered as trademark provide a better legal basis for use.
DO NOT use pictures of infants on the labels of Covered Products. Neither the container nor the label should carry pictures of infants, nor should they have other pictures or text which may idealize the use of infant formula.
DO NOT use the terms “humanized”, “materialized” or similar terminology on the label.
Healthcare Systems
DO emphasize the importance of breastfeeding.
DO provide science-based and factual information towards HCPs in Healthcare Systems.
DO donate money for clinical research only in accordance with guidance given by the Healthcare Systems and responsible departments.
DO NOT donate or subsidize medical supplies for Healthcare Systems, unless:
- Prices are based on the best wholesale prices (not for free or with discount);
- Normal procurement procedures are followed;
- When requested by governmental or aid agencies to support social or humanitarian purposes (for free supplies).
DO NOT allow displaying of information of the Covered Products in nurseries and hospitals in public areas.
DO NOT donate items to Healthcare Systems:
- If the donated items are more than 3 per year;
- If the items carry the name of
Covered Products; - If the price of the donated item
exceeds 50 euros.
Healthcare Professionals
DO emphasize on the importance and preference of breastfeeding when talking to HCPs.
DO supply clear and evidence based information to Healthcare Professionals, which is approved by the Global Marketing Department and Global Regulatory Affairs Department and can be justified through (scientific) research.
DO give ≤5 scientific written materials (leaflets, brochures etc.) to HCPs at one visit to avoid potential distribution of the materials in public areas such as waiting rooms.
DO only sponsor Healthcare Professionals to attend scientific meetings under the following circumstances:
- All sponsoring activities per HCP are documented and documents are retained for 5 years and in accordance with guidance by the healthcare management;
- Only sponsoring of scientific activities are allowed and only reasonable costs are reimbursed;
- Sponsoring does not aim to recommend or prescribe Covered Products;
- Only the costs of the HCPs can be reimbursed (not costs of spouses or relatives).
DO only provide samples of Covered Products to Healthcare Professionals under certain conditions:
- A limited number of samples (<5) labelled with statement ‘for professional evaluation’;
- If an HCP asks for a sample for patients with a medical indication, he must submit a written request;
- The delivery of samples does not aim to recommend or prescribe covered products;
- Samples may be supplied for (clinical) research approved by the responsible R&D Department.
Implementation and monitoring
This Policy is endorsed by the CEO of Ausnutria Dairy Corp Ltd and further embedded and implemented in the business. All General Managers and marketing employees within Ausnutria, its joint ventures, subsidiaries and contracted distributors will have to sign off and be trained on the content of this Policy. Deviations from the Policy need to be approved by the Board.
Internal audits will be conducted to assess and evaluate the implementation of the Policy. Appropriate measures will be taken when activities or materials are not in line with the content of this Policy.
