ITC Limited's Food Division Marketing and Communication Policy

Preface

Over the years, the Company's multiple drivers of growth have been carefully crafted to match internal competencies with the emerging opportunities of a growing Indian market, with the aim to develop a customer-focused, high performance organization which creates value for all its stakeholders. We are cognizant that the Company has been given to us in "trust" by all our stakeholders and we shall endeavor to deliver consumer expectations of value, quality and satisfaction. We aim to do so with a robust portfolio of businesses that leverage the Company's unique enterprise strengths including deep consumer insights, intimate rural linkages, superior Agri-sourcing, path-breaking R&D, world-class manufacturing, brand building skills, culinary insights of the Company's Hotels' chefs, innovative consumer packaging, focus on digital technologies, and an extensive trade marketing, distribution and logistics network. These unique strengths enable the Foods Division of ITC Limited to create a portfolio of winning businesses across all operating categories. Our vision to create a high-performance organization that benefits all is embodied by our credo of 'Nation First - Sab Saath Badhein'.

With the changing health dynamics in the country and the associated regulatory requirements, it has become essential for every Food and Beverage manufacturer to endorse a responsible communication & marketing plan. We have always been one of the most responsible organisations in embracing & leading the change - in line with its commitment to the consumers, customers, society, country and the eco-system at large. We are committed to provide safe, nutritious and sensorially superior food products and we believe that it is our "shared responsibility" to help consumers make informed choices. We shall follow a three-pronged approach to carrying this commitment to our customers:

Research & unparalleled insight into the Indian consumer: We continue to invest in latest research to understand the changing nutritional needs and taste preferences of our consumers in context to the dynamic external ecosystem. We believe that being an Indian corporate, with deep understanding and roots in India, we are best suited to cater to the food needs of the aspiring Indian. Keeping with the evolving aspiration of the Indian consumer, new products are being developed and launched to meet both the taste and nutrition needs, along with the convenience expectations of our consumers.

Regulatory compliance in product development & communication: We always comply with self-regulatory codes like the Advertising Standards Council of India's Code for Self-Regulation in Advertising and laws like the Food Safety & Standards Act, 2006 at as may be applicable at various levels of operations and they also guide us in making the most appropriate and responsible decisions, keeping the consumers' interest at its core, both at the brand and corporate levels.

Responsible marketing communication: We are equally aware of the responsibility that it brings when we communicate with our consumers via various communication touch points across different media. Our consumer communication and marketing policy aims to define the principles on which all its communication initiatives and activities will be based and in full compliance of.

Policy Scope

These principles are applicable only to the Foods Division of ITC Limited's Marketing Communications and Activities across the Foods Division's portfolio.

1. GENERAL COMMUNICATION PRINCIPLES

• We believe that transparent, ethical and responsible communication drives consumer awareness and is key to develop trust, consumer behaviour and choice for its world-class brands.
• We shall ensure that all its product labelling, claims and communications follow the applicable laws of the land.
• We continue to adopt self-regulation on responsible communication and marketing besides adhering to the Code for Self-Regulation in Advertising prescribed by the Advertising Standards Council of India.
• We strive to ensure that all representations including text, sound, and visual accurately represent the product, including taste and content.
• Health claims relating to its product will have a scientific basis and will comply with all applicable laws and regulations and would be easily understood by consumers.
• Nutrient content information, including fortification and nutritional claims, are backed with test reports by accredited laboratories and made in a way that accurately reflects the nutrition composition of the product and comply with applicable laws and regulations.
• Advertisements should not contain indecent, vulgar, especially in the depiction of women, or nothing repulsive which is likely, in light of general prevailing standards of decency and propriety, to cause grave and widespread offence.
• Advertisements should not depict any content which is offensive to any religious, ethnic, and political groups as per generally accepted norms.
• Advertising should not denigrate, attack, or discredit the product, or advertisements of competition directly or by implication.
• Advertisements which may require an obvious exaggeration and/or hyperbolic treatment should be accompanied by clear warning of being performed under expert supervision and warn consumers against from re-enacting the same.
• With the growing impact of social marketing and the concerns emerging from misleading and fake news by unscrupulous players, the Company ensures dissemination of the right facts about our products and brands to consumers to uphold the reputational equity of our brands.

2. COMMUNICATION PRINCIPLES TO AND FOR CHILDREN

• We believe and we encourage that children should stay active and enjoy healthy, balanced, diversified diets in right portions to remain happy and fit. The role of gatekeepers like responsible adults (especially parents) is extremely crucial and we believe & support this responsible sharing to ensure a healthy future for all children.
• Advertisements shall not depict children aged under 6 as protagonists. Advertisements may only depict children under 6 if it is essential to the context in which the advertisement is set and a responsible adult is in control of the situation depicted e.g. portrayal of a family.
• Media channels wherein 35% or more of the audience are children <12 years of age, are to be restricted to around 20% of the overall media spends.
• We are committed to ensure that the design of website/ pages is appropriate to over 12 years predominantly, i.e. not designed to attract younger children.
• Advertising should not portray or encourage any behaviour which can create anxiety in children, including depiction of extreme graphic violence or sexual innuendos to avoid moral harm to children.
• Sampling and promotional activities of products in schools and events will be done with the prior consent of the school administration and event organisers in compliance with all applicable laws.
• We shall not use influencers (people with more than 10,000 fans on social media channels) under the age of 12 for marketing with the exception of promoting awareness on matters of public interest sponsored by the brand.
• Gifts, toys, and giveaways primarily appealing to children under 12 shall be marketed responsibly viz. basis entertainment and educational purpose only and not exploit the inexperience or credulity of children. Consumer promotion shall be done in a manner that buyer is made aware of the conditions that are likely to affect their purchase decision.
• We fully support the "The Eat Right School programme" which was launched in September, 2016 as Safe and Nutritious Food (SNF) at School programme, with the objective to create awareness about 'Eating Healthy', 'Eating Safe', and 'Eating Sustainably' among school children and through them in the community at large, by FSSAI.

Data Collection:

• All the data collected for any marketing and communication purpose at all levels are done with written consent and in line with the local and national laws.

Compliance & Monitoring:

• All the appropriate stakeholders and the marketers will be required to take an assessment of their understanding of this policy.
• Annual reviews on the understanding and implementation would be tracked and recorded by our internal audit teams.
• This will also be audited by independent, 3rd party and the results would be shared as reports on appropriate public platforms pertaining to ESG, ATNI etc.