Ethical Marketing Policy

ETHICAL MARKETING POLICY STATEMENTEthical Marketing Policy

1. Purpose

Wine&Earth is committed to marketing and communications that are honest, responsible,

lawful, accessible, and aligned with its purpose and stakeholder commitments. This policy

sets out the principles and minimum rules that apply to all Wine&Earth marketing and public-

facing communications so that customers, trade clients, producers, workers, partners, and

wider stakeholders can trust the information we provide.

2. Scope

This policy applies to all Wine & Earth external marketing and public relations activity,

including:

• brochures, catalogues, price lists and wine lists

• website content and online shop content

• email marketing and newsletters

• social media and digital advertising

• press materials and partnerships

• sales decks and trade materials

• event materials, POS materials and packaging copy where relevant

• any content produced by agencies, freelancers, partners or other third parties on

Wine&Earth’s behalf

This policy applies to both trade-facing and direct-to-consumer communications.

3. Core principles

Wine&Earth will ensure that its marketing and communications:

1. Are truthful and accurate.

We will not make statements that are false, misleading, exaggerated, selective, or

likely to create a misleading overall impression.

2. Are precise, verifiable and substantiated.

Social, environmental, sourcing, quality, product and business claims must be

supported by evidence we hold or can obtain promptly.

3. Are clear and understandable.

We will use plain English where possible, explain technical terms where needed, and

avoid vague terms that consumers or trade buyers may misinterpret.4. Present a fair picture.

We will not highlight one positive feature while hiding material limitations, trade-offs,

exclusions or contrary impacts.

5. Are responsible in relation to alcohol.

We will market wine and other alcoholic drinks in a socially responsible way and will

not encourage harmful, excessive, anti-social or underage drinking1

.

6. Respect stakeholders.

We will consider the likely effect of our communications on consumers, trade

customers, producers, workers, communities and the environment.

7. Comply with law and applicable codes.

This includes consumer law, advertising rules, licensing requirements, and claims

guidance relevant to the UK market2

.

4. Rules for product, sourcing, environmental and social claims

When Wine&Earth makes claims about products, producers, packaging, sourcing,

biodiversity, climate, community impact, labour practices, or the business as a whole:

• claims must be based on current evidence, not aspiration alone

• claims must state their scope where needed, for example whether they relate to a

product, producer, vineyard, packaging component, delivery option, campaign, or the

company overall

• claims must be dated where timing matters

• claims must be qualified where there are limits, assumptions or exclusions

• comparative claims must compare like with like

• certification, accreditation or third-party marks may only be used where valid and

current

• broad terms such as “sustainable,” “eco-friendly,” “ethical,” “responsible,” or “better

for the planet” must not be used unless the basis is explained clearly enough for a

reasonable customer to understand

• we will not overstate environmental benefit based on a single attribute such as

lighter bottles, recycled packaging, or one producer initiative if the broader picture is

mixed or unknown

• we will not imply that a product has no impact where it still has material

environmental or social impacts

1 ASA

2 GOV.UKWine&Earth will follow the UK Green Claims Code principles that claims must be truthful and

accurate, clear and unambiguous, not omit important information, make fair and meaningful

comparisons, consider the full life cycle, and be substantiated. We will also remember that

responsibility for claims can sit with retailers, brands and others in the supply chain, not only

the original producer3

.

5. Rules for alcohol marketing and responsible drinking

For any consumer-facing communication about alcoholic drinks, Wine&Earth will:

• not target people under 18

• not place alcohol marketing in media where more than 25% of the audience is under

18

• not use content, tone, imagery, influencers, characters or partnerships likely to appeal

particularly to under-18s

• not show or feature anyone drinking or playing a significant role who is, or appears to

be, under 25

• not imply that alcohol enhances confidence, popularity, mood, social success, sexual

success, physical performance, driving, work, or sporting success

• not portray drinking as a challenge or encourage excessive, immoderate,

irresponsible or anti-social consumption

• not place undue emphasis on alcoholic strength or intoxicating effect

• not show alcohol being handled or served irresponsibly

• include a clear responsible drinking reminder on the consumer-facing website and

relevant D2C promotional pages, with signposting to independent advice such as

Drinkaware

These rules reflect the CAP Code’s alcohol principle and related rules, and the Portman

Group’s broader expectation that alcohol is marketed socially responsibly and only to adults.

Drinkaware provides independent alcohol advice and tools that can be signposted from the

site4

.

6. Rules for the D2C website and online sales journey

Wine&Earth’s direct-to-consumer site must:

• clearly state that alcohol is sold only to people aged 18 or over

• use age verification at checkout or another equivalent control before sale

3 Green claims code

4 ASA• ensure delivery processes also support age verification before alcohol is physically

handed over

• avoid imagery, design choices or promotional mechanics that normalise over-

consumption

• present product information, price and delivery terms clearly

• make responsible drinking messaging easy to find on the site

UK licensing guidance says remote alcohol sales must comply with age verification

requirements, that online age verification should be used so alcohol is not sold to under-18s,

and that licence holders should also consider what steps are needed before delivery, so

alcohol is not physically served to someone under 18.

7. Partnerships, third parties and user-generated content

Where third parties create or distribute content for Wine&Earth:

• they must be briefed on this policy

• Wine&Earth must approve alcohol and sustainability claims before publication,

unless a written exception is agreed

• paid partners, creators or affiliates must not target under-18s or use youth-coded

content

• Wine&Earth will remove, correct or request amendment of non-compliant content

within a reasonable timeframe

• reposting or amplifying third-party sustainability claims does not remove

Wine&Earth’s responsibility to consider whether those claims are credible

8. Accessibility and clarity

Wine&Earth will aim to make key customer-facing communications accessible and easy to

understand. As a proportionate minimum, Wine&Earth will:

• use plain, non-technical language where possible

• avoid image-only text for key messages

• use readable colour contrast and font sizes on the website

• provide alt text for meaningful website images where practical

• caption video content where used

• make key PDFs and downloadable materials reasonably accessible where practical

• aim for website content to align with WCAG 2.2 AA where reasonably practicable

over timeWCAG 2.2 is the current W3C web accessibility standard and is designed to make web

content more accessible to a wider range of people with disabilities5

.

9. Internal approval and evidence

Before publication of any material containing product, sourcing, environmental, social or

responsible-business claims:

• claims must be checked

• the supporting evidence must be held in an accessible folder or linked file

• any limitations or qualifications must be captured in the final wording

• the final approved version should be saved

• higher-risk claims, including broad sustainability claims, carbon-related claims,

producer welfare claims, or partnership campaigns, should receive director-level

sign-off

Evidence may include producer certifications, published LCA (life cycle assessment)

sources, supplier statements or surveys, product specs, logistics data, internal calculations,

audit reports, webpages captured on date of use, or other reliable documentation.

10. Complaints, concerns and corrections

Wine&Earth will maintain an accessible route for stakeholders to raise concerns or

complaints about marketing, product information, environmental claims, ethics, or

responsible drinking content.

At minimum:

• the website will include a clear contact route for complaints or grievances

• complaints will be acknowledged promptly

• Wine&Earth will investigate and respond within a stated timeframe

• if a claim cannot be supported, it will be corrected, qualified or removed

• material complaints and outcomes will be logged

• retaliation against anyone raising a genuine concern is prohibited

This helps support the B Lab grievance expectation as well as good governance.

(Full procedural guidelines for complaints handling can be found in the ‘Customer Service

Policy’).

11. Training and communication

5 W3CAll relevant workers and regular contractors involved in sales, marketing, website content,

customer communications, and partnerships will be made aware of this policy. This may be

done through onboarding, periodic reminders, short guidance notes, and practical review

checks.

12. Governance and review

This policy will be reviewed at least annually. The annual review should consider:

• any complaints or grievances relating to marketing or claims

• any corrections, takedowns or near misses

• any changes in advertising or licensing rules

• whether evidence systems are working

• whether staff need refresher guidance

• whether Wine&Earth’s public claims remain proportionate and supportable

A short annual summary should go to the highest governing body as part of the broader B

Corp governance review.

Appendix: Audit checklist for each material

Use this as a yes/no check before publication:

Check	Yes/No
Is the audience appropriate and not under 18?
For alcohol content, does it avoid encouraging excessive or irresponsible drinking?
Does it avoid youth appeal and avoid showing anyone drinking who is or appears under 25?
Are all factual claims supportable with evidence held on file?
If there is an environmental or social claim, does it meet the 6 Green Claims Code principles?
Is the claim clear about scope, basis, timeframe and any limitations?
Does it avoid vague, sweeping or selective wording?
Is there a responsible drinking message where appropriate on consumer-facing content?
For D2C sales, are age-verification controls in place at sale and delivery stages?
Has the material been reviewed and approved by the named owner?

Document owner: Dale Agar

Approved by: Wine&Earth Board

Version: 1.0

Effective date: 22/05/2026

Review date: Every 12 months, or sooner if law, B Corp requirements, or business activities

materially change.