1. Scope
This policy applies to all VitaMini commercial communications intended for children or likely to be seen by them, including website, packaging, GDO/pharmacy materials, social media, video, influencers, advergames, events, schools, sampling, promotions, competitions, QR codes and approved distributor materials.
2. Primary audience and role of adults
The website and information initiatives are designed primarily for parents, holders of parental responsibility, caregivers and professional operators. Communications must not undermine adults’ role in food choices or suggest that buying VitaMini is evidence of good parenting.
3. No direct exhortation and no pester power
Children must not be directly urged to buy, consume, request or cause adults to purchase VitaMini. Calls to action, games, rewards and creator content must be designed consistently with this prohibition.
4. Fairness, inexperience and social pressure
Creative work must not exploit children’s credulity, inexperience, loyalty, fear, guilt or need to belong. It must not imply inferiority, exclusion, greater popularity, superiority or school/sport success resulting from purchase or consumption.
5. Balanced diet and responsible consumption
VitaMini must not be presented as a substitute for water, fruit, vegetables or a varied and balanced diet. Excess consumption, inappropriate portions or sedentary lifestyles must not be normalised. Educational messages should remain distinct from commercial promises.
6. Claims, health and fear
Nutrition, health or performance claims may be used only after legal/regulatory approval and when all conditions of use are met. Medical promises, disease prevention/treatment implications or fear-based messages suggesting a child will be worse off without the product are prohibited.
7. Characters, creators, influencers and sponsored content
Characters, mascots, creators and influencers must not obscure the commercial nature of the message. Briefs, scripts, visuals, hashtags and disclosures require approval, with heightened care where children could confuse advertising with editorial content.
8. Schools, events and sampling
Activities in schools, sports centres or child-oriented environments require a dedicated protocol covering venue authorisation, adult oversight, allergens, safety, data collection, images and the absence of coercive purchase pressure.
9. Competitions, gamification, loyalty and QR
Before competitions, loyalty schemes, advergames, interactive QR codes, UGC or communities are activated, promotional law, age, parental consent, moderation, prizes, advertising transparency, privacy and the need for a DPIA must be assessed. Such tools must not be used to circumvent protections against pressure on minors.
10. Personal data and advertising
Behavioural targeting of children is not intended. Digital campaigns will be aimed primarily at adults and will require review of audience settings, suppliers and platforms. Advertising segments must not rely on child data or inferences in a manner incompatible with applicable law.
11. Prior approval process
Campaigns should follow at least a four-eyes model: Marketing proposes; Legal/Regulatory verifies claims and fairness; Privacy/DPO participates when data, tracking or child-facing technology is involved; Quality validates product-related statements. Evidence must be archived with version and date.
12. Agencies, partners and distributors
These rules also apply to agencies, media partners, influencers, trade partners and distributors when using VitaMini materials or communicating on behalf of the brand. Agreements should provide for compliance obligations, prior approval and removal of non-compliant content.
Main references
Directive 2005/29/EC and national implementing law; Regulation (EU) 1169/2011; Regulation (EC) 1924/2006; GDPR and applicable privacy law; and, for Italy, the IAP Code and the IAP rules on commercial communication for food and beverages protecting children.