Responsible Marketing and Communications

Our policy in advertising and marketing is to comply with all applicable laws in the country where we are communicating. We apply worldwide the practices adopted in guidelines issued by the U.S. Federal Trade Commission (FTC). The FTC regulates advertising in the United States, with the goal of preventing consumer deception. In cooperation with the states and the U.S. Environmental Protection Agency, the FTC published Guidelines for the Use of Environmental Marketing Claims, commonly known as the FTC's "Green Guides." The Green Guides explain FTC interpretations of federal advertising law. They also influence court decisions, state regulation of advertising, Better Business Bureau responses to complaints about advertising, and challenges to "green marketing" claims.

We are a member of the U.S. Council of Better Business Bureaus' National Advertising Division (NAD). NAD employs advertising review attorneys with expertise in claims substantiation, advertising and trade regulation, litigation and arbitration. NAD mediates agreements to resolve advertising disputes but can issue informal rulings and refer unresolved cases to the FTC.

We are also a founding member of the Keystone Center's Green Products Roundtable. Roundtable members include experts on green labels, standards, and marketing, retailers and product manufacturers, government agencies, and environmental and other non-governmental organizations. Their mission is to reduce confusion in the "green" marketplace and improve production and buying decisions of product manufacturers, institutional purchasers, and consumers.

As part of our annual reporting, we post whether or not we sold products banned in any markets. In 2011, we believe we did not sell products banned in any markets. We have staff in our businesses and law department with expertise on consumer protection and advertising law. We train our business marketing managers to comply with applicable laws and policies, including the Green Guides, and regularly conduct centralized reviews of selected advertising and marketing materials, especially if they involve environmental marketing claims.