Demographic Data/Advertisement Placement
Guidelines to Implement
the Responsible Placement Provisions
of the
DISCUS Code of Responsible Practices
for
Beverage Alcohol Advertising and Marketing

Set forth below are guidelines regarding placement of advertisements in various media and periodic, random after-the-fact audits (post audits) of placements to meet the demographic standard where at least 70% of the audience for TV, print and radio advertisements is reasonably expected to be 21 years of age or older (the legal purchase age (LPA) audience composition).

1. Media placement and the 70% LPA standard

   1. A placement will be considered to be in compliance with this LPA standard if:

      1. The advertiser has a reasonable expectation, determined by using reliable, up-to-date audience composition data, that the LPA audience composition will be at least 70%;

      2. The advertiser conducts internal, semi-annual after-the-fact audits of a random portion of past placements to verify that such placements were in compliance with the 70% LPA audience composition standard; and

      3. The advertiser, upon learning of a non-compliant placement, takes appropriate, corrective action for future placements.

   2. A reasonable expectation for meeting this demographic standard takes into account marketplace realities, the medium and available demographic audience composition data, and includes:

      1. Recognition that a company’s media buys generally are determined prior to its upcoming fiscal year for placement during the course of that fiscal year;

      2. Recognition that a company’s media buys rely upon historical demographic data to estimate the future LPA audience composition;

      3. Recognition of the availability and publication intervals of syndicated audience composition data; for example, MRI TwelvePlus data are published annually and Arbitron data are published quarterly, whereas national broadcast networks have the most frequently measured syndicated audience composition data (national Nielsen data) thereby affording, among other things, more data for advertisement placement and for more expeditious after-the-fact audits, as compared to, for example, local (spot) TV and cable, as well as radio and print media.

2. Media placement and audience composition data

   1. For TV--broadcast (network/local), cable (network/local) and syndication:

      1. Purchase by program (or, if program specific data are unavailable, by daypart/timeslot) using nationwide "2+" audience composition data, such as national Nielsen data, based upon the last two quarters of such data

      2. For new programs, data for similar programs or time periods

      3. A placement will be considered appropriate when the above-referenced data show that the placement is in compliance with the Code

      4. Post audits: A past placement will be considered appropriate where data published or supplied for the quarter in which the placement ran show an LPA audience composition that was in compliance with the Code

   2. For radio:

      1. Purchase by daypart (e.g., "a.m. drive," "midday," "afternoon drive," etc.) using "12+" audience composition data, such as Arbitron data, based upon the last two quarters of such data

      2. If the station is not measured by a syndicated data source (e.g., a new station or a station not measured by Arbitron), data provided by the station regarding the target listenership audience or data for stations with similar formats in similar markets

      3. More specific data than daypart can be used for audience composition such as, for example, narrowing the a.m. drive hours from 6:00 a.m.-10:00 a.m. to 8:00 a.m.-10:00 a.m. to determine audience composition

      4. A placement will be considered appropriate when the above-referenced data show that the placement is in compliance with the Code

      5. Post audits: A past placement will be considered appropriate where data published or supplied for the quarter in which the placement ran show an LPA audience composition that was in compliance with the Code

   3. For print:

      1. Purchase by publication using "12+" audience composition data, such as MRI consolidated TwelvePlus data (designed to allow analysis of "12+" youth and adult readership) or, if unavailable, MRI "18+" data, based upon the last publication of such data

      2. If the publication is not measured by a syndicated data source (e.g., a new publication or a publication not measured by MRI), data provided by the publisher regarding target readership audience or data for similar publications (see section D below for general circulation unmeasured magazines)

      3. More specific data regarding audience composition also meet this standard, such as a "21+" subscriber special edition of the publication

      4. A placement will be considered appropriate when the above-referenced data show that the placement is in compliance with the Code

      5. Post audits: A past placement will be considered appropriate where data published or supplied subsequent to the placement show an LPA audience composition that was in compliance with the Code

   4. Independent measurement of unmeasured magazine demographic profiles (effective October 1, 2006):

      1. Magazines intended for general circulation that are not measured by a syndicated data source, such as MRI or Simmons, and have or are intended to have a subscriber base should have an independent measurement of their subscribers, which meets the following criteria:

      2. A demographic survey of subscribers should be conducted periodically for established magazines and for new magazines before consideration of an advertisement placement (and again for new magazines once the subscriber base has stabilized; for example, after initial subscribers have had an opportunity to renew would be appropriate in the latter instance)

      3. Survey of magazine subscribers must be conducted by an independent third party research company using established research methods, such as the ABC Subscriber Study Audit requirements

      4. Survey supplier and date survey was conducted must be identified

      5. Sample should be at least 300 in-tab (tabulated) respondents with the sample frame fully reported

      6. Sample must be pulled on an nth name basis from all eligible names on the publication's full subscriber file for U.S. only. No complimentary copies, international, business addresses, demographic, or regional edition splits (unless these copies also are used for the advertising)

      7. Subscribers, not other household members, should be asked to fill out and return the survey

      8. Actual age, year of birth or check off for appropriate bracket of age are acceptable, as long as the age bracket identifies 21 as a starting point (for example, 21-34 versus 18-24)

      9. Upon the receipt of the independent demographic survey, a potential advertiser will evaluate the audit in conjunction with other factors prior to purchasing an advertising placement, such as the content of the magazine, similar or comparable publications, the "pass along" rate and/or circulation distribution of similar or comparable publications

      These Guidelines will be reviewed periodically to ensure that they reflect the most current and appropriate recognized electronic and print audience composition data.

      March 2006