Category results show that six out of 16 companies – Coca-Cola India, Mondelēz India, Nestlé India, PepsiCo India, Britannia Industries and Hindustan Unilever – have responsible marketing policies aimed at all consumers, see Table 1. Five out of these six companies, except Britannia Industries, implement policies in India that were developed by their global parent companies. Britannia Industries is the only India-headquartered company to have its own responsible marketing policy. For the most part, companies’ policies adhere to the ICC Code, an industry best practice. This code is a globally-applicable self-regulatory framework developed by industry sectors worldwide.

Although the research did not find evidence of ITC having a marketing policy, the company states in its Food Product Policy, which is available online, that it adheres to the ASCI Code for Self-Regulation in Advertising. The code provides a commitment to honest advertising and to fair competition in the market-place. The ASCI code is aligned with the principles of the ICC Code and ITC’s commitment was credited accordingly.

Overall, little progress in this Category D1 of the Index (Marketing Policy) is observed compared to results from the previous India Index in 2016. Britannia Industries is the only company that demonstrates improvement by adopting a new marketing and communications policy.

Overall, the media channels covered by the companies that have adopted a marketing policy or that at least make a commitment related to responsible marketing (like ITC) are similar. Table 2 shows that the biggest gap in channels covered is ‘additional forms of media’, which includes, for example, cinema, outdoor events, sponsorship, product placement in movies, TV shows, online games and apps).

Only two out of six companies that have a responsible marketing policy, Hindustan Unilever and Nestlé India, apply their commitments to all media channels.

To improve and accelerate their efforts to support all Indian consumers, especially children and teenagers, to make healthy choices, food and beverage manufacturers in India are encouraged to:

• Develop and implement a responsible marketing policy for all consumers, including specific arrangements for children and teens up to 18 years old. The policy should adhere to the ICC principles, and respect or go beyond compliance with Indian regulations.
• Ensure marketing approaches explicitly cover all relevant media, including non-traditional channels such as product placements and social media.

Limited progress was found regarding Indian food and beverage companies adopting responsible marketing policies towards children. At the time of research and engagement with companies (in 2019), little regulation on marketing to children was implemented. Table 3 shows that, overall, only 6 companies have adopted responsible marketing to children policies and or commitments.

Voluntary industry-wide responsible marketing to children

Since 2016, Britannia Industries was the only company that has implemented a new policy. In its ‘Britannia Marketing Communications Policy,’ the company commits to “only selectively market products to children which the Company qualifies as having requisite nutritional content which is good for consumption by children.”

In addition, Britannia commits to only market products meeting its own healthy standards in and near primary and secondary schools. All the multinational companies with headquarters outside India adopt their global practices or commitments in India, and they are also signatories of the FBAI Pledge.

Audience thresholds are used by companies to restrict advertising on measured media to avoid inappropriately reaching younger age groups. Index results show that most companies have set the threshold at 35%, meaning they will restrict their practices in medium where 35% of more of the audience is of the restricted age group. Nestlé India is the only company that has defined a lower threshold, at 25%.

Table 4 shows that significant gaps remain regarding companies’ practices towards ensuring their digital media marketing and advertising are not targeted at children. For example, Index results revealed that only two out of the six companies, Mondelēz India and Nestlé India, have a responsible policy for marketing to children using age screening tools prior to logging or registering on websites.

Most of the companies have tools to ensure the design of their websites and the third-party sites they chose to advertise do not appeal or target predominantly children under 12 years old. Companies are encouraged to continue strengthening and monitoring their marketing practices in the digital media. Companies that have not yet adopted responsible marketing practices and/or policies covering children must include digital media when designing and implementing such policies.

To improve and accelerate their efforts to support all Indian consumers, especially children and teenagers, to make healthy choices, food and beverage manufacturers in India are encouraged to:

• Adopt a responsible marketing policy with special arrangements for children and teens and publicly disclose their commitments to ensure stakeholders can hold the company to account.
• Ensure marketing approaches explicitly cover all relevant media i.e. traditional and digital channels including social media. Companies must adopt tools to ensure the websites, sponsorships, third-party sites, etc., do not appeal or target predominantly children and teens under 18 or only include healthy products.

• Companies must do as much as they can to avoid the marketing and provision of branded materials in primary and secondary schools in support of the new FSSAI (Safe food and healthy diets for school children) regulation banning the sale of HSSF products and within 50 m of school campuses. Companies can expand their commitments on marketing to children and teens to include places where children typically gather, i.e. public parks and sport facilities.

ATNI assesses companies’ public commitments and evidence of performing accordingly by assessing whether third-party audits of their marketing practices are in place and results are disclosed publicly. At present, ATNI does not have the means to assess companies’ marketing practices directly.

Results show that only four out of six companies – Coca-Cola India, Hindustan Unilever, Mondelēz India, and PepsiCo India – have responsible marketing policies covering all consumers as well as specific arrangements for children. These same companies have auditing practices in place for all audiences.

The International Food & Beverage Alliance (IFBA), of which some companies in this Index are members, commissions Accenture to conduct annual, global audits of TV, print, radio and internet advertising. However, India specific results are not published. Table 5 shows that that the only company that commissioned an independent, third-party audit covering all relevant forms of media for marketing to children is Nestlé India.

Five out of 6 companies report having response mechanisms for corrective action regarding their marketing practices. For example, in its new Marketing Communications, Policy Britannia Industries states its commitment to “undertake internal audits (annually or more frequently, if required) on marketing practices covering all audiences including children and/or teens, and, wherever required, corrective action will be taken.”

To improve and accelerate their efforts to support all Indian consumers, especially children and teenagers, to make healthy choices, food and beverage manufacturers in India are encouraged to:

• Audit compliance with its policy in India covering all audiences, including children and teens.

• Appoint an independent external auditor to assess compliance with its policies or take part in an auditing process of an external body (not industry association) undertaken by independent company.
• Annually assess compliance of all aspects of marketing covering all audiences to the same standards that are applied in assessing compliance for children and teens.

The Product Profile is an independent assessment of the nutritional quality of companies’ product portfolios undertaken by analyzing the levels of fat, salt, sugar, and other components within individual products. ATNI commissioned an independent research organization, The George Institute for Global Health, to undertake the nutrition profiling element of the Product Profile.

Similar to the process of the previous India Spotlight Index, two sets of results are generated for each company: one to determine the nutritional quality of the company’s products, by applying the Health Star Rating (HSR) both at the Category and portfolio level, and another by using the WHO South-East Asia Region (SEAR) regional standard to determine what percentage of products are suitable to be marketed to children. The latter system is used to examine, on average, what percentage of companies’ portfolios are suitable to be marketed to children. The WHO SEAR model was published in 2016 and was used for the first time in the India Index Product Profile 2020. See a comparison of the HRS and WHO SEAR models.

This assessment did not investigate whether these products are in practice marketed to children and teens by the companies in scope. Instead, it provides an extra indication of the healthiness of the company’s portfolios by checking whether the products, in theory, would be suitable to be marketed to children using the WHO nutrient profiling models. If companies are found to have a small number of products suitable to be marketed to children, it is of high priority that they implement responsible marketing policies to ensure these products are not undermining children’s health.

Importantly, this assessment does not impact companies scoring in the Index, as the Product Profile results utilizing the HSR system are integrated in Category B. This assessment provides an additional perspective on the healthiness of companies’ portfolios but it is not an indication of actual marketing practices and performance in relation to healthy/unhealthy products.
A maximum of five best-selling product categories for each company were analyzed in this assessment, based on their estimated Indian retail sales in 2018. Details on the scope of this assessment are provided in Table 6 below.

Overall, only 12% (183 out of 1,494) of products included in the analysis for all companies combined were found to be suitable to be marketed to children according to WHO SEAR criteria. This proportion is lower compared to Category B Product Profile results, which shows 16% of products meet the HSR ‘healthy’ criteria. This lower result reflects the more stringent criteria applied for eligibility to market to children, as entire categories are ineligible under the WHO SEAR criteria, whereas the HSR uses a cut-off point to determine healthiness.

Mondelēz India and Parle Products, had no products in the research eligible for marketing to children at all, showing that it is essential for them to implement and audit its responsible marketing policies and commitments in India.

The sales-weighted proportion of products found suitable to be marketed to children (29%) was higher than the unweighted proportion of products (12%). This means, in general, that companies derive more sales from these products. Overall, company rankings did not change significantly when sales-weighting was applied. Hatsun Agro Product improves its sales-weighted ranking jumping from 11^th to 8^th place. In constrast, Hindustan Unilever moved from 7^th to 11^th place after applying sales-weighting. Details are shown in Table 7.

Marico significantly improves its performance when sales-weighting was applied. Although less than half (44%) of the company’s products were found to be suitable to be marketed to children, the company was estimated to derive 76% of its 2018 sales from products found suitable to be marketed to children.

Figure 2 provides an overview of the percentage of products researched that were found suitable to be marketed to children for each company. The results of this assessment are impacted by the number of products in the analysis (in brackets), as well as the quality of nutrition information available.

The companies with the overall highest proportion of products suitable to be marketed to children are Adani Wilmar, with 12 out of 13 products found to meet WHO SEAR criteria, and Emami Agrotech, with five out of six products meeting the criteria. For both companies, only a limited number of edible oil products were assessed.

Only three out of the 16 companies in the Index, were found to have a considerable proportion of products suitable to be marketed to children (more than half the products in their portfolios meeting WHO SEAR criteria), with Marico improving performance when applying sales-weighting. This confirms, as Category B also highlights, there is ample scope for companies to focus more on changing their portfolio to offer healthier products.

More details on the methods, results, and limitations of the Product Profile study are available in the report by ATNI’s research partner, The George Institute for Global Health.

To improve and accelerate their efforts to support all Indian consumers, especially children and teenagers, to make healthy choices, food and beverage manufacturers in India are encouraged to:

• Make a commitment not to market/advertise products to children and teens at all or to only market foods and beverages that meet specific nutrition criteria, preferably established by independent national or international bodies, for example, the WHO SEAR nutrition criteria.
• Improve disclosure of nutrition information and report on relevant metrics so that stakeholders can have a better understanding of performance.