WSTA Toolkit: Social Responsibility

Transcription

1 WSTA Toolkit: Social Responsibility The Wine And Spirit Trade Association One strong voice for the trade

2 WSTA Toolkit: Social Responsibility Contents 1. Introduction 2. Developing a Social Responsibility Policy An outline business case for social responsibility Key points for a social responsibility statement 3. Embedding your Social Responsibility Policy Information to include in staff induction packages Key pointers for HR managers on training 4. Product Labelling Key things to consider when designing labels Information on Department of Health voluntary format 5. Advertising & Marketing 6. Website Suggested internal process for agreeing materials and ideas Links to existing key Codes and Standards Recommendations on age verification pages Recommendations for on-line sales pages 7. Selling Alcohol Responsibly Suggested considerations on promotions The Retail of Alcohol Standards Group Comment or feedback If you have any questions or would like to make any comments, please contact the WSTA on or info@wsta.co.uk Page 2

3 1. Introduction

4 WSTA Toolkit: Social Responsibility 1. Introduction Social responsibility is the recognition that as a business involved in the production, import, movement, storage, marketing or sale of alcohol you have a responsibility to society. Alcohol is a product that is consumed in a sensible manner by the majority of people. Consumed moderately it can bring both health and social benefits. But, a socially responsible company recognises that alcohol can be misused and that this can cause serious consequences, both for individuals and for wider society. Companies that embrace social responsibility fully consider what they can do to promote the sensible consumption of alcohol and reduce social and health harms related to misuse. Such companies take pride in the products they make and sell, and have no interest in seeing these products misused. WSTA member companies are already working hard to raise standards across the industry and much progress has been made. However, more needs to be done if we are to demonstrate to Government and key stakeholders from outside the industry that self-regulation is working. What individual companies can actually do will differ greatly, depending on the nature of the business. This toolkit is designed to help you assess what your business can do to ensure it operates in a socially responsible manner, and how this can be done. Using the WSTA toolkit The WSTA has produced this toolkit to provide member companies with practical guidance on how to embed social responsibility principles within your business. The toolkit has been divided into specific sections so that you can pick the relevant elements for your business. Some sections will be more relevant to your business than others. Where appropriate, references are included to the relevant section of the Social Responsibility Standards for the Production and Sale of Alcohol Drinks in the UK, published by the industry in conjunction with the Government in November If your business has already embedded social responsibility policies then the toolkit can serve as a checklist. All sections of the toolkit are freely available to members on the WSTA website. We are happy for you to include any part of this toolkit within your company policies and procedures. Page 4

5 2. Developing a Social Responsibility Policy It is important for every business in the alcohol drinks industry to have a Social Responsibility Policy which sets out your commitments in this area.

6 WSTA Toolkit: Social Responsibility 2. Developing a Social Responsibility Policy It is important for every business in the alcohol drinks industry to have a Social Responsibility Policy which sets out your commitments in this area. Making the Business Case Everyone in your business should understand the business case for implementing a Social Responsibility Policy. The business case could include the following points: Supporting industry self-regulation and promoting responsible consumption may help to enhance your reputation as a respectable business; Promoting moderate consumption helps to ensure a sustainable long term business; Promoting responsible consumption helps to build the premium nature of brands, and promotes long term consumer loyalty; Supporting industry self-regulation helps to preserve long term trading freedoms; Working for a responsible and ethical company may help to motivate staff; Binge drinking and other types of alcohol misuse damage the reputation of the alcohol drinks industry as a whole; Writing your Social Responsibility Statement If your company invests time and resources in developing a social responsibility policy, it is important that this is reflected in all external-facing publicity materials. For this reason, we recommend that your Social Responsibility Policy includes a Statement setting out why your company believes social responsibility is important. Page 6

7 2. Developing a Social Responsibility Policy This could be included in company materials, your website and might include some of the following points: We are extremely proud of the high quality brands which we produce / import / market / sell; We are very aware of our responsibility for the communities and consumers we serve; The consumption of beverage alcohol has played an accepted and important role in the cultural, religious and social traditions of both ancient and modern society; We urge adults who do drink, to do so responsibly; Nevertheless it is the obligation of each consumer who chooses to drink to enjoy beverage alcohol products in a responsible manner. The Drinkaware Trust The Drinkaware Trust is an independent UK-wide, public-facing body with the objective of positively changing public behaviour and the national drinking culture to help reduce alcohol misuse and minimise alcohol-related harm. The Trust is funded by voluntary contributions from across the alcohol drinks industry. The WSTA encourages members to consider supporting the work of the Trust in any way they can. In particular, when considering or developing existing individual brand based Corporate Social Responsibility initiatives, companies might like to consider discussing these with the Trust at an early stage to ensure maximum value for such initiatives. If you would like to discuss contributions or how your company can get involved, please call For more information about the Trust: For more information about the work the Trust does: Page 7

8 3. Embedding your Social Responsibility Policy In order for your company to successfully embed the principles of social responsibility into internal processes it is important that every member of staff, whatever area of the business they work in, understands what the issues are and why they are important.

9 3. Embedding your Social Responsibility Policy In order for your company to successfully embed the principles of social responsibility into internal processes it is important that every member of staff, whatever area of the business they work in, understands what the issues are and why they are important. The principles of social responsibility should be reflected in all parts of your business. You should consider all aspects of your work or the scope of your teams and departments, and consider how this can best be done. Nominated person In order to provide a common theme and understanding of the social responsibility agenda within your company, you may want to consider nominating one person who would have responsibility for championing implementation of your Social Responsibility Policy throughout the entire company. Ideally, he/she should be a senior manager who is capable of securing buy-in from across all parts of the business, from product development, marketing, PR, public affairs, sales etc. Dependant on available resources, this is not necessarily a full-time position but rather a single point of contact and responsibility for the broad social responsibility agenda. Once you have identified the person in your company who is to be responsible for your Social Responsibility Policy you may wish to inform the WSTA so we can support them and keep them informed of policy, best practice and regulatory developments. Training You should consider including a section on social responsibility in your induction and refresher training for staff. This might include the general principles of social responsibility and how it relates to the work of that person and possibly some information on the issues surrounding consumption and misuse of alcohol. In particular, you may want to consider explaining the Government s Sensible Drinking Message and the concept of units to your staff. Page 9

10 WSTA Toolkit: Social Responsibility 3. Embedding your Social Responsibility Policy The WSTA has produced the Alcohol, Social Responsibility and you leaflet (available from for you to give to new members of staff. It sets out the importance of social responsibility and what it means for people working in the industry. Government s Sensible Drinking Message In order to help consumers understand levels of safe consumption of alcohol, the Government has developed a Sensible Drinking Message which is set out below: Men The health benefit from drinking relates to men aged over 40 and the major part of this can be obtained at levels as low as one unit a day, with the maximum health advantage lying between one and two units a day. Regular consumption of between three and four units a day by men of all ages will not accrue significant health risk. Consistently drinking four or more units a day is not advised as a sensible drinking level because of the progressive health risk it carries. Women The health benefit from drinking for women relates to postmenopausal women and the major part of this can be obtained at levels as low as one unit a day, with the maximum health advantage lying between one and two units a day. Regular consumption of between two and three units a day by women of all ages (excluding pregnant women) will not accrue any significant health risk. Consistently drinking three or more units a day is not advised as a sensible drinking level because of the progressive health risk it carries. Page 10

11 3. Embedding your Social Responsibility Policy In communications, this is generally presented as men should not regularly drink more than three to four units of alcohol a day and women should not regularly drink more than two to three units of alcohol a day. After an episode of heavy drinking it is advisable to refrain from drinking for 48 hours to allow your body to recover. This is a short term measure. People whose pattern of drinking places them at significant risk should seek professional advice. Pregnant women The UK Government advises women not to drink alcohol whilst pregnant or whilst trying to conceive. If women chose to drink, they are advised not to drink more than one or two units once or twice a week. The Chief Medical Officers for England, Scotland and Wales have agreed that for alcohol labels and point-of-sale materials the following shorter message may be used: Avoid alcohol when pregnant or trying to conceive. Alternatively, the French pregnancy logo has been deemed acceptable to convey this message on labels. [More information on labelling is included in Section 4: Product Labelling] Understanding units In the UK, a unit is defined as the equivalent to eight grams, or 10ml, of pure alcohol. (NB: different definitions apply in other countries). The number of units in a particular drink can be calculated by multiplying the volume of the drink in ml by the alcoholic strength by volume (abv) and dividing the answer by Unit labelling refers to the practice of labelling alcoholic drink containers with the number of alcohol units that they contain. This is not currently compulsory in the UK, but it is considered best practice and is widely implemented across all types of alcohol. E.g. the number of UK units in a bottle of wine at 12% abv is: (750 x 12) / 1000 = 9 UK units [More information on UK units is included in Section 4: Product Labelling] Page 11

12 WSTA Toolkit: Social Responsibility 3. Embedding your Social Responsibility Policy Written workplace alcohol policy In order to demonstrate that your company puts its principles into practice, we recommend that you consider developing a workplace alcohol policy. This could serve to remind staff of their responsibilities and might include some of the following points: Staff are ambassadors for the company; Alcohol should be enjoyed responsibly; The alcohol drinks industry is, and should be, a fun place to work, but the availability of alcohol should not encourage people to consume immoderately; The legal alcohol limit for driving in the UK is 80 milligrams of alcohol in 100 millilitres of blood. There is no fail-safe guide as to how to stay under the legal alcohol limit, so it is generally recommended that if you plan to drive you should avoid alcohol. Useful advice for staff could include the following: Know what a unit is and how many are in your drink; Make sure you understand the Government s Sensible Drinking Message and how it relates to you; Avoid top-ups so you can keep track of your unit intake; Consider alternating your drinks with water to stay refreshed; Consider soft drink spacers between drinks to help pace an evening; Consider eating before or whilst drinking which can slow alcohol absorption; Think about how you re going to get home before you leave home book a taxi or designate a driver. Page 12

13 4. Product Labelling Labels are seen by the Government as being one of the key ways in which to communicate information about alcohol to consumers.

14 WSTA Toolkit: Social Responsibility 4. Product Labelling Labels are seen by the Government as being one of the key ways in which to communicate information about alcohol to consumers. Whilst we recognise that information contained on labels may be of use to consumers, we also believe that this must be in conjunction with wider educational initiatives. There are numerous rules and regulations covering the labelling of alcoholic products. The information set out here is in relation to sensible drinking information only. For more details on legal labelling requirements, please refer to the WSTA Checklists, or contact the WSTA. The labelling of products is also covered by The Portman Group s Code of Practice. [More information is detailed in Section 5: Advertising & Marketing] Government / Industry voluntary labelling agreement In May 2007, the Government announced that it had reached an agreement with representatives of the drinks industry for a UK wide voluntary scheme for the inclusion of Sensible Drinking Messages on alcohol labels. Many companies already include such information on their labels, and this agreement is to help ensure that the consumer is given accurate and easily understandable information. This agreement is voluntary. The Government has also accepted that such information will not be appropriate for all alcoholic drink products. There will be a review of uptake, including planned uptake, at the end of The Government has made it clear that if industry implementation does not meet their expectations, they will consult on the need for legislation. Page 14

15 4. Product Labelling Companies wishing to implement this voluntary agreement should include some or all of the following information: The number of UK units contained in the drink The recommended Government safe drinking guidelines: UK Health Departments recommend men do not regularly exceed 3-4 units daily and women 2-3 units daily Website: In addition, the Government is also encouraging the companies to include sensible drinking information for pregnant women on labels. More information on each of these, and the Department of Health s preferred format, is included below. The number of UK units contained in the drink: In the UK, the alcoholic content of drinks is measured in units (one unit = 8 grams or 10 ml of pure alcohol and can be worked out as volume in ml x abv and dividing by 1000). NB: different definitions apply in other countries Clearly displaying the number of units contained in the bottle or can will help consumers make informed choices about their alcohol consumption. We strongly recommend that you include the number of units per container (and, additionally, per standard glass) on the labels of your products. Page 15

16 WSTA Toolkit: Social Responsibility 4. Product Labelling If you chose to include unit information, we strongly recommend that you follow the protocol set by The Portman Group. The details can be found in the WSTA s labelling guide (see link below). Example: Spirits 40% ABV 1 litre bottle / 25 ml glass For spirits the agreed standard glass size is 25ml. For wine the agreed standard glass size is 125ml. Example: Wine 13% ABV 75 cl bottle / 125ml glass For more information on The Portman Group protocol go to For artwork of the icons please use the WSTA Templates: Page 16

17 4. Product Labelling Below is a general units table which sets out the number of units contained in drinks by volume and container size for wines, fortified wines and spirits. UK units: Wine ABV 75cl bottle 125ml glass *to one decimal place UK units: Fortified Wine ABV 75cl bottle 125ml glass UK units: Spirits ABV 1litre bottle 25ml glass Other appropriate opportunities could be used to communicate unit awareness and responsible drinking sponsorship of events etc. Page 17

18 WSTA Toolkit: Social Responsibility 4. Product Labelling The Government s Sensible Drinking Message In order to help consumers understand levels of safe consumption of alcohol, the Government has developed a Sensible Drinking Message (revised in 1995). [This is set out in more detail in Section 3: Embedding your Social Responsibility Policy] For use on labels, the message can be shortened as follows: UK Government recommends that adults do not regularly exceed: Men Women 3-4 units a day 2-3 units a day In conjunction with unit information this information can help consumers judge whether or not they are drinking responsibly. Information on drinking during pregnancy (or logo) In addition to the Sensible Drinking Message, the WSTA and other trade associations have agreed to take a positive approach to help the Department of Health communicate the revised pregnancy guidance, and will explore the most effective way to implement this, including labelling, in parallel with the Government s enhanced communication of the Sensible Drinking Message. If companies wish to include a pregnancy message, they can include an abbreviated version of the revised guidance on their labels: Avoid alcohol if pregnant or trying to conceive. Page 18

19 4. Product Labelling Alternatively, companies may wish to include the French pregnancy logo, shown here. If companies chose to include either the wording or the logo, this information should be portrayed as part of the Government s Sensible Drinking Message for men and women so that the advice is seen to be the Government s advice. For use on labels, the message can be included as follows: UK Government recommends that adults do not regularly exceed: Men Women 3-4 units a day 2-3 units a day Avoid alcohol if pregnant and trying to conceive Reference to the Drinkaware website In order to signpost consumers to further information on alcohol, safe consumption and health, we highly recommend that you also include reference to the Drinkaware website. Drinkaware are also making available for international companies to use on their product labelling. This can be either as or by including the drinkaware logo, which is available from The Drinkaware Trust, or the WSTA. Page 19

20 WSTA Toolkit: Social Responsibility 4. Product Labelling Responsibility slogan Some companies may also choose to include a responsibility slogan or message such as Enjoy Responsibly, Drink in moderation or the Department of Health s campaign message: Know Your Limits. Suggested formats The discussions between the industry and the Department of Health resulted in total flexibility in terms of format and positioning. The Department of Health have drawn up their preferred format, but there is no obligation to follow this. The only real requirement is that the information is presented in a clear and legible fashion. Drink Responsibly UK Chief Medical Officers recommend adults do not regularly exceed: Men 3-4 units a day 2-3 units a Women day Drink Responsibly UK Government recommends adults do not regularly exceed: Men 3-4 units a day 2-3 units a Women day Drink Responsibly UK Health departments recommend adults do not regularly exceed: Men 3-4 units a day 2-3 units a Women day Drink Responsibly UK Government recommends adults do not regularly exceed: 3-4 units Men a day 2-3 Women units a day Drink Responsibly UK Government recommends adults do not regularly exceed: Men 3-4 units a day Women 2-3 units a day Page 20

21 4. Product Labelling Low calorie / therapeutic claims Care should be taken when developing creative materials for products, such as half sugar etc and only factual information should be given. Promotional materials must not imply that these products can be beneficial as part of a calorie controlled diet or that they should be an incentive to drink more solely due to the lower calorie content. Labels should not claim that products have physical or medicinal benefits. Health Claims Regulations Regulation (EC) N 1924/2006 of the European Parliament and of the Council on nutrition and health claims made on foods came into force on 1 July Regarding the types of claims that can be made on / about alcoholic products, the Regulation states: Beverages containing more than 1.2 % by volume of alcohol shall not bear health claims. As far as nutrition claims are concerned, only nutrition claims referring to low alcohol levels, or the reduction of the alcohol content, or the reduction of the energy content for beverages containing more than 1.2 % by volume of alcohol, shall be permitted. The WSTA has produced a full industry update on these regulations. Page 21

22 5. Advertising & Marketing Advertising, marketing and promotions are the public face of brands. These activities therefore present an ideal opportunity to demonstrate in a highly visible way to consumers, Government and the wider public that you are a socially responsible company. Conversely, a company which fails in this area can tarnish the industry as a whole. This is an area that is highly regulated. Information on statutory and industry codes is set out at the end of this section.

23 5. Advertising & Marketing Introduction Advertising, marketing and promotions are the public face of brands. These activities therefore present an ideal opportunity to demonstrate in a highly visible way to consumers, Government and the wider public that you are a socially responsible company. Conversely, a company which fails in this area can tarnish the industry as a whole. This is an area that is highly regulated. Information on statutory and industry codes is set out at the end of this section. Youth appeal It is important that the content and placement of all marketing and promotions must be targeted at over-18s. This should be made clear to all marketing and advertising agencies. Producers should avoid promotional activity which may have a strong appeal to underage drinkers. Advertising and creative material should use images of people who are, and appear to be, at least 25 years old. Internal approval process for materials and ideas All marketing and promotional practices should present the responsible enjoyment of alcohol and should not encourage misuse or excessive consumption of alcohol. Materials and campaigns must abide by existing codes and regulations (ref: Section 4.2 and 4.3 of the Social Responsibility Standards document). In addition, you may wish to consider using consumer advertising and promotional materials to promote a consistent moderation message to encourage and educate consumers eg Drink Responsibly/Drinkaware website. In this way, all merchandising and promotional materials and activities will reflect your company s commitment to social responsibility. Page 23

24 WSTA Toolkit: Social Responsibility 5. Advertising & Marketing The following steps may help you in this: Ensure that your nominated person is involved early in the approval process. Ensure that all employees within the sales and marketing teams are aware of the relevant laws, regulations and self-regulatory codes which govern marketing and promoting alcoholic drinks (more information below and links can be found on the WSTA website). Ensure that any external agencies used (design or advertising agencies, market research companies, media buyers etc) are fully briefed, and are willing to undertake to abide by such policies in any work they do on behalf of the company. Put in place a firm process in which advertising and promotional material is authorised prior to production. This should include all advertising, packaging, promotions, press releases, websites, sponsorship, branded merchandise, sampling, advertorials and point of sale material. TV commercials must be vetted before broadcast by the Broadcast Advertising Clearance Centre (BACC, and all national and certain special categories of local and regional radio must be vetted before broadcast by the Radio Advertising Clearance Centre (RACC, (See note at end of Section) In addition, non-broadcast materials may be sent to The Portman Group s pre-launch Advisory Service. Agreeing promotions with the on-trade (Social Responsibility Standards ref: 6.3) Note: nothing in this document is intended to impose restrictions on price related issues, and its provisions should be read in that context. Page 24

25 5. Advertising & Marketing Promotions must comply with the British Code of Advertising, Sales Promotion and Direct Marketing (see below), and should comply with The Portman Group Code of Practice and the British Beer & Pub Association s guide to Point of Sale Promotions. Irresponsible promotions damage the reputation of the brand, and expose the industry as a whole to accusations of irresponsibility. Materials and plans for promotions should be approved by your nominated person. As a rule of thumb, promotions should not: Encourage excessive drinking or drunkenness Encourage anti-social behaviour Offend common standards of taste and decency. In order to do this, the British Beer & Pub Association suggests that you avoid the following types of promotions: Double for singles promotions 2 for 1 promotions Happy hours Retailers should also be offered clear guidance regarding: Displaying branded point of sale information in a way that does not encourage irresponsible consumption Displaying general point of sale information regarding sensible drinking levels and sensible drinking messages Advice on in store tastings (see below) Page 25

26 WSTA Toolkit: Social Responsibility 5. Advertising & Marketing Samplings and Tastings (Social Responsibility Standards ref: 7.5.1) Staff should be fully trained and all elements of sampling activity should be agreed by the nominated person. Samplings and tastings should adhere to The Portman Group s Code of Conduct. In particular sampling activity must not: Encourage illegal, irresponsible or immoderate consumption, such as binge- drinking, drunkenness or drunk driving; Have particular appeal to under 18s. Sampling activity should not involve giving away individual samples of greater volume than recommended by the Government for an individual s daily consumption. Staff involved in the sampling should be, and should look, over 18 years of age. They should be fully briefed on the importance of promoting moderate and responsible consumption of alcohol. They should also be fully informed about the alcoholic strengths of products, the number of units per sample and the Government s Sensible Drinking Message. In order to ensure that samples are not given to under 18s, staff should also be made aware that anyone who appears to be under the age of 21 should be asked to prove that they are over 18. In line with current retail policy, the only identification that should be accepted are photo-driving licences, a PASS approved card or a passport. Staff should also seek to ensure that the sample is to be consumed by the person receiving it. Page 26

27 5. Advertising & Marketing On-trade sampling In order to ensure that staff are not encouraged to give out drinks irresponsibly, companies should consider setting targets for the number of bars or venues visited, rather than the number of drinks distributed. In addition, we recommend that sampling in the on-trade is done early in the evening, and over a short space of time. In conjunction with the nominated person, educational materials can be developed and handed out with drinks. When sampling in the on-trade, staff should be reminded of the importance of: Not offering more than one drink per person Not providing samples to people who are inebriated Off-trade / public spaces sampling When sampling in the off-trade or in public spaces, particular consideration should be given to location. Sampling should not occur in or near areas that attract or appeal predominantly to children or young people (e.g. youth clubs, schools, bowling alleys etc). Samplings should not link the consumption of alcohol with potentially dangerous activities such as driving, swimming etc. Page 27

28 WSTA Toolkit: Social Responsibility 5. Advertising & Marketing Note: Broadcast and non-broadcast advertising rules Advertising codes are the responsibility of two industry Committees of Advertising Practice CAP (Broadcast) and CAP (Non-broadcast). These are independently administered by the Advertising Standards Authority. CAP (Broadcast) covers all radio and television advertising. Central copy clearance is required. CAP (Non-broadcast) applies to: adverts in newspapers, magazines etc; posters; cinema and video commercials; advertisements in non-broadcast electronic media eg online ads, pop-up s etc; viewdata services; marketing databases; sales promotions; and, advertisement promotions. Copies of the full codes and the alcohol-specific sections can be found at: Note: The Portman Group Code of Practice The Code applies to a drink s packaging (including its brand name) and also to point-of-sale advertising, brand websites, sponsorship, branded merchandise, advertorials, press releases and sampling. All decisions about complaints received are made by an Independent Complaints Panel. The Portman Group s Code complements and is consistent with a number of other Codes governing the advertising and marketing of alcoholic drinks in the UK. A full copy of the Code can be found at: Page 28

29 5. Advertising & Marketing Note: The Portman Group Advisory Service This service offers drinks producers and importers an opportunity to seek advice, in advance, about the packaging (including naming and labelling) of any alcoholic drink they are planning to launch or relanch or any promotional material or activity that they are intending to undertake that is covered by the Code. This enables any concerns about possible breaches of the Code to be discussed and dealt with at an early stage. To obtain advice, send your designs or details of your plans to Kay Gill at or call Kay on Page 29

30 6. Websites Websites are increasingly important in building consumer awareness of, and loyalty to, brands. Because it is hard to limit your website to only a specific section of people, it is absolutely essential that all website content, including pictures and music, adheres to The Portman Group Code of Practice.

31 6. Websites Websites are increasingly important in building consumer awareness of, and loyalty to, brands. Because it is hard to limit your website to only a specific section of people, it is absolutely essential that all website content, including pictures and music, adheres to The Portman Group Code of Practice. We recommend that your nominated person is notified of any proposed changes to the website, and any major alterations should be passed through The Portman Group Advisory Service. Access for under 18s The Portman Group has recently issued a help note offering guidance age verification pages. This is reproduced below: An age verification page (AVP) is a website landing page which requires visitors to confirm they are of a certain age before they can enter the website. It is impractical to require all visitors to undergo an external check before being allowed entry to a site and it is recognised that self-verification is open to abuse by the visitor. Nonetheless, in the interests of deterring underage visitors and demonstrating commitment to best practice, companies should require visitors to a dedicated brand website to navigate an AVP before being allowed entry to the site. The method of AVP should require the visitor actively to input their date of birth (e.g. from a drop-down menu) rather than allow access through clicking a default option. This is because the former method is the most stringent and the most effective deterrent to under 18s. Page 31

32 WSTA Toolkit: Social Responsibility 6. Websites If access is blocked because the visitor enters an age/date below 18, they should be given an appropriate message or directed to an appropriate alternative site (e.g. an alcohol education site for young people such as Companies should not use patronising language or refer to the visitor to a clearly inappropriate website (e.g. a site for toddlers products). Repeat visitors may be invited to set-up a remember me option to facilitate easier access to the site in future but this invitation should be accompanied by a reminder to the visitor to consider the appropriateness of this option if the computer is shared with someone aged under 18. Corporate websites, used solely for company information rather than to promote a particular brand(s), do not need to feature an age verification page. Age verification is particularly recommended in relation to on-line sales of alcohol. Distance Selling or Online sales The WSTA Distance Selling Panel has developed a Code of Practice. The Code affirms the high standard of service they provide as part of their commitment both to consumers and to abiding by UK and European legislation. The Distance Selling Code of Practice can be downloaded from: Policy statement Companies may want to consider including a statement on their company s Social Responsibility Policy on their website. This can include similar points as set out in the Developing your social responsibility policy section. Page 32

33 6. Websites Under 18s Businesses selling alcohol online should ensure that under 18s are not using their service to purchase alcohol. Online retailers should have a stated policy explaining how age verification is done. Selling alcohol to a minor is an absolute offence, and if suspected of such an offence, a retailers only defence is due diligence. There are currently three ways of ensuring that under 18s cannot buy alcohol online: Only accept payment by credit card (this is because under 18s are not eligible for credit cards). Please note that debit cards are issued to under 18s. Run thorough credit checks against all other cards, which will help identify the age of the would-be purchaser. If you operate a membership scheme, sell alcohol to members only. This way, customers are encouraged to join allowing retailers to collect information about them and verify their identification through some kind of checking system. The website should make it very clear that it is illegal for under 18s to purchase alcohol and that the information provided by the would-be purchaser will be checked to confirm identity. Delivery It is illegal to sell alcohol to an under 18. However, under the Licensing Act 2003, no offence is committed if alcohol is delivered to an under 18 at the place where the buyer or the person to be supplied (who must both be over 18) either lives or works. Page 33

34 WSTA Toolkit: Social Responsibility 6. Websites Consumer information Companies may also consider including information for the consumer on responsible consumption on their website. This most usefully can be the Government s sensible drinking message (as set out in Section 3: Embedding your Social Responsibility Policy) and some indication of the number of units contained in relevant drinks. Drinkaware In addition, we recommend that your website should contain a link to which will allow consumers to find out more information about alcohol and responsible consumption should they wish to. Page 34

35 7. Selling Alcohol Responsibly As the interface between alcohol and consumers, retailers have a huge responsibility to ensure that they behave responsibly.

36 WSTA Toolkit: Social Responsibility 7. Selling Alcohol Responsibly As the interface between alcohol and consumers, retailers have a huge responsibility to ensure that they behave responsibly. Retail environments differ greatly, the pointers towards responsible trading set out here are geared towards the off-trade. For more information regarding either off-trade or on-trade retailing please contact the WSTA. General considerations LEGAL INFORMATION It is illegal to sell alcohol to anyone under the age of 18 It is illegal to sell alcohol to anyone who is drunk It is illegal to sell alcohol to an adult who is buying on behalf of an under 18 It is illegal for a person under 18 to sell alcohol without being authorised at the time of sale by a person over 18 and approved to do so by the licence holder It is illegal to sell alcohol directly to members of the public unless you have a licence The penalties for breaking the law are severe. You should ensure you have in place strict policies, relating to selling alcohol legally and responsibly. Page 36

37 7. Selling Alcohol Responsibly Training Retail staff are the front line of enforcement. It is their responsibility to ensure that under 18s and drunk people cannot acquire alcohol on your premises. You might consider appointing a social responsibility champion in every store whose job it is to ensure company policy is implemented in a socially responsible manner, and to keep other staff members motivated to reduce underage age and other illegal sales. You should ensure that all your staff dealing with alcohol sales are adequately trained, you may like to consider offering them formal qualifications (e.g. Wine & Spirit Education Trust, BII, Confederation of Professional Licensees, etc). The WSTA supports Challenge 21 and No ID No Sale policies. This means that retailers should ask anyone who appears to be under 21 to prove that they are over 18 before they can buy alcohol. The only acceptable forms of ID are a passport, a photographic driving licence or an ID card bearing the PASS hologram. More information on these policies can be found on The Retail of Alcohol Standards Group (RASG) is a forum for alcohol retailers in the off-trade to share best practice and develop new ideas. They have drawn up an outline best practice list for training which is reproduced below. For more information about the Retail of Alcohol Standards Group, or for examples of training records, signage, refusals registers and other information mentioned please contact the WSTA. Page 37

38 WSTA Toolkit: Social Responsibility 7. Selling Alcohol Responsibly RASG Training Best Practice Training should: Explain that legal controls on the sale of alcohol exist to protect young people and the communities in which the company operates. State the commitment of the company to ensure that the legal controls are followed. Set out the criminal law rules on the sale of alcohol (that employees would need to know) and personal nature of the employee s legal responsibility: No sale to under 18s No sale to those buying on behalf of under 18s No sale to drunks Any sales by under 18s must be specifically authorised by an over 18 State clearly that the employee could be prosecuted and fined for making an underage sale. Make clear your company s policy on Challenge 21 and acceptable proof of age: Proof of age card with PASS hologram Photo driving licence 10 year UK Passport Guide the employee how best to ask a customer for proof of age and how to avoid confrontation. Encourage the employee to think about situations that could be suspicious (e.g. a transaction in which just alcohol is being bought) or loitering youngsters. Emphasise the need for vigilance at all times and the need to challenge for ID whenever there is any doubt. Page 38

39 7. Selling Alcohol Responsibly Emphasise that the employee will receive active support and encouragement of the management and other staff in challenging customers and refusing sales if proof of age cannot be provided. Make clear that an underage sale made in breach of company policy would be a disciplinary matter. Make clear that test purchasing by enforcement regularly takes place to ensure everyone follows the rules. Encourage staff to check around the alcohol aisles when passing, and make themselves visible to discourage theft or illegal sales. Validation of training should: Demonstrate that each aspect of the above message has been fully understood. Include an observed practice element to give colleagues confidence to challenge customers and confirm competence. Records of training should include: Date of training Method of training and the materials used Name of person giving training Name of trainee Signature of trainee to confirm receipt of specified training Validation of knowledge achieved Records of training should be readily available for review by visiting personnel. Page 39

40 Retail of Alcohol Standards Group WSTA Toolkit: Social Responsibility 7. Selling Alcohol Responsibly Reminders and refreshing of training A system should exist to ensure that employees are regularly reminded of key aspects of their training. This could be by recognition and discussion of level of refusals made or inclusion in regular team updates, communication or shift handover notes. Till prompts and materials displayed in colleague areas should reflect key training messages. A more focused briefing on the importance of age of sale issues should be carried out at least four times a year and more frequently depending on the nature of the employee and customer base. If evidence comes to light of failure in the system then training of all colleagues should be revisited promptly. Records must be kept of additional training provided. This should be kept with other employee training information. In-store signage Signage can be used to remind both staff and customers of the need to adhere to the law. Point of Sale (POS) materials should be displayed at each alcohol display area and also by tills. We recommend that you use the RASG Under 25? signage, available from which makes it clear that you follow a Challenge 25 policy. Some retailers also include the Government s Sensible Drinking Message (that men should not regularly exceed 3-4 units of alcohol a day, or women 2-3 units) as information for consumers at point of sale. Retailer Alert Bulletins UNDER 25? Please be prepared to show proof of age when buying age restricted products Retailer Alert Bulletins (RABs) are issued by The Portman Group and give up-to-date information about products that are deemed to infringe their Code of Practice, together with a timetable for action. RASG Page 40

41 7. Selling Alcohol Responsibly Retailers should not stock the products in question until they have been amended to comply with the Code (when the retailers will be informed). For more information on this, please contact The Portman Group at Lower Alcohol Wines There is growing interest in the UK in broadening the range of lower alcohol wines so as to provide consumers with greater choice. Parts of Government are also seeking to encourage producers and retailers to provide a wider range of lower alcohol products. Research indicates that consumers do want the option to choose lower alcohol wines. The WSTA is currently seeking a temporary derogation to enable lower alcohol wines to be made within the EU making use of oenological practices currently prohibited ( reverse osmosis or spinning cone ) to reduce alcoholic strength. We hope that this will in time facilitate the production and sale of lower alcohol wines. Promotions (Social Responsibility Standards ref: 5.5 & 7.4) Point of sale promotions on alcohol are held for a number of reasons: To showcase a new brand or product To increase customer awareness of a product To introduce new customers to a particular product To provide a special offer to customers for a limited period on a popular or established product. Promotions on price, such as discounts on quantity or linked discounts, are legitimate promotions and an important part of business. However, any point of sale material must not encourage or promote irresponsible consumption. Retailers should consider the risks of planned promotions, and should assess the impact of their promotions and modify as appropriate. Page 41

42 WSTA Toolkit: Social Responsibility 7. Selling Alcohol Responsibly The Social Responsibility Standards includes the following information on promotions for both the on- and off-trade: Promotions or promotional material should not: Condone, encourage or glamorise excessive drinking or drunkenness or encourage anti-social behaviour. Effects of intoxication should not be referred to in any favourable manner. Be linked to sexual imagery implying sexual success or prowess. Refer to consuming alcohol to recover from previous overindulgence. Be disrespectful of contemporary, prevailing standards of taste and decency and avoid degrading or gratuitously offensive images, symbols, figures and innuendoes. Promotional material should not be demeaning to any gender, race, religion, age or minority group. Appeal, through images / symbols, primarily to those under the legal purchase age. Characters should only be used if it is clearly established that their primary appeal is to adults. Use of any cartoon character popular with children is unacceptable. Contain any direct or indirect references to drug culture or illegal drugs. Have any association with violence or anti-social behaviour. The promotions sections of the Social Responsibility Standards from which the above text comes was agreed in consultation with the Department of Health, the Home Office and the Department for Media Culture and Sport. The actual words were discussed at length with the Office of Fair Trading, who issued very prescriptive advice to the industry at the time the standards were launched. This advice severely limits the ability of the industry to enforce these parts of the standards. Retailers should be confident that any extra displays or instore promotions will not have a negative impact on consumer Page 42

43 7. Selling Alcohol Responsibly behaviour or local problems, such as anti-social behaviour. [More information on tastings can be found in Section 5: Advertising & Marketing] Store security Properly considered store security can help deter both attempted underage and proxy sales and theft of alcohol. We recommend that you consider the following points: Where possible, the alcohol display area should be covered by CCTV; In order to discourage theft, consideration should be given to the placement of alcohol within your store; If you have a security tagging system, it may be helpful to apply it to any items considered a specific target for theft, particularly alcoholic drinks over a certain price; Local police and / or trading standards may be willing to work with you on issues relating to store security, and may be well placed to offer advice; Consider joining local retail / business initiatives. This can often allow stores to be warned of potential trouble makers. Prevention of public nuisance Often retail premises can be inviting places for young people to spend time. If this is a problem for your store, you might consider trying to make the outside of your store less attractive by removing low walls and canopies that provide shelter, and also making sure the area is well lit. Companies are strongly encouraged to work with local police, licensing forums and the Crime and Disorder Reduction Partnership. Not only will this allow store managers to build good relationships with enforcement agencies and other retailers in the local areas, it will also allow for better information / intelligence sharing. Page 43

44 THE WINE AND SPIRIT TRADE ASSOCIATION One strong voice for the trade International Wine & Spirit Centre Bermondsey Street London SE1 3XF +44 (0) Registered number: England Limited by Guarantee