Abt Electronics, Inc. Social Media Endorsement Policy

Abt Electronics, Inc. (“Abt”) is committed to transparency and honesty in all of its advertising messages and promotional communications with consumers. Consumers must understand when a social media endorsement is sponsored by us.

Defining an Endorser Covered by This Policy

An individual or entity communicating on social media is covered by this Policy if its promotional messages about Abt or our products, services, or brand are sponsored by us ("Sponsored Endorser"). If the individual or entity is acting independently, it is not subject to this Policy.

A message is sponsored by us if we have a material connection with the individual or entity. A material connection is a tie to us which if known to consumers might make consumers question the credibility of the endorser or materially affect the weight consumers place on the endorsement. It puts the endorser's independence in question. For example, Abt creates a material connection if we do any of the following either directly or through an advertising agency, public relations firm, or other third party:

Hire an agency to blog, post, or serve as a community manager on our behalf (both the agency and its employees then become Sponsored Endorsers).
Enter into an agreement with an individual to blog or post.
Pay an individual to blog or post.
Provide free accommodations or travel to an individual for a company event or experience.
Provide discounts, sweepstakes entries, or other incentives to an individual.
Provide an individual with free prizes for giveaways or sweepstakes on social media platforms.
Provide an individual with free samples to review on social media platforms.
Provide an individual with free samples after that person has blogged or posted independently, especially if providing the free samples creates the expectation of additional free samples (which makes the individual a Sponsored Endorser going forward, not retroactively).
Engage affiliate marketers to advertise, blog, endorse, or sell on our behalf (making the affiliates and their employees Sponsored Endorsers).

Disclosing a Material Connection Clearly and Conspicuously

When posting about our products or services, Abt requires Sponsored Endorsers to disclose their material connection to us clearly and conspicuously. This policy does not require specific language to disclose a material connection, but Sponsored Endorsers must communicate the material connection effectively so that consumers:

Can easily find and understand it.
Obtain sufficient information to make a judgment about the credibility of the endorsement.

Consult Appendix A to this Policy for examples of language that successfully communicate a material connection and language that does not do so.

To ensure a disclosure is clear and conspicuous, appropriate consideration should be given to the limitations and nature of the platform being used. Sponsored Endorsers must:

Ensure the disclosure is:
- well-placed so it can be easily noticed; and
- prominent so it can be easily read.
Avoid burying the disclosure:
- in a bio;
- below the fold;
- in a hyperlink, like a "Legal" or "Disclosure" button; or
- among a series of hashtags, other disclosures, or general copy.
In video posts, including podcasts:
- place the disclosure both within the video itself, and in the description of the video; and
- display the disclosure long enough for a consumer to be able to read and understand it.
In Instagram posts, disclose a material connection before the "More" button.
For a live stream, repeat the disclosure as needed to ensure that consumers see it or keep it posted throughout the live stream.

Avoid encouraging endorsements that use features that do not allow for clear and conspicuous disclosures, such as likes, Pins, or shares, if the absence of that disclosure is likely to be misleading.

A social media platform may have a required tool or feature for paid endorsements. Although these tools or features must be used to comply with the platform's rules, they should not be relied on alone to meet FTC disclosure requirements.

APPENDIX A
Best Practices For Disclosure Language

As stated in the Policy, Sponsored Endorsers are required to disclose material connections to Abt. Listed below is sample disclosure language. Alternative but substantively comparable language may also be used where appropriate. Although Abt does not require specific disclosure language, it does prohibit certain hashtags and other disclosure practices specifically found by the FTC as insufficient. The goal for a material connection disclosure is to ensure it is readily seen and understood by consumers and accurately describes our relationship with the Sponsored Endorser.

Statements about the material connection should identify the nature of the connection, such as:

For receipt of free products:
- Abt Electronics gave me this product to try; or
- Thanks Abt Electronics for the free products.
For paid Sponsored Endorsers:
- I was hired by Abt to post about its products;
- I have partnered with Abt Electronics to promote its products.
For personal relationships:
- I am a (friend of/related to) Abt Electronics (known employee or principal)
For other material connections:
- "Advertisement";
- "Sponsored";
- "Paid ad"; or
- "Ad:" (this would go at the beginning of the statement to indicate the statement is an ad).

If using a hashtag to identify a material connection, make it unambiguous, such as:

#ad.
#paid.
#sponsored.
#Abtambassador.
#Abtendorser.
#Abtpartner.

Avoid ambiguous hashtags to identify material connections, such as:

#sp.
#spon.
#thanksAbt.
#teamAbt.
#ambassador.
#consultant.
#partner.
#adviser.
#collab.

Additionally, if a Sponsored Endorser has posted a "Disclosure and Relationships Statement" section on their blog, website, profile page, or similar site, the statement should:

Fully disclose how the endorser is working with us.
Disclose how the endorser works with other companies generally.
List any conflicts of interest that may affect the credibility of the sponsored or paid reviews.