Responsible Marketing Code
As a vertically integrated global ecommerce technology group and brand owner, we are committed to being a business that has a positive impact on both the communities and the environment in which we operate.
We have pledged to use our global scale, world-class talent, and dedication to innovation to act as a force for good - detailed in our 2030 Sustainability Strategy - THG x Planet Earth.
For us, good governance is about more than adhering to codes of conduct - it's about living according to our values and doing business the right way.
We recognise the importance of responsible marketing and take our commitment seriously.
That's why we want to guide our employees, brands, customers, and partners on responsible marketing.
The scope of our Responsible Marketing Code covers all forms of marketing communications across THG, including those of our three businesses (THG Beauty, THG Nutrition and THG Ingenuity), and extends to our external media partners.
Across the Group, we promise that our marketing communications will:
| Comply with relevant laws, regulations, codes, and standards, and be decent, honest, and truthful; not misleading |
| Be prepared with due sense of social and professional responsibility |
| Always present data clearly, not exaggerating the validity of any claims |
| Ensure every testimonial, endorsement, or supportive documentation we refer to is genuine, verifiable, and relevant |
| Not impair public confidence in marketing and ensure age-appropriate messaging for children and young people |
| Respect human dignity and will not incite or condone any form of discrimination, including that based upon ethnic or national origin, religion, gender, age, disability, or sexual orientation |
| Ensure AI tools are used to enhance the customer experience when employed for customer engagement, i.e. chatbots or personalised recommendations |
| Ensure that AI tools and algorithms are developed with no negative biases |
| Ensure that AI algorithms are regularly audited for bias to avoid inadvertently favouring or discriminating against any demographic/group |
| Follow the environmental and ethical standards of this code when making green claims |
Across THG Nutrition, we promise that our marketing communications will:
| Ensure health, nutrition, performance, and sustainability claims are supported by scientific research, testing, certification, verified user experience, or measurable performance metrics, and will adhere to the applicable codes and standards |
| Adhere to recognised international frameworks for responsible marketing, ensuring compliance with global and local standards for product safety, quality, and ethical considerations. This includes, but is not limited to, regulations governing health, environmental, and sustainability claims |
| Continuously review and update our marketing communications to remain compliant with changing regulations and global best practices, ensuring that we uphold the highest standards of responsibility across all markets and product categories |
| Be transparent and set the standard for how we write about, display, label, and promote our products (including promotion transparency) by always accurately and realistically showing any material characteristics advertised, ensuring customers can make informed decisions |
| Provide clear explanations of the functional benefits of our products, including our clothing |
| Avoid actively marketing to children and young people |
| Be responsible in encouraging healthy intentions and have an inclusive representation across all cultures, ethnicities, shapes, sizes, and abilities |
| When applicable to our own imagery, not make editorial material changes to a person’s shape, size, proportion, skin, hair, or eye colour |
| Be transparent about the use of any human-appearing AI that may impact the efficacy of the product being promote |
| Responsibly use influencers and ambassadors, ensuring they share our values and comply with our ethical marketing practices. This includes transparency around sponsored content and substantiated claims |
Across THG Beauty, we promise that our marketing communications will:
| Make truthful and evidence-based claims, and not mislead our customers by providing educational information about the products and claim |
| Be fair and transparent when labelling and promoting products (including promotion transparency) enabling our customers to make informed choices |
| Use appropriate age marketing and not encourage misleading or harmful messages on habits for children and young people including beauty routines |
| Strive to be responsible and inclusive in our approach to casting models and promote products that cater to a range of hair, skin types, and tones |
| Be mindful of cultural differences and avoid perpetuating harmful beauty standards or stereotypes |
| When applicable to our own imagery (and encouraged for our brand partners), not make editorial material changes to a person’s shape, size, proportion, skin, hair, or eye colour |
| Be transparent about the use of any human-appearing AI that may impact the efficacy of the product being promoted |
| Responsibly use influencers and ambassadors, ensuring they share our values and comply with our ethical marketing practices. This includes transparency around sponsored content and substantiated claims |
| Avoid greenwashing or scaremongering and strive for concrete and reliable certifications |
| Follow the environmental and ethical standards of this code when making green claims |
Across THG Ingenuity, we promise that our marketing communications will:
| Make truthful and evidence-based claims, and not mislead our customers by providing educational information and/or validated data about the products and claim |
| Only include genuine, verifiable, and relevant testimonials, endorsements, or supportive documentation |
| Not convey any misleading or harmful messages to children and young people and be mindful of cultural differences of our customers and consumers |
| Be responsible and inclusive in our approach to casting models and offer products and services that cater to a range of customers |
| When applicable to our own imagery, not make editorial material changes to a person’s shape, size, proportion, skin, hair, or eye colour |
| Be transparent about the use of any human appearing AI that may impact the efficacy of the product/service being promoted |
| Responsibly use brand partners, advocates, influencers, and ambassadors, ensuring they share our values and comply with our ethical marketing practices. This includes transparency around sponsored content and substantiated claims |
| Follow the environmental and ethical standards of this code when making green claims |
| Our claims will always be substantiated and with appropriate data and evidence. |
| We require all employees who are responsible for developing, writing, and publishing sustainability claims to have training and to have read THG’s Green Claims Policy, in reference to our internal process and against latest public guidance on green and ethical claims. |
| We require our supply chain partners to adhere and comply with THG’s Supply Chain Standards. |
